CFG
10/03
1. Introductory
remarks
Foodaware welcomes the opportunity to comment on the above consultation.
Please note that these comments are at present draft and result from
consultation with our members via our email list-serve. The issue
will be discussed further at our members’ meeting on 24 July
2003. Nevertheless, we hope that this paper can make a contribution
to the debate at this stage.
2. Foodaware comments
The Core Stakeholder Group suggests that two options to replace the
Over Thirty Month (OTM) rule should be considered:
i) to allow animals born after 1.8.96 into the food supply,
with testing of OTM animals;
ii) to move entirely to testing all animals slaughtered for human
consumption.
2.1 Lack of justification for changing
from the OTM rule
Foodaware accepts that there is a need to review the OTM rule given
the scientific and legal developments since its introduction in 1996.
However, it is convinced that public health concerns must remain paramount,
whatever the economic considerations. It is equally convinced that
this must be perceived to be so by consumers if public confidence
is not to be eroded.
To this end it considers that neither of the options put forward are
acceptable at present and that, for the time being, the OTM rule should
not be relaxed. The reasons for this opinion are as follows:
2.1.1 The need for precaution
Although the number of BSE cases is declining, this is not happening
in line with government predictions and there is inadequate explanation
as to why cases are continuing to be found in cattle born after the
1996 feed ban reinforcement. Equally, many uncertainties remain about
Transmissible Spongiform Encephalopathies (TSEs). National Consumer
Council and FSA research shows that consumer risk perceptions about
BSE remain salient and any change to a more lenient regime therefore
risks being viewed in a negative light. Research into consumer responses
to any change to the current system of controls is needed.
2.1.2 Enforcement considerations
Both the options proposed are dependent upon rigorous enforcement
of regulations that are complex and would clearly require far greater
resources than the existing arrangements. A change to testing as the
means of reduction of risk is not acceptable until a test has been
developed which is both reliable and effective in the early, incubation
stage of BSE. This is particularly important, as it is known that
cattle present a much higher risk in the 12 months prior to the onset
of clinical disease. While we accept that the OTM rule is costly,
it does have the advantage of relative simplicity. It should not be
replaced unless and until it can be demonstrated that a testing regime
is certain to work as effectively. We believe any such testing regime
would require, in addition, regular monitoring, further research on
improved testing and continued exchange of information with other
member States on their results.
There are also reservations about proposals to shift responsibilities
from Meat Hygiene Service to in-house staff.
Foodaware would highlight the importance of reliability of the cattle
identification procedures needed to permit traceability and to prevent
fraud. Traceability is central and testing details for each individual
animal would need to be entered on to its ‘passport’ in
a reliable and consistent manner across the EU.
2.1.3 Risk assessment
Much of the argument justifying removal of the OTM rule and its replacement
by testing comes from the extremely small predicted increase in risk
(0.04 extra deaths over 60 years). On that basis there may be some
grounds for argument in favour of a change to birth-limit together
with testing, especially for specialist beef herds (where the incidence
of herds affected by BSE is far lower than in dairy herds). However
it is unclear what assumptions and judgements have been made by the
model used to achieve this figure. There is a need for greater transparency
over the risk assessment issues.
3. Conclusions
Given the above reservations, Foodaware does not favour any relaxation
of the OTM rule at the present time. While, we acknowledge the legal
and economic pressures to review the rule, we believe that any future
testing regime should be demonstrated to be effective, reliable and
transparently audited before it be considered as a replacement for
the current arrangements. It would need to be regularly monitored,
would require ongoing research into improved testing and continued
exchange of information with other Member States. Likewise, research
into consumer reactions to any change would provide useful information
on the likely impact on consumer confidence in beef and the food supply
in general.
July 2003
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