CFG
11/05
Proposals to
amend the Legislation on BSE Testing of Cattle over 30 Months - possible
change to draft legislation in relation to 'No Test' results
Letter from Foodaware dated 31 May 2005 to Ms Sinjini Mukherjee,
Defra, BSE Division Branch C:
Foodaware, the Consumer’s Food Group, co-ordinates the broad
UK consumer movement’s work on food safety, nutrition and standards.
Our mission is to give UK consumers a strong voice on food policy
by bringing together the organisations that represent them. We also
consult and support the UK consumer representatives on food-related
committees, and further the public understanding of science. Foodaware
developed from the Food and Agriculture Working Party of Consumers
in Europe Group. Our members are consumer, women’s, family,
ethnic minority and enforcement organisations, who also contribute
time and expertise to our representations.
A number of changes in the way consumers are protected against BSE
are being proposed currently. Both Defra and the Food Standards Agency
have formal consultations underway on specific proposals for a testing
regime to replace the Over Thirty Month rule. But the picture from
a consumer perspective remains confused with the risk from beef perceived
as lower and that from other species (such as goats) increasing. Consumer
confusion is not helped by the lack of a coherent vision for BSE regulation,
and the apparently piecemeal way the legislation is evolving.
The specific question asked in this consultation relates to Section
13 of Schedule 1A. This concerns the action that should be taken in
the abattoir if a laboratory has been unable to test a brain stem
sample from an over thirty month animal for whatever reason. We note
that there is a difference of view between the UK and EU over whether
only the untested animal and its parts should be identified and incinerated,
or whether the one animal before and two after should also be destroyed.
Since one of the main reasons for abolishing the Over Thirty Month
rule and moving to a regime based on testing is to bring the UK into
line with arrangements in other parts of the EU, we believe that the
EU’s interpretation should prevail. While this will be more
costly for producers than the original proposal, it will provide for
a higher level of protection to the public and act as an incentive
for abattoirs to ensure that the samples they supply can give an acceptable
(i.e. reliable) result.
Foodaware is content for this response to be made publicly available.
Yours sincerely,
Susan Knox
Chairperson
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