CFG
15/03
September 2003
Comments by Foodaware
on the Food Standards Authority strategy for the control of campylobacter
in chickens
Introduction
Promotion of Good Biosecurity
Control Measures
Slaughterhouse Controls
Evaluation
Implementation
Introduction
Section 1
Foodaware welcomes the FSA’s commitment to establish a strategy
to reduce the contamination of chickens with Campylobacter and the
priority given to improving controls on the farm and during processing.
Public concern about food poisoning remains high. With about 50,000
cases of illness a year in the UK from Campylobacter, the organism
is the biggest cause of food borne illness in the UK and deserves
to be a priority for action.
A survey by the FSA finalised in February 2003 found that in 2001
Campylobacter was present in 50% of chicken on retail sale in the
UK. It is of particular concern that when broken down by country,
the rates for Scotland and Northern Ireland was 74% compared with
44% for England and Wales. The reason for these differences is not
stated. Contaminated produce is entering domestic and catering premises
on a daily basis. It is self-evident that the FSA’s wider objective
of reducing food poisoning by 20% between 2001-6 may be jeopardised
without a significant reduction in the contamination of raw produce
by Campylobacter. The risks of cross-contamination from this bacteria
before cooking are particularly high both because of the proportion
of contaminated produce in the food chain and because only a small
number of the organisms can cause infection in humans. The Agency
considers that there is strong evidence that improper handling and
preparation of chicken is a major contributing factor in producing
food poisoning.
The Advisory Committee on the Microbiological Safety of Food (ACMSF),
which advises the FSA, first highlighted the importance of this organism
in causing food poisoning in an interim report in 1993. It is regrettable
that it has taken ten years for a strategy to reduce the prevalence
of Campylobacter in chickens to be produced and that this strategy
falls short of a comprehensive action plan despite significant amounts
of research and public expenditure.
We know of the FSA’s ongoing work to promote HACCP controls
in food manufacturing and its Food hygiene campaign, and note that
these initiatives will be linked with the specific actions on farm
and in the slaughterhouses.
Promotion of Good Bio-security
Section 2
While we recognise that the FSA’s powers in this area are limited
by the lack of specific legislation, there is very little in the document
which represents new knowledge or a different approach. General powers
requiring firms to exercise due diligence exist under the Food Safety
Act and apply throughout the food chain. Legislation is also available
to ensure accurate labelling by those promoting produce from voluntary
farm assurance schemes.
Firms which were committed to best practice in the 1990s recognised
then the importance of high farm standards and bio-security. Improved
Salmonella controls have not reduced Campylobacter contamination and
specialist advisers do not appear to be able to explain why. The estimate
that up to 400 million chickens a year produced in the UK are heavily
contaminated with Campylobacter is an indictment of supposed food
safety strategies in the 1990s. Despite this, the FSA seeks to rely
mainly on a high profile education and training programme for farmers
and slaughter houses to achieve an unspecified reduction in contamination
and hence infection. A high profile campaign working with suppliers
is undoubtedly necessary, but to achieve the level of commitment from
individual producers on a scale that will deliver the culture change
the FSA believes necessary, a stronger and clearer enforcement strategy
will be essential.
Control Measures
Section 3
The FSA acknowledges that there are currently no specific Campylobacter
control measures on farms and slaughterhouses, and its reference to
the value of HACCP in providing control in the future is regrettably
vague. The FSA should set a timetable within which it will strengthen
its strategy and identify target measures for enforcement to ensure
its delivery. These should be developed concurrently with the plan
for the next 3 years. The Agency should similarly clarify its intentions
with regard to extensive production systems. The request for expressions
of interest for possible research into control systems is also vague,
with no time-scales or indications of the levels of resource that
may be available.
Advice to the FSA has rightly stressed the importance of raising bio-security
on the farms. Foodaware therefore supports the FSA’s decision
to give priority to reducing contamination in broiler flocks as this
should reduce risks to individual consumers. This knowledge is not
new, however and the approach needs to be supplemented by further
ongoing measures to identify appropriate controls and ensure compliance.
What needs to be raised is the commitment to act; for poultry producers
to respond appropriately and for major retailers to make improved
hygiene a key element in their specifications. The FSA stresses the
role of the Defra Code of Practice for the Prevention and control
of Salmonella in identifying good practice and providing a foundation
for control (paragraph 2.2). It also acknowledges that 85% of UK chicken
is produced within the Assured Chicken Production Scheme. Should not
the strategy therefore focus on the level of compliance within this
Scheme as a means of getting urgent measurable action? Is it not a
requirement of this voluntary scheme that suppliers comply with the
code, and do they not have to have an annual inspection? The Strategy
should include some specific actions in this area to enhance compliance
with the voluntary standards that promote ACP chickens to UK consumers,
and not just as a conduit for providing information.
There appear to be potential conflicts between the animal welfare
obligations which result in thinning the number of birds in flocks
and the impact of this practice on bio-security and hence contamination
rates (paragraph 3.5 - 7). The potential risk from this practice seems
better understood in Denmark and Norway. Foodaware is disappointed
that the FSA has accepted the industry view that economic considerations
make it ‘impossible’ to ban this practice at the present
time. In our view, if a comprehensive cost-benefit appraisal was undertaken
which took account of the cost of food poisoning for public health,
a different conclusion might be reached. Overstocking also contributes
to excessive use of anti-biotics and poor hygiene and management practices
which may raise costs generally. As the ACMSF recorded in its 2002
Annual Report: The maintenance of good flock health was seen to convey
economic benefits, and it was felt that Campylobacter control measures
were likely to reduce the risk of introducing other infections into
the flock.
Significant risk from feed contamination remains despite recent initiatives
within Defra and advice from the Advisory Committee on Animal Feed.
This area has been given little attention in the draft strategy. We
think the risks from on-farm mixing and poor storage which can result
in contamination from wild birds and rodents should be included in
the strategy and that the Agency should work with Defra so the effectiveness
of initiative to eradicate poor on-farm feeding practices can be monitored.
Foodaware is concerned at the potential for farmers to evade these
proposals. The FSA should work together with all relevant bodies who
are involved in food standards and enforcement, strengthening their
links with public and private inspection agencies to improve compliance
with voluntary standards and existing legal obligations. The priority
should be public health. It is simply not acceptable to put contaminated
food into the food chain. The FSA should consider how, within EU controls
on zoonoses, it can encourage the State Veterinary Service to raise
standards and use its existing powers of enforcement. We note the
FSA’s commitment to work with relevant stakeholders, but consider
that the FSA’s proposed strategy for action is too vague on
these crucial matters and needs to reflect the urgency of the public
health problem.
The FSA survey of retail chicken has shown significant levels of antibiotic
resistance in the Campylobacter strains found in retail chicken[1].
It has been demonstrated that the use of antibiotics in animal production
contributes to the growing problem of resistance to antibiotics in
the treatment of both humans and animals. Foodaware supports the need
for a complete ban on antibiotic growth promoters and would not wish
anti-biotics to form part of the routine control measures for Campylobacter.
Slaughterhouse Controls
Section 4
Foodaware has previously expressed concern that European Community
legislation on food hygiene does not make it compulsory for farmers
to implement the HACCP system. As the FSA recognises, a policy on
the prevention of zoonoses such as Campylobacter cannot be successful
without the implementation and control of good hygiene practices at
the level of primary production. We welcome the proposals to strengthen
HACCP in slaughterhouses, but the legal obligations must be appropriately
enforced and the enforcement proposals should form part of the strategy.
The FSA rejects the experience of Scandinavian countries in reducing
contamination in their market as being inappropriate for the UK. This
may be so, but another feature of implementation strategies in those
countries has been the government commitment to act, and the clear
timetable for so doing. The FSA should reconsider this element of
its strategy.
Evaluation
Section 5
We agree that the FSA should seek to assess the effectiveness of its
strategy, but it will need more specific targets and clearer goals
within the strategy in order to do so. The rolling retail survey will
be valuable in providing data on the contamination rates at different
times of the year and may help in identifying particular sources.
It is nevertheless important that the retail survey should include
smaller outlets as well as the major retailers and that some means
should be found for monitoring food processors and catering establishments
which supply raw chicken. We understand that a significant proportion
of UK produced poultry is sold as whole birds and that imports are
used for the value-added cuts sold at retail and to processors. A
more broadly based survey would be important both to ensure effective
coverage of the market and to monitor the standards of processors.
Implementation
Section 6
When the FSA surveyed chicken on retail sale, it found that the frequency
of Campylobacter contamination was higher in UK produce. It is appropriate
therefore to tackle contamination in domestic produce systematically.
While the FSA suggests (paragraph 1.11) that ‘the control measures
identified in this strategy will be equally applicable to non-UK produced
chicken’, this is unlikely to be achieved without support from
buyers in major UK retailers and the European Food Safety Agency.
The FSA should continue to raise the profile of these issues with
other stakeholders in the UK and internationally.
The Consultative Group on Campylobacter and Salmonella in Chickens
identified a need for research to improve sampling and testing techniques
for detecting Campylobacter in poultry on the farm and to control
it in extensive production systems. Given the time such research is
likely to take, and the cost of food poisoning outbreaks for public
health, the FSA should encourage funding agencies to support this
work as a matter of urgency.
1 UK-wide Survey of Salmonella and Campylobacter
Contamination of Fresh and Frozen Chicken on Retail Sale, FSA 27 February
2003
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