CFG
15/05
Letter dated 29 July
2005 from Foodaware to David Plummer, Vet Tec Project Officer, Veterinary
and Technical Directorate Meat Hygiene Service (MHS):
Dear Mr Plummer,
Proposed Changes to instructions to Meat Hygiene Service Authorised
Officers to implement changes in the Food Hygiene Regulations
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.
The changes to instructions comprise a substantial number of requirements
to ensure MHS staff can verify that food businesses that supply fresh
meat do so in compliance with EU Regulations. The new UK legislation
will also underline the responsibility of all food businesses to ensure
safe meat production and introduce HACCP requirements, and on which
we have commented separately.
The changes to instructions comprise a substantial number of requirements
to ensure MHS staff can verify that food businesses that supply fresh
meat do so in compliance with EU Regulations. The new UK legislation
will also underline the responsibility of all food businesses to ensure
safe meat production and introduce HACCP requirements, and on which
we have commented separately.
As the new regulations should significantly change the relationship
between suppliers and MHS staff in the plants, it is important that
sufficient resources are made available to train OVS and MHS staff
at local level and that they are confident in their application of
the new requirements. In particular, we welcome the obligation on
enforcement officials to carry out audits of HACCP and good hygiene
practices that verify food business operators apply procedures continuously
and properly. As a result, some businesses may need to invest in HACCP
training and its implementation and they should be encouraged to do
so to ensure ongoing compliance. We hope that this will create a ‘
level playing field ‘ across the meat sector and at the same
time allow for some flexibility for small businesses. Options to do
things differently are welcomed as long as the outcome is the same
and hygiene standards are met.
We also welcome the requirement that cutting plants and retail butchers
which supply the catering trade must be approved, since they comprise
a significant and increasing proportion of the market, and can expose
the public to specific risks.
The Wall Enquiry into BSE testing failures indicated that there were
some problems for OVS staff and MHS personnel in using the operating
manual, particularly because of its length and the frequency with
which updates were required. As these new instructions have been developed
with staff from across government, we trust that they will be less
complex to apply, available on line and that they will be allowed
to bed down within the service for some time before significant revisions
become necessary.
The Partial Regulatory Impact Assessment has specifically asked for
views on the approach to enforcement. In general, Foodaware supports
risk based enforcement since this should lead to resources being focussed
where the public health risks are greatest. However, if slavishly
followed this approach could mean all the enforcement being focussed
on the biggest suppliers. If the largest are also the most modern
and efficient plants and can demonstrate that they have highly effective
HACCP arrangements in place, this would not be proportionate on an
ongoing basis. In the initial stages of the new regime, there should
be a commitment from MHS to sample compliance arrangements across
the industry, but with the high volume producers receiving prompt
attention.
Foodaware is content for this response to be made publicly available.
Yours sincerely,
Susan Knox
Chairperson
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