CFG
18/06
Letter dated 6 July 2006
from Foodaware to Liz Olney, Veterinary and Technical Directorate,
Meat Hygiene Service (MHS):
Dear Liz Olney
Proposed changes to veterinary supervision arrangements within
the Meat Hygiene Service
In the light of the Wall Report into failures in BSE testing, the
requirements considered necessary by the Independent Advisory Group
(IAG) to protect the public following removal of the Over Thirty Month
Rule and the recommendations of management consultants for organisational
changes, these new proposals are welcome to strengthen veterinary
supervision and provide much needed support for Official Veterinarians
(OVs) working in abattoirs and meat cutting plants. The Wall Report
made a number of recommendations regarding the training, supervision,
and performance of Official Veterinarians, and recognised the need
for improvement in the accountability of contractors. It also highlighted
the need to develop a more integrated service between veterinarians
and the meat hygiene inspectors to improve working relationships.
To do nothing is clearly not an option.
Consumers need to have confidence in the effectiveness of the supervision
arrangements in abattoirs and meat cutting plants, which are the front
line in ensuring traceability, combating disease and contamination,
and ensuring the quality of meat for retail sale. It is essential
that the service is adequately resourced, and that the personnel are
appropriately trained, supervised and competent in carrying out their
duties. Their role in protecting public health in a high risk area
of the food industry makes it essential that they are accountable
for their work through appropriate management structures.
You have asked specifically whether the proposed changes meet the
recommendations of the Wall report and the requirement of the IAG
by providing direct veterinary and technical supervision, and meet
business needs. At face value, the MHS Management Board’s preferred
option of:
- continuing to work with contractors (who currently supply 92%
of Official Veterinarians to the MHS) but with clearer reporting
lines and more effective support and supervision, but
- gradually moving to a situation where 40-50% of OVs are directly
employed,
seems to be pragmatic, realistic and desirable in the public interest.
Whether it will prove to fulfil the recommendations in practice,
will depend on securing sufficient qualified staff in a market in
which they have been in short supply, and improving and maintaining
morale in an often unpleasant working environment. Weaknesses in
management support and poor working relationships at plant level
should be addressed by the proposed changes but will require sustained
commitment from the MHS for the foreseeable future as the impact
of change creates further uncertainty. We want the MHS to monitor
the effectiveness of the changes as these proposals are implemented,
and would expect the Board to report publicly on progress and any
problems encountered in achieving the necessary improvements. For
consumers, the effectiveness of these changes should be assessed
by output measures (such as the number of inspection, detection
and audit failures in relation to throughput, levels of morale as
indicated by turnover and sickness rates etc).
The proposed changes should help to ensure that consistent policies
are in place and that decisions are taken at the correct level.
Appropriate decisions will also require clarity about the requirements
of EU or UK law, where MHS guidance is obligatory, and where professional
discretion can be exercised. There is undoubted tension between
the traditional command and control practices in the meat industry
and the risk-based approach being implemented through the Food Hygiene
Regulations. This could, at least in the short term, lead to further
confusion, particularly if reduced veterinary attendance at certain
slaughterhouses is perceived as merely a cost cutting exercise and
not by an open assessment of risk. In any case, reduced attendance
should not be interpreted to mean ‘no’ attendance, as
that would allow potential for poor practice or fraudulent activity
to develop with consequent risk to consumer safety.
Thank you for the invitation to comment. We are content for our
response to be made public.
Yours sincerely
Barbara Saunders
pp Susan Knox
Chair
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