CFG
27/05
Letter dated 31 October
2005 from Foodaware to Kevin Naylor, Nutrition Division, Food Standards
Agency:
Dear Mr Smith
Consultation on Reducing campylobacter in UK-produced chickens
The main objective of the FSA’s work in this area is to achieve
a reduction in levels of campylobacter infection in chickens, and
as a consequence to reduce human infection. The primary objective
must be for the producers to eradicate the causes of infection and
FSA has a strategy in place for doing this. Although campylobacter
is a difficult organism to conquer, 10 years seems far too long to
achieve a 50% reduction in contamination rates for raw poultry on
sale to the public. The FSA priority should focus on the animal health
and welfare issues rather than debating the validity of the statistics.
The FSA has analysed in detail the existing data on campylobacter
in chickens and the only authoritative conclusion is that there are
widely differing results. Variations result from differences in geographical
area, laboratory at which the analysis was done, time of year, nature
of the sample and the place where the samples were taken (on the bird,
on farm, in slaughterhouses and at retail). The Agency chooses to
take its own 2001 survey which was a structured national survey of
retail poultry as a starting point for establishing a benchmark against
which its target for reducing campylobacter contamination can be measured.
Although that survey suggests the baseline falls within the range
42-76%, the FSA considers that, taking other research into account,
‘levels of contamination are at present at least 70%’.
There appears to be no sound evidential basis for this figure which
is at the higher end of the contamination rates found in 2001. The
consultation document states that this figure is proposed as ‘a
challenging starting point’. Foodaware does not agree with this
conclusion – the figure is arbitrary and
should be recognised as such. That is not to ignore the fact that
the FSA target to reduce campylobacter contamination by 50% by 2010
is very challenging.
However, best practice in the industry in the mid-1990s showed that
some firms had already reduced contamination levels for campylobacter
in poultry flocks to below 50%, and contamination rates of 50% have
also been found in some surveys. We would support a level lower than
the 70% figure chosen.
Another flaw in the FSA analysis is in the conclusion, based on Scandinavian
and Dutch experience, that a 50% reduction may take up to or more
than 10 years to achieve. All these examples had a much lower rate
of prevalence of the disease in flocks when the additional bio-security
measures were introduced, and this may be because the standards of
bio-security were much higher than those in the UK at the outset,
and therefore the room for improvement was less.
The FSA’s objective is to bring about a reduction in human disease
by reducing the amount of contaminated chicken on retail sale, and
hence being brought into domestic kitchens. We strongly support this
approach. However, what is important is not the level at which the
benchmark is set (although it should be more challenging than that
proposed) and achievement of an overall target, but the absolute reduction
in contamination at every stage of the production process. The FSA
should focus attention on designing an appropriate survey methodology
that can show the contamination rates across all stages of production
for different types of chicken and the changes from year to year as
additional bio-security controls take effect. Only when the survey
methodology is robust and comparable, can the public have confidence
that improvements are being made in practice, and not just being claimed.
Foodaware is content for this response to be made publicly available.
Yours sincerely
Barbara Saunders
pp Susan Knox
Chairman
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