CFG
31/05
Letter dated 25 November
2005 from Foodaware to Ms Frances Radcliffe, BSE Division, Defra:
Dear Frances
BSE : Lifting the Export Ban and Harmonising SRM Controls
applicable in the UK with those in other Member States
Thank you for taking the time to brief us at the start of the month
and for your open invitation to comment as soon as possible on these
issues which will help prepare the UK for potential reclassification
as an EU Member State with moderate BSE risk. We have reflected on
our views in the light of those discussions.
As you know, 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.
Foodaware fully appreciates the disastrous impact of BSE on the beef
industry and consumer confidence, and wants to ensure that in the
future the controls are commensurate with the risk from this highly
infectious agent and sufficient to sustain consumer confidence. The
UK currently imports more than 40% of its beef so legislative changes
that enable the UK to become more self-sufficient with good quality
meat while protecting consumers are desirable. The testing regime
for Over Thirty Month cattle which began recently will need time to
bed down and we await with interest the results of the audit of the
abbattoir approval arrangements, and an assessment of the effectiveness
of the first six months of the new scheme’s operation. Any additional
changes brought about by a change in the UK’s risk status should
also be subject to monitoring and the implementation team would seem
to be an appropriate group to undertake that work, and report on it.
However, we believe that the Department should not rush into making
further wholesale changes before the new arrangements for OTM cattle
are known to be working effectively.
There are two other issues on which you are consulting which particularly
effect consumers.
1. Derogations
The UK currently has a derogation to classify vertical column as SRM
in animals over 30 months of age. If the export ban is lifted and
the UK is required to come into line with existing EU legislation,
it is anticipated that a new EU limit under which vertical column
is designated SRM at 24 (rather than the current 12) months will apply.
Vertebral column must be removed in licensed cutting plants but the
UK will consider whether it is appropriate to allow a derogation which
would allow this to be removed at specifically authorised, monitored
and registered butcher’s shops. Many small butchers shops currently
remove this bone up until 30 months under the UK’s beef on the
bone arrangements. The TSE (England) Regulations will need to be amended
to bring about this change.
We do not generally favour the use of derogations which undermine
the common market principles and can be used to erode consumer protection.
Such derogations should in any case only be used on a temporary basis,
and be subject to review in the light of experience from monitoring
of the effectiveness of the controls and enforcement arrangements.
Policy considerations in the EU have resulted in more rigorous controls
on vertical column removal than those previously applied in the UK,
despite our high-risk status. Logically, if VC is designated SRM at
24 months, the UK must comply with that. The consultative document
highlights implications for small businesses in rural areas where
craft butchers would no longer be able to mature half or quarter carcasses
of animals between 24 and 30 months and bone them out in their shops.
This would restrict supply to consumers and pose serious problems
for small butchers. We understand that hill farmers in particular
like to keep beef cattle until 28 or 29 months feeding on grass and
silage, and some slow maturing and rarer breeds benefit from grazing
on the mountains until 36 months. The meat is considered to be of
better quality, with improved fatty acids and better marbling. In
contrast, intensively reared animals can be finished at younger ages
and 50% of meat comes from this source. It is likely that the age
of kill will rise following changes in the payment of the beef subsidies.
Less than 5% of meat currently is sold with the bone in, and 75% of
this is sold through butcher’s shops. Some consumers prefer
roasting joints with the bone in as it can carry the heat through
the joint during cooking. If the derogation was introduced it would
have some consumer benefit, allowing better quality meat to be made
available through traditional outlets. There would have to be additional
controls on the boning and disposal of the SRM. Of 189 small slaughterhouses,
68 have a co-located cutting plant. Ninety per cent of these abattoirs
are linked to a retail butchery outlet. Thus, it would be possible
for controls to be exercised through the abattoir or directly at the
cutting plant or butcher’s shop. Given that the impact of this
derogation would benefit some consumers, that the number of suppliers
and quantity of meat is likely to be low, and the affect on risk is
negligible, we are prepared to support this change which will benefit
rural communities and local markets. It should also mean that the
animals do not have to be transported so far.
We are concerned, however, about how the changes will be enforced
and monitored, The butchers will need to be specially licensed to
remove the VC and must have appropriate arrangements for removal and
disposal of the SRM. We are not convinced that local authority agencies
will have the resources to take on enforcement of additional SRM controls
particularly in rural areas where personnel are few in number. This
role should be brought within the scope of the MHS arrangements currently
in place as they have the necessary expertise in relation to SRM.
All waste from such shops should go for incineration by properly licensed
and monitored operators. Is this adequately covered by the Animal
By-Products regulations or will further legislative amendment be required
to achieve such control? Transporting SRM around the country would
increase the risk of spreading disease and taking it back to the slaughterhouse,
the food source, would seem highly undesirable.
2. Head Meat
At present, the entire head from cattle is SRM from 6 months of age.
The EC may permit head meat over 12 months of age to be removed in
the slaughterhouse for human consumption with only skull, brain and
eyes being designated as SRM. The EU may also allow Member States
a derogation to allow head meat to be removed in specifically authorised
cutting plants. We most strongly oppose this change which would allow
parts of the head to enter the food chain. This is the most high risk
part of the carcass, there would be significant risk of both cross
contamination from brain and spinal tissue, and we believe this part
of the animal should not re-enter the food chain. It would be likely
to be used in the catering and processed food industry, would be of
low economic value and could jeopardise public confidence and public
health.
Although the consultative paper says that there are no ‘significant’
human health implications this would depend on it being properly carried
out, handled and disposed of. We understand that SEAC may have concerns
about the reintroduction of trade in head meat and find the proposal
wholly unacceptable. We would also oppose the use of a derogation
to allow such meat to be extracted in cutting plants and believe that
the precautionary principle should be applied.
Foodaware is content for this response to be made publicly available.
Yours sincerely,
Barbara Saunders
pp. Susan Knox
Chairperson
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