We review the challenge in importation, say, through border posts in the furthest eastern reaches of the growing EU that may go without further inspections and control inot shops in west Wales. We demand severer tests to counter smuggling, terrorism, and don't overlook husbandry and animal welfare that wouldn't pass muster in the UK.
Amendments to the Products of Animal Origin Third Country Imports (England) (No.3) Regulation 2004.
We attended today an Open Meeting of the Council of the Food Standards Agency at which John Bell described current information supplementing the detail in your dispatch; VEGA and a representative attended an earlier meeting in London of interested parties. This simplifies our response, because we endorse the praiseworthy efforts that the information describes; however, we still have some reservations, which follow:
1. Freedom of Trade is a principle that must not be allowed to deny choice to nations with particular needs to defend national custom or culture, as well as to accommodate exigencies of health, terrorism, ect. It must take account of the need of “fire breaks” in the global village in which threats from mobile pathogens and migratory animals, knowing nothing of border posts and controls, can evade essentially land-based restrictions while enjoying free passage through the seas and air.
2. The regulations must therefore embrace best practice in terms of animal welfare and the environment common to the exporting and importing countries, as well as those obtaining at intermediate stages. Movements of live animals (such as day old chicks and breeding stock, e.g. poultry) of commercial importance or for a destiny in zoos, circuses, or private collections, as well as animals for breeding or sporting exploitation (e.g. “spent” livestock such as cast cows, tups, and hens, and racing horses and greyhounds) must be accommodated within the collection of amended regulations, which must also include live animals traded and exchanged for research; provisions (such as CITES) for endangered species must also be allowed for (which would entail appointment of specialized officials and trained carers).
3. Importers must be bound to the most rigorous regimens for traceability and documentation, all of which should be in English and at least one other European Language. Provisions on animal welfare and slaughter must attain or surpass those applied relevantly by DEFRA and the FSA in the UK (some of which are governed by agencies such as the Meat Hygiene Service); environmental consequences of methods of breeding, rearing and killing must be observed with deference to required practice and employment standards obtaining in the countries involved in the trade (these might involve quotas in emissions and pollution).
4. Exertion of the required controls and supervision requires competence and authority are only now being developed. A specialized investigation service, with undercover facilities and trained in collaboration with Customs and Excise, is required. It is a scandal that suspect and notorious markets have persisted for so long. Supervision costs money. If a system such as the levying applied by the MHS is resorted to, miscreants can use it as a form of insurance to protect them from potential litigation. This is a foreseeable impediment now besetting the MHS (analogy can be found in government health warnings that inhibit smokers’ resort to claims over ill effects). The ploy of using market forces and competition to drive standards up, with the assistance of clever claims and advertising, requires generally unpopular dog-bite-dog tactics, exposing murkiness that all parties have little incentive to expose to expose flagrantly; even customers don’t want to know much about the provenance of animal-derived products. However, the British pig-industry and importers, with interventions from the Advertising Standards Agency, are persevering with a knocking campaign against importation from the Netherlands and Denmark that appeal to customers’ aroused conscience on animal welfare. These are tactics that have produced success for British-made “cruelty free” cosmetics and could erupt to good effect in claims made on British and foreign foods and toiletries.
5. Supervision before products enter the UK or border-posts is a desirable precaution, but it suffers setbacks as the Government and political parties seek to cut the costs of running consulates and embassies, as well as trim the activities of the “Food Safety Agency”. The present Food Standards Agency shows little enthusiasm for extra duties on these accounts and the industry and farmers are generally content to apply the “British” Tractor (probably a Renault) symbol to imported products finished off by an element of British enterprise. Flights and sailing and in-transit travel must carry warnings to incomers to dispose of inadmissible animal-derived products before departure and arrival at BIPs. Carriers must be held responsible for due diligence on these matters. Means must be provided at BIPs for confiscated articles and for dumping and disposal, at least, if not storage for the traveler’s return. Incoming passengers must be warned at points of departure-at the responsibility of the carrier-that animal-derived products covered by the regulations must be not imported in baggage and that arrivals will incur much stricter examination and possible confiscations than heretofore (warnings on rabies posted at ports and harbors provide precedent).
6. We have discussed in DEFRA meetings our concern that local TSOs and EHOs may be stretched unfairly when performing at ports or railway stations duties of national significance. Levies and docking dues may redress the cost of inspection, but they may bear unduly on BIPs at, say, the smaller airports or railway stations. The FSA is at the moment discovering and exposing failures some years ago (e.g. at Dover) that bear witness to such local inadequacy.
7. Human materials, like those from non-human animals (as widely defined) come into the UK from countries outside the EU. Such would include human hair and manufactured goods, e.g. wigs, and organs for transplants and other medical purposes, e.g. blood and derived products. Human placental material may find its way into cosmetics. Semen and other genetic material (especially with advances in biotechnology and controversy therewith) must be considered for listing. We cannot be sure that gelatin, collagen and ossein are not derived from human cadavers or bones. Hyaluronic acid is another ingredient of cosmetic products that can be derived from human umbilical cords.
8. Other pharmaceutical and nutraceutical products derive from by-products (or co-products) from the slaughterhouse, which may be working by methods unacceptable in the UK. Such would be hormones such as insulin and thyroid extracts and BSA (bovine serum albumin), as well as glucosamine, chondroitin, and testicular extracts. Descriptions and labelling must alert potential customers making choices over the sources of such products and the suitability of uncontroversial alternatives. Fetal calf serum will be imported, at least while BSE, Scrapie, and vCJD persist in the UK, for medical research (notably as a factor in replacements for experimentation on live animals) and in the preparation of vaccines. Fetal calves are often delivered by the slaughter at term of pregnant cows, the calf dying unacceptably to many people, by drowning in body fluids. Many vaccines are imported and are produced by methods offensive to animal welfarists; at least, the derivations and formulation of all such products should be easily ascertainable by the simplest use of 1T.
9. Wool, fibers and skins from many species of animals bring in a number of exotic accompaniments that may escape into the environment before they are killed by processing. Wool wax is a source of lanolin and vitamin D3. Some of these products may be derived by shearing or molting; others are taken from slaughtered animals. Lanolin is much used in toiletries and medicaments. Customers, patients, nurses and doctors must always be warned about risks of allergenicity. Feathers are an avian analog of wool in obtention and usage (e.g. for badminton shuttles and bedding). British livestock receive rough treatment and their hides are not favored for the best grades of footwear and clothing. Labelling, as for meat must be required for customers’ information on the origin of leather.
10. Chitin (and chitosan) are by-products of the shellfish industry, now being turned by value adding into processing aids (e.g. to water-proof fruits). Importation of prawns and derivatives offends environmentalists, because intensification of the industry is destroying mangrove swamps and their protection of coastal areas from swamping by tidal waves and tsunamis.
11. Some marine oils for specialized engineering purposes and in exotic foods may be imported that derive from protected or endangered species, e.g. whales. A well informed (and expensive) policing and monitoring service, armed with efficient means of tracking consignments “ from farm to fork” or “ocean to oiler” is necessary and with powerful methods of screening. A consignment of walnuts from, say, China could enter the EU by rail at the Union’s easternmost BIP and traverse many countries coming west through several brokers before it goes on- sale in a health food store in west Wales. We are not assured that conditions of farming, “fair trade”, and safety (e.g. of mycotoxins), which may be compromised during transit through the EU, are being achieved now and are likely to be secured in the near future. Soya products brought in from the Far East have been found on the British market contaminated with toxic DCPs and delegations of officials have had to be dispatched to China in one-off missions to remedy the situation. It is unlikely that any BIP is equipped to measure levels of DCPs. Examinations at British Ports fail to detect illegal drugs among apparently innocent cargos-or even immigrants destined to provide sweated labor for the nastier jobs in the British food industry. Privately chartered and owned means of travel by air and sea, as well as military movements, require enhanced BIP facilities, as well as Customs and Excise control, and points of entry at present inadequately serviced.
12. Components of instruments for pleasure are derived from animals. Some are imported and synthetic alternatives are available, e.g. for strings in musical instruments and sports racquets. Horse hairs are used for bows for stringed instruments. Horse hair has traditional uses for clothing and bedding. It also has been used-like human hair- as a source of proteinaceous materials and amino-acids for nutraceuticals. These basic materials are likely to be imports derived by methods reprehensible if practised in the UK. The British slaughtering industry has lost much of the marketing by-products to enterprise overseas. Welfare considerations-among others- prevent commercialization of antler velvet from British deer as an ingredient for nutraceuticals and tonics; however, this nicety is not observed in New Zealand and imported velvet is used in products sold without adequate description on the British market. Nor are boxed imports of New Zealand sheep-meat labeled clearly with details of the method of slaughter.
13. Some Marine Oils for specialized engineering purposes and in exotic foods may be imported that derive from protected or endangered species, e.g. whales, Objectionable-on environmental and welfare grounds- of materials for fish meal and for surimi for human consumption are imported through British ports by ships flagged by various countries; some may not be full members of the EU.
14. Other challenges to test the competence of a BIP inspector trying to satisfy the requirements of labelling and acceptance on foods, feeds, and other goods could be:
• Application of genetic modifications
• Detection of dairy-products from animals whose feed contained GM components (eg maize, soya, or cottonseed meal).
• These tests would have to extend to milk and derivatives from cows treated with somatotrophins (BSE), as well as to eggs and meat yielded by livestock fed other growth boosters, performance or digestive enhancers, or by metaphylaxis or by the administration of drugs disallowed in the UK that could lead to inadmissible levels of residues. “Hormonised” beef would thus have to be tested for and judged as grounds for rejection on a firm basis of measurement.
• Eggs from caged layers must be distinguished from those of other systems (eg free ranger or organic and similar claims)
• Horse or donkey-meat (or other exotics) in sausages
• Microbial pathogens in products such as meat-and fish-pastes
• Screening and testing for foods and feeds that may have been subjected to irradiation at levels disallowed in the EU.
15. Aftermaths of BSE and foot-and-mouth disease and revived fears of viral diseases spreading from increasing importation of animal-derived foodstuffs (and feedstuffs) indicate that supervision of the dire activities of the live/dead stock industry entail much increased severity in monitoring and control, with penalties for violations, confiscations, and impoundments charged on the polluter-pays principle. Lessons can be learnt from shortcomings in the MHS’s performance and in inter-state trade in the USA. Costs of policing and litigation will be high.