We air some of the views that animals and the environment would like to make on the Standards in the FSA's anthrocentric draft regulations, albeit otherwise informatively presented for the meat industry. We play, Doolittle-style, the roles of moover and clucker. And not forgetting the fish...
VEGA's comments for an FSA consultation.
Re: Public Consultation Draft. Guide to Food Safety and other Regulations for the Meat Industry
Our website www.vegaresearch.org illustrates our interest and status in relevant matters, especially as they relate to the wider purviews of the FSA, which would represent Standards embracing matters of general safety in the production of food (and other products from farming) and the care of the land and environment, as well as the well-being of animals, workers, customers, and consumers.
1. Presentation and content of the Draft Guide are very good and apt. Ring binder organization of the material seems most suitable: it allows for insertion and emendations, which are likely to arise quite often (e.g. with changes associated with the over-30-month procedure and consequences of BSE and scrapie). Distribution of the dossiers must be audited. They must be displayed within relevant premises with easy access for inspection, which would be necessary in the course of normal operation, as well as for the purposes of training and scoring for the HAS, and for scrutiny of HACCP procedures. Copies should also be in the keeping of the owners of all catering establishments and departments licensed to purchase and process products of animal derivation intended for food or for manufacturing purposes (e.g. of gelatine, finings, footwear, clothing, and leather). Consistency must be assured with Home Office regulations on Scientific Procedures for the intended killing of animals released from experimental procedures and for disposals of their remains. This provision would extent to all spent livestock, whether reared for breeding in the food industry or in the production of medical materials (e.g. vaccines) and to injured animals intended for experimentation. Common standards at the higher level must obtain, with due attention to the FAWC’s Five Freedoms (which have some relevance even in the conditions of slaughter and butchery).
2. Wording in the Guide needs in many contexts shifting up a gear from conditional and subjunctive forms to imperatives. In Advice for Operators (Part 2, page 11, section 14.3.3), for instance, the guidance is too feeble. It states, “Clean healthy livestock should not be injured or stressed during transport and the opportunity for animals to become contaminated should be minimized. Stressed and dirty animals present a food safety risk.” For further information on Animal Welfare, operators are referred to another Part and Chapter. In any exploration or routine handling of any animals perpetration of cruelty by any description must not occur; if it does, prosecution must ensue. Similar stipulations apply to all movements of animals in the processes of draft, marketing and auctioning, and transhumance (agistment). Records of meat and offal inspection and rejections must be detailed and available in public inspection as antemortem information complementary to postmortem recording of clues to diseases, bruising etc indicating flaws in hygiene and in the care of the live animals.
3. In the interests of traceability and labelling all meat should be sold in labelled packaging or at the point of sale with details of the place and method of slaughter, with further details as necessary on processing for prepared food products. Such information must be stated in an appropriate way for game. These requirements, which extend to meat products purveyed in the service industries and for feedstuff, pet foods and materials sold for consumption by carnivorous animals kept in collections, breeding establishments, and farms. Similar indications, as in nearly all these matters, should be applied to fish. These stipulations unify recommendations by the FAWC for at least the labelling of meat and products from animals killed in the Jewish and Muslim fashions with a consistent overall system without specific discrimination or exemption.
4. Information must be publicly available on gradings based on HAS scores on the facilities and competence of slaughterhouses. Details must be given on the species killed and services for casualty slaughter. The MHS is charged with welfare at slaughterhouses (which must include animals human and non-human) and provision must be made for gradings of performance scored, as with the HAS system, for welfare. Staff in the industry must be granted union facilities or formation of organizations with powers of collective negotiation with management and employers. Owners of premises must take ultimate responsibility for the safety of contract labour and they must indemnify themselves against any claims from the public in respect of food-borne disease and nuisance: alleged adherence to official codes, guidelines, and requirements can count as no more than mitigating pleas in defence against claims of harm and nuisance as well as withdrawals of suspect materials from the market and culling. All factory buildings, including restrooms and offices, must be non-smoking zones. Use of animals such as Judas sheep and goats entails some conflicting considerations of welfare and hygiene; however any reduction of pre-slaughter stress benefits both factors. Inspections of animals from the farm to the slaughterhouse and supervision of loading and unloading, as well as lairaging, demands supervision and control by recognized and responsible agents and handlers. Facilities and buildings may have to be modified to allow maximum recourse to transfers of calm groups of animals in small numbers in comfortable pens raised and lowered, as necessary, by mechanical lifts for the whole journey to the final stage. Judas animals would then be unnecessary.
5. Lists of species being slaughtered must be available for the capabilities of each plant and include, where appropriate, less common animals such as bison, buffalos, equids, cervids, ratites, camelids and exotic vertebrate and invertebrate species. For all these purposes fish must count as animals caught within the definition of the meat industry.
6. Prescribed monitoring of atmospheres and effluents from plants and factories must be continuously recorded. Appropriate measurements, according to relevant HSE requirements, must be recorded and acted on in respect of aerosols, vapours, humidity, and steam in the atmosphere and of BOD in effluents. Special attention must be paid to ammonia in atmospheres and to blood and gut fill and fat taken off in the drains. Air for inflation, e.g. in certain procedures of meat inspection, must be drawn from well ventilated areas outside the premises. All such recording and auditing must be open to public inspection and review. As we have recommended in earlier consultations with DEFRA, all local authorities must be accorded right of entry and inspection to all premises involved within their geographical and political area of responsibility, with a frequency and choice of interested parties not otherwise holding official status or being employees of the factory or premises. Records of such applications and their outcome must be published in the minutes of the local authorities’ committees.
7. Provisions for returns to work of animal or food handlers after a bout of allergy or infectious disease must be stipulated, together with procedures for compensation and appeals. Employment of women of child-bearing age needs special consideration. All employees must wear suitable garb and identification, with changes from outdoor clothing and footwear to disposable kit or overalls etc. that must be laundered in specified facilities. Provisions must be made for “Typhoid Mary” eventualities, when a carrier may have to be excluded for life from the food industry. Cross-contamination must be avoided by appropriate separations of activities and workforces and dedication of premises and production lines. Washing of common machinery may be inadequate in removing sources of contamination and objection from sufferers of aversions to manufactured foods for reasons of allergy (e.g. dairy-products), religion (e.g. Jewish), and vegetarianism.
8. Regulations for the meat industry must cover all material imported or brought into the UK otherwise, with traceability – if necessary with veterinary consulates overseas – through EU border posts, markets, brokerage, and transport literally from farm to fork and with principles of welfare and hygiene applied consistently to meat and products sold and labelled with the details of its origins. The regulations must extend to special trades and anticipate trends in demands and consumption, e.g.
• Supplies for the armed forces.
• Products brought into the UK and Europe by travellers and among catering supplies in ships, aircraft, and trains victualled in ports overseas.
• Definitions of non-human animals are comprehensive in most relevant regulations administered by the FSA and DEFRA. Omissions of animals taken from the wild in various forms of hunting and conditions in game larders must not be overlooked; nor should specialist markets in smokies, frogs, snails, sturgeon, kangaroos, alligators, and bushmeat. Production of maggots as bait for anglers is another process with relevance to welfare, hygiene, nuisance, and environment.
9. Regulations must require supervision and reporting of maintenance and test of performance on machinery and mechanical devices (e.g. stunning guns) and electrical gear and gauges (e.g. for stunning tanks and stun-kill operations). Temperature controllers and recorders (e.g. in refrigerators, working areas, and scalding and dehairing tanks) also need the same attention and reporting. Logs must include information on breakdowns and repairs.