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EC Review of Animal By-products Regulation EC1774/2002 - 18/06/2007
 
VEGAs response to the EU Commission's review of regulations on animal by-products
VEGA's comments are in italics below

For consultation letter click here.


Clarifying the scope

A. Determination of the end of the ABP life-cycle*

Option (a): Do-nothing - Disagree
Option (b): Self-regulation, co-regulation or guidance - Strongly agree
Flexibility in developing HACCP and policing and enforcing can stimulate research and invention. Wildlife interests must also be entertained. Records of rejections of carcases, organs, and offals must be easily accessible and used for research purposes.
Option (c): Legislative review
i. Strongly agree
At-risk material must be dealt with speedily and rendered harmless before storage or dangers in handling and processing may arise.
ii. Agree

B. Coverage of wild animals

Option (a): Do-nothing – Agree
Landfill stipulations will differ from country to country, as well as reasons for culling, destruction, and disposal and control, as well as facilities for, say, power generation and for livestock in collections such as zoos, circuses, and hunt kennels and for fertilizer.
Option (b): Self-regulation, co-regulation or guidance – Disagree
See answer for option (a) above.
Option (c): Legislative review
i. Disagree
ii. Disagree
iii. Disagree
None of these three options indicates adequate rigor in the policing and enforcement of controls.

Categorising new products and technical use of all three categories of ABP

A. Categorising new ABP

Option (a): Do-nothing - Agree
All uses of such materials in manufactured products should be indicated on labelling.
Option (b): Self-regulation, co-regulation or guidance – Agree
Post-BSE regulations offer good lessons in management of risks and the need for “fire-brigade” prevention and action (eg with avian flu).
Option (c): Legislative review – Disagree
i. Disagree
ii. Disagree
iii. Agree
Expedition and competent intervention are best served with this means of control, especially when precautions for the sake of safety may at first sight seem too costly financially.

B. Technical use of all three Categories of ABP

Option (a): Do-nothing – Agree
Option (b): Self-regulation, co-regulation or guidance – Agree
Option (c): Legislative review
i. Agree
ii. Agree
iii. Agree
Policing and enforcement in the “offensive trades” must be asserted by training and licensing of responsible staff, with career development programs. Technological developments should ease the strain of boring and irksome surveillance.

Clarifying the approvals / registrations and controls

Option (a): Do-nothing – Agree
Option (b): Self-regulation, co-regulation or guidance – Agree
Option (c): Legislative review
i. Disagree
ii. Disagree
iii. Disagree
iv. Agree

Clarifying the derogations

Option (a): Do-nothing – Agree
Option (b): Self-regulation, co-regulation or guidance – Agree
Option (c): Legislative review
i. Agree
ii. Agree
Extending derogations should be allowed only for events counting as national disasters and durations of remissions and renewal of such derogations must be allowed with severity and constant overhaul.

Other contributions

Imports from countries outside the EU, either in the raw state or in processed foods or for pharmaceutical or medicinal purposes must be given attention and allocation to appropriate legislative controls and enforcement.

*This consultation was available online on the European Commission website until the 18th June. For full consultation questionnaire contact us at info@vegaresearch.org or try the European Commission.  
 
 

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