Final progress on Meat Industry Red Tape Working Group recommendations for FSA action

Tuesday 27 July 2004

Last update: 27 July 2004

RECOMMENDATION	GOVT RESPONSE	PROGRESS TO DATE
1. We recommend that the Government uses the report of the HACCP working group to press the case in Brussels for the current meat inspection rules to be replaced by a risk-based system of checks in which plant operators would be much more directly involved and audits of the system would be carried out by independent inspectors in line with general food hygiene requirements.	Accept. ACTION PLAN FOR FARMING (No 39)	Completed The Commission published revised proposals for Regulation 854/2004 on Official Controls in respect of Products of Animal Original was adopted on 29 April 2004. This Regulation will apply in all Member States from 1 January 2006. In addition to inspection tasks, the official veterinarian will be required to audit the slaughterhouse and cutting plant operator's application of HACCP Principles and plant hygiene procedures. Frequency of audits will be based on an assessment of public health, animal health and animal welfare risks (see also items 6 and 7).
2. We recommend that, in order to inform the necessary negotiations in Brussels, research is commissioned into microbiology, epidemiology, meat handling, packing and distribution methods.	Accept.	Ongoing Research has been commissioned to establish non-destructive microbiological sampling methods and carcass hygiene criteria, which may be used for the verification of HACCP in meat plants. Initial results of this research were produced in spring 2002 and reflected in the Meat (HACCP) Regulations 2002. While the results failed to demonstrate mathematical equivalence between a destructive and a non-destructive method they indicated that hygiene control could be achieved by either method. A national data base for results from large plants has been set up within the research project.
3. Government should consider giving financial support for encouraging HACCP in the slaughtering sector.	Not Accepted.	Note HACCP is now a mandatory requirement in licensed meat plants with implementation required from June 2002 or June 2003, according to plant throughput.
4. We recommend (a) the earliest possible introduction of a regime of unannounced, thorough, targeted inspection of plants by the independent authority; (b) higher penalties than at present for those convicted of contravention of the rules; (c) a speeding up of the timetable for revocation of licences in appropriate cases; and (d) withdrawal of inspection services from plants in cases of non-payment of charges for those services.	a) Accept in principle. A system of unannounced inspections to replace the current inspection regime would depend on full introduction of a HACCP system and amendments to EU legislation. b) Accept in principle. (Current penalties at Food Safety Act limit). c) & d) Accept.	Completed. a) Linked to changes to official controls (see item 1 above). b) Offences and penalties will need to be established as part of in new national regulations to apply from 1 January 2006when new EU rules are drawn up (linked to item 1 above) c) The Enhanced Enforcement Powers Regulations came into force in England on 01/03/00, in Scotland and NI on 30/06/00 and in Wales on 16/06/01. d) Regulations providing for the withdrawal of MHS inspection in cases of non-payment came into force in England on 01/03/00, in Scotland on 01/04/00, and in Wales on 18/12/01.
5. We recommend that the situation of some catering butchers falling outside the scope of the meat hygiene rules be reviewed with a view to rectifying the position.	Accept in principle.	Completed EU Food Hygiene Regulations, (see item 1 above) will apply in all Member States from 1 January 2006, and The current draft of the proposed EU hygiene regulations wouldRegulation 853/2004 will require catering butchers to be and subject to meat hygiene the same controls as cutting plants, unless exempt. All food businesses will be subject to Regulation 852/2004.
6. We recommend that the Government instigate urgent discussions with the RCVS about the feasibility of the provision of ‘official veterinarian’ training courses, and with the European Commission about the acceptability of such qualifications for the purposes of EU legislation.	Accept. However, any such proposal would have to be accepted by the EU (not just the Commission). ACTION PLAN FOR FARMING (No 40)	Completed RCVS content that many OVS duties could be carried out by suitably trained auxiliaries acting under the responsibility of the OVS. The EU Regulation 854/2004 on Official Controls will apply in all Member States from 1 January 2006 (see item 1). It sets out the training requirements for Official Veterinarians. Discussions on implementing these requirements have been instigated with relevant organisations.FSA will pursue in context of proposals for new food hygiene regulations (see item 1).
7. We recommend that the Government should seek to persuade the Commission that 100% veterinary supervision in all plants, including cutting plants and cold stores, is wholly disproportionate to the risk and therefore unjustified.	Accept.	Completed The EU Regulation on Official Controls (see item 1 above) will apply in all Member States from 1 January 2006. It removes the requirement for 100% veterinary supervision for slaughterhouses and cutting plants and the requirement for veterinary supervision from cold stores. FSA will seek to ensure that new EU official control requirements are risk-based. (see item 1).
8. Freezing of veterinary supervision at April 1999 levels	Not Accepted.
9. Publication of HAS scores should cease.	Not Accepted.
10. We recommend that all plants that have a well-constructed HACCP with independent third party audit, and which meet pre-determined standards, should be exempt from HAS procedures and subject only to audit visits from the MHS to ensure that the underlying objectives of HAS are being met.	To be considered.	Completed From 1 January 2006 OVSs will, as part of their duties, audit the operators’ hygienic practices and HACCP-based procedures, under the new EU regulations (see item 1). HAS will be replaced by new audit arrangements.
11. We suggest that the level of the low throughput licensing threshold be reconsidered when the EU legislation is next revised.	Accept.	Completed The concept of low throughput plants has been removed under the new EU Hygiene Regulations (see item 1 above) that will apply in all Member States from 1 January 2006. The Commission’s proposals for new hygiene regulations (item 1 above) would remove the concept of low throughput plants.
12. We recommend that the so-called ‘Fleischmeister’ provision should be introduced as a matter of urgency.	Accept.	Completed. As of June 2004To date, 1519 fleischmeister licences have been issued applications (1011 in England, 4 7 in Wales and 1 in Scotland).
13. We recommend that the Government pursues the question of artisan status to see whether smaller operators here would benefit from the implementation of the designation.	Accept.	Completed. Having sought information from all other member states,. We it is clear that neither current EU meat hygiene legislation nor the new EU Hygiene Regulations (see item 1 above) does not provide for such a status.
14. We recommend that the feasibility of the MHS contracting qualified meat inspectors employed by the local authority should be explored with the local authority organisations with a view to its introduction as quickly as possible. In addition, the possibility of MHS staff selling any "spare" time to the State Veterinary Service should also be explored.	Accept.	Completed. MHS held meetings with local authority associations, CIEH, the SVS and other interested organisations to explore possible options. Issues relating to qualifications and availability of alternative work meant that no practical options could be identified.
15. a) We recommend that efficiency targets are set for the MHS and that meeting them should be one of the personal performance targets of the Chief Executive. b) A suitable yardstick could be British charges not exceeding the average of EU charges. The MHS should publish tables monthly, with trend analysis, to show its comparative performance.	Accept.	Completed. Efficiency, value for money and financial performance targets are now included in the annual performance targets for the MHS, set by the FSA. The objective of b) has been achieved by the introduction of an MHS charging system based on headage / throughput, as permitted by EU charges legislation (see item 20).
16. We recommend that the MHS should see if there is any way their efficiency could be improved by a return to cold inspections.	Accept in principle. In low volume plants this may be possible if SRM controls are not compromised.	Completed. After detailed consideration, the FSA has concluded that this could not be taken forward within the current legal framework. Will bear in mind in any future legislative changes proposed.
17. We recommend that wherever economically beneficial to the plant the OVS should undertake the post-mortem inspection of carcases (including monitoring of SRM controls).	Accept. ACTION PLAN FOR FARMING (No 37)	Completed
18. We recommend that, as soon as possible after it is established, the Food Standards Agency should sponsor a thorough, independent efficiency review of the MHS.	Accept. ACTION PLAN FOR FARMING (No 34)	Completed. The report of the independent consultants, Deloitte & Touche, and the responses of the Meat Hygiene Service management and staff were discussed by the Agency’s Meat Hygiene Advisory Committee (MHAC), who agreed there should be further work on the recommendations, including highlighting stakeholder benefits that would arise from implementation. Work is underway on implementing agreed recommendations. Presently awaiting the outcome of a further internal efficiency review.
19. We recommend a speedy conclusion of the MAFF official review of MHS charging policy so that all charging can be seen to be justified and appropriate.	Accept. ACTION PLAN FOR FARMING (No 35)	Completed. The review was implemented in 2000/01. Ministerial decisions to limit increases in MHS charges to the rate of inflation anticipated these changes.
20. We recommend that a small task force is established, with industry involvement, to explore in more detail, within a specified deadline, all the issues surrounding a ‘capping’ approach to charging. The terms of reference should also permit it to consider alternative ways of alleviating the excessive costs faced by low volume plants.	Accept. ACTION PLAN FOR FARMING (No 41)	Completed. The FSA established the Meat Inspection Charges Task Force (chaired by Colin Maclean) in April 2000. Following the Government’s acceptance of the main recommendations of the Task Force, the meat inspection charges regime was amended from April 2001. As a result, in the year 2001/02, Government assistance on meat inspection costs amounted to some ¿20million., and is expected to be at about the same level in 2002/03. The Government continues to meet the shortfall between full costs and the charges paid by industry.
21. We recommend that there should be an independent element to the internal MHS appeals mechanism.	Accept.	Completed. A revised internal complaints handling procedure, incorporating the independent element, has been issued to plant operators and MHS staff.
22. In developing future MHS targets, we recommend that the industry should be involved.	Accept.	Completed. In setting high level performance targets for the MHS, the FSA consults a wide range of external stakeholder organisations, including meat industry representative bodies.
23. We recommend that the Government reconsider the need for SRM controls in sheep, given the theoretical nature of the risk as well as the decline of the BSE epidemic in cattle.	Controls on SRM are kept under constant review. Any changes will be based on scientific advice.	Completed – The Core Stakeholder Group on BSE and Sheep reviewed the need for further precautionary measures. This did not recommend any relaxation of the controls on sheep and goats. The report was endorsed by the FSA Board in June 2002.
24. We urge the Government to see if there is any other way to remove spinal cord from sheep effectively without the need for the carcass to be split.	Accept.	Completed The UK partners of the REMCORD EU demonstration project have demonstrated the effective routine use of the saw in the abattoir 'working line'. Improvements have been made such that the saw is now effective in removal of the column including the spinal cord and DRG. The final demonstration of the bovine saw took place at the end of June 2004. Further development and introduction of the saw in abattoirs will require industry acceptance and commercial financial support.
25. We recommend that the dentition check for sheep be abandoned & replaced by a seasonal carcass check when older animals are being presented for slaughter.	Consider further whether there are any viable alternatives to a 100% dentition check.	Completed The Core Stakeholder Group on BSE and Sheep was of the view that there was no viable alternative until a reliable sheep identification system was in place.
26. We recommend that SRM enforcement costs should be considered as public health protection measures and be met by the Government for as long as the controls remain in place.	Action to defer charging until 31 March 2004 at least announced by FSA in August 2000.Action to defer charging until at least April 2002 announced by Agriculture Minister in September 1999.	Completed The cost of MHS enforcement of SRM controls will continue to be met by FSA for the time being.
27. We recommend that proposals to replace dentition of cattle as the prime indicator of age come forward and are introduced as quickly as possible.	Accept.	Completed At their meeting on 10 July 2003, the FSA Board agreed to recommend to Ministers that the OTM rule (which relies on dentition as the primary indicator of age) should be replaced by the EU-wide testing requirement for OTM cattle slaughtered for human consumption. The recommendations are currently being Board considered by Ministers.that the earliest such a system could be introduced was January 2004.
28. SEAC should measure not only the risk associated with domestically produced Meat-and-Bone Meal (MBM), they must also assess the consequential risk of importing products from animals which may have been fed MBM.	Accept.	Completed. The EU adopted a wide-ranging ban on 1 January 2001, on the feeding of all processed animal protein to farmed livestock.
29. We recommend that the rationalisation of requirements in rendering plants for streaming of SRM and non-SRM materials should be pursued urgently.	Transferred by agreement to Defra in May 2001.
30.	For Defra
31.	For Defra
32. We recommend that all future reviews of the economic impact of legislation on the industry must include consequential as well as direct costs.	Accept in principle. Implementation will depend on the circumstances of any future reviews of the economic impact of legislation on the industry.	Ongoing All legislative proposals are required to include a regulatory impact assessment that follow Cabinet Office guidance.
33. We recommend that the establishment of an EU system be explored to identify real costs on a common basis across the Community.	Accept in principle. It is the European Commission’s responsibility to ensure the EU charges legislation is implemented on a common basis across the EU.	Completed New EU rules on the financing of official controls, including meat inspection, as part of the Regulation on Official Feed and Food Controls, were adopted on 29 April 2004. The rules on charging will apply in all Member States from 1 January 2007.Proposed EU Legislation including the funding of official controls wasPublished on 5/02/03. Negotiations have now begun and are on going within the Council Working Group. The Italian Presidency has indicated they would give this priority.
34. We recommend that a separate policy forum be established, chaired by Meat Hygiene Division, so that the MHS Industry Forum can return to its primary purpose.	Accept. It may be appropriate to extend membership of a policy forum to include representatives of retailing and other customer bodies and of consumer interests.	Completed The first meeting of the FSA's Meat Hygiene Policy Forum took place on 16th April 2002, involving a wide range of stakeholder organisations. including meat industry representative bodies. Meetings are held two or three times a year with papers made available on the FSA website.
35.	For Defra