Rural Development Sub-Committee
Inquiry into Animal Welfare and Meat Hygiene
Response from The Association of Meat Inspectors
Dear Mr. Jones,
Please find below the Association of Meat Inspectors (AMI) response to your consultation questions for the enquiry into animal welfare and meat hygiene:
1. How effective are the current enforcement structures on animal welfare and meat hygiene standards in abattoirs and slaughterhouses?
The AMI has voiced its concerns about the so called “light touch enforcement” in the past and still has its concerns today. Much of this stems from the HACCP based systems of production that are now a requirement of the regulations that are now in place.
HACCP based systems of production should be a pro-active approach, identifying potential problems in advance, setting parameters and implementing a system of rectification and verification should these parameters be exceeded. This having been set down, we would argue the point that if any plant is in the situation where it is having to employ a ”trimmer” to remove contamination immediately prior to inspection, then the HACCP system in that plant is failing. Unfortunately, the MHI is only in a position to be able to record contamination actually presented at the inspection point, so no matter how diligent the MHI, the recording system in place will never be able to accurately reflect the effectiveness or otherwise of the HACCP based system.
Another example of where this system is failing is the cleanliness of live stock at the point of intake. Prior to 2006, the MHS had at its disposal the Clean Livestock Policy. This allowed Official Veterinarians and Meat Hygiene Inspectors to prohibit the processing of excessively dirty livestock; a system that proved satisfactory for both the competent authority and the slaughter staff (for whom the processing of dirty livestock can be prove to be at the best inconvenient and at the worst downright dangerous due to knife slippages etc.). The people who were inconvenienced by this approach were the very people who might reasonably have been expected to procure clean livestock in the first instance.
However, since January 2006, the Clean Livestock Policy has been revoked and replaced by the aforementioned HACCP based procedures. This will mean that every HACCP system in every plant will state that only clean livestock should be processed, but in actuality this will mean that dirty livestock will on occasion be processed. This will happen in some plants more than others and at certain times of the year more than at other times. The requirements of the trade would appear to override the provision of clean livestock. This represents a failure of the HACCP based system but, to our knowledge, to date, there has not been any instance of enforcement in this area.
The Clean Livestock Policy was viewed by many within the trade as possibly the greatest step forward in the production of clean carcases and its demise has been much lamented. Should any government be brave enough to re-instate this policy, it would be welcomed by all those physically involved in the production of meat.
With regards to animal welfare at the point of slaughter, it should be noted that in the past a system of rotation within the inspection team has been utilised, particularly in the high throughput plants, allowing the MHI’s to stay “fresh” at their tasks, but also allowing one MHI during every rotation to perform ”other” duties. This would have included welfare checks in the lairage and at the point of slaughter. Following pressure from industry to reduce MHS staff and thus costs, many inspection teams have been reduced to the absolute minimum required to carry out the mechanics of meat inspection. Therefore it is not possible for many MHI’s to carry out welfare checks other than at the start of the kill, their presence being required constantly at the post-mortem inspection point in order to maintain the flow of production.
2. How should veterinary supervision arrangements be delivered in abattoirs and slaughterhouses in Wales?
It is felt by a great many of our members that the current system of contracted veterinary agencies delivering official controls in meat plants has lead to a “reluctance “ by some to “rock the boat” for fear of losing the contracts in the future. Whether there is any substance to this or not, we feel that it would be preferable to see all Official Veterinarians in the position of being employed directly by the Meat Hygiene Service and this could not then be an issue. With regards to the cost of doing this, it has often been asked as to whether the engagement of contractors is in fact the most cost effective option?
We would go on record as stating that a return to the past system of having the MHI performing most of the routine tasks in plant, including ante-mortem inspection is the most cost efficient system of delivery with the Official Veterinarian taking the advisory/auditory role and being on hand/available at all times to the inspection teams in plant. In the past, MHI’s were permitted to carry out ante-mortem inspection on juvenile animals and ensuring that adult animals and those showing abnormalities were detained for closer examination by the Official Veterinarian. This system seemed to work very satisfactorily to all involved and there should be no reason why this system could not work just as well again.
3. How effective is the relationship between the Meat Hygiene Service and the industry?
It is the Association’s view that the lines are blurred sometimes as to exactly who the “service” is provided for – the consumer or the industry? During post-mortem inspection, the benefit of any doubt will always lie with consumer, thus the service is being provided to them. Hopefully the industry will benefit by the enhanced confidence in meat that this inspection provides. It is our view that, as this is first and foremost a service to the consumer, the service should be provided for and funded centrally. The cost of meat inspection is, quite obviously a major point of debate within industry, with the FSA/MHS constantly having to justify their figures. This has lead to some major reviews of staffing levels on lines, and to MHI’s taking on enhanced workloads. In some cases this has meant that some MHI’s on some very high speed/high throughput lines have not had the time to physically do the job to standards that they themselves might expect. This might take the form of “corner cutting” such as only visually inspecting green offals (intestines) where the regulations might require palpation (as in the case of cattle and pigs). It should be borne in mind that not only is time required to actually perform the task of physically inspecting the green offal, but time is also required to wash and sterilize hands and equipment. This is particularly relevant where the MHI is also required to inspect the red offals, meat that is quite likely to go for human consumption and merits the highest standards of hygiene.
4. Could the Welsh Assembly Government take any further action to ensure the proper implementation of relevant legislation on meat hygiene and animal welfare in abattoirs and slaughterhouses in Wales?
The AMI feels that the role of the meat hygiene inspector (MHI) has been greatly diminished since the introduction of the new regulations in January 2006, with greater emphasis placed on the role of the Official Veterinarian and the effective implementation of HACCP based systems of production, with the MHI effectively reduced to merely carrying out the mechanics of meat inspection. We feel that this a waste of valuable resources, with many years of experience being ignored and replaced in some circumstances by inexperienced veterinarians. Therefore, we would contend that a very obvious answer to this question is to enhance the role of the Meat Hygiene Inspector.
It should be noted that this opinion is directly counter to the FSA’s stated intention to move to a “more proportionate and risk based system “of meat inspection and their ultimate goal of handing meat inspection back to industry, in much the same manner as we can now see with the Plant Inspection Assistant (PIA) system being utilised in the poultry industry. We view these intentions as little more than a way to cut costs and, while we appreciate the need to deliver meat inspection in the most cost efficient manner, we would question the wisdom of any move that might be perceived as a drop in standards.
We believe that every carcase produced should be subjected to a full and thorough post-mortem inspection and an informed and crucially, an impartial judgement made as to the fitness of the carcase for human consumption. We fear that this impartiality could well be lost if meat inspection is handed back to industry and we fear that the benefit of any doubt would no longer favour the consumer.
Sir, I sincerely hope that the information and opinion provided here by the Association of Meat Inspectors proves to be of some value to your enquiry, and I invite you to call upon the Association whenever you require a professional opinion on the subject of meat hygiene inspection.
Yours sincerely,
Ian Robinson
General Secretary,
For and on behalf of AMI (GB) LTD
