Regulation 854/2004 (H3)
In the FSA's Partial Regulatory Impact Assessment, the agency
notes at paragraph 11:
"The changes to controls on meat hygiene will take account
of the introduction of HACCP-based procedures in slaughterhouses.
These changes will also take account of the fact that the traditional
meat inspection regime is not equipped to cope with the presence
of pathogenic micro-organisms which now account for most food
bourne disease incidents."
UNISON nationally has to challenge the out-dated and mis-informed
assumptions which have led FSA to make this inaccurate and misleading
statement We have repeatedly told the agency that these views
are at least 8 and probably 10 years out of date. FSA has never
given a reasoned argument to the points UNISON has raised in
the past and will now state yet again.
If by "traditional meat inspection," FSA means a
system, which has as its priority the detection of physiological
or pathological lesions, no such inspection has been practised
in the UK for years. Such lesions, as referred to above, are
still looked for at inspection, and the skilled process of judgement
on the amount of meat that needs to be rejected as a result
of what is found is still undertaken by our members. Our members
know, however, that the detection of faecal contamination and
SRM, and the prevention of these materials entering the food
chain, is the priority.
MHS staff also frequently stop production and ensure unhygienic
practices are prevented and a cleaner product is produced. If
inspectors did not carry out on-line inspection, meat plants
would produce a more contaminated product. An FSA microbiologist
has confirmed that the US meat industry, which relies heavily
on HACCP, produces a much more faecally contaminated product
than that found in the UK.
HACCP has been in place in slaughterhouses in Britain for some
years now and has made little or no improvement to meat hygiene.
UNISON nationally surveyed its MHS members earlier this year.
457 people responded.
We asked members:
"Has HACCP improved the quality of product presented for
inspection at your plant?"
91.5% said no, only 8.5% of respondents said yes.
A high percentage of carcasses of all species are still presented
for inspection with visible faecal contamination.
MHS operational staff ensure that the product from British
abattoirs is clean. The FSA argument about "traditional
meat inspection" has not been relevant for years.
We are pleased to see, however, that in the recent, "Report
of the 10th Session of the Codex Committee on Meat Hygiene,
DRAFT CODE OF HYGIENE PRACTICE FOR MEAT (Agenda Item 3),
Point 26, it is stated: "Ante and post-mortem
inspection are fundamental for public health"
The "Codex Committee" further state at "Points
58 and 62" of the "PROPOSED DRAFT ANNEX ON RISK-BASED
POST-MORTEM EXAMINATION PROCEDURES FOR MEAT (Agenda Item 4),"
that the, "Detection of visible contamination," is
a function of meat inspection. As we have already stated above
the detection of faecal contamination is one of the most important
parts of post-mortem inspection. Not only does such detection
remove visible contamination from the food chain but also it
is the only effective way of applying pressure on slaughterhouse
operators to produce clean meat with less invisible contamination,
rather than producing a dirty product and then removing the
visible contamination later.
It is our view that the above realisation has influenced Codex
to make the statement referred to at point 26. We are pleased
to see that the "Codex Committee" is more up to date
with their view of post mortem meat inspection. The FSA would
do well to note this position.
We have also asked the FSA many times to use the results of
official post mortem inspection to audit plant HACCP systems.
We find our view on this subject also supported by the latest
"Codex Committee" opinion. At "9.2 PROCESS CONTROL
& 9.2.2 HACCP, Point 92," Codex confirms that post
mortem inspection is part of "Process Control." Such
inspection, it is stated, should form part of the HACCP or QA
"Codex" return to the subject of HACCP at "9.5.1
Design of post-mortem inspection systems Point 136, Bullet point
10" which states that one of the aims of a post mortem
system is, "Integration with HACCP plans for other process
control activities, e.g., establishment of zero faecal tolerance
criteria for faecal contamination of carcasses."
We suggest that the FSA requires the results of post mortem
inspection, carried out by the official team, to be compared
with the objectives and records of plants' HACCP plans.
The view of our members on the effectiveness of HACCP in the
UK is hardly surprising when members also tell us that high
percentages of carcasses are still presented every day with
visible faecal contamination. How can this be happening if HACCP
is such a successful system? What CCP findings are such companies
recording? The FSA should conduct an immediate investigation
into this divergence between the appearance and reality of HACCP
in meat plans.