Modernisation of veterinary inspection in abattoirs

Transcription

French Presidency of the Council of the European Union
Modernisation of veterinary inspection
in abattoirs
LYON Seminar – 7 to 11 July 2008
CONTENTS
MODERNISATION OF VETERINARY INSPECTION IN ABATTOIRS
1
CONTENTS
1
List of acronyms used in this report
.I Introduction
7
9
.1 Incorporating risk assessment into meat hygiene
9
.a
Presentation of EFSA, the European Food Safety Authority ..............9
.b
Presentation of the Biological Hazards Panel (BIOHAZ) ..................10
.c
BIOHAZ work on meat hygiene and how the work is incorporated
into regulations .........................................................................................10
.d
Conclusions......................................................................................11
.e
Questions .........................................................................................11
.2 Role of the seminar in the context of work on the Hygiene Package – Updating
the legislation to reflect scientific developments
12
NB: The full talk by Éric POUDELET is available on the CD-rom of the seminar
minutes.
12
Questions .............................................................................................14
.3 Importance of the modernisation of veterinary inspection in abattoirs in the
European context
15
NB: The full talk by Jean Marc BOURNIGAL is available on the CD-rom of the
seminar minutes.
15
.II
The current regulatory framework
French National Veterinary School, Lyon, 7 to 11 July 2008
16
1
.1 The Philosophy behind the Hygiene Package: its origins, implementation,
evolution, advantages and disadvantages
16
.a
Origins of the Hygiene Package .......................................................16
.b
Principles of the Hygiene Package...................................................17
.c
Specific elements of the Hygiene Package for the meat sector........17
.d
Links and contradictions between the General Food Law and meat
inspection..................................................................................................18
.e
.2
Reflections for the future ..................................................................18
Veterinary inspections in abattoirs, animal health and animal welfare
19
.a
OIE's procedures for drawing up standards .....................................19
.b
Cooperation between the OIE and Codex Alimentarius ...................19
.c
The OIE "PVS" initiative ...................................................................19
.d
OIE recommendations on animal welfare.........................................20
.e
OIE standards regarding slaughter...................................................20
.3 Work of the Codex Alimentarius on inspections in abattoirs: current situation and
future plans
21
.4 How do we reconcile single, harmonised regulations with individual risk analysis
by each country and performance obligations with choice of which methods to use? –
Impacts on international SPS agreements
23
Round table ..........................................................................................23
.III Scientific basis of veterinary inspections
26
.1 Collection of information on zoonoses and microbiological risk assessments
within the EU framework
26
.2
Hazards and risks: developing the concept
.a
26
Hazard identification and a suggested classification ........................27
.b
Evaluating the exposure of European consumers to the 12 major
hazards .....................................................................................................27
.c
Quantifying the notion of severity of the harmful effect.....................27
.d
Conclusion........................................................................................28
2
.3 Risk factors in livestock farming and connection with meat quality: example of
pig meat - Results from an FCPR (further training through research) thesis
28
.a
Informative value of meat inspection in relation to the six hazards
under consideration ..................................................................................28
.b
Conclusions......................................................................................29
.c
Risk factors on farms which increase biological hazards..................29
.4 Risk assessment: impact on meat, directions for national guidelines – Example of
action taken in Denmark against Campylobacter in poultry
29
.5 Who approves individual risk assessments for each country and each sector, and
the choice of which hazards should be addressed in the context of a safeguard clause
for a given country? Consequences for harmonisation of safety and hygiene criteria
within the European Union – How should the Hygiene Package be developed within a
single-market system?
31
Round Table .........................................................................................31
.IV Modernisation of inspection: tools at the farm stage
34
.1 Food Chain Information (FCI) principles in the Hygiene Package: the Belgian
system
34
.2
Implementation of FCI provisions in the German pig sector
35
.3 Good hygienic practice guides for farms and food chain information in the
ruminants sectors:
36
.4 The good hygienic practices guide for adult cattle, veal calf, sheep and goat
rearing
37
.5
.6
Principles of the compulsory veterinary visit to cattle farms
38
.a
Purpose ............................................................................................38
.b
Conducting the visit ..........................................................................38
.c
Role of the visit.................................................................................39
.d
Conclusion........................................................................................39
Example of feedback to farmers: the British system
39
.7 Relevance of the FCI and effectiveness of the system – Farmers' thoughts on
abattoirs and consideration for public health objectives – Role of farmers' veterinarians
in public health – How can farmers be motivated?
40
Round table ..........................................................................................40
3
Questions from the floor .......................................................................42
Conclusion............................................................................................44
.V
Modernisation of inspection: tools in abattoirs
44
.1
Visual inspection of pigs: presentation of work and results from the Netherlands
45
.2
Opinions in the industry regarding modernisation of inspection
46
.3
Implementation of HACCP in UK abattoirs
47
.4
Opinion of official auxiliaries – changes in the inspection profession
48
.5 Complementary elements of inspection – Operators' sanitary control plans.
Changes to inspection: how far can we go? Thoughts on changes in the role of abattoir
veterinary inspector
49
Round table ..........................................................................................49
.VI Constraints and limitations facing modernisation of inspection
52
.1 Presentation of the pilot scheme "risk markers for official seizure in French
broiler chicken production"
52
.2 Modernisation of inspection in the poultry and rabbit sectors: the French pilot
scheme
52
.a
Framework of inspection in poultry and lagomorph abattoirs ...........52
.b
Comprehensive control of health risks in the poultry and rabbit
sectors: the French pilot scheme ..............................................................55
.3 Opinions of members of the poultry industry on modernisation of inspection – the
AVIPOLE training programme
56
.4 Modernisation of inspection and the consequences for international trade and
exports
58
.5 Presentation of the French poultry sector, organisation of exports and issues
facing modernisation of veterinary inspection in abattoirs in France
59
.a
Structure of the French poultry sector ..............................................59
.b
Modernising inspection: the issues involved.....................................59
.6 Changes to inspection – how far can we go? – thoughts on the trade and export
aspects
60
4
Round table ..........................................................................................60
.VII Inspection responsibilities and associated costs
63
.1 Participation of staff, delegation, role of veterinary inspection in abattoirs,
developments in animal welfare
63
.a
The legal basis underpinning official controls in abattoirs; role and
responsibilities of official veterinary surgeons and official auxiliaries; role of
abattoir employees in inspection...............................................................63
.b
Revision of EU legislation on animal welfare during slaughter .........65
.2 Organisational aspects of inspection – overseeing the veterinary services’
activities – second level controls
66
UAS (official inspection audit unit) ........................................................67
The national abattoir "key contacts network" (RNA) .............................68
.3 Standards and inspection: could standard-based certification be introduced into
the inspection concept and how?
69
.a
Producers' responsibilities................................................................69
.b
Responsibilities of the competent authorities (regulation (EC)
882/2004)..................................................................................................69
.c
.4
A shift of paradigm: for whom?.........................................................70
Charging systems for inspection
.a
70
The Belgian system for financing controls in abattoirs .....................70
Contributions ........................................................................................70
Fees......................................................................................................71
.b
Situation regarding financing of official controls in the different
Member States .........................................................................................72
.5 Links between inspection, audits and certification – overseeing the effectiveness
of inspection – ISO 22000: standards and inspection
72
Round table ..........................................................................................72
.VIIIRecommendations and conclusions
.1
Conclusions
75
75
5
Future directions for inspection.............................................................75
Responsibilities of operators in the sector and the competent authorities75
Food Chain Information (FCI) ...............................................................76
Pilot projects .........................................................................................76
Animal welfare ......................................................................................76
Training.................................................................................................77
Fees associated with inspection ...........................................................77
Comments from the floor ......................................................................77
.2
Recommendations from the seminar
78
Future directions for inspection.............................................................78
Responsibilities of food sector operators and the relevant national
authorities .............................................................................................78
FCI........................................................................................................78
Pilot projects .........................................................................................79
Animal welfare ......................................................................................79
Training.................................................................................................79
Fees......................................................................................................80
6
List of acronyms used in this report
French
English
AFSCA: Agence fédérale pour la sécurité de Federal agency for safety in the food chain
la chaîne alimentaire
(Belgium)
AFSSA: Agence française
sanitaire des aliments
de
sécurité French food safety agency
ASDA: Attestation sanitaire à délivrance Cattle health certificate (France)
anticipée
BIOHAZ : Biological Hazards
CIDEF: Comité interprofessionnel de la dinde French joint turkey industry committee
française
DAB: Document d'accompagnement bovin
DDSV:
Direction
services vétérinaires
départementale
Accompanying document for cattle
des Veterinary
services
département (France)
DGAL: Direction générale de l'alimentation
division
for
the
General food directorate (of French Ministry
for agriculture and fisheries)
DG-SANCO: Direction Générale de la santé European Commission Directorate General
et protection des consommateurs
for Health and Consumer Protection
AESA: Autorité européenne de sécurité des EFSA : European Food Safety Agency
aliments
ENSV: Ecole
vétérinaires
nationale
des
services French national veterinary services school
ENVN : Ecole nationale vétérinaire de Nantes French national veterinary school in Nantes
ESB: Encéphalopathie spongiforme bovine
BSE: Bovine spongiform encephalopathy
OAA : Organisation des Nations unies pour FAO: United Nations Food and agriculture
l'agriculture et l'alimentation
organisation
FCPR: Formation complémentaire par la Further training through research
recherche
FNGDS:
Fédération
nationale
des National federation of cattle health protection
groupements de défense sanitaire du bétail
associations (France)
FNICGV: Fédération nationale des industries National federation of meat producers and
et du commerce en gros des viandes
wholesalers (France)
HACCP: Analyse des dangers et des points HACCP: Hazard Analysis Critical Control
7
critiques pour leur maîtrise
Point
ICA: Information sur la chaîne alimentaire
FCI: Food Chain Information
IFIP – ITP: Institut de la filière porcine – Pig sector institute – Pig sector technical
institut technique du porc
institute (France)
INTERBEV:
Association
nationale National joint cattle
interprofessionnelle du bétail et des viandes
association (France)
MIGA: Mission
d'audit
d'inspection
générale
and
meat
trade
et General inspection and audit team (France)
OIE: Organisation mondiale de la santé World Animal Health Organisation
animale
OMC: Organisation mondiale du commerce
WTO: World Trade Organisation
PVS: performance des services vétérinaires
Performance of Veterinary Services
RNA: Référents nationaux en abattoirs
National key contact persons in abattoirs
SNCP: syndicat national du commerce du National pig traders' union (France)
porc
SNGTV: Société national des groupements National society of
techniques vétérinaires
associations (France)
technical
veterinary
SNISPV: syndicat national des inspecteurs National public health veterinary inspectors'
de la santé publique vétérinaire
union (France)
SNIV: Syndicat national des industries des National meat industry union (France)
viandes
UAS: Unité d'audit sanitaire
Health Audit Unit (France)
UECBV: Union européenne du commerce du European Livestock and Meat Trading Union
bétail et de la viande
CLITRAVI: Centre de liaison des industries CLITRAVI: Liaison Centre for the Meat
transformatrices de viande de l'Union Processing Industry in the European Union
européenne
8
.I Introduction
Paul MENNECIER, head of the Food Safety division at the French General Food Directorate
(DGAL), explained that the French Ministry for Agriculture and Fisheries is organising three
seminars within the framework of the French EU Council Presidency: The current seminar on
modernising veterinary inspection in abattoirs; a seminar on traditional products and food safety,
due to take place in Paris on 23 and 24 October, and finally a conference on sustainable agriculture
and pesticides in Paris on 25 and 26 November 2008. In addition, the informal council of
Agriculture and Fisheries Ministers will meet in Annecy and EU Chief Veterinary Officers will
hold an informal meeting in Strasbourg from 12 to 15 October.
He then explained that the Lyon region, where the current seminar is being held, is the home region
of Michel Barnier, French Minister for Agriculture and Fisheries. But Lyon is also an important
place in terms of the work of this seminar: it is actually the birthplace of veterinary science in the
world, since Claude Bourgelat founded the first French Veterinary School here in 1761. In addition,
the seminar is being held at the National Veterinary Services School (Ecole Nationale des Services
Vétérinaires – ENSV) which, as its Director Olivier FAUGERE explained, trains official
veterinarians from France and abroad, as well as vets in private practice who wish to specialise in
veterinary public health management. The School also provides ongoing training for practising
vets. Finally, ENSV is also one of the Collaborating Centres of the OIE, the World Organisation
for Animal Health, for which it provides expertise on training for veterinary service auditors.
This seminar relates to the central concerns of official veterinarians, and hence of the National
Veterinary Services School, given that in the meat sector abattoirs are the place where primary
production and processing food of animal origin meet. This is why, in addition to meat inspection,
several other checks are carried out in abattoirs, on traceability, animal welfare, monitoring of
animal diseases and testing for drug residues and contaminants for example. Modernisation of the
approach to inspection closely involves the ENSV, as it may lead to changes in the duties and skills
required of inspectors.
Stéphane MARTINOT, Director of Lyon National Veterinary School, one of the four French
veterinary teaching establishments, gave an introduction to the School, which was to be the
backdrop for the seminar. This was the first veterinary school in the world. It has had a European
dimension for many years, as it is accredited by the European Association of Establishments for
Veterinary Education and is in the process of being accredited by the American Association. The
subject of this seminar constitutes an important part of its teaching.
.1 Incorporating risk assessment into meat hygiene
.a Presentation of EFSA, the European Food Safety Authority
Luis VIVAS-ALEGRE described how during the 1980s and 1990s, a series of food safety-related
incidents had occurred whose impact was felt well beyond the Member States in which they arose
and even beyond the boundaries of the European Union. This prompted the publication of the
Green
9
Paper on food law in 1997, followed by a White Paper on food safety in 2000, which led to the
development of a food safety strategy that introduced among other things the "farm to fork"
approach.
The first outcome of this process was the adoption of food safety principles and priorities. Risk
assessment has become the framework within which these principles are guaranteed.
Today, EFSA provides scientific opinions and technical support in all areas relating to food safety.
It also engages in publicity activities regarding the risks.
.b Presentation of the Biological Hazards Panel (BIOHAZ)
The panel is part of EFSA and deals with matters relating to food-borne disease. It therefore deals
with zoonoses, food safety and BSE and waste management.
The panel's day-to-day work is based on questions which are put to EFSA by different sources,
such as a Member State, the European Parliament, the Commission, or EFSA itself. The first phase
is risk assessment, which is carried out prior to drawing up a scientific opinion. The BIOHAZ panel
experts, who are independent, use their knowledge on the subject in question to do this, which
guarantees an independent opinion. This initial work is then reviewed by the EFSA teams. In
practice, the panel is given a specific mission and it then sets up a special working party, in which
outside experts may also be asked to participate. This group produces a draft opinion which is then
examined by the panel, who are responsible for approving it. This opinion is then sent to the
authority that submitted the question, and the authority decides what risk management measures
should be put in place.
A communication process is set up for this purpose, by which the opinions of various professionals
affected by the expert opinion are solicited. The opinions are made public, primarily via the
Internet. A series of recommendations aimed at improving knowledge about the subject under
consideration is drawn up. If gaps are identified at this level, new research topics can be opened
up.
.c BIOHAZ work on meat hygiene and how the work is incorporated into regulations
Firstly, as regards traditional meat inspections, Luis VIVAS-ALEGRE explained that BIOHAZ had
published seven opinions, which related mainly to visual inspection without incision. Commission
regulation EC 1244/2007 lays down certain criteria on the subject with respect to calves and the
young of small ruminants.
Secondly, as regards microbiological meat hygiene, BIOHAZ has produced two opinions, one on
the effect of nitrites and nitrates on microbiological safety of meat, which was published in 2006,
and the other on microbiological criteria and targets based on risk assessment. These have not yet
been fully implemented on the ground.
BIOHAZ has also produced two opinions relating to treatment of carcasses with a view to reducing
or eliminating risk, the first of which related to freezing methods used to allow human consumption
10
of meat contaminated with trichinella or cysticercus and the second of which related to carcass
decontamination.
Finally, the work of BIOHAZ has resulted in two opinions relating to risk assessment verification.
.d Conclusions
Luis VIVAS-ALEGRE reiterated that EFSA provides transparent, independent scientific advice
and technical support on existing food safety legislation and policy.
The BIOHAZ panel deals with biological hazards and food-related disease. Its work relates to
traditional inspection techniques, as well as to the appraisal of new inspection methods for specific
areas. Expert groups are appointed for the different topics associated with inspection.
Finally, EFSA's approach is based on risk assessment which will identify food safety risks that need
to be controlled through EU legislation.
.e
Questions
A representative from the British Food Standards Agency asked for confirmation that when EFSA
formulates its recommendations on risk assessment, it does not take any cost-reduction aspects into
account, but bases its recommendations solely on scientific considerations.
Luis VIVAS-ALEGRE replied in the affirmative: the experts take practical considerations on
board, on the basis of scientific evidence. It is down to the national authorities to implement their
opinions in practice. Until now, there have not been any problems with implementation.
A participant asked whether people in the trade or trade associations are able to submit questions to
EFSA and the BIOHAZ group.
Luis VIVAS-ALEGRE answered that lobbies can ask questions via the Commission. EFSA does
not deal with private questions. It does, however, have a consultation platform which represents all
stakeholders in the sector.
A participant asked what coordination there is between the assessments carried out by BIOHAZ
and those carried out by the various national risk-assessment agencies.
Luis VIVAS-ALEGRE replied that one of EFSA's objectives is to improve coordination and
networking between the Member States. It therefore works together with national agencies that
deal with the same areas. In the past, there has been some doubling up of opinions between the two
levels, but there are now provisions which set out the division of responsibilities between the
national and European levels.
11
.2 Role of the seminar in the context of work on the Hygiene Package – Updating the
legislation to reflect scientific developments
NB: The full talk by Éric POUDELET is available on the CD-rom of the seminar minutes.
Eric POUDELET, DG SANCO, European Commission, observed that meat inspection has been a
key concern of veterinary practice for centuries. Every civilisation has realised the importance of
food for development, and law makers throughout the ages have intervened in implementing
preventive measures to guarantee food safety.
The Mirepoix Charter of 1303, proclaimed by Jean 1st of Lévis, a vassal of Philippe Le Bel,
stipulates that, "We must act to prevent the dangers which arise from consuming meat". These
dangers were not clearly understood, but the Sire of Mirepoix wished to do everything in his power
to avoid them. Public health was therefore already a major concern, which came before financial
considerations. This mentality continues today, in legislation which aims to provide the highest
possible level of food safety, whilst ensuring that food can circulate freely under market conditions
which are fair and equitable for the operators concerned. The Charter banned consumption of horse
meat outright on ethical grounds, as well as the consumption of goat's meat due to the bad
reputation which goats had for often having fevers and carrying Malta Fever (Brucellosis). As for
sheep, they only needed to be inspected once, before slaughter. Cattle were inspected after
slaughter, while pigs underwent two inspections, before and after slaughter. Even at that time,
therefore, people were already aware that some illnesses were transmitted from animals to humans.
The fundamental principles behind meat inspection therefore have a long history, which is far from
over. The European Community's first veterinary directives, directive EC/64/432 on live animal
trade and EC64/433 on meat trade, brought national laws on production of meat intended solely for
trade within the EU into harmony with each other. They also defined good practice for "traditional"
inspections.
Later, the 2000 White Paper on Food Safety, European Commission regulation no. 178/2002,
known as the "General Food Law" and the introduction of the Hygiene Package on 1 January 2006,
allowed meat inspection to take a new direction. The new legislation package has introduced an
integrated "farm to fork" approach covering all food, which is designed to protect consumers. It
also adopts a new legislative approach, emphasising performance obligations rather than insisting
on the means used, thereby removing unnecessary detail and defining the outcomes which need to
be achieved, rather than prescribing what methods should be followed, as was the case with the
1964 directive. The legislation package also makes business operators responsible in the first
instance for food under their control. It provides the necessary flexibility to allow all businesses in
the agri-food sector, especially those with fewer than ten employees, to achieve the outcomes
prescribed by EU legislation.
With specific regard to the meat sector, the Hygiene Package has introduced among other things
guaranteed access to the EU market, regardless of the size of the business: any approved abattoir
can market its products in the 27 Member States and export them to countries outside the EU. The
12
legislation includes a temporary measure, ending on 31 December 2009, which allows small
businesses to obtain EU approval. There is no planned extension of this measure. The Authorities
will therefore need to adhere to this deadline for ensuring that small abattoirs meet EU standards.
After that date, all abattoirs which do not comply with the provisions will be closed. The Hygiene
Package has also introduced exchange of information across the board for all species, so that
slaughtering can be scheduled more efficiently and inspections can be more targeted. Finally,
procedures based on the overall principles of the HACCP system have been introduced, so that all
businesses can draw up their own HACCP plans.
As regards the relevant national Authorities, the Hygiene Package has brought in a fundamental
change to official inspection practices, which can now involve non-official personnel. The package
has also introduced experimentation with new meat inspection methods, within the framework of
pilot projects. Finally, the rules regarding trichinella control have been relaxed for farms or regions
which are recognised as being free from the disease. For example, Denmark is currently a declared
low-infestation zone for trichinella.
In order to ensure that the relevant Authorities implement these changes successfully, it has been
necessary to provide the inspection bodies with the most up-to-date information. With this in mind,
the European Commission launched the "Better training for safer food" initiative in 2006, which
was designed to complement national training on the subject. The scope of the training courses on
offer has been widened in 2008 to include the meat sector. This movement is set to continue, and
to broaden in scope. It is vital in order to ensure that EU legislation is properly implemented.
Finally, Eric POUDELET explained that modernisation of veterinary inspection practices in
abattoirs has already begun. However, it has not yet been finalised: improvements can still be
made, and are necessary. This seminar will therefore provide an opportunity to suggest avenues for
developing the EU system. Its conclusions will also feed in to the discussions which will be taking
place between now and 31 December 2009. A report is due to be submitted to the European
Council in May 2009 on the opinions of business operators and national authorities regarding
implementation of the Hygiene Package. It will provide the basis for a more in-depth discussion
which will lead to new proposals for improving the existing provisions, especially in the field of
meat inspection.
Eric POUDELET said he believes that abattoirs play a special role, as they are a determining factor
for food safety from several different points of view. Indeed, abattoirs deal both with animal health
and food safety, and the link between the two is very close. It does not seem possible, therefore, to
withdraw official veterinarians entirely from the abattoir, due to the number of different inspections
which are required, nor can they be replaced by other professions such as engineers, economists or
doctors.
Official veterinarians need to remain as the central overseeing element in abattoir inspection
activities. They need to become more forceful, and not to be afraid of halting the slaughter process
wherever they spot deviations. They already have this capacity, but do not always use it to the full.
However, there are some questions which still need to be asked. For example, should veterinary
officers always be the only people authorised to carry out meat inspections along the slaughter
chain? Do they need to be present throughout the whole inspection? Would it be possible for them
13
to be present only for the inspection of high-risk batches? Should more work be done to develop
visual inspections? These matters could spark off new regulatory changes within the framework of
the Hygiene Package.
Finally, Eric POUDELET said he was sure that this seminar would be a unique opportunity to look
at the points of view of all those involved in the meat production sector. Directions for future
action which come out of it will contribute to the development of European legislation on
inspections in abattoirs.
Questions
A participant asked whether the Member States have already been able to put the recent changes to
the 2002 General Food Law into practice on the ground.
Eric POUDELET replied that ten years ago, the meat industry had asked for more flexibility and
greater involvement in European regulations. The General Food Law satisfied their request on
these points, but did not lay down what methods should be use to achieve the required the
outcomes. Whilst the Authorities fulfilled their side of the bargain by producing more flexible
regulations, the OAV Inspectors who conduct audits in the Member States report that there are still
problems, especially regarding implementation of the HACCP plan by operators, in abattoirs in
particular. The HACCP plan was designed to offset the reduction in official controls. One of its
main requirements is to record everything, especially any changes which are made, and this is not
usually done in abattoirs. Identification of critical areas is actually straightforward, but is rarely
implemented. Implementation of the Hygiene Package needs to be further improved, but this
entails extra costs for the industry. However, modernisation of inspections should not lead to them
being weakened in order to reduce costs for operators: on the contrary, it should allow obsolete
practices to be removed and replaced with more efficient modern practices, but without lessening in
the slightest the food safety we deliver to the consumer.
One participant said that the Hygiene Package had turned practices upside-down in small
establishments, which are struggling to put the HACCP approach into practice, as well as the
approach of some Inspectors. He therefore asked whether the good practice guides which are being
introduced and which will be validated in stages by the competent authorities will actually become
regulatory, which will enable both the inspectors and those who are inspected to know where they
stand.
Eric POUDELET answered that these guidelines are not intended to replace the regulations. They
have originated from a voluntary initiative by businesses and provide a road map which should be
followed.
The representative of a major European meat producer wondered how it would be possible to
implement the Hygiene Package in its current format within the space of two and a half years,
especially since amendments to it have been spoken about. If the industry is to evolve and take
responsibility in this area, the Authorities must be expected to do the same, and they should not
reinvent what is already in place. Good practice guides are a tool for implementing the legislation.
However, if they are to continue being of use, it is important that the legislation does not change too
often. It will also be important to agree on rules which suit both the industry and the Authorities, in
order to achieve effective controls. At the moment, there are no suitable sanctions for problems
which are encountered.
14
Eric POUDELET replied that finding the balance between the requirements of the authorities and
the industry is not always straightforward. However, the idea is to convince operators that if the
conditions in which they are conducting their business are not optimal, they will not be able to
continue. For their part, official veterinarians need to check that the HACCP plan is being
implemented, and also to check that animal welfare and general hygiene conditions are being met.
It should not be forgotten that the signature of the official veterinary surgeon is important. Of
course business operators want to maximise their profits, but this must not be done at the expense
of hygiene. Several different ways for achieving a high level of meat hygiene can be considered,
however recommending to consumers that they cook their meat well because the abattoirs have not
done their work in terms of hygiene, for example, is not one of them. The plan is therefore not to
change the Hygiene Package, which has only just begun to be implemented on the ground, but to
improve it, whilst highlighting the benefits it represents for the industry if they implement it.
However, there is no intention to simplify veterinary inspections without the industry being obliged
to improve food safety in return.
A representative of the British Food Standards Agency asked whether it might be possible to
guarantee operators that they would not face spot-checks if they could prove that they had effective
measures in place. He felt that operators had been discouraged by the current format of inspections.
Eric POUDELET agreed in principle, acknowledging that risk management needs to be based on
mutual trust. If a business can prove that it has achieved an excellent standard of risk control, and
that it has undertaken, for example, to withdraw its products from circulation in the event of
contamination, as well as having proved itself in the past, it would be acceptable to impose a
slimmed down version of inspections and to reduce its veterinary inspection levy. But before
reaching that point, the operator would need a track record showing that it was trustworthy. In any
event, this type of approach could not be the norm.
.3 Importance of the modernisation of veterinary inspection in abattoirs in the European
context
NB: The full talk by Jean Marc BOURNIGAL is available on the CD-rom of the seminar
minutes.
Paul MENNECIER spoke on behalf of Jean-Marc BOURNIGAL, Director General for food
(DGAL) at the French Ministry for Agriculture and Fisheries, who was detained in Paris at the last
minute. He explained that the work done during this seminar fitted into the overall framework of
the Hygiene Package. The discussions that would take place would form the basis for ten or so
recommendations which would be presented at the Chief Veterinary Officers' informal meeting to
be held in October 2008 in Strasbourg. They would then be used to inform the discussions of the
European Commission, which is due to submit a report on the Hygiene Package to the European
Parliament in Spring 2009.
France had chosen veterinary inspections in abattoirs as one of the topics for discussion during its
EU Council Presidency because it is one of the fundamental priorities of the veterinary sector's
activities, both in terms of its aims and objectives as in terms of its day-to-day work. The
inspection of live animals and carcasses is based on fundamental health principles which are shared
15
by all veterinary surgeons. Its importance for animal health and public health is an accepted fact. It
is a major factor in guaranteeing optimal safety standards in meat products and is at the heart of the
meat inspector's role.
Within the system of official controls, inspection of products in the abattoir is unique. Whilst the
aim of official controls is to check that regulations are being implemented by business operators,
inspection of products constitutes a direct intervention by the inspector on the product. In all
countries, it requires a large number of people who are authorised by the Authorities. For
consumers, the health mark is a guarantee that the products are safe for their health.
Whilst there is no doubt that these inspections in abattoirs are necessary, at present the inspections
are restricted. They need to change in order to take on board the latest scientific data. Progress is
needed so that we can continue to guarantee the highest possible safety standards for consumers.
The work done by the OIE and Codex Alimentarius show that at the worldwide level, the
underlying principles for progress in inspections have already been established. They provide a
flexible approach based on risk assessment. The French EU Council Presidency is also an
opportunity for all the Member States to share experiences and points of view regarding
modernisation of inspections and joint work between inspectors and operators which will guarantee
product compliance.
Finally, Paul MENNECIER highlighted that this seminar would be an opportunity to deal with the
subject of animal welfare. France had organised meetings over the previous months on the theme
of "Animals and Society", the conclusions of which were to be published on 8 July 2008.
.II The current regulatory framework
Session Chairperson: Éric POUDELET, DG SANCO
.1 The Philosophy behind the Hygiene Package: its origins, implementation, evolution,
advantages and disadvantages
.a Origins of the Hygiene Package
Willem DAELMAN, DG SANCO, explained that the Hygiene Package had come into force in
2006. He also highlighted the fact that meat inspection is not a new discipline: in Ancient Times, it
was practised by Egyptian Priests, and later by representatives of the City of Rome. They
performed visual ante mortem and post mortem inspections. In the Middle Ages, inspections were
carried out by butchers' guilds. In the 19th Century, scientific discoveries were made regarding
trichinella and tuberculosis, and links between animal health and human health were established. It
was during this period that the role of veterinary surgeons was firmly established.
Why was a reform of European legislation on inspections in abattoirs considered necessary? It was
because after the internal European market opened up in 1992, there were 17 different directives
covering the field of food safety and hygiene. They also covered other aspects in addition to food
hygiene, such as animal health. They were very wide-reaching and entailed obligations for
business operators and the veterinary authorities. They constituted a sort of 'Catchall' and in some
instances crossed over or even contradicted each other. They also left gaps in the law, or at the
other end of the scale, included details which were not relevant for practitioners. It was therefore
clear that they needed to be revised.
16
Work began on the reforms in 1995, well before the publication of the White paper. The work
focused on defining objectives and removing the unnecessary details in the existing directives. The
work also focused on implementation concerning consistency between procedures for all food
products and for imported foodstuffs. The Hygiene Package was also designed to clarify where
responsibilities lay, fill the gaps in the law, separate quality criteria from labelling criteria and
distinguish between animal health issues and human health issues.
The 17 directives were therefore reorganised into 5 regulations:
•
•
•
•
•
Hygiene 1: general food hygiene: regulation EC 852/2004;
Hygiene 2: hygiene requirements for food of animal origin: regulation EC 853/2004;
Hygiene 3: official controls on products of animal origin: regulation EC 854/2004;
Hygiene 4: animal health rules for food of animal origin: directive 2002/99/EC;
Hygiene 5: repeal of the 17 directives: directive 2004/41.
.b Principles of the Hygiene Package
These are as follows:
•
•
•
•
•
•
"farm to fork";
primary responsibility of business operators;
hygiene and HACCP prerequisites;
good practice guides and HACCP;
flexibility;
prescribing outcomes objectives as opposed to giving detailed descriptions.
.c Specific elements of the Hygiene Package for the meat sector
The following points relate specifically to the meat sector:
• conditions regarding approval of abattoirs, including the smallest ones, have been simplified.
All abattoirs which meet the conditions stipulated in directive 64/433 should be approved without
any problem;
• since 1992, small abattoirs have had to fulfil certain requirements. Current problems suggest
that until now, this has not always been done: they will therefore need to be approved according to
EU requirements;
• food chain information: this is a new element introduced by the Hygiene Package, which has
received the approval of livestock farmers' representative bodies throughout the EU;
•
HACCP;
• microbiological criteria: these were already covered in the 17 directives which existed before
the Hygiene Package;
•
flexibility.
17
On the authorities' side, official veterinarians (OVs) will now conduct audits of the establishments
they visit, in place of detailed inspections. The role of official auxiliaries will also be more
prominent and they will be able to assist the OVs at all stages.
As regards participation in the inspection by the operators' staff, a proposal was made to extend the
principle already used in the poultry sector to all sectors. It was rejected however by the European
Parliament, which decided to restrict the principle to poultry and rabbits.
The Hygiene Package has also introduced new visual inspection methods. One Member State
wished to extend these to the pig meat sector, however the Americans were against this and
threatened to block exports of European pig meat, therefore the proposal was dropped2.
The rules on trichinella have also been updated: they actually only applied to countries outside the
EU, not to Member States. Requests for dispensations have also been updated. At present, no
Member State has made such a request, with the exception of one country which has declared that it
is totally free from trichinella.
Finally, the relevant national authorities can run pilot projects in their own countries, and some of
these have already begun. The authorities are also able to adapt regulations on the presence of
official veterinarians in abattoirs.
.d Links and contradictions between the General Food Law and meat inspection
The General Food Law can be applied to all types of operators, including those which produce
hazardous products. In terms of abattoirs, the competent Authorities are obliged to visit the
establishments regularly to ensure that procedures are being properly applied. They, and not the
operators, are solely responsible for ante and post mortem inspections. In the event of errors, the
national authorities are fully responsible, however this constitutes a contradiction between the
General Food Law and the principles of veterinary inspection in abattoirs.
The question arises as to whether operators now wish to take on this responsibility, which would
allow them to reduce their inspection costs. If operators are to be made responsible for inspections,
this will require debate at the international level, for example within the Codex Alimentarius
framework.
.e
Reflections for the future
Delegating inspections to private companies is a possibility, but this will need to be approved. Two
Member States have already requested this.
2 In September 2008, the FSIS finally recognised the principle of visual inspection as practised in one of the Member
States. However, recognition is given on a country-by-country basis, and there is no blanket recognition under the
Hygiene Package.
18
.2 Veterinary inspections in abattoirs, animal health and animal welfare
.a OIE's procedures for drawing up standards
Sarah KAHN explained that the purpose of the OIE (World Animal Health Organisation, formerly
the Office International des Epizooties, founded in 1924) is to oversee the implementation of
international rules. Within the European Union, there is a system of harmonised regulations,
whereas the OIE has 170 different countries all with very different cultures and health standards,
who need to work together. The OIE works to:
• improve transparency in the area of animal health;
• provide scientific opinions;
• promote exchange of information between countries;
• publish animal health standards in order to facilitate international trade in food from animal
farming.
These standards are needed, in order to:
• guarantee the safety of international trade in these products;
• support transparency during disease outbreaks;
• provide a framework for harmonising national laws and regulations;
• promote business opportunities by helping developing countries gain access to the international
markets.
OIE's procedure for drawing up standards usually takes two years. It is based on questions which
are put to the Organisation. These questions are considered by commissions of specialists, who
take advice from other experts and commissions, before drawing up a draft text which is submitted
to the OIE delegates. These deliver an initial opinion, which is then sent back and looked at by the
specialist commissions. The commissions then deliver their final opinion, before the definitive
version of the standard is published.
.b Cooperation between the OIE and Codex Alimentarius
The purpose of the work between the two organisations is to ensure consistency between Codex
Alimentarius texts and OIE standards, and to avoid doubling up or gaps. Many people feel that joint
work on standards would be beneficial, however this would be difficult in practice, as the OIE has a
2-year process for producing standards, whereas the Codex has an eight-stage process. However,
this would not be impossible in the long term.
.c
The OIE "PVS" initiative
The OIE campaigns at international level to highlight the importance of the role played by
veterinary services in public health. It emphasises that veterinary services should not focus
exclusively on animal health. The 2006 Terrestrial Animal Health Code brought in ante and post
mortem inspections. Certification is the responsibility of the veterinary services belonging to the
relevant national authority, which acts as guarantor for the decisions delivered. The work of the
OIE includes the concept of hygiene and risks which have greater repercussions on public health
19
than on animal health. The work on salmonella in the poultry sector is an example, which is a
priority in some countries whereas it is not taken into consideration in others.
The initiative referred to as "Performance of Veterinary Services" (PVS) aims to strengthen the role
of the veterinary services in the area of food safety, especially in developing countries. This
involves the services monitoring animal diseases and applying international standards during
inspections in order to make these as effective as possible.
This approach is a voluntary process. It is not a question of carrying out an audit, but more of
providing technical support following a request by a country's Authorities. International financial
backers, especially the World Bank and the European Union, are in favour of using this resource. It
shows that the OIE is the only international organisation which seeks to promote cooperation
between national veterinary services.
.d OIE recommendations on animal welfare
This is a role which has been given to the OIE recently. Animal welfare has in fact been identified
as one of OIE's strategic priorities since 2001, and it has set up a working group to deal with the
subject. Its approach is as follows:
•
•
to publish texts which are applicable to the 172 member countries;
to publish guidelines, followed by recommendations.
Within the OIE's Code, animal welfare refers to the way in which an animal grows and develops
within its surroundings. An animal's wellbeing, which is assessed on a scientific basis, is
considered to be satisfactory if the following criteria are met: good state of health, adequate
comfort, good nutrition, safety, the opportunity to express its natural behaviour and the absence of
suffering such as pain, fear or distress.
The following are requirements for animal wellbeing: prevention and treatment of illness, suitable
protection, care, suitable food, handling without cruelty, slaughter in decent conditions. The notion
of animal wellbeing refers to the animal's state, whilst the treatment an animal receives is covered
by other terms, such as "care", "breeding conditions", "ethical treatment".
.e
OIE standards regarding slaughter
The overall principles include the following points:
• animal transport and handling;
• design of slaughter facilities and consideration for animal wellbeing;
• management of fœtuses;
• actual slaughter methods;
• unacceptable practices: for example, the question of ritual slaughter of animals in the context of
religious practices still arises.
The OIE is developing the "person responsible" concept for all the stages which animals go
through; better results are achieved when the person responsible is identified.
20
.3 Work of the Codex Alimentarius on inspections in abattoirs: current situation and future
plans
Steve HATHAWAY, Chairman of the Codex Committee on milk and milk products, was one of the
authors of the Meat Inspection Code. Since the agreement between the Codex Commission and the
WTO was signed, Codex has been working on the subject of raw materials, hygiene practices in
livestock production, general food hygiene principles and microbiological and chemical risk
assessment. It has also been doing some cross-disciplinary work on certification. Among other
things, it has drawn up a Code of hygienic practice for meat, which is compatible with EU
regulations.
The Codex aims to introduce a risk assessment approach for all food types. In terms of inspection
in abattoirs, it has introduced an integrated approach which is geared more towards managing risk
than particular hazards which may be present. This may seem to be a contradiction in terms, as the
concept of risk is assessed throughout the food chain, and only hazards which relate to the risks
identified are taken into account.
The Codex is working towards wider application of the concept of control based on risk
assessment, by implementing a 4-stage approach:
• when a food safety matter arises, an information-gathering exercise is organised and a scientific
opinion is produced;
•
based on this, the various options for risk management are identified and selected;
• control measures are then implemented, once they have been validated and checked by qualified
agents recognised by the appropriate veterinary or health authorities;
•
ongoing monitoring and supervision is then required.
As regards attributing the contamination to a particular food source, epidemiological studies are
carried out, however the Codex cannot do this in all countries. Therefore risk management work
needs to be combined on the ground with epidemiological work.
In the area of equivalence, the work of the Codex is still in progress. It is based on the principles of
mutual recognition and comparability. However, information regarding the impact of inspection in
abattoirs on protection levels within the different national situations is still very limited.
21
Finally, the Codex commission is working on a draft code on control measures for Campylobacter
and Salmonella in chicken meat, in collaboration with New Zealand and Sweden. To produce the
code, it has been necessary to go beyond the General Food Code, which does not deal with specific
pathologies. The risk profile which has been drawn up is very detailed. Control measures are based
on the good hygienic practices described in the Codex commission's Code of hygienic practice for
meat (see FAO website).
The main features are:
•
•
hazard prevention at all stages;
implementing control measures based on risk management.
The aim of the chicken meat code is to provide a decision-making aid for specific incidences. The
information in the code, especially scientific information, is continuously updated and added to, and
as it is accessible on the Internet the Codex hopes that it will encourage application of HACCP
rules and risk management at national level.
Finally, Steve HATHAWAY mentioned some general questions which had arisen on inspection in
abattoirs based on a risk management system:
• Is animal cleanliness a factor in terms of the public health results achieved by abattoirs? What
impact does it have on human health?
•
Is the prevention of hazards adequate confirmation of the value of inspection?
• What contribution do inspection activities make in terms of cross-contamination and
redistribution of disease?
•
How should establishments' performance be measured?
• Is it not the case that post mortem inspections are only an intermediary stage in the control
process? Is it not necessary to introduce ante mortem and post mortem inspections, as is already the
case in Europe?
Can abattoirs really have a risk-based approach? Whilst it is important to stipulate very precise
conditions, this does not mean that we should make prescriptions which are too restrictive: it is
important to allow room for manoeuvre, so that certain adaptations can be made at national level.
To sum up, the Codex believes that risk analysis principles should be applied. All advice given on
risk management should also be based on sound scientific data and should be adapted to each
country's individual public health situation. Inspection should also be adapted to the contamination
risks present in different countries. The Codex does not lay down public health targets and does not
publish standards: it intends to continue providing advice and assistance based on sound scientific
data.
22
.4 How do we reconcile single, harmonised regulations with individual risk analysis by each
country and performance obligations with choice of which methods to use? – Impacts on
international SPS agreements
Round table
Eric POUDELET introduced the discussion by asking representatives of the industry present what
their position is regarding these questions.
André LEPEULE from the French Poultry Industry Federation (Fédération française de l’industrie
avicole - FIA) felt that internationally recognised systems of control are required. Product quality
also needs to be guaranteed, whilst ensuring that operators do not have to bear excessively high
costs for controls.
Fernando PASCUAL, representing ASOCARNE (Asociacion española de empresas de la carne –
Spanish meat industry association) and UECBV Spain, brought up the question of animal welfare.
He did not feel that this European notion could be transferred to OIE and Codex Alimentarius
standards. He also felt that full implementation of the Hygiene Package should be facilitated on the
ground. It is coming up against strong resistance. In addition, business operators and veterinary
services are still not working closely enough together. And there is not enough training leading to
qualification for both professions. There is still much work to be done, therefore, within the
European Union, before considering the international level.
Miroslaw ROZYSCKI, National Veterinary Research Institute (NVRI), Poland, explained that the
law changed in his country in 2004. However, there is still a problem: work needs to be done with
business operators and veterinary services on implementation of the Hygiene Package, which is not
yet being implemented across the board. Nonetheless, Poland has made progress in this area.
He also said that risk assessment practices were different in different Member States. However,
when these States wish to export to countries outside the EU, their meat is stamped "European
Union", and it is the EU which is blamed if there is a problem.
Eric POUDELET wondered how we can reconcile the demands of countries which import
European produce, who require certification, and the adaptation or relaxation of current legislation
between the EU Member States.
Paul MENNECIER, DGAL, replied that the main difficulty in this respect lies in implementation of
the equivalence principle. The appropriate levels of protection in each country need to be
comparable. As these are rarely explicit, there has to be a discussion with the other trading party.
This means that when the health situation in the EU is considered more favourable than in other
regions, we need to be in a position to prove it, so that the importing party can see that it is
unnecessary to ask questions about certain produce. The same logic should also hold at other
levels, especially in the context of risk analysis, which should be implemented jointly by business
operators and the authorities.
Sarah KAHN explained that the OIE has attempted to define a framework which can be applied by
its member countries. However, some countries only apply the parts which suit them. She felt that
an initiative such as that of the European Union, which aims to set up a permanent veterinary
23
committee between itself and certain regions of the world, should be expanded. As regards animal
health, the OIE tries to identify safe products rather than focusing on country of origin.
Steve HATHAWAY of the Codex Alimentarius thought that a shift in paradigm was taking place in
the area of meat hygiene, after several centuries of immobility. But he said we need to look
carefully at each element of the issue, and ask "why, what, who?" every time and not try to do
everything at once. In particular, we need to simplify risk assessment so that we can see the results
more clearly.
As regards appropriate protection levels, he emphasised that whilst the situation is very different in
different countries, audits and controls still need to be carried out and certification systems are
needed. When this is done at product level, it becomes very complicated. It would therefore be
preferable to concentrate on regions which pose problems.
Willem DAELMAN replied to a question regarding the pilot projects: the aim is to ensure that
unanticipated situations are covered and that control and protection measures are tested.
He then answered a question about the possibility of having health and ID marks on carcasses
which would identify the veterinary surgeons and operators responsible. He felt that this idea
would be difficult to put into practice.
Fernando PASCUAL felt that it would be better to have one mark for all the EU countries as
opposed to separate marks.
Willem DAELMAN answered a question regarding audit methods and how animal welfare is
covered in these. He emphasised that when official veterinarians visit an abattoir, they may use any
inspection method they deem necessary. He felt that veterinary audits should be carried out on a
continuous basis. They should take the animal welfare aspect into account.
He then answered a question regarding the deadline for approval of laboratories: all official
laboratories must have been accredited by the end of 2009.
Eric POUDELET asked what the views are at international level on replacing official inspectors
with private bodies.
Steve HATHAWAY answered that in New Zealand there is a government agency in charge of
inspections, but there is also a government-affiliated private agency. In Australia, some inspections
have been privatised. The United Sates and the EU have not accepted this principle, unless an
official inspector is brought in at the end of the inspection.
Sarah KAHN said that as far as the OIE is concerned, inspections of live animals may be delegated,
but the final decision and certification are the responsibility of the relevant authority. Governments
are responsible for the delegations they make and the competence of the agents they delegate.
Willem DAELMAN stated that as far as the European Union is concerned, responsibility for
inspections is strictly a matter for governments.
24
A representative of the French national federation of cattle health protection associations (FNGDS)
asked whether it was conceivable that privatised inspections could in future be entrusted directly to
the business operators, and whether this would not contradict the principle of independence of
inspection vis-à-vis operators' interests.
Willem DAELMAN answered that in the case of poultry, abattoir personnel can take part in the
inspection, under the supervision of the relevant authority. Another possibility is to hand over
certain tasks, which would involve delegating inspection tasks to a private organisation, in this case
a group of private veterinary surgeons, for example. The organisations could apply for
accreditation.
Eric POUDELET added that there was no possibility of handing all inspections over to the private
sector.
Steve HATHAWAY felt that rather than focusing on the "who", we should be focusing on the
"what", i.e. the desired level of protection. He pointed out that ten years ago in New Zealand, the
operators wanted greater flexibility in inspections, with a larger proportion taken on by the private
sector. They are now coming back to this approach. A combined business operator/official
veterinarian system would be a better route.
A participant suggested that the new potentials offered by the legislation should be used to target
current problems, in particular Campylobacter and Salmonella, instead of targeting risks which
were present 30 years ago such as brucellosis or tuberculosis, which have be eradicated in most of
the Member States.
Luis VIVAS-ALAGRE from EFSA answered that within the present context of protecting
consumers against food-related risks, the predominant approach must be risk-based. However,
such an approach requires a major drive in terms of training, especially in the industry, in order to
give operators a clearer understanding of what the authorities require. He asked whether there was
any plan at EU level for disseminating information about these requirements.
Eric POUDELET answered that there is no such plan at present: it is up to the industry to take the
initiative in this area.
Sarah KAHN brought up the issue of publicising risks to the public, which is becoming
increasingly necessary as the public is now aware of the importance of controls in abattoirs. The
OIE has begun studies into publicity of this nature.
A participant mentioned that work was also needed on the contradictions between the Food Law
and Directive 854/2004.
To sum up, André LEPEULE gathered from the discussions that if inspections were to be handed
over to private operators, this would be done under the supervision of the public authorities, who
would be solely responsible for the outcomes of the inspections. He also gathered that risk analysis
is now making good progress. Finally, he emphasised that producers are keen to provide
consumers with healthy, high quality products. The conditions governing inspection are yet to be
defined more precisely within the framework of the Hygiene Package.
Paul MENNECIER suggested that work should be done on areas that would clarify the indicators
and criteria which need be followed, in order to move away from local or regional variations and
obtain results which are relevant in a risk analysis context. It is also important to look at how best to
25
work with farmers to take public health concerns into consideration, and to allow the HACCP
system to be implemented more effectively, primarily through good practice guides.
.III Scientific basis of veterinary inspections
Session chairperson: Tobin ROBINSON, EFSA
.1 Collection of information on zoonoses and microbiological risk assessments within the
EU framework
Tobin ROBINSON explained that EFSA is responsible for risk assessment, while the European
Commission is responsible for risk management and the associated public communication. Indeed,
the European Union needs to base its food safety policy on application of the three components of
risk analysis: assessing the risk, managing the risk and communication.
To carry out risk assessments, EFSA has three methods for gathering and analysing data:
•
monitoring and surveillance;
• EU-wide surveys of prevalence at EU level, which are harmonised and subject to very precise
specifications regarding data collection by the Member States, who forward the data to the
European Commission, which then hands over to EFSA to analyse the data;
• requests for data sent out by EFSA via its website. These calls are directed both at the Member
States and at the industries. They relate to precise topics, sometimes required in the context of
forward planning for risk assessments which the European Commission may request.
All the data which is gathered is used to develop a strategy for a quantitative assessment of the
microbiological risk, which takes the requirements of the parties involved into account (Member
States, scientists, business operators). The data is set out in a risk assessment questionnaire, the
QMRA (Quantitative Microbiological Risk Assessment). QMRAs have been published on subjects
such as salmonella in pigs and farmed chickens.
These risk analyses need to be based on data which is representative of all the parties involved. In
order to be effective and relevant, EFSA needs data on slaughtering practices in all the member
States.
.2
Hazards and risks: developing the concept
Catherine MAGRAS of ENVN, France, presented her work on a scientific analysis approach to
hazards and the methodological bases used to arrive at a quantitative approach. The aim of the
26
work is to provide a methodological basis for scientific analysis of hazards, and to establish an
initial quantitative approach designed in the first instance to prioritise hazards according to their
potential threat to humans.
The EU regulatory framework recommends the systematic use of methods leading to measures that
are more precisely targeted and therefore more effective, so that guarantees can be provided in
terms of human health. The principal method for doing this is HACCP.
Level of risk depends on the likelihood of a harmful effect on human health and the severity of this
effect after human consumption of the contaminated product.
.a Hazard identification and a suggested classification
The work was done in relation to pig meat. There are around forty biological hazards which can
have a harmful effect on consumers. In order to identify which ones represent the greatest threat, it
is necessary to determine the precise context for the assessment of risk to the consumer. This
involves looking at the geographical boundaries of the study and of the food or foods in question.
All hazard analyses and hence risk analyses must be based on the "hazard-product" relationship.
The hazard classification criteria proposed by Catherine MAGRAS are as follows:
•
•
•
Is it a known or a suspected hazard?
What is the geographical distribution of the hazard (Europe / outside Europe)?
Is the hazard currently present in the geographical area in question?
In order to answer these questions, a critical analysis of the scientific literature must be carried out.
In this study, 400 different works were studied, based on which 35 biological hazards associated
specifically with pig meat were identified, 12 of which can be classified as 'major', as they are
known in Europe and are currently present.
.b Evaluating the exposure of European consumers to the 12 major hazards
One way of measuring exposure is the number of cases of illness reported. However, human
consumption of a contaminated product is not the only means by which disease is spread. All
information should therefore be studied in connection with the product and the hazard under
consideration. To do this, it is necessary to identify the products suspected in clinical cases and
analyse the data available on incidence of the disease in relation to human consumption, in order to
assess the average incidence of human cases. For example, on this basis, it seems that among the
fifteen original EU Member States, 56 % of trichinellosis cases can be traced to pig meat.
The average annual incidence of cases of food-borne illness connected with a particular hazard and
a particular product is calculated as follows: incidence for the product in question = incidence x
number of cases reported per 100,000 inhabitants/year.
.c
Quantifying the notion of severity of the harmful effect
How should the severity of an illness be quantified? By whether or not it leads to hospitalisation?
By mortality rate? By days' work lost? By the commercial repercussions for the food industry?
27
Catherine MAGRAS has identified two numerical indicators: morbidity rate and mortality rate,
based on which the level of clinical severity can be calculated: average rate of hospitalisation + 10
x case fatality rate (10 being the chosen weighting factor).
Finally, a "risk score" can be calculated as follows: risk is equal to the incidence of cases caused by
consumption of the product in question contaminated by the hazard in question, multiplied by the
harmful effect severity score for the hazard.
.d Conclusion
Catherine MAGRAS stressed that these are only the first steps towards a quantitative scientific
analysis. She added that there is a problem with availability of scientific data.
However, she feels that these first steps are sound. Finally, she emphasised that all risk
assessments will need to be updated in accordance with changes in the data available and the
systems for recording the illnesses in humans.
.3 Risk factors in livestock farming and connection with meat quality: example of pig meat Results from an FCPR (further training through research) thesis
Julien FOSSE of ENVN, France, presented the principal results of a study which consisted of
applying risk assessment within an overall approach with a view to achieving total control of
threats to consumers in Europe from pig meat. It dealt with six different hazards: Campylobacter,
Clostridium perfringens, Listeria, various Salmonella, Staphylococcus aureus and Yersinia
enterocolitica.
.a Informative value of meat inspection in relation to the six hazards under consideration
Meat inspection is based on the carcass ante and post mortem. It allows contaminated parts of the
carcass or cuts to be kept out of the food chain. To calculate the ratio of failure to provide control in
abattoirs, the prevalence of hazards in carcasses needs to be taken into account, as well as rates of
non-detection and secondary contamination and the impact of pig meat consumption on the cases of
illness reported. However, there are no precise facts available about non-detection and secondary
contamination rates. Julien FOSSE described how ENVN carried out a field study to remedy this,
which revealed poor detection of the hazards which had the highest risk scores. It seems therefore
that indicators relating to the herds need to be devised as a supplement to inspection.
In order to determine these indicators, a correlation needs to be established between infections on
farms and carcass contamination. A study was conducted for this purpose, using the ISOrecommended bacteria identification methods. The study found that:
•
100 % of faecal matter samples contained Campylobacter, but none contained Listeria;
• there is a sharp rise in prevalence of infection of live animals between the farm and the abattoir.
This points to the effect of stress during transport, or to contamination from animal to animal
during transport and during the wait at the abattoir;
28
• there is a wide variation in prevalence of carcass contamination between different abattoirs and
there are wide variations in the degree of contamination.
Julien FOSSE explained that a "transfer rate" can be calculated for a particular hazard and a
particular abattoir: for example, when Campylobacter is detected in live animals, there is a 100 %
chance of it being found in the carcass.
.b Conclusions
The following have been produced by these studies:
•
characterising factors for contamination prevalence among farmed animals;
•
characterising factors for contamination prevalence among animals on entry into the abattoir;
•
characterising factors for contamination prevalence in carcasses.
Each of these factors can be weighted by specific risk factors at each of the stages under
consideration.
On farms, prevalence of contamination among the animals varies according to their exposure to
potential risk factors. During transport of the animals to the abattoir, prevalence can be increased
by up to a factor of 5. Finally, the link between contamination prevalence on entry into the abattoir
and prevalence in carcasses varies according to different abattoirs.
Based on a theory of a low accentuation effect of excretion of the infection during transport, the
prevalence of carcass contamination is only 10%. Conversely, if the accentuation effect of
transport is high, prevalence of carcass contamination can be as high as 90 %.
.c
Risk factors on farms which increase biological hazards
The four risk factors correspond to four major categories:
•
•
•
•
non-compliance with biosecurity measures;
type of feed;
farm management, in particular mixing different animal batches;
animal health management.
In order to apply a risk assessment approach to the pig meat sector, risk profiles need to be defined
for both farms and abattoirs and the two then combined. To define the farm risk profile, it could be
useful to identify the above-mentioned risk factors. To determine the abattoir risk profile, it could
be useful to use the results of bacteriological tests, which can be used among other things to
calculated the transfer ratios, taking Campylobacter as a useful control for faecal contamination.
.4 Risk assessment: impact on meat, directions for national guidelines – Example of action
taken in Denmark against Campylobacter in poultry
Karin BRECK of the Danish Food Ministry explained that risk analysis is used to prevent
Campylobacter in poultry meat. The Danish administration is engaged in risk management
29
activities alongside publicity about the risk, in collaboration with the National Food Institute and
the National Veterinary Institute, which are responsible for scientific risk assessment.
The Danes have succeeded in reducing the incidence of Campylobacter and Salmonella infections
in humans, following outbreaks in the late 1990s. With regard to Campylobacter in particular, a
systematic collection of data was launched in 1990, on the basis of which a risk profile was drawn
up which in 1998 revealed prevalence of the bacteria in poultry products. An assessment of the risk
was carried out in 2001. In 2003, these elements formed the basis of a strategy to reduce the
prevalence of the disease. It took the shape of a voluntary programme based on risk assessment.
The objective was to reduce prevalence in broiler birds. A biosecurity good practice code was
drawn up for the poultry industry and the industry undertook to adhere to the code and attempt to
reduce levels of Campylobacter contamination in flocks as far as possible.
Tests were performed on broiler flocks which were due to be slaughtered one week later, as well as
on refrigerated and frozen poultry products.
Finally, a publicity campaign was launched in 2003, aimed at consumers and in particular at young
adult males, who are the group most affected by Campylobacter infections.
The presence of Campylobacter both in flocks and in poultry meat was considerably reduced.
However, the number of people falling ill after eating poultry is still high. This seems to have been
linked to imported meat. A national plan to combat Campylobacter was therefore launched in
2008.
The plan includes obligatory measures concerning primary production, abattoirs, consumer
information and imported products as well.
The poultry sector is currently drawing up a good hygienic practice code. Studies are due to be
carried out on the number of Campylobacter infections in free-range chickens. Detection of carrier
animals will also be improved.
As regards abattoirs, the measures which are being considered relate to improvement of logistics
and treatment of infected meat before the freezing stage. An experiment has been conducted with
heat treatment for this purpose. A process to monitor the meat produced in the two largest abattoirs
in Denmark has also been set up, which could be extended to other abattoirs.
In terms of consumer education, an advice booklet aimed at private individuals has been
distributed, and educational booklets for children have been distributed in schools.
30
With regard to imports, Denmark has adopted the advice of the European Union regarding
Campylobacter in poultry. It has also asked distributors to introduce stronger food safety
precautions.
To conclude, Karin BRECK said that Denmark had had a good experience of the use of risk
analysis, which had enabled it to reduce the number of Campylobacter infections linked to
consumption of poultry meat.
.5 Who approves individual risk assessments for each country and each sector, and the
choice of which hazards should be addressed in the context of a safeguard clause for a given
country? Consequences for harmonisation of safety and hygiene criteria within the European
Union – How should the Hygiene Package be developed within a single-market system?
Round Table
Stuart ROBERTS, representing UECBV and CLITRAVI UK, explained that there was a large body
of data available on risk assessment and that it was a question of making political decisions based
on these assessments. He believed that many other factors also play a part, such as perception of the
risks in society, or the attitudes of political leaders towards them. He also mentioned the issue of
time: it seems that at present, studies tend to focus on historical rather than current risks. They need
to be brought up to date.
He came back to the idea of defining risk "scores", which he felt would be an excellent starting
point for any risk management system. Special attention should also be given to the issue of
publicity around risks.
Previous speakers had mentioned the fact that more data was needed, not on risk assessment, but on
risk factors. Stuart ROBERTS deduced from this that sharing of data needs to be considerably
improved and trust between the different stakeholders needed to be strengthened, at a time when the
industry is being asked to taken on wider responsibilities in the area of food safety. The industry
therefore needs to become even more involved than previously in gathering information. The
industry is a stakeholder in risk control.
Brice MINVIELLE from IFIP-ITP, France, said that business operators are not responsible for risk
management, but they are responsible for the products that they market and the hidden hazards
which these may contain. The pig meat sector has therefore undertaken to draw up good hygienic
practices for farming and slaughter, in order to raise awareness in the profession and to help
operators decide on suitable control measures. However, these measures have come up against the
obstacle of hazard prioritisation. Having found a lack of information on the subject, the pig meat
sector has based its approach on a list of reasonably foreseeable hazards, without prioritising them.
Since the control measures identified on this basis are not specific to individual hazards, the
absence of prioritisation does not appear to be a problem.
Quantification of risk factors is nonetheless an issue, as is the encouragement given to business
operators to put in place control measures and carry out microbiological analyses in order to test the
usefulness of these measures. Additional checks would not necessarily provide relevant
information, but they would generate extra costs. Brice MINVIELLE said he is more in favour of
targeted tests for particular hazards, which goes back to the argument put forward by Catherine
Magras.
31
Tobin ROBINSON said that a large body of microbiological data exists, but it is difficult to get
hold of. Also, the data is not gathered in the same way by different countries and some data is not
relevant in the context of risk analysis.
Gilles SALVAT from AFSSA (French Food Safety Agency) stressed that in order to perform a
relevant risk assessment, a suitable framework needed to be defined, especially from the "cultural"
point of view (how will the product be prepared and eaten in the country or region in which the
meat is to be sold?). He added that educating consumers is a lengthy process and only produces
results after around twenty years.
He also commented that there was no obvious correlation between inspections and the risk level
which has been assessed, which raises the question as to the usefulness of inspection. It does seem,
however, that the difference between the amount of bacteria transferred on entry and exit from an
abattoir varies greatly from one abattoir to another. This proves that vigorous inspections in
abattoirs are needed, but they need to be different and to focus more on continuous auditing of a
slaughter facility so that it can continuously improve, rather than focusing on measuring bacterial
zoonosis risks.
Finally, he felt that Europe lacks a standardised food safety measurement instrument. At present, it
is impossible to tell whether certain countries have less Yersinia enterocolitica because their
measuring system is better, or because their food consumption habits do not favour proliferation of
the bacteria.
Arie OTTEVANGER, Public Health CVO, Netherlands, thought that a pilot project should be
launched to test the new risk analysis theories, which would produce results more quickly.
Willem DAELMAN stressed that in terms of food safety, concrete measures can produce positive
results. He felt that it would be advisable to concentrate more on risk management. The
Commission ought to focus on the research done by Catherine Magras and Julien Fosse.
A question was asked from the floor concerning risk analyses, which should be based on validated
scientific data. However, is it not true that the availability of such data is posing a problem? In
order to improve data collection, would it not be advisable to strengthen cooperation between the
authorities and all those involved in the industry?
Tobin ROBINSON answered that quantitative assessment of microbiological risks has been seen as
a panacea in many quarters, however it now seems that most of the data needed to carry out
qualitative assessments is not available.
Catherine MAGRAS felt that there is a genuine problem regarding validation of scientific data,
added to which the data available is not always the data needed for addressing current issues.
32
Gilles SALVAT added it would be useful to carry out studies and use the results for quantitative
risk assessments. But it is also important to stress food hygiene in the home and cooking habits, and
to develop hygiene lessons for schools.
A participant thought that it would actually be better to use all the data which is already available.
Primary responsibility for food safety does in fact lie with the producers, and the authorities then do
their work on the basis of scientific information. He believed that there is enough scientific data to
conduct all the necessary studies. In order to make progress, all those involved need to play their
part.
Willem DAELMAN stressed that data can be used to prove many things, however it needs to be
used scientifically, which does not always happen. Not all the available data lends itself to risk
assessment.
In Europe, there is collaborative system for gathering data. This should eventually enable us to
reduce the prevalence of current hazards relating to food safety.
Stuart ROBERTS thought that using the existing data, even if it is not entirely reliable, is better
than inaction on the grounds that the data is not usable. The worst of all worlds would be to decide
that the science is not up to scratch.
Tobin ROBINSON disagreed with the claim that there is insufficient data which is used by some
people as a reason for not conducting studies. We should not be looking for excuses not to act, but
pinpointing areas where the data can be improved so that there can be more studies in the future.
The following question was asked by a participant: in view of the problems with controlling
Campylobacter in the Member States, why did members of the European Parliament reject carcass
washing as an additional safety measure?
Willem DAELMAN answered that Parliament was not the only body to have rejected carcass
washing: it has also been rejected by various Member States.
Tobin ROBINSON wondered what impact carcass washing had on food safety.
Gilles SALVAT replied that the technique is effective if it is used properly. Nonetheless, the
philosophy behind EU regulations has focused on pathogen control further up the chain. If we
implement carcass decontamination, we could risk wasting all the efforts that have been made over
many years.
Brice MINVIELLE added that business operators want to know what methods to use to reduce
bacterial contamination levels. Washing is one method, but experience has shown that the
effectiveness reported in numerous publications is obtained with artificial carcass contamination.
When natural contamination methods are used, they seem to be much less effective. This raises the
issue of how economical the methods are.
Arie OTTEVANGER said that chlorine washing currently has a very bad reputation, which he felt
is a shame as it could be used as an additional decontamination method. He believes a pilot project
on the subject should be launched in order to see whether chlorine decontamination on an industrial
scale would be effective against Campylobacter contamination.
33
Pietro NOE, Minister for employment, health and social policy, Italy, asked how effective visual
inspections were in terms of faecal contamination.
Brice MINVIELLE replied that carcasses must be free from visible faecal matter. All business
operators are aware that this is an important point which it needs to be minimised or remedied.
Gilles SALVAT added that the length of time between contamination by faecal matter and rinsing
is very important. It only takes a few minutes before it becomes impossible to remove the bacteria.
To conclude, Tobin ROBINSON felt that there was still major work to be done to ensure that
microbiological data was both valid and available, and to develop mutual trust between the various
players concerned, so as to promote sharing of information.
.IV Modernisation of inspection: tools at the farm stage
Session Chairperson: Olivier FAUGERE, ENSV, French Agriculture Minister
.1
Food Chain Information (FCI) principles in the Hygiene Package: the Belgian system
Magda VAN CAUWENBERGHE from AFSCA, Belgium, explained that primary producers are
obliged to keep records and to make these available to the relevant authority and the receiving
abattoir operators when they request it. The relevant authority in the animals' place of departure
requests the minimum FCI information intended for abattoirs to be sent to it. The person
responsible for sending the animals ensures that the information is available.
At the abattoir end, operators are obliged to request, receive and check the FCI, after which they
decide whether to accept or reject the animals sent to them.
The official veterinary surgeon studies the FCI and uses it as an integral part of the inspection
procedures. They must record any symptoms or illness present in an animal or a herd which could
affect public or animal health or may be detrimental to the animals' wellbeing, and where
applicable, inform the relevant authority for the farm of origin's food sector, or any other authority
concerned.
Business operators in Belgium objected that the system which was being applied entailed an
additional administrative workload, and expressed their fears that requests for data could be abused
by the commercial parties. They also objected that it was impossible to record Food chain
Information throughout the whole life of an animal, and that abattoir operators could not check all
the data.
AFSCA replied that ideally, FCI should be automated and sent electronically, and that zoonotic
infections are often asymptomatic. It emphasised the vital role of the farm's local vets in
diagnosing disease, the role of the authorities in establishing surveillance programmes for
diagnosing zoonotic
34
infections and the role of the official veterinary surgeon in the abattoir.
Under the new FCI system, the minimum information which pig farmers must provide is the animal
health status of the farm of origin or the region. For pig farmers, this includes information on
medicines and additives used on the animals, with the length of time administered and withdrawal
period, as well as declaration of episodes of illness which may affect meat safety. Mortality must be
reported if the rate is above 5 %. Morbidity must be reported if treatment has been administered to
more that 20 % of animals in a single batch.
Pig producers are also obliged to send the results of any disease diagnosis tests done on samples, as
well as data on zoonosis surveillance and residues, if these are important for public health
protection. Finally, they must submit data on rearing processes, the name and address of the private
veterinarian they use and data on the farm.
FCI came into force in the pig sector on 1 January 2008. For the horsemeat and veal sectors, which
are less organised, negotiations are underway. It may be a matter of delegating FCI declarations to
an approved body. The main difficulty is lack of harmonisation of FCI systems between the
Member States.
.2
Implementation of FCI provisions in the German pig sector
Karin METZ, Federal Minister for Agriculture, Germany, said that when the Hygiene Package
came into force, all players involved in the sector understood that they would have to provide
information for the purpose of FCI as of 1 January 2006. Abattoir operators were obliged to submit
their FCI data to the official veterinarians and to keep detailed records which should be available
when required by the authorities and other business operators.
The State's initial intention in Germany had been not to help with setting up the FCI system, as it
was the responsibility of the industry. However the adoption of regulation 2076 allowed Member
States to introduce FCI in stages in the different business sectors, and abattoir operators had
expressed their concerns regarding the extra administrative workload involved in recording the
data. Farmers' representatives stressed that operators needed a transitional period for exchanging
data. As regards fattening pigs, this posed a problem in southern Germany, where there were a large
number of small holdings. The operators therefore asked for a quality inspection system to be set
up on the ground which would be accessible to all types of holding.
Germany therefore decided to make full use of article 8 of regulation 2076/2005 and introduced a
transitional period leading up to 1 January 2008, as well as producing a standard FCI declaration so
as not to increase operators' administrative workload. The declaration was devised in consultation
with all the stakeholders, including small holders, and for all species intended for slaughter. It is
used to confirm the following:
35
•
that none of the information regarding the health status of animals in the farm of origin or
on the production processes suggests that there has been any illness;
•
there are no signs of illness which could affect the meat;
• no veterinary medical products have been administered 7 days before transfer of the animals to
the abattoir;
• no results from sample testing suggest that the animals in question may represent a public
health risk.
This declaration represents a balanced solution which fulfils the requirements of all the
stakeholders. The final version was presented to operators in the sector be filled in on a voluntary
basis if they so wished: at that time, there was no legal obligation (it was introduced in 2007).
Germany then had to attempt to standardise all electronic data exchange regarding FCI, and an
information campaign was run for this purpose. Model forms were also published, to encourage
farmers to become part of the FCI framework.
A voluntary quality assurance ("QA") system was also introduced, as well as a system known as
"Farmers' friends", which originated in the Netherlands.
.3 Good hygienic practice guides for farms and food chain information in the ruminants
sectors:
Martial PINEAU from INTERBEV, France, described the approach adopted by the cattle sector. He
explained that the FCI covers information from the farms for the abattoirs and inspection services,
to enable them to optimise their management of high risk animals and their ante and post mortem
inspections. INTERBEV decided to work collaboratively and as efficiently as possible to formulate
proposals on the subject. All members of the trades involved in the food chain took part in the
process: farmers, transporters, abattoir operators. Their aim was to set up a system which was
simple, convenient, pragmatic and easy to put into practice.
In order to determine what information should be included in the FCI, they asked five questions:
• What hazards can be identified by the farmers and/or their local vets?
• How do we determine how reliable the information is?
• Does the hazard relate to more than one animal?
• When should the information be sent?
• Does the information entail specific action in the abattoir by the abattoirs, in the context of good
hygienic practice implementation, or by the official veterinary services?
These led them to the conclusion that information should be included in the FCI regarding clinical
cases of salmonella, listeria and botulism infections confirmed by laboratory tests and diagnosed by
a veterinarian, as well as information on cysticercus infections, veterinary medicines used and
whether or not the withdrawal period was over.
However, certain hazards cannot be identified by farmers but can be covered by measures in the
abattoirs, for example environmental pollutants (dioxins, PCB, heavy metals, radionuclides). These
hazards have therefore been included in the information which is to be submitted, but only in
36
accordance with the instructions of the relevant veterinary authorities, which are the sources of
information.
As regards exchange of information, computerised systems are not an option at present. France has
around 250,000 cattle farms. Representatives of the trade were in favour of using an existing
document, the ASDA (Cattle health certificate), which is issued in France for each animal. This
certificate already accompanies each animal, whether it is going to slaughter or changing owners.
It currently contains information on the health status of the herd and is signed by the farmer. Food
Chain Information will be added to the document, in which the farmer will certify that the animal
presents no health risk for consumers. If there is any information on listed hazards, the farmer will
insert this on the reverse of the document.
The information must be given every time cattle are moved: from primary production to market,
from market to collection centre and from collection centre to farms as store cattle or to the abattoir.
Due to the specific nature of the cattle trade in France, where over 98 % of animals are handled by
a middleman before being sent on to the abattoir, the information will travel with the animals. The
ASDA is stuck to the passport. There will be some exceptions to the rule at the request of the
official services in the event of contamination of groups of animals, in order to give the abattoir and
the inspection services the opportunity to organise handling of the animals. In these cases, the
information will be sent 24 hours in advance.
To conclude, Martial PINEAU highlighted the fact that the issue of harmonisation of Food Chain
Information between Member States and circulation of the information within the EU has not been
resolved. The situation is the same with regard to countries outside the European Union. However,
the EU is a net importer of animals. It is possible that increasing quantities of meat from outside
the EU will be consumed in future in the Member States. We will therefore need to ensure that this
meat is subject to the same FCI conditions.
.4
The good hygienic practices guide for adult cattle, veal calf, sheep and goat rearing
Jean-Marc GAUTIER from the French Institut de l’Elevage (Livestock Farming Institute)
explained that the guide was the result of a join initiative between members of the farming
profession, and had been supported by the administration. The Institut de l’Elevage was given the
task of producing the guide, and did so with the help of recognised technical and scientific experts.
The guide was drawn up to complement the good hygienic practices and HACCP implementation
guides for the abattoir and cutting sectors and the work on FCI, with a view to creating a concrete
connection between the different links in the food chain, and to provide consistency in terms of
hazard analysis.
The guide applies to ruminants in the dairy and meat sectors. It also links in with the good practice
guide on the production of raw materials for animal feed.
37
In producing the guide, around thirty different biological, chemical and physical hazards were
analysed with a view to identifying the risks which need to be controlled, of which there are 20: 12
of biological origin, 6 of chemical origin and 2 of physical origin (radionuclides and foreign
bodies). 19 of these concern adult cattle, 15 concern veal calves, 17 sheep and 18 goats.
The good practice guide, which covers control methods, is 200 pages long. It is therefore not
designed to be distributed in full to all farmers. In order for it to be taken on board more readily, it
has been decided that the guide should be a reference work, which should be used on the ground via
a tool that is already used in the trade and across disciplines: the "cattle farming good practices
charter", to which 126,000 or two thirds of farmers adhere, representing 80 % of meat and milk
output.
.5
Principles of the compulsory veterinary visit to cattle farms
.a Purpose
Jacqueline BASTIEN, SNGTV (National society of technical veterinary associations), France,
explained that the main purpose of the compulsory veterinary visit to cattle farms is to keep abreast
of a changing health environment. Certain prophylactic treatments, for brucellosis and tuberculosis
for example, are no longer in use, which means that surveillance procedures need to be adapted and
new tools need to be introduced, such as SIGAL (Système d'information de la DGAL – the French
Ministry of Agriculture's food directorate information system).
Originally, the compulsory visit, brought in by a ruling of 24 January 2005 and carried out by
animal health officers, was once a year. It is now carried out every two years and its scope has
been extended to include public health issues on farms. It now reflects the high expectations of
consumers and citizens in terms of veterinary public health, as well as the legal requirements
introduced since the Hygiene Package came into force.
The purpose of the visit is:
•
•
prevention and control of known contagious diseases;
prevention and control of health risks connected with food at the primary production stage.
On the basis of the data collected, the administration is able to conduct a risk assessment on the
situation in the farms, based on which it can decide on how to focus its control procedures or work
with the different sectors.
.b Conducting the visit
This is a compulsory visit made to all cattle farms by an animal health officer. It is done on the
basis of a standard form and with the aid of a guide which is distributed to animal health officers
and an information sheet which is distributed to farmers. It is reimbursed by the State. The visit
falls into six headings:
•
•
•
•
•
sanitary protection at the farm;
farm premises and equipment;
animal health management;
management of veterinary medicines;
milking hygiene;
38
•
the farm's health documentation.
The animal health officer gathers information under each heading via observation or by questioning
the farmer, then carries out an evaluation based on appraisal criteria described in the guide and
gives recommendations and advice.
The visit is recorded and entered into a tracing system. The farmer keeps the original copy of the
form and the animal health officer keeps a copy. The information in the summary table is sent
electronically to the regional veterinary services division, which is the local representative of the
national authority.
.c Role of the visit
For farmers, the compulsory veterinary visit is an opportunity to obtain advice and to enter into
dialogue with the animal health officer about contagious diseases and public health.
Animal health officers are crucial figures in terms of veterinary public health. They work alongside
farmers on implementation of new regulations and reinforce and renew farmers' links with the
State.
From the administration's point of view, the visits improve their acquaintance with all the farms and
enable them to target official controls at certain farms which appear not to be providing complete
assurance in terms of health.
For the farming sector, the visit acts as an evaluation tool which helps it achieve its performance
targets, for example regarding risk assessment of zoonoses, risk assessments for contamination of
foodstuffs by environmental pathogens, risk assessments for contamination of foodstuffs by drug
residues and finally assessment complemented by an advice service aimed at preventing the risks
which have been assessed.
.d Conclusion
The veterinary inspection can be seen as part of the ante mortem inspection at the farm and it would
benefit from being backed up by an ongoing surveillance and alert system.
.6
Example of feedback to farmers: the British system
Andrew KNOWLES from BPEX, British Pig Executive Ltd., explained that there are 10,000 pig
farms in the United Kingdom. 1,600 of these account for 80% of production and belong to 10
companies. There are also 173 dedicated pig abattoirs in the country, 18 of which handle 92% of
slaughtering.
In addition to official inspections, there is a voluntary inspection system, which covers 92% of pig
meat production and leads to the award of the "Pork Quality Standard" mark. The inspections take
place every two years. This voluntary quality assurance programme has led to the development of
a large database which holds information on feed products used, production systems, names and
39
addresses of the vets responsible, national zoonosis database, etc. The information is available to
farmers via a data server. Farmers can therefore fulfil their regulatory FCI obligations in a few
clicks by connecting to a website.
The information which is gathered provides the basis for clear, effective and transparent
communication and enables operators to make appropriate decisions, for example when dealing
with an at-risk batch of animals. It also has an influence on farmers' practices and helps them meet
the highest food safety standards.
BPEX had already set up a national pig health scheme prior to this, which is designed to improve
the health of herds, which in turn determines food safety and hence consumers' health. It covers all
illnesses which can be detected on animal carcasses. It uses the services of professional veterinary
surgeons, who carry out a diagnosis and record their observations. They inspect approximately
one carcass out of every two and a maximum of 50 pigs per batch of 150 or 200. Checks are carried
out on one day per fortnight. The procedure is financed by the pig sector and provides a clear
picture of the situation of the herds. The information is fed back to the farmers and veterinary
surgeons electronically or by post within 48 hours after slaughter.
Andrew KNOWLES emphasised that the system is not restricted to simply stating the illnesses
which have been found in the animals: it also includes information on their severity and incidence
of the illness in the herd in question.
Quarterly reports are also sent, which allow the farmers to compare themselves with neighbouring
farms and other farms in the region or the country. In addition, since this information feedback
scheme has been in operation for several years, it has been possible to give farmers comparisons
covering several years.
To date, the project has succeeded in reducing the number of cases of pneumonia and pleurisy in
pigs.
The FCI system which BPEX uses provides frequent feedback of information, which enables
farmers to respond rapidly when necessary. It also allows statistical calculations to be made in
order to ascertain whether targets are being met.
.7 Relevance of the FCI and effectiveness of the system – Farmers' thoughts on abattoirs
and consideration for public health objectives – Role of farmers' veterinarians in public
health – How can farmers be motivated?
Round table
Olivier FAUGERE spoke first of all about the FCI. He felt that the presentations had demonstrated
that there were problems which were common to all the States who had tried to implement it, which
related to the role of the State, the involvement of the trade, the persuasion needed to encourage the
different players to adhere to the system, and concern for the proper use of the information to
prevent it from being used for purposes other than public health reasons, for example for
commercial ends.
40
The information can be sent in several different formats, either electronically or on paper. He
thought that electronic means would be difficult for small-scale farmers.
Olivier FAUGERE also made a distinction between approaches based on individual animals for
slaughter or on batches of animals.
Finally, he emphasised the importance of feeding information back to the farmer.
He wondered whether all these systems had already altered or would in future alter approaches to
health concerns among those involved in the production sector.
Marc GAYET, FNGDS (National federation of cattle health protection associations), France, said
that in many cases, the FCI system had been devised in consultation with members of the sector.
While it is attractive in theory, in order to be effective, all the players concerned need to adhere to
it, especially farmers. The farmers are prepared to do this, in that they have already put certain
precautions in place and believe in the genuine value of information feedback. He felt what was
required was systems which were simple and introduced gradually. Finally, the information will
need to be made secure so that it cannot be used for commercial purposes.
Marc GAYET thought that the FCI system should not encumber inspections for certain illnesses,
such as tuberculosis, which he believes has not yet been completely eradicated. He added that the
role of veterinary inspections in abattoirs was to give credibility to the system.
He also underlined the importance of feedback to the farmers, which would help reduce risks, in
conjunction with monitoring of the herds in liaison with local vets.
He also felt it was important for communication with farmers and local vets to be organised
systematically and at an early stage in the production chain.
In France, the measures which have been implemented have succeeded in more precise targeting of
at-risk herds and in planning ahead for problems.
Catherine FAMOSE, Director of the regional veterinary service (DDSV) for the Gers département,
France, observed that inspection on products in abattoirs had reached a limit and was not able to
detect all hazards. Since 2000, farmers have been obliged to keep an identification register of their
animals, which includes a section on health. Until now, what has been missing is a system by which
this information can be followed up from farm to abattoir. The FCI does this.
She emphasised that this system of exchanging Food Chain Information also needed to be
strengthened. Trade organisations had done this using good practice guides, however second level
controls were also needed. This is where animal health officials come in. They conduct
compulsory health visits which at present only concern cattle farms, but which will be extended to
poultry and pigs. Finally, an appropriate sanctions system needs to be put in place. France already
has the Code Rural (Rural Code), but the Hygiene Package allows us to go further.
Finally, Catherine FAMOSE said that the inspection services have asked for electronic systems for
sending information to be extended, even though this may not always be straightforward, as use of
IT among farmers is still low.
41
Pierre BEAUBOIS, representing SNIV and SOCOPA, France, explained that in France all groups
in the different sectors had been involved in devising the FCI from the beginning, which is what has
made it a success. France had introduced a traceability system via the DAB (Cattle accompaniment
document) in 1978. This experience had helped France to set up a traceability system for beef,
which provided consumers with information on the origin and breed of animal that produced the
meat. This saved the cattle sector in the wake of the BSE crisis.
In 1996, the SOCOPA group set up a computerised system with information starting from when an
animal arrived at the abattoir and ending with the final product. In 2004, it decided to set up a
central system which would allow it to manage all its sites. It approached DGAL, which at the time
was considering how best to manage information relating to the inspection services. The two
players worked together to introduce the "NERGAL abattoir" system, from which data is exported
to DGAL's SIGAL system. To do this, the veterinary authorities were given three computer
workstations on which they entered ante and post mortem information immediately on-line. The
system for feedback to farmers still needs to be improved.
Questions from the floor
M. WALL, Ireland, asked what would be the benefit of the FCI system if nothing changed in the
system of inspection in abattoirs.
Martial PINEAU answered that within the overall framework, the actions of abattoir operators and
the veterinary services are based on the information they receive via the FCI. The information they
receive allows abattoir operators to adapt their sanitary control plan and to target problem animals.
It also allows the inspection plans and the regular sampling in abattoirs to be more targeted. When
contamination is identified in an animal, appropriate action can therefore be taken. He therefore
felt that the FCI had led to several specific actions.
Catherine FAMOSE added that the FCI enables information to be given on invisible hazards, to
arrange the slaughter of batches according to their different levels of contamination, to confirm
observations made during visual inspections, and to detect other problems.
Magda VAN CAUWENBERGHE considered that the main purpose of the FCI was to help
abattoirs to decide whether to accept or reject animals.
Pierre BEAUBOIS agreed with this point.
Andrew KNOWLES said that the systems which had been set up in the UK allowed changes
occurring on the ground to be spotted. He felt that a risk-based approach was not the only possible
approach and a quality-based approach was also suitable.
BPEX had asked abattoir operators to state what problems they were experiencing so that they
could be given appropriate help by the inspectors. He asked whether there were any statistics
showing numbers of animals rejected on arrival at abattoirs.
42
Pierre BEAUBOIS replied that SOCOPA owns a site which slaughters 70,000 head of cattle per
year. Out of 35,000 cattle, the information for 280 was unsatisfactory and led to additional controls
and checks, which did not all lead the animal being destroyed.
Marc GAYET thought that all of this shows the importance of working on problems early in the
chain, providing training and information and having responsible practices in place.
Jan VANA from the State veterinary Service, Czech Republic, mentioned the timescale issue: the
FCI is supposed to be sent to abattoirs no later than 24 hours before the animals arrive. He asked
what the maximum length of time is.
Martial PINEAU answered that the regulations do not stipulate a maximum length of time. There
is no benefit in asking for information a long time in advance, as the information is needed to find
out the animals' condition shortly before they enter the abattoir.
Pierre BEAUBOIS said that operators such as SOCOPA would like to receive the information on
the animals at the time the animals arrive, not 24 hours in advance.
Andrew KNOWLES said that in the UK the information is sent at midnight on the day before
slaughter. This means that the animals arrive in the abattoir at virtually the same time as the
information.
Anne COSTAZ, SNISPV, France, brought up the fact that in the UK, independent veterinary
surgeons carry out inspections in abattoirs. She asked what the purpose of this practice was and
what additional benefit it provides in relation to the official veterinary checks.
Andrew KNOWLES answered that they were not there to detect disease in the animals, but to
assess the severity of the diseases affecting the animals, as the rate of throughput (approximately
400 pigs/hour) does not allow for this type of expert checks. 95% of farmers have joined the
scheme. It does not require all the animals to be inspected. Also, the information produced by this
system is available before the information from the FCI system.
Pietro NOE, Minister for employment, health and social policy, Italy, said that his country imports
live animals from other Member States and from outside the EU. How does one obtain relevant
information about these animals, especially if they are not due for immediate slaughter but are for
slaughter at a later date?
Martial PINEAU felt that the answer had to come from the EU. The European Commission had
attempted to harmonise the FCI a few years ago, but the initiative had failed. The Commission
therefore left it up to each Member State to set up its own FCI system. The issue of harmonisation
is now coming to the fore again and will need to be dealt with.
Paul MENNECIER explained that within the framework of the French European Council
Presidency, the issue would be dealt with during a meeting of the Chief Veterinary Officers, with a
view to establishing a method for harmonising information exchange for live animal trade within
the EU.
A British participant suggested that a pilot project should be run to investigate a statistics system
which would provide all the relevant information, whilst ensuring that there are no gaps left in
relation to public health.
43
Andrew KNOWLES was in favour of this approach. He felt that the scheme set up by BPEX could
be used for further stages.
Pierre BEAUBOIS asked whether the British were considering supplying information to
consumers, since this way of checking products randomly does not comply with current European
legislation.
Andrew KNOWLES answered that consumer confidence is vital to the industry. Having said this,
he did not feel that consumers clearly understand the control practices which are in place. Products
marketed in the UK carry quality and checking information. However, it is important to look at
how existing systems can be improved on in a proportionate manner.
A participant thought that the Hygiene Package has imposed a number of different measures on
producers. He felt that it was now producing results, since operators have been taking the initiative
to improve food safety. He felt that it was now the turn of the authorities in the different countries
to make improvements.
A participant thought that the timescale for sending information of 24 hours before the animals
arrive in the abattoir is only relevant for logistical purposes, but not for the other information. He
felt that FCI is relevant for slaughter of batches, especially poultry, but he could not see the
relevance of it for cattle inspection, as cattle are slaughtered individually. The 24 hour time period
should therefore be adjusted for cattle.
On this point regarding cattle, Pierre BEAUBOIS specified that for certain hazards such as
salmonella in a minced beef chain, it is important to have the information before the animals arrive.
Conclusion
Olivier FAUGERE said that Food Chain Information clearly has a role to play in forging links
between the different players, as it facilitates ongoing dialogue between farmers, abattoir operators
and veterinary services. Nonetheless, the scheme is in its infancy and needs to improved,
particularly in terms of communication. We need to ensure that we build a system which supports
the interests of all parties in the sector.
Work will also need to be done on harmonising FCI methods, in order to facilitate trade between
Member Sates and with countries outside the EU.
Finally, Olivier FAUGERE said he was happy to see that the farming profession is showing a
greater interest in food safety.
.V Modernisation of inspection: tools in abattoirs
Session Chairperson: Viveka LARSSON, deputy CVO, Sweden
44
.1 Visual inspection of pigs: presentation of work and results from the Netherlands
Ate JELSMA, Food and consumer product safety authority, Netherlands, said that under the
European hygiene regulations, it had been possible to adopt a new system for post mortem
inspections. Regulation EC 854/2004 in particular stipulates that on the basis of epidemiological or
other data on a herd the relevant national authorities are able to decide that fattening pigs reared in
certain conditions may undergo a visual-only inspection. This is how the pilot project initiated by
the Netherlands in 2006 began. When it began, the question arose as to whether an inspection
method would need to be introduced to replace lymph node incision. The FCI issue also came up in
relation to how food safety levels in pig meat could be improved.
It was decided to replace incision with a different measure for the control and surveillance of
Mycobacterium avium in meat. As regards FCI, it was based on the IKB system which was already
in use in the industry. For post mortem visual inspections to suffice on their own, animals must
satisfy the IKB system criteria and the Mycobacterium avium control procedure.
The procedure for visual inspection of pigs is therefore based on the FCI, which is available in the
abattoir 24 hours before slaughter. It is only used for animals from herds which are compliant in
terms of Mycobacterium avium incidence. In order for the batches to undergo a visual-only
inspection, the FCI is checked when the animals arrive at the abattoir, and checks are made at the
farms they have come from. Internal audits are carried out by independent animal health officials
from the VWA, the Dutch veterinary health authority.
The national authority oversees post mortem visual inspection. Checks are made on the tasks
carried out during the inspection and on application of hygiene rules during slaughter. The abattoir
itself must have supervision practices in place and check a certain number of carcasses and sets of
offal per day. The rate of non-compliance detected must be lower than 2%, based on a comparison
between visual inspection and traditional inspection.
Another arm of the project is an analysis of the threat from Rhodococcus equii and risk assessment
for food safety in relation to endocarditis.
A pilot study to consider visual inspection was run on 174,250 pigs, in which both methods were
used in succession. It appears that a very low proportion of carcasses were not correctly detected
with visual inspection – only nine – which could have been due to logistical reasons. An audit of
the results was commissioned and did not lead to any specific comments.
The standards in place regarding visual inspection are identical to those for traditional inspection.
It has therefore been possible to compare results between the two methods, which has shown that
with visual inspection, the daily percentage of faulty inspections detected has remained below 2%.
The introduction of visual inspection therefore represents a benefit in terms of food safety. The
following are key factors for success:
45




.2
use of an FCI system from farm to abattoir;
introduction of a serological surveillance system on farms designed to identify the profiles of atrisk herds;
introduction of an information system regarding abattoirs;
use of official veterinarians to audit the system.
Opinions in the industry regarding modernisation of inspection
Flemming THUNE-STEPHENSEN, Danish Meat Association, Denmark, said that meat inspection
practices had barely changed since the late 19th Century. They were already based on risk at that
time, though the concept was unknown. However the system is now archaic. Representatives of
the sector believe that a new system needs to be devised to cover risks which are actually present
now and which can vary from one country to another, as present-day zoonoses are quite different.
For example, in Denmark and Sweden, salmonella has been brought relatively well under control,
after several major crises in the years leading up to 2000. It should be remembered that human
salmonella infections can come from a variety of sources. Meat accounts for approximately 36% of
the cases recorded between 1958 and 2006.
How can food safety be improved? To do this, both primary production and abattoirs need to be
taken into consideration. Close cooperation has been established between these two sectors and the
authorities, however the results have not been satisfactory: salmonella still causes deaths among the
population. The possibility of abolishing controls in abattoirs has been brought up, given their
ineffectiveness in controlling the problems in question.
In addition to this, primary production has changed: animal health has been greatly improved and
we have succeeded in preventing repercussions on food safety from the diseases that have occurred.
Moreover, it seems that cases of animal carriers of Salmonella, Yersinia, Campylobacter, Listeria
and E coli VTEC cannot be detected by meat inspection. In addition, 97 % of pig tongues are
contaminated with Yersinia enterocolitica and 94 % are contaminated with Salmonella sp.. In spite
of this, inspection using incision of the lymph nodes still continues.
Would it not therefore be better to change inspections, putting an end to the incision procedure and
focusing on visual inspection, in addition to implementing HACCP principles, so that we can focus
controls on diseases that are actually present?
Flemming THUNE-STEPHENSEN believed that new risk-based inspection principles should be
introduced. The European Union published a draft text on modernisation of inspection in 2002 and
the Codex Alimentarius published its text in 2005. However, reforms are taking a long time to
materialise: the political will is still lacking.
In future, it will be necessary to implement the whole of the Hygiene Package, providing for riskbased meat inspection and introducing visual inspection at all stages of the food chain and for all
animal species. We will need genuine collaboration between the official authorities and operators.
Flemming THUNE-STEPHENSEN also brought up the possibility of introducing a "bonus/malus"
payment adjustment system, involvement of abattoir personnel and the introduction of a "right of
recourse" when an operator does not agree with a decision made by the relevant authorities in their
46
country, as well as right to compensation when a mistake is made which puts their business in
jeopardy.
.3
Implementation of HACCP in UK abattoirs
Peter HEWSON, Food Standards Agency (FSA), UK, explained that there had been an inquiry on
the subject. In 1997, there was a major outbreak of Escherichia coli in Scotland, which killed a
considerable number of elderly people. An official inquiry was launched in the wake of the tragedy,
to see how a repeat of such an occurrence could be avoided. It highlighted the need to implement
the HACCP system. In 2005, another outbreak of Escherichia coli occurred, this time in Wales,
which affected 150 people, mostly schoolchildren who had eaten school dinners. 31 people were
admitted to hospital and one 5-year-old child died. The butcher responsible was sent to prison. He
had not been using the HACCP system. But how was it possible for the problem to occur? Have
things really changed since HACCP was introduced?
Joanna FULLICK, FSA, UK explained that EC ruling 2001/471 came into force in 2002 and
imposed the obligation on meat businesses to introduce food safety management procedures based
on HACCP principles. The large abattoirs were supposed to do this before the end of 2002 and the
smaller ones were given an extra year. However, the small abattoirs experienced major difficulties
in doing this. The FSA therefore decided to offer training modules to operators in the sector.
During the process, the FSA realised that all operators were experiencing problems in
implementing HACCP, due to financial and time constraints. This prompted the authority to
undertake various actions in 2002: it produced good practice guides, distributed a CD-Rom with
generic document templates, published a newsletter on HACCP and organised 13 training
workshops.
The Hygiene Package was published in 2004. It includes 4 different references to HACCP
principles, in regulations 852, 853 and 854/2004. In October 2004, the European Commission
produced a draft guide to HACCP principles, stipulating that they did not apply to businesses with
10 or fewer employers, the very ones which had been targeted for training on HACCP by the
British authorities. In the light of this contradiction, it was decided to wait, and to persuade
operators of the necessity to progress towards HACCP systems. Some flexibility was introduced
into the system. Generic guides were deemed to be appropriate for businesses where the production
process is linear and production methods similar, and where occurrence of hazards is high, which
applies to abattoirs.
In the UK, a guide was drawn up on implementation of these regulations by the meat industry, after
consultation with the industry and with veterinary surgeons. Flexibility applies to recording
methods, follow-up of non-compliance cases and corrective actions. All the people involved are in
agreement on the control points which need to be included: animal cleanliness, dressing techniques,
removal of SRM.
A model HACCP form was produced, which is very straightforward to fill in. It takes the existence
of critical control points into account. In the event of visual-only inspections, a logbook must be
used to record anomalies that are detected and what corrective actions are used. A model logbook
was published for small operators. It includes a daily check-list, listing activities which need to be
carried out before processes are begun. The check-list must be signed every day, to prove that all
the operations have been properly carried out. Businesses need to see that the aim is to promote a
non-compliance management culture.
47
To conclude, Joanna FULLICK commented that:
• ordering businesses to implement HACCP is ineffective, as it does not encourage small
operators to be accountable – applying HACCP cannot make a bad operator better;
• the existence of critical control points are a determining factor in implementation of HACCP
principles, but there are not always CCPs;
• every link in the food chain should conduct its hazard analysis as though it were the final link,
and not rely on the links further down the chain;
• check-lists and logbooks can be effective tools for small operators who need practical help with
implementing a food safety management system.
.4
Opinion of official auxiliaries – changes in the inspection profession
Stéphane TOUZET presented EWFC, the European Working Community for Food Inspection and
Consumer Protection, whose purpose is to bring together associations representing the largest
numbers of controllers and inspectors of food, especially meat, in the EU Member States. It has
been in existence since 1991. The exercise has led to the production of a common vocabulary,
which is a measure of the organisation's responsiveness. Its aims are to promote improvement and
standardisation in food controls, in the interests of both consumers and producers. It produced two
practical guides at the request of the European Commission before the Hygiene Package was
introduced and organises seminars. The most recent seminar, held in 2006, was on qualifications
for personnel responsible for health inspections and the outlook for future changes to inspections.
The work of veterinary inspectors is not always recognised. Stéphane TOUZET said that the
official auxiliaries who conduct inspections are motivated and involved and believe in the value of
their work, provided that the proper conditions for it are satisfied.
Stéphane TOUZET wondered if a Europe-wide veterinary inspection was a realistic prospect. He
said the Hygiene Package represented considerable progress, as it simplified implementation of
regulations and aimed to standardise and raise the profile of inspection. However, its impact has
been far from uniform. The EWFC conducted a survey in 2007, the initial results of which show
that the harmonisation which the Hygiene Package was intended to produce is difficult to put into
practice. In addition, the HACCP system is generally regarded positively in the industry, but not in
abattoirs, where it is related more to good hygienic practices than highly formalised procedures.
Stéphane TOUZET also wondered whether the Hygiene Package is under threat before it has even
been applied in all Member States. In some areas, the veterinary inspection bodies are not in a
position to implement the provisions of the package. He reported that official auxiliaries are in a
precarious position. Some countries employ agents on temporary or part-time contracts, on a
'needs'
48
basis and their status is vulnerable. On top of this, some people are not appointed according to
regulations or are not adequately qualified. The result is that certain "key" personnel simply do not
exist in some countries. This leads in some instances to confusion of roles and problems with
hierarchy and to poorer quality, less effective inspections.
In terms of qualifications, the Hygiene Package provides a clear framework for initial and ongoing
training of auxiliaries and official veterinarians. In addition to training, there is the issue of the level
at which auxiliaries are recruited. They need a minimum level of training to enable them to keep
up with developments in the job and the environment.
As regards number, Stéphane TOUZET said that these are in free-fall in all the EU countries. The
workforce is ageing or the numbers are not high enough. He felt that a blind reduction in numbers
of personnel could jeopardise all the work done on inspection in the past, as well as present and
future work.
Moreover, traditional veterinary inspections are sometimes compromised in some countries, for
cost reasons and due to circumstances. If inspectors are reduced to inspecting carcasses "on the
fly" in abattoirs, where the speed of throughput is extremely high, can this really be called an
inspection? It certainly cannot be called a veterinary inspection in terms of what is defined in the
Hygiene Package.
Stéphane TOUZET then brought up the matters of sub-contracting and privatisation of inspection.
He believed that they represent a false economy and result in pressure being applied on inspectors,
or direct conflicts of interest. In addition, once such measures are taken, the situation is difficult to
reverse.
To conclude, Stéphane TOUZET said that inspection personnel are highly involved in their work.
Inspections are effective, but they are in a fragile balance, which means that caution needs to be
used when it comes to 'modernisation'. He felt that the prospects for traditional veterinary
inspections are good, provided that the profession learns from past mistakes. What is required
above all is exchange of information and harmonisation of practices within the EU.
.5 Complementary elements of inspection – Operators' sanitary control plans. Changes to
inspection: how far can we go? Thoughts on changes in the role of abattoir veterinary
inspector
Round table
Marc SIMON, SNCP (National pig traders' union), France, is the person responsible in his
company for liaising with the official services. They are implementing HACCP. He felt that
relations with the French veterinary authorities were good. When operators present clear,
consistent documents, the authorities are receptive and open to discussion.
Anne COSTAZ of SNISPV (National veterinary public health inspectors' union), France, said that
the Hygiene Package places official veterinarians at the centre of inspection in abattoirs. This
presupposes that they have the human resources and legal backing to carry out their job. The work
of inspections in abattoirs is done as a team between veterinarians and official auxiliaries.
49
Nonetheless, certain hazards cannot be detected during ante and post mortem inspection. Inspection
therefore needs to change. In this respect, the question arises to what extent work can be delegated
to operators and how far they can participate. Anne COSTAZ felt that each animal species poses
specific problems. Delegation should therefore be done with care. She emphasised that the official
authorities are inevitably the sole guarantors of food safety, especially in the event of a crisis.
Stuart ROBERTS, representing CLITRAVI and UECBV, UK, thought that FCI should be thought
of as an integral part of sanitary and food risk management strategy. It should even be the most
important part. It is a matter of public health protection. However, for this to happen we need to ask
what the actual purpose of inspection is, before asking who should do it. We also need to
encourage a professional approach in the industry.
Finally, we need to ask why the issue of modernisation of inspection has arisen. It is not a case of
whether the risks justify inspection, as we know that the risks would be higher if there was no
inspection.
Willem DAELMAN, DG SANCO, felt that the frequency of inspections should be adjusted to the
level of the threat. He felt the tuberculosis example was pertinent in this respect. Some countries
consider it to have been eradicated, whilst this is not the case in others. However, people need to
remain vigilant everywhere.
In terms of HACCP principles, he thought that the scheme for helping operators presented by
Joanna FULLICK was very useful. He also came back to the European Commission's proposal for
small and medium-sized businesses, which appeared to clash with the British authorities' scheme:
he explained that it only applied to small businesses supplying food directly to consumers, not to
small abattoirs.
Anne-Marie VANELLE, DGAL, France, asked why the scheme run in the Netherlands was based
on a test for Mycobacterium avium.
Ate JELSMA answered that the Netherlands was trying to implement an approach based on risk
analysis. It was found that the risk associated with the effects of Mycobacterium avium on human
health could not be completely removed, which is why a specific test was developed.
M. COPPALLE, ENSV, France, asked what the inspection position is in the organic sectors.
Flemming THUNE-STEPHENSEN replied that there should not be any major difference between
herds in the organic and conventional sectors. In both cases, zoonoses need to be combated at
source, therefore inspection should be the same.
A participant asked what the situation is regarding steam decontamination.
Willem DAELMAN answered that it is effective, but it can cause changes in the characteristics of
the meat, especially its appearance. No decision has been made at present. However, some
Member Sates believe that all decontamination should be banned.
50
The Vice Chairperson of EWFC (European Working Community for Food Inspection and
Consumer Protection) wondered whether the seminar would conclude that there should be a single
qualification for inspection personnel, and whether skills and responsibilities needed to be
reviewed, especially by the authorities and the operators.
Willem DAELMAN answered that the question of who should carry out inspection and who is
responsible is an issue. Denmark feels that operators should be involved. This is well outside the
simple framework of the authorities' role.
A participant said that inspectors should be trained in such a way that they are able to adapt to
whatever context they are working in.
Anne TOURATIER, FNGDS, France, agreed with the idea that FCI should be integrated into
inspection and should be the most important part. However, the top end of the chain should not be
given all the responsibility for risk control. All players in the food chain need to share the
responsibility.
Anne-Marie VANELLE wondered whether priority should not be given to known risks, rather than
potential risks.
Flemming THUNE-STEPHENSEN answered that in the context of risk-based inspection, the actual
situation in each country needs to be taken into account. Once practices have been harmonised, he
felt that some flexibility would be possible. As regards tuberculosis, even if a country is free from
the disease, it is still important to carry out incisions on random samples.
A participant thought that the authorities and the industry should work together more closely in
order to find intelligent approaches to regulation. We need to find the best solutions for public
health, while at the same time taking the current realities of the world into account. Herd
classification systems should influence inspection.
Flemming THUNE-STEPHENSEN agreed with his position. Denmark is working on visual
inspection for pigs, in consultation with producers but also with the United States, which is an
export market for Danish pigs. The operators are therefore working together with the authorities.
Olivier LAPOTRE, Rhône département state veterinary services, France, said that the importance
of veterinary inspection was proved in the United Kingdom when it spotted an outbreak of foot and
mouth disease, which is not a zoonotic infection, as soon as it started. What would the
consequences have been if it had been discovered several days or weeks later?
Stuart ROBERTS replied that the veterinary officer responsible for the meat hygiene inspection did
indeed identify the disease during an ante mortem inspection. If foot and mouth had not been
identified immediately, the consequences would have been even more serious. However, for the
time being, he has not heard any proposal as radical as ending the involvement of vets in
inspections.
Flemming THUNE-STEPHENSEN stressed that active surveillance of disease via ante mortem
inspection is vital and needs to be kept. It also plays a part in animal welfare.
51
.VI Constraints and limitations facing modernisation of inspection
Session chairperson: Laszlo TOTH, Hungary
.1 Presentation of the pilot scheme "risk markers for official seizure in French broiler
chicken production"
Coralie LUPO, AFSSA, France, explained that an integrated approach to veterinary inspection had
already been proposed but had not yet been formalised. AFSSA has therefore been looking into
areas which could lead to this type of standardisation.
The scheme was organised into two stages: the first was to describe official seizures in quantitative
and qualitative terms and the second to identify markers for official seizures.
A data gathering exercise was organised. The study covered 404 batches of broiler chickens from
375 different farms.
The second aim of the project was to analyse markers for seizure. 31 variables were identified,
which fell into four categories:
•
•
•
•
structure of the farm and farming practices;
health history and specific characteristics of the batch;
transport conditions and lairage conditions at the abattoir for the batch;
characteristics of the abattoir receiving the batch.
The impact of each category of variables on seizure rate was assessed. The findings showed that
each of the categories had a similar impact on seizure rate: 20 %, 34 %, 24 % and 22 %
respectively.
Two "reason for seizure" groups were then established:
•
•
infection or metabolism-related;
trauma.
To conclude, the project provided a reliable description of official seizures in France, which were
seen to relate to multiple factors.
.2
Modernisation of inspection in the poultry and rabbit sectors: the French pilot scheme
.a Framework of inspection in poultry and lagomorph abattoirs
Vincent HERAU, Food Safety Division, French Ministry of Agriculture and Fisheries General
Food Directorate, presented the regulatory framework, which sets out a clear division of
responsibilities for the authorities and operators, designed to ensure a high level of consumer
protection.
52
With specific regard to abattoirs, operators are required to implement hazard control via the
HACCP method and the authorities are required to organise inspections. They use the following
tools for these:
For operators:
•
•
•
•
traceability;
good hygiene practices;
HACCP system;
FCI.
In France, these four points form the "Sanitary Control Plan", which is designed to control hazards.
Operators have a performance obligation but few obligations in terms of methods which can be
used.
For the authorities:
The tools used are inspection of the establishments and ante and post mortem inspections, which
look for clinical signs and lesions. They therefore have a high level of obligation in terms of what
methods to use and few performance obligations.
The boundaries of the respective responsibilities are difficult to define in poultry and rabbit
abattoirs. Vincent HERAU pointed out however that:
• the products carry an identification mark, unlike carcasses of slaughter cattle and game, as the
operators are responsible for marking, not the OVs;
• operators are obliged to classify carcasses in accordance with common agricultural policy
regulations: regulation (EC) 854/2004 requires unfit carcasses to be removed by the inspection
services, while regulations 1234/2007 and 543/2008 stipulate that they should be classified as A or
B, which relates to the reason for removal.
Under the Hygiene Package, the following are required:
•
•
•
an inspection to detect visible hazards;
an HACCP system in abattoirs to prevent hazards at this level;
FCI, to provide the abattoirs with a clearer picture of the live animals' characteristics.
In the poultry sector, the hazards which the animals represent cause little in the way of visible
lesions. This means that inspection can only detect a small proportion of the hazard compared with
the hazard prevention procedures that abattoirs use as part of their HACCP systems.
The following specific technical features are relevant to this sector ante mortem:
•
•
size of the batches;
transport in boxes;
53
•
stacking of boxes.
Post mortem, the features are:
•
•
•
size of the batches;
slaughter throughput rate, which can reach 13,000 animals per hour;
automation of many of the tasks, especially evisceration.
Detection of unfit carcasses is therefore restricted to easily detectable microscopic anomalies.
Within the organisational context of reducing budget expenditure, States often concentrate their
efforts on the most essential tasks.
To conclude, Vincent HERAU said that:
•
traditional ante and post mortem inspections are not suited to the poultry and rabbit sectors;
• the primary responsibility of chicken and rabbit abattoir operators needs to be emphasised and
hence the importance of previous stages in the chain and FCI;
• it should be forbidden to send diseased poultry or lagomorphs to the abattoir, which is not the
place where animals should be sorted or diagnosed;
• the veterinary services' human resources should not be devoted to "product" inspections but to
checking that operators have a sanitary control plan in place, with a suitable HACCP system, and
are carrying out their tasks in the proper manner.
54
.b Comprehensive control of health risks in the poultry and rabbit sectors: the French pilot
scheme
The scheme is the product of an integrated approach to managing hazards and their associated risks:
•
Action to be carried out by operators:
- on farms: implementing good hygiene practices for farms and producing ad hoc guides;
establishing alert criteria for known contagious diseases (especially bird flu);
- during transportation: animals sorted on the farms; veterinary diagnosis in the event of any
health problems made before animals are sent to the abattoir and any disease with an impact on
public health ruled out;
- at the abattoir: good hygienic practices guides, systems designed to target hazards; training
of personnel and participation in inspection tasks (at delivery and during removal and sorting);
alerting the authorities if any problems are identified in a batch. The objective is to make
operators responsible and to have effective hazard control;
- downstream stages: there are no specific actions for the poultry sector: good hygiene
practices and HACCP;
•
Action to be carried out by the authorities:
- on farms: organising sanitary inspections which tie in with the risk factors, carried out by
animal health officials every two years; extra checks for farms identified as being
unsatisfactory, plus sanctions;
- during transportation: ban on sending of sick batches; standardising FCI form templates and
developing their content;
- at the abattoir: checking that abattoirs are coming up to standard; basing inspection
schedules on a risk analysis; setting up a national network of key contact persons; training
veterinary service agents in official inspection; providing the 'lesions' tool (for veterinary
services and operators); assessment of operators who participate in removal of obviously unfit
carcasses and sorting (frequency and estimating risk); direct inspection of batches identified as
being at-risk or flagged up;
-
downstream stages: scheduling inspection on the basis of risk analyses.
To summarise, the main features of the proposed pilot scheme are:
•
a comprehensive approach to hazard control;
• inspection on receipt of batches, removal of obviously unfit carcasses and sorting by the
operator, who will be appropriately trained and checked by the veterinary services at intervals
based on the calculated risk level (reliability of procedures, tonnage, origin of the animals), except
for batches which must strictly be slaughtered under the direct supervision of the veterinary
services.
55
Three parameters must be taken into account during inspection:
•
•
•
quality of the farm;
the batches (FCI);
quality of the abattoir.
If these three elements are satisfactory, the intervention of the veterinary services may be confined
to inspection of the establishments, with an assessment of the removal and sorting operations
conducted by the operator.
If however these three elements are not satisfactory, intervention by the veterinary services must
take the form of direct inspection of the slaughter conditions and the removal operations, with
individual management measures. In these cases inspection will be ongoing.
.3 Opinions of members of the poultry industry on modernisation of inspection – the
AVIPOLE training programme
Gilles LE POTTIER, France, spoke in a dual capacity:
1/ as chairman of the Avipôle Formation training association
2/ as General Secretary of CIDEF (French joint turkey industry committee)
1/ He explained that AVIPOLE had trained 1,500 advanced poultry technicians since it was formed,
as well as thousands of farmers, operators and employees. It trains around 600 people per year.
Since 2001, it has also been offering training on removal of carcasses unfit for human consumption,
designed to provide abattoir employees with the skills needed for moving obviously unfit carcasses
and sorting them into separate containers, with a minimal number of errors. This requires highly
practical training, which covers:
• classroom teaching accompanied by photos, covering the different anomalies which may be
encountered in the abattoir: smell, colour, shape, appearance, anomalies in the entrails and the
abdominal cavity;
• a review of the abattoir (highlighting risk points concerning the batches of animals: position of
personnel on the lines, practices observed during evisceration and cutting, cross-contamination
risks;
•
observation of carcasses kept aside by the abattoir;
•
written assessment based on photos, plus a recap and summing up at the end of the course.
Trainees are assessed on:
• their knowledge of regulations regarding food safety and hygiene rules;
• their ability to recognise anomalies which do or do not warrant the complete or partial removal
of carcasses and offal;
56
• identification of by-product categories in relation to the anomalies observed;
• ability to record the main reasons in order of priority, in the appropriate format;
• ability to alert the veterinary inspector in the event of particular problems. Through the courses,
the trainees are able to:
• acquire sound experience;
• standardise practices across the various different tools in the abattoir and between the different
departments;
• use the batch assessment form (numbers of seizures, main reasons, overall evaluation) as a basis
for implementing corrective actions at the farm stage.
The following points still need to be finalised within the framework of the pilot scheme:
•
•
•
criteria for alerting the veterinary inspection authority;
validation of on-site training;
producing national guidelines for each species.
2/ Gilles LE POTTIER also presented the "progress contract" initiative which was set up by the
turkey sector in 1993. This consists of a set of procedures which give assurance that traceability and
good working practices have been used from the origin of the product, i.e. the egg, to the point of
sale. The initial aim was to strengthen the confidence of customers and the administration in the
turkey sector's sanitary control procedures and to get all members of the trade involved in the
initiative in order to make progress and enhance the system's reputation for reliability. The system
involves:
•
collection of data, organised in the hatcheries, farms, abattoirs and cutting plants;
•
monitoring practices:
- how are audits carried out? Certification protocol;
- what are the applicable requirements? Responsibility for each link in the turkey production
chain;
- what audit tools should be used for certification? Producing an audit check-list for the
"certification" option;
- what tools should be used for self-assessment? Audit check-list for the "self-assessment"
option (farms).
The system is based on two cross-checking tools: consolidation of the microbiological test results
between the links in the chain and regular audits of each link.
People wishing to join the "progress contract" scheme must meet certain conditions:
•
layer farms may only join through a hatchery;
• hatcheries must undertake to abide by the criteria of the "hatcheries charter", to arrange internal
evaluation of the farms, and to send their test results to CIDEF every quarter;
•
broiler farms may only join through a producers' organisation;
57
• abattoirs and cutting plants must undertake to abide by the criteria of the "abattoir charter" and
send their test results to CIDEF every quarter;
• producers' organisations must undertake to abide by the criteria of the charter which applies to
them, to be responsible for internal evaluation of the farms and to send their test results to CIDEF
every quarter.
To summarise, the "progress contract" demonstrates the turkey sector's commitment to
transparency, from production to consumption.
.4
Modernisation of inspection and the consequences for international trade and exports
Susanne JENSEN, Danish Meat Association, Denmark, said that in her country, levels of pig
exports are very high, in fact they account for 6% of combined exports across all sectors. There are
over 7,000 pig farms, producing 26.3 million animals and 1.9 million tonnes of meat every year.
Slaughter is carried out in private abattoirs and by cooperatives. Meat is exported, in descending
order of quantity, to Germany, the UK, the USA and Poland. Inspection therefore has a very
important role in assuring the quality of both animals and meat.
Susanne JENSEN presented the way in which inspection of fattening pigs is moving towards visual
inspection. For this to be a success, it has been vital to set up strong cooperation between the
authorities, scientists and members of the trade. At international level, Denmark has also been
successful in forging links with its trade partners from the start of the project, which has led to
positive cooperation and increased acceptance of Danish meat in the export markets.
Denmark exports most of the pork it produces, which means that the equivalence system is very
important for the country. However, there is still no international system and discussions therefore
take place on a bilateral basis. Discussions of this nature are currently underway with the United
States regarding technical matters. All of this is enabling Denmark to gain experience in these
areas.
In planning the renewal of its inspection system, Denmark decided to overhaul its technical skills
base and built it on risk-based arguments, using all the knowledge available on the subject.
The visual inspection project began in May 2007. An initial plan was put forward in September
2007, which was drawn up jointly by the industry and the Danish veterinary authorities and
approved the Agriculture Minister. A project was also introduced regarding exports to the United
States, comprising two stages: risk assessment to replace incision where applicable and a pilot
study of two chosen abattoirs, which will finish at the end of 2008.
Susanne JENSEN felt that for a project of this nature to succeed, the following are needed:
58
•
•
•
transparency and dialogue;
strong technical expertise and abundant documentation;
patience, determination and perseverance.
She hopes that the project will be brought to completion and that visual inspection will be
introduced in the Danish pig meat industry in a few years' time.
.5 Presentation of the French poultry sector, organisation of exports and issues facing
modernisation of veterinary inspection in abattoirs in France
.a Structure of the French poultry sector
The poultry sector in France is structured as follows:
• the live animal production stage: breeders, multipliers, hatchery operators: 120 companies,
6,500 jobs, 1,2000 breeding farms, 1.1 million square metres. Hatchery operators and breeders
have the best reputation for cleanliness in the sector;
• farmers own their own buildings. There are 14,000 farms in France, covering 15 million square
metres;
•
feed for the animals is provided by 340 feed mills;
• abattoirs check the birds in and the official veterinary services are responsible for inspecting the
birds.
.b Modernising inspection: the issues involved
Jean-Christophe PARISSE, FIA, France, said that the aims behind modernisation need to be shared
by the whole sector – farmers, processors and the official inspection services, so that food safety
can be guaranteed and trust can be created among customers and consumers.
The aims are based on the fundamental principle that "all animals that enter the food chain must be
healthy". This principle was the best argument which the sector presented to consumers during the
2006 bird flu crisis. And indeed, customer confidence was restored when processors were able to
stick the statement "we certify that all birds slaughtered by us are guaranteed healthy by the official
veterinary services" on all their packaging.
Jean-Christophe PARISSE explained the role of each player in the sector:
• Farmers are responsible for monitoring the flocks and recording information on the farmer's
form. A veterinary surgeon approves the sanitary element. Technicians serving farmers' pools
provide the necessary technical assistance. 48 hours before slaughter, the duly completed FCI is
sent, stating among other things the medication withdrawal periods where applicable and the
mortality rates and salmonella test results. If an incident occurs at the farm after the FCI has been
sent, the farmers alert the veterinarian, the pool and the abattoir. The data is also analysed and the
analysis is fed back to the farmer.
• Processors enter into a contract with the live animal producers which contains specifications
covering sanitary requirements. They are responsible for ensuring that all the FCI is received for
59
analysis before slaughter. This analysis determines whether or not batches are accepted and if
doubts are raised, leads to a more thorough investigation or outright refusal of a batch. Processors
are also responsible for removing carcasses from the production line which are obviously unfit for
human consumption and for informing the veterinary services if an alert criterion is observed, as
well as being responsible for sending this information to the authorities and to the farmers.
• The official services (DGAL, DDSV) define what constitutes a sick batch, criteria for removal
and how removed animals should be dealt with. They also provide training for personnel in reasons
for removal and provide expert assistance and deliver a decision in the event of a dispute between
processor and farmer, or for problem batches. Finally, they are responsible for assuring third
countries to which the animals or meat are exported that the guidelines have been adhered to.
Finally, Jean-Christophe PARISSE felt that modernisation of veterinary inspection in abattoirs
should be seen as a resource and an asset in terms of developing the sector's business by providing
food safety assurance.
.6
Changes to inspection – how far can we go? – thoughts on the trade and export aspects
Round table
Cees VERMEEREN from AVEC (European poultry association), Belgium, emphasised the
necessity of involving abattoir personnel in inspection, which requires appropriate training.
Philippe AMAR, SNCP (National pig traders' union), France, said that the Member States can
implement their ideas outside the boundaries of the Hygiene Package and conduct different
experiments. Nonetheless, if these are to be applied across the board in all Member States, all the
players need to be involved in all countries, to arrive at a common standpoint leading to mutual
benefits.
Regarding validation and equivalence between the various national systems, he noted that each
country had chosen indicators corresponding to problems which have already been identified. The
main principles aside, the problems present in individual establishments also lead to a certain
degree of accommodation.
Finally, he stressed the importance of consumer confidence and the associated issue of confidence
among importing countries. In this context, it may be difficult for individual Member States to
resolve issues in an isolated manner. Here again, common areas need to be identified so that all the
Member Sates can present a united front. There needs to be an image of consistency throughout the
EU in terms of exports.
Pietro NOE from the Italian health ministry's export bureau said that in his country most meatbased products are exported. Information from the abattoirs is very important in this respect. Italy
imports meat from Denmark which is then re-processed by its own food sector before being
exported to countries such as Germany. Italy also imports raw meat and live animals from France,
Spain, the Netherlands and Denmark, which are slaughtered in Italy. This means that FCI is needed
from
60
these countries so that effective inspection can be carried out in its abattoirs. The information not
only fulfils a food safety purpose but it also plays a role in animal welfare. The destination
countries need to be advised of any problems in this area.
Vincent HERAU said that at present there are no criteria for equivalence or recognition of the
different risk management measures implemented in the different Member States. The European
Commission is the only body which could determine these criteria.
Philippe AMAR added that equivalence systems of this nature could lead to a certification scheme.
He felt it was important to keep this type of tangible indication, which provides necessary
reassurance for the trade.
Anne COSTAZ asked whether members of CIDEF's "progress contract" scheme highlight their
involvement by means of a label on the products.
Anne TOURATIER, FNGDS, France, asked what percentage of the various operators participate in
the scheme and what it costs. Also, does participation in the scheme enable them to sell products at
a higher price on the grounds of higher quality?
Gilles LE POTTIER answered that one person will carry out audits in the different hatcheries and
breeding farms to ensure a standard approach to controls. At the farming end of the chain, CIDEF
procedures have become a benchmark for the whole of the French poultry sector. Regarding audits,
not all broiler farms are audited in the same way. They are audited internally, though here again,
they use CIDEF procedures. Only 30 % of them undergo external audits, which are carried out by
approved centres.
In terms of product pricing, CIDEF procedures are seen as a yardstick in the sector and the products
of operators who have not reached the required level should be priced down. There is no pricing up.
Finally, the sector has not wanted to introduce an additional "premium" logo for products, as it
considers that transparency and product safety are a consumer's right. Promotion is carried out visà-vis clients, especially by looking for areas of equivalence with other European schemes, like the
IKB and QS systems in Germany. Gilles LE POTTIER felt that there is actually only one way to
obtain impeccable products.
A participant thought that discussions should be entered into with countries outside the EU on the
basis of sound scientific facts, so that equivalence systems can be established. Nonetheless, he did
not understand why so many countries are opposed to decontamination, as it has been proven to be
effective.
Cees VERMEEREN answered that reluctance to accept decontamination treatment is linked with
the use of chemical additives, which could spoil the commercial image of the products. He
emphasised that while chemical treatments will no doubt progress, decontamination is a much
wider issue, which relates to political aspects and consumer acceptance.
61
Gilles LE POTTIER said that the different sectors have been implementing good hygiene practices
throughout the whole production process and these are valid for all contaminants as well as many
other factors. Decontamination at the end of the chain would undermine all these efforts. He added
that the products used for decontamination are acids, which present a handling hazard and do not
have a neutral effect on the products they are used on.
He stressed that current European regulations have considerably increased operators' responsibility.
He felt this was very important, as quality is not pronounced or created in the abattoir, but at every
stage in the production chain. Abattoir operators and processors want good quality raw materials. It
is therefore important to establish all the areas in which farmers, hatcheries or feed producers are
responsible in the event of non-compliant products. This is a hefty task, but it is a step in the right
direction and is proving its worth in terms of sound, high quality products. He therefore felt that it
would not be advisable to authorise decontamination in abattoirs, as this would constitute a major
step backwards.
Jean-Christophe PARISSE said that the purpose of decontamination is to eliminate bacteria from
animal carcasses at the end of the chain. If the end-consumer wants this, it will need to be brought it
in. However, all the measures which the different sectors now have in place far surpass
decontamination and have allowed France to avoid some of the major crises which have occurred in
some of her European neighbours.
Vincent HERAU emphasised the fact that decontamination is a political subject. When making
their decisions, the national authorities need to take consumers' opinions into account, which in this
instance are explicit: they are opposed to it. He added that we do not have all the data we need to
guarantee that the decontamination products do not have a harmful effect on the meat or on the
environment in the longer term. He added that the work done by the trade to reduce pathogens is
being carried out within a long-term approach, whereas decontamination is a temporary solution
and could lead to relaxing of standards further up the chain, which would be a recipe for major
crises.
Martijn WEIJTENS, Agriculture Minister, Netherlands, asked what role the European Commission
could play with regard to exports to third countries. It is true that some Member States are
attempting to resolve their issues with these countries on a bilateral basis. How might the
Commission intervene?
Vincent HERAU answered that the Commission needs to begin by approving the steps already
taken by the Member States and to provide them with help in this respect, before working on an
EU-wide position. The Member States can also establish contacts with each other in order to share
experiences.
Cees VERMEEREN said that there is a tension between the Member Sates and third countries. The
Commission's support could be helpful in this respect. It could play an important part by giving
greater support to pilot projects so that these can be introduced in the other Member States.
Willem DAELMAN, DG SANCO, said that vis-à-vis third countries, bilateral projects cannot be
extended automatically to all the Member States, whereas pilot schemes can be extended, unless the
Commission or Member States have criticisms to make. The Commission could actively participate
62
in discussions with third countries, either by making direct contact with them or by dialoguing with
them within the Codex Alimentarius framework.
Paul MENNECIER, DGAL, France, felt that if modernisation of inspection leads to the outright
elimination of any of the stages, it is bound to be a failure in the eyes of third countries. He felt that
for pilot schemes to be accepted and inspection programmes adapted to the health situation in each
Member State, transparency is the key, based on criteria developed at EU level. Transparency will
smooth the path for discussions with the EU's trade partners and will show that when properly
validated scientific and technical criteria are used, it is possible to reach the same level of reliability
as through inspection.
Cees VERMEEREN suggested that the information gathered for the purpose of FCI should be put
to better use in terms of demonstrating the level of food safety that different countries have
achieved. He wondered if it was being managed and used to good effect by the relevant national
authorities.
.VII Inspection responsibilities and associated costs
Session Chairperson: Anne-Marie VANELLE, DGAL
.1 Participation of staff, delegation, role of veterinary inspection in abattoirs, developments
in animal welfare
.a The legal basis underpinning official controls in abattoirs; role and responsibilities of official
veterinary surgeons and official auxiliaries; role of abattoir employees in inspection
Bibiána JANAČKOVÁ, DG SANCO, said that without cooperation and a clear division of duties, it
is not possible to work together to protect consumers' health.
The General Food Law (Regulation (EC) 178/2002) provides the legal framework for official
controls. Article 17 of the Law stipulates that operators bear the responsibility for food safety,
whilst the relevant authorities in the Member States are responsible for ensuring that their operators
act in accordance with EU regulations.
The competent authorities and operators need to take on different responsibilities, which must not
contradict each other and which may converge provided that genuine cooperation is set up between
them. The Member States must also ensure that inspection personnel are suitably skilled.
The competent authorities send official veterinarians into abattoirs, whom they have appointed to
carry out specific tasks: audit and inspection. Inspection covers the aspects of FCI, ante and post
mortem inspection and examination of the animals' wellbeing. OVs can be assisted by official
auxiliaries or by abattoir staff, the latter under certain very strict conditions. Official auxiliaries are
qualified persons appointed by the authorities, who work under the authority and responsibility of
63
an official veterinarian, whom they can assist in all tasks apart from auditing, ante mortem
inspection and animal welfare checks. They can stand in for OVs in post mortem inspections,
though the OV still has overall responsibility. They cannot do this in the event of emergency
slaughters, where the auxiliaries must set aside meat showing anomalies for subsequent inspection
by an OV.
Training for official veterinary surgeons and auxiliaries is the responsibility of the Member States.
The same applies to training for abattoir personnel, however in 2008 the European Commission
also introduced specific training courses on hygiene and meat inspection. The aim is to harmonise
practices across all Member States. The training is intended for experienced inspectors, who may
stipulate their individual requirements and the sessions can then be geared towards certain specific
issues. The Commission also expects people who take part in the training to disseminate what they
have learnt in their own countries.
Bibiána JANAČKOVÁ then brought up the issue of approval of facilities, which is the first stage in
meat production. This is the responsibility of the relevant national authorities. An establishment
can only receive approval after a site visit has been carried out. The authorities can also withdraw
an operator's approval if the operator is not fully implementing the regulations. The Member States
must also keep a list of approved establishments, which must be available to other States on
request.
Bibiána JANAČKOVÁ then brought up the question of official controls. These concern audits of
good hygiene practices and HACCP procedures and should be carried out on an ongoing basis.
At least one official veterinarian should be present in the abattoir during ante and post mortem
inspections. The national authorities are entitled to alter this rule in certain instances, on the basis
of a risk analysis and in accordance with certain very precise criteria, i.e. facilities which do not
work on a continuous basis and have meat storage facilities. However, in general they do not make
use of this potential flexibility.
The work of official veterinarians is also defined by specific rules concerning inspection. OVs are
responsible for making all the necessary decisions pertaining to FCI, animal welfare, live animals
and meat.
There are also specific rules governing ante mortem and post mortem inspection aimed at detecting
disease in the animals and establishing a firm diagnosis, and detecting factors which could lead to
declaring batches unfit for human consumption. For post mortem inspection in particular, all
carcasses must be inspected. The rate of throughput of the slaughter lines and the inspection
staffing levels must be suitable to ensure proper conditions for inspection. Inspection must also be
carried out immediately after slaughter. It may be done visually, on the basis of a risk analysis.
Special attention must be given to the zoonotic illnesses listed by the OIE.
Finally, Member Sates are entitled to ask abattoir personnel to assist the official veterinarians, but
only in the poultry sector. The personnel must be properly trained and must have received official
authorisation. They must work under the supervision of the OV, who must be present during the
ante mortem inspection. In addition, in the event of a health problem detected during the
64
inspection, the personnel must be replaced immediately by official auxiliaries.
To conclude, Bibiána JANAČKOVÁ said that the division of skills and duties between the different
players is now clear. However, for inspection to go smoothly, there needs to be a good level of
cooperation between all the players concerned and between operators and official personnel. This
being said, there is currently a shortage of official veterinary surgeons. Bibiána JANAČKOVÁ felt
that pilot schemes should therefore be run with a view to recruiting the best official veterinarians to
meat inspection duties, which is interesting and rewarding work.
.b Revision of EU legislation on animal welfare during slaughter
Denis SIMONIN, DG SANCO, Unit D5 Animal Welfare, said that 360 million mammals and over
4 billion birds pass through European abattoirs every year. At the same time, consumers are taking
a growing interest in the issue of animal welfare, which was not the case 50 years ago. For
consumers, it is not a negotiable matter and they feel that when it comes to the way animals are
killed, there can be no half measures: it must be done properly. The role of official veterinarians in
abattoirs is important from this point of view as they are the only people who can ensure that the
job is being done properly.
There is a European directive on animal welfare during slaughter, which goes back to 1993. It has
been considered necessary to make changes to it in view of the fact that the OIE has published good
practice guides on the subject, technological developments have taken place since the directive was
published and the Hygiene Package has introduced radical changes in the area of inspection, but
also in view of the fact that there is now a European Animal Welfare Action Plan.
The specific problems which have been identified relate to:
• stunning methods: these are not clearly defined in the current provisions, which also do not lay
down any approval procedures;
• abattoir equipment, which is covered by old laws. the present provisions also do not cover
these thoroughly in the abattoir approval process;
• the current law, which only mentions limited responsibility of operators and does not cover the
animal welfare aspect in operating procedures;
• the prescriptive nature of the current directive, which contains very little in the way of technical
requirements, hence the very disparate nature of results on the ground and a focusing on certain
criteria rather than on the outcome, which is the animal's wellbeing. Stunning of animals is a
highly technical subject;
• skill of abattoir personnel, which is often inadequate in the area of animal handling, stunning
and bleeding;
65
• restricted skills of inspection personnel, who lack the skills required for ante mortem
inspections and who concentrate on food hygiene and post mortem inspection. However, the
animal welfare approach is very different from the hygiene-based approach.
The Commission has made the following proposals regarding future changes to the animal welfare
directive:
• it will now be a regulation, not a directive. This means it will be directly and immediately
applicable and it will also include technical provisions;
• as regards stunning equipment, there are specialised machines for this. The equipment
manufacturers will be asked to include a user and maintenance manual with the equipment they sell
and to give indications regarding optimum effectiveness;
•
the regulation will be in line with the Hygiene Package on certain points, with:
- more thorough coverage of structural requirements;
- standard operating procedures (SOPs) based on HACCP principles for the stunning process;
- an evaluation procedure for stunning;
- introduction of animal-centred indicators which operators will be required to provide, with a
performance obligation to be overseen by the competent authorities;
•
introduction of a competence certificate for abattoir personnel;
•
creation of an "animal welfare officer" post in most abattoirs;
• creation of a national reference centre which will provide technical support to the authorities
and will be responsible for performance accreditation, evaluation of stunning methods and
equipment and producing guidelines and good practice guides.
• stipulating specific stunning methods: type of animal, key elements, criteria which operators
must adhere to;
•
a more transparent accreditation system.
This new approach will be compatible with the Hygiene Package: it will be flexible regarding
means but strict in terms of methods. It is also intended to implement a policy aimed at developing
knowledge in the area of animal welfare.
.2 Organisational aspects of inspection – overseeing the veterinary services’ activities –
second level controls
Pascale GILLI-DUNOYER, head of DGAL’s office for slaughter and cutting establishments at the
French Ministry of Agriculture and Fisheries said that two systems have been put in place to
oversee the activities of veterinary services in abattoirs:
• A Veterinary Audit Unit (Unité d’Audit Sanitaire - UAS), which is independent of the authority
(DGAL);
• A national network of key contact people for the abattoir sector, working within a technical
support unit for the office for slaughter and cutting establishments.
66
At the same time, DGAL has set up an accreditation scheme for inspection services based on
standard ISO/CEI 17020. This should be completed in 2009. The option of internal audits was
chosen, for which an independent body outside DGAL will be used: UAS/MIGA, the official
inspection audit unit of the Agriculture Ministry’s general inspection and audit team.
Internal audit is an independent, objective exercise, which gives an organisation – in this case
DGAL – assurance as to how well its operations are under control, provides advice on improving
and enhancing these.
UAS (official inspection audit unit)
UAS has carried out extremely rigorous procedures to ensure that the conclusions of its audits are
watertight. The audits must follow a precise method, based on the internal audit manual
(international standards) and the European Commission guidelines published in 2006. Auditors
also take specific regulations relating to each specific area into account, as well as standard ISO
17020.
These audits are designed to ascertain, by means of a methodical examination, whether the system
in question is being put into practice and is relevant, efficient and effective. Each audit is also
conducted in the same way. Auditors must:
• identify strong points;
• identify good practices;
• identify deviations (non-compliance with regulations) and their root causes;
• identify weak points;
• make recommendations for correcting the deviations or remedying the weak areas in the bodies
in question and for making the whole system in question (whether regional or national) reliable and
streamlined.
There is a formal framework in terms of organisational structure: a memorandum, a framework
agreement and an internal audit charter. The person with overall responsibility for audits is the
Director General for Food, who makes a request for an audit to the relevant service provider, in this
case UAS/MIGA. UAS/MIGA then draws up the specifications, chooses which bodies to audit and
conducts the audits.
There is also a steering body: the internal audit committee (Comité d’Audit interne - CAI), which
approves the proposed audit schedules and ensures that they are carried out and followed up.
Risk analysis for the purpose of defining audit priorities is carried out by DGAL. Plans for audit
topics are made on a yearly basis and the programme is jointly approved with the CAI.
Since it was formed in 2006, UAS/MIGA has conducted audits on the fight against salmonella in
poultry, emergency plans, inspection at destination, accreditation of agri-food establishments and
European plant passports.
67
After an audit has been carried out, a provisional report is produced and sent within two weeks to
the audited body. The body must return its comments and proposed action plan within one month.
The final report is then sent to the audited body and to DGAL. After an evaluation on a particular
theme, a summarised report containing recommendations is sent to DGAL. Follow-up can take
place over a period of a few weeks, months or years.
The national abattoir "key contacts network" (RNA)
There are seven "key contact persons". They are official veterinary surgeons who have been
appointed because of their experience on the ground in abattoirs, their experience of official
controls in abattoirs, their knowledge of the sector and their skills. The network has been operating
since April 2008 and acts as a technical support unit at the DGAL office responsible for monitoring
abattoirs.
These key contacts work from the départements and are attached to DGAL, which coordinates their
work and activities.
The RAN network’s tasks are as follows:
• auditing abattoirs which operate on a regular basis and providing assistance for foreign experts
carrying out audits in French abattoirs;
• ensuring that inspection processes are sound, harmonising inspection practices at national level,
organisation training activities for veterinary services personnel;
• contributing to drawing up regulations and helping to disseminate these in the abattoirs and the
regional veterinary services (DDSVs). The network also takes part in studying and approving good
hygienic practices guides;
• participating in evaluation of inspectors’ competence, supervision, suggesting training activities
for veterinary service personnel;
•
acting as an intermediary between the central body (DGAL) and the regional services (DDSVs);
•
liaising with the industry;
• participating in the design and implementation of national information systems, in particular the
system for recording inspections in databases (NERGAL abattoir);
•
scientific monitoring in the meat and abattoir sectors;
•
answering questions which are asked by the départements;
•
participating in research and discussions on safety of veterinary service agents in abattoirs.
The RNA network members may be audited by UAS. They can also provide their technical
expertise for audits carried out by UAS in the fresh meat sector.
68
.3 Standards and inspection: could standard-based certification be introduced into the
inspection concept and how?
Bert URLINGS of Vion Food Group, Netherlands, felt that private certification would not
contribute greatly to inspection. It can however make a useful contribution to good practice guides
which can be certified. He felt therefore that radical changes in the area of food safety should be
discussed: a move towards private control under public supervision.
Vion Food Group is part of a producers' organisation based in Southern Holland which has 18,000
members. The company has three branches: Vion Ingredients, Vion Fresh Meat and Vion
Convenience, which sells mainly vegetarian pre-prepared products in the local market.
Bert URLINGS presented what he considered should be the responsibilities of each player in the
"world food village".
.a Producers' responsibilities
Producers should be responsible for:
•
devising quality systems based on HACCP principles and ISO 9001 quality management rules;
• developing procedures which take hygiene procedures, process control and raw materials
control plans into consideration;
•
surveillance and checks;
•
evaluating and developing performance standards and analysing trends;
• standards regarding adherence to the current rules, bearing in mind that it is almost impossible
to adhere to the rules 100 %.
.b Responsibilities of the competent authorities (regulation (EC) 882/2004)
The competent authorities should be responsible for auditing HACCP systems and evaluating
performance on the basis of scientific evidence. They should also check operators' compliance,
setting realistic targets for this.
It has been suggested that the authorities could play an advisory role within the framework of the
Hygiene Package: in Bert URLINGS' opinion, this would not be a positive move. This is not a role
for certifying bodies but for consultancy firms.
69
.c
A shift of paradigm: for whom?
Bert URLINGS believed that producers are aware of their responsibilities. They should not hide
behind the inspection authorities, but accept their responsibilities full-on. The industry is well able
to do this.
This paradigm shift can work at two different levels. The first is the organisational level: the
competent authorities now need to adapt to private systems. As for inspectors, they need to move
away from an inspection approach towards supervision and strengthening controls.
The legislators for their part should concentrate on passing appropriate legislation and not become
involved in the inspection services.
Some changes should also be made under the Hygiene Package framework. The industry certainly
needs rules which are relevant and simple to oversee and control.
Regulation (EC) 2073/2005 also contains useful criteria for hygiene procedures. However, in Bert
URLINGS' opinion, the food safety criteria for salmonella in fresh meat-based food are not
adequate, as they are do not represent a "zero tolerance" approach. They actually only lay down a
requirement for five samples per batch and five batches per week, whereas some private systems
are more strict, sometimes taking five times more samples. Food safety criteria regarding
salmonella in fresh meat-based food should therefore be changed to include hygiene criteria in the
production processes.
There is a proverb in the Netherlands which says that, "a butcher should not inspect his own meat".
Bert URLINGS feels it should be changed to: "a butcher who will not inspect his own meat should
not be certified by the authorities".
.4
Charging systems for inspection
.a The Belgian system for financing controls in abattoirs
Michel LAMBERT, AFSCA (Federal Agency for Safety in the Food Chain), Belgium, explained
that the Agency has specific responsibility for controls. A system for financing the controls was
introduced on 1 January 2006. All operators pay a contribution for controls. They contribute in
this way to AFSCA's income, added to which it receives a budget from the State, fees for "on
demand" services, a contribution from the European Union for its participation in certain
programmes, and other resources, such as administrative fines for non-compliance picked up on
during inspections.
Contributions
Each year, every operator is obliged to send a declaration for each unit of their establishment, in
which they must give certain details regarding their business. The declarations are entered into an
"operators' database", in which operators' businesses are classified, each business having one or
more units (e.g. headquarters, production or distribution facilities). The contribution payable by
70
each operator is worked out on the basis of these two parameters. The contribution includes a fixed
amount based on the sector to which the operator belongs and a variable amount which is based on
the size of their business.
The contribution system is used to encourage operators to develop approved self-inspection systems
within their businesses, by means of a bonus/malus system which is applied to the contributions. If
a business has an approved self-inspection system, its annual contribution will be reduced, and vice
versa. The systems can be approved by AFSCA or by OCIs (Inspection and Certification Bodies) if
there is an approved sectoral guide covering the business in question.
The bonus/malus system will come into effect in 2009 and initially the reduction bonus will be 50%
and the increased contribution 120 %. In 2011, the reduction will be 50 % and the increase 200 %.
Fees
AFSCA charges fees for services provided at an operator's request, such as:
•
•
•
•
•
granting or amending a licence;
issuing certificates;
compulsory regulatory controls;
ante and post mortem inspections in abattoirs;
repeat inspections following negative audits.
There are three types of payment which concern abattoirs. These can be in connection with:
•
•
•
expert opinion, in the context of ante and post mortem inspections;
residue testing: the fee is 1.40 Euros per tonne of meat;
screening for TSEs: the fee is 11.07 Euros per head of cattle submitted for a rapid BSE test.
Ante and post mortem inspections are carried out by roughly 750 officers, who are independent
veterinary surgeons carrying out inspections as OVs on AFSCA's behalf.
Operators are obliged to declare the information to AFSCA which it needs for calculating the fees
owing. For abattoirs, the declaration is done via the BELTRACE database. The information is
subsequently checked by the veterinary officers during the inspection.
A charge of 43.28 Euros is made for licence applications, which covers administrative and clerical
costs, plus an additional 30.30 Euros per half-hour for on-site inspection.
A charge of 38.80 Euros is made for certification, which covers the establishments and the first
certificate, then 25.87 Euros for each additional certificate. There is also a 25.96 surcharge for each
additional half-hour required.
To conclude, Belgium's financing measures are designed to:
•
spread the costs among all the business sectors;
71
• establish an "application and payment" principle;
• develop a bonus/malus system and charge for repeat visits, which favours operators who adhere
to the regulations.
.b Situation regarding financing of official controls in the different Member States
Paolo CARICATO, DG SANCO, said that the inspection levy systems are far from harmonised
among the Member States. A study is being carried out on behalf of the European Commission, for
the purpose of:
•
assessing the current situation in the Member States;
• examining the possibility of other sectors such as fruit and vegetable producers contributing to
funding for official controls, in addition to the meat sector;
•
setting minimum rates for fees which take risk factors into account in particular.
Six case studies have been carried out in countries which are representative of the different types of
funding systems: the UK, Poland, Italy, Germany, Slovakia and France. The study began in April
2008 and is due to finish at the end of November, when a report will be submitted. The
Commission will be consulting the Member States in early 2009 before submitting a report and
proposals to the European Parliament.
.5 Links between inspection, audits and certification – overseeing the effectiveness of
inspection – ISO 22000: standards and inspection
Round table
Svetla CHAMOVA, representing UECBV, CLITRAVI and AMB (Bulgarian Meat Association),
Bulgaria, said that there are both advantages and disadvantages to the current charging system. The
main disadvantage is that there is a monopoly on inspections in abattoirs, which diminishes their
effectiveness. She cited the bonus/malus system as one of the advantages.
She said that procedures vary from one Member State to another and according to the different
animals being inspected, and therefore the inspection systems are different. In some countries, fees
are paid per animal, whereas in others they are paid per hour of inspection. She also emphasised
that there are not enough sanctions in place for people who breach EU laws. The breaches may be
made by the operators, but the Member States are also responsible, depending on how lax their
authorities are in enforcement.
Svetla CHAMOVA also wondered why the meat sector should be the only sector to have to pay for
inspections, while other parts of the food industry pay nothing.
The legislation should therefore be harmonised and should stipulate that controls in abattoirs should
be funded by the State out of public finance.
72
She also felt that it would be impossible to arrive at a harmonised system for fees, as the same sum
of money has different values in the different EU countries since standards of living and salaries are
very different.
Nicolas DOUZAIN, FNICGV, France, said that traditional inspection was one of the foundations of
the single European market and allowed EU-wide regulation to be introduced. Nonetheless, the
regulations are now 44 years old and should therefore be adapted to take emerging risks into
account. In addition, the abattoir is no longer the focal point for food safety. We also need to take
advantage of the powerful means of information we now have. Changes to the regulations are
therefore unavoidable and are in fact urgently needed. They should be incorporated into the review
process for the Hygiene Package, along two lines:
• a new regulatory basis which sets out areas that are not the abattoirs' responsibility;
• the enforcement of a levy to be used for modernising inspections, which will be funded by all
the food sectors, not only the meat sector.
Martijn WEIJTENS, VWA, Netherlands, said that there are wide variations in the role of veterinary
and auxiliary inspection officers. He felt that modernisation of the Hygiene Package should allow
some room for manoeuvre.
He also felt that there are inequalities in the animal welfare situation between abattoirs. He was
happy to hear Denis SIMONIN's proposals.
Finally, he approves of the Commission's initiative to study the different financing systems within
the European Union.
Patrick WALL, Ireland, asked whether the European Commission would find it acceptable for a
Member State to hand over full control over ante and post mortem inspection to operators, with the
veterinary inspection services being responsible solely for checking the observations made by the
operators.
Martijn WEIJTENS, Netherlands, answered that under the terms of the General Food Law, it would
make sense to give operators primary responsibility for inspection. Nonetheless, the competent
authorities unquestionably have a supervisory role to play at this level, especially concerning the
question of animal welfare and health. He also felt that Patrick WALL's proposal would have a
significant effect on the question of fees. We need to make sure that fees are used to encourage
operators to adhere to regulations.
Paolo CARICATO felt it would be difficult or even impossible to reach a harmonised charging
system between the Member States. However, he felt it was important to begin discussions about a
better system for financing official controls. It is also important to ensure that the controls are of
real value to operators as well as to the Authorities, so that there can be lasting improvements in
food safety. In this respect, Paolo CARICATO felt that all the food sectors should pay official
inspection fees, not only the meat sector. He hoped that this proposal would be included as one of
the conclusions of the seminar.
Finally, he felt that EU law-makers should lay down general criteria and leave it up to Member
States to set their own fees.
73
Cees VERMEEREN came back to Bert URLINGS' statement that the inspection services, who are
responsible for controls, should not be able to give advice. He pointed out that some small farms
cannot afford to bring in private consultancy firms.
Bert URLINGS replied that the AVIPOLE experience which had been presented during this
seminar shows the opposite: producers can organise themselves at regional or national level. He
also reiterated that it is impossible for the same public body to both inspect and give advice.
M. DOMINGUEZ, CLITRAVI, asked whether the European Commission had developed a
scientific assessment on which to the parameters for evaluating animal welfare could be based.
Denis SIMONIN replied that the Commission uses two different scientific bases, which describe in
detail all the methods for stunning and killing used commercially for the different species, as well
as information which is explained in the OIE's guidelines. He also mentioned another source of
information on animal welfare which has been developed by a British voluntary sector organisation,
regarding the settings used in each stunning or killing method. Nonetheless, he felt that it was not
possible to produce blanket legislation for settings.
A participant asked whether the Commission had estimated the economic impact of the new
measures envisaged for the meat sector.
Denis SIMONIN replied that it had.
Bert URLINGS said that the Commission should consider the fact that animal welfare needs to be
looked at in the context of the current situation worldwide. He hoped that forthcoming legislation
would reiterate the objectives set at the worldwide level and would take into account the
requirements of the different stakeholders in the market, as well as where funding would come
from. Some of the major food firms are prepared to invest in improving animal welfare and they
should be taken up on this. However, it is important not to introduce rules which will lead to an
situation which is untenable from a financial point of view.
Martinus WEIJTENS pointed out that the large firms are the only ones who are keen to improve
animal welfare and they do not represent the majority.
Denis SIMONIN emphasised that there cannot be a standard response to the issue, as the degree of
self-management depends on how the meat industry is organised and concentrated in the different
countries. However, he observed that when a scandal breaks out, consumers always look to the
public authorities and the operators. It is therefore important that the public sector be in a position
to guarantee a minimum level of animal welfare.
Peter HEWSON, FSA, UK, said that under the terms of regulation (EC) 854/2004, countries which
wish to introduce national measures may do so. He asked what the position was regarding pilot
schemes: could a Member State launch a pilot project to test inspection of lambs by abattoir
personnel, for example?
Bibiána JANAČKOVÁ answered that the Member States can indeed adapt the annexes to
regulation (EC) 854/2004 to their national laws. Pilot schemes are innovative projects which are
used to test new measures on the ground. It is not up to the Commission to make the decision:
these projects need approval from the Member States.
74
Willem DAELMAN added that within the context of a pilot project, only the provisions in annex 1
of regulation (EC) 854/2004 may be adapted, not the provisions of the regulation itself.
.VIII Recommendations and conclusions
.1
Conclusions
Paul MENNECIER, DGAL, France, presented an overview of the points which had been discussed
during the seminar.
Future directions for inspection
•
Are official inspections taking the most significant current hazards into account?
• Why, to what end and how should inspection be carried out? Who should carry out the
different inspection tasks?
• Sanitary inspection of meat must be modernised in order to cover known food-related hazards
which cause human health problems, as the European Union's annual report on zoonoses highlights.
• The epidemiology of zoonotic agents varies from one Member State to another. In seeking to
provide proper control, therefore, different priorities need to be established in the different
countries.
• There needs to be an adequate degree of flexibility between one Member State and another in
order to target the most significant pathogens present in each of them.
Responsibilities of operators in the sector and the competent authorities
• There is a potential contradiction between the current terms of the General Food Law and those
of the Hygiene Package: the General Food Law stresses the responsibilities of operators in the food
sector, while in the Hygiene Package, in regulation (EC) 854/2004, the role of inspection in the
meat sector is emphasised.
• The role of operators and the official services during ante and post mortem inspections needs to
be reviewed and redefined.
• The role of official auxiliaries could become more significant, depending on their skills, in
countries where they work on an organised basis. Nonetheless, official veterinary surgeons are still
the key figures in terms of responsibility for official inspection.
• The role of official services needs to be clarified, in terms of advice and technical support on
the one hand and enforcement of regulations on the other, as the two roles have sometimes been
seen to preclude each other.
75
• Official inspection in abattoirs cannot fully cover all hazards which have an impact on public
health. Primary producers therefore need to be involved in sanitary controls.
Food Chain Information (FCI)
• What constitutes relevant FCI? Should there be information for each species? Is FCI relevant
for all species, regards of how they are reared?
•
What impact does FCI have on inspections carried out in abattoirs or on farms?
• EU provisions refer to the principle of subsidiarity in defining inspection and FCI in the
different Member States. This being the case, how should we cater for imports and exports of live
animals? FCI needs to be provided for all animals, including those from countries outside the EU.
Where data on the state of health of an animal or a herd is not available, what additional controls
can be carried out?
Pilot projects
• Pilot projects must be transparent for other Member States and for the European Commission,
but also for third countries, in accordance with article 17 of regulation 854/2004.
• It is vital to gather scientific or technical data in the context of pilot projects, so that new riskbased inspection procedures can be justified and evidence can be provided that they are able to
offer the same level of protection as more widely-used inspection procedures.
• Any changes to inspection procedures requires a certain level of approval by trading partners
International organisations such as the OIE and the Codex Alimentarius commission have already
established international standards, which should be adhered to within the framework of pilot
projects.
Animal welfare
• Any modernisation of the inspection system must ensure that animal health and animal welfare
aspects are covered.
• Consideration for the animal welfare in the approval process for establishments must become
more widespread.
•
The primary responsibility of food sector operators in this area must be reiterated.
76
Training
• The key to sanitary control is adequate training, both for operators and for officials, in all the
relevant domains but especially in the area of inspection in abattoirs.
Fees associated with inspection
• Bonus/malus systems provide a useful incentive to encourage food sector operators to aim for
excellence in their implementation of EU law on sanitary issues.
• It will be difficult to introduce a standard charging system which would be applicable across the
EU. Nonetheless, a study of the different charging systems is currently in progress. It will provide
useful data which may lead to these systems being adapted.
Comments from the floor
A participant underlined that discussions on changes to inspection will need to take place on a
species by species basis.
Michel MAS, ENSV, France, spoke about adjustable charging measures (bonus/malus systems):
they are still based on an assessment of how well abattoirs are operating. Harmonisation of these
systems will therefore entail harmonisation of the way abattoirs are assessed. He asked whether
there are any plans for this type of harmonisation of audit and inspection methods and assessment
guidelines.
Paul MENNECIER answered that the Member States are responsible for overseeing
implementation of EU law. Regarding activities carried out for official control purposes,
regulations (EC) 882/2004 and (EC) 854/2004 set out the main principles.
A representative of the European Commission answered that the approach adopted until now has
been to leave each Member State to develop their own guidelines. However, if a wish for
harmonised guidelines is expressed, work could be undertaken on the issue.
A representative of the Belgian Meat Federation felt that a summary of the different national selfinspection guides for abattoirs could be produced with a view to drawing up an EU-wide selfinspection guide which would be recognised throughout the European Union.
Paul MENNECIER thought that a tool of this kind would be extremely useful.
A representative of the Dutch Meat Industry Organisation mentioned operators' obligations: in
order to determine what these should be, the regulations regarding microbiological criteria would
need to be examined so that appropriate food safety criteria could then be established.
A French participant in the seminar felt it should be stressed that regarding the charging system,
there was no longer any reason why abattoirs should be the only group to finance official
inspections.
77
Paul MENNECIER answered that the EU system and regulation (EC) 882/2004 in particular does
not preclude inspections being financed by all players in the food sector.
.2
Recommendations from the seminar
Future directions for inspection
• A review should be carried out of implementation of a risk-based approach as stipulated in the
Hygiene Package, from farm to abattoir, for all animal species.
• Based on experiments in some Member States in certain fields, avenues and means for
implementing risk-based systems for checking meat hygiene should be explored.
• The scientific aspect will be vital for these discussions. EFSA and ECDC, at the request of the
European Commission, should establish criteria or define what quantitative data is needed by the
Member States in order to conduct a risk analysis which will then allow them to adapt their overall
inspection methods.
Responsibilities of food sector operators and the relevant national authorities
• The European Commission's report on the Hygiene Package, which is to be published in 2009,
will be crucial. The opportunity should be used to clarify the respective responsibilities of
operators and authorities in relation to abattoirs.
• It is necessary to define which tasks in the meat inspection process may be delegated under the
terms of article 5 of regulation (EC) 882/2004.
• The role of official auxiliaries could be enhanced, depending on their skill levels in the different
Member States.
FCI
• It will be necessary to define how animals or herds imported from third countries should be
dealt with.
• The implementation of approval schemes should be encouraged for each livestock species, in
relation to certain current public health hazards and taking risk analyses into account.
• The usefulness of FCI should be assessed species by species, as well as its repercussions on
meat inspection based on risk analysis.
78
Pilot projects
• Pilot projects should be encouraged in order to explore inspection systems which are more riskbased.
• Member States should work together on running pilot projects in areas where this is feasible
and should share the results with their counterparts in the other States.
Animal welfare
• The approval process for abattoirs and training for abattoir personnel should take account of the
relevant animal welfare considerations.
Training
A participant felt that a recommendation should be made to encourage greater transparency and
increased sharing of expertise and to establish an equivalence framework for diplomas and
qualifications in the veterinary sector, so that employees of food sector businesses can have their
qualifications recognised in all Member States.
Paul MENNECIER replied that operators in the food sector are responsible for ensuring that their
staff are qualified to a high enough level.
Willem DAELMAN said that training for official auxiliaries and veterinarians meets the same
requirements in all Member States.
Michel MAS said that there is no diploma for official auxiliaries and veterinarians and therefore he
did not see how a German official auxiliary could come to work in France for example.
Anne COSTAZ proposed that a recommendation be made encouraging exchanges of experience on
the issue of training which would give some Member States information to help their discussions
on the subject, which is very important.
The following recommendations have been made by some of the seminar participants:
•
Exchanges of experience between Member States on the issue of training should be encouraged.
• As regards official auxiliaries and the staff of food sector operators, the issue of mutual
recognition of qualifications between the Member States should be looked at.
79
Fees
• All decisions regarding changes to the way fees are worked out should be based on the findings
of the study being carried out on behalf of the European Commission. The fees charged should
reflect the level of compliance with regulations and the degree of official control required.
Document produced by Ubiqus – Tel. +33 (0)1.44.14.15.16 – http://www.ubiqus.fr – [email protected]
80

Modernisation of veterinary inspection in abattoirs

Transcription

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