If the European Union expects to produce improved public health by the administration of HACCP in abattoirs, then investment will have to be made into the education and training requirements of the people who administer the schemes. Whether that be plant operators or enforcement agencies is irrelevant, the training needs will be identical. Failure to recognise and support these training needs will lead to HACCP systems in abattoirs that are purely paper based and are ignored. I t has been clearly stated by leading members of industry that HACCP systems unless properly enforced are meaningless and that industry will cheat. Experience from the United Kingdom recently within the poultry industry has demonstrated this quite clearly.
Duties of Official Veterinary Surgeon (OVS) 4.6
HACCP 5
5.1
Hazard Analysis and Critical Control Point is not a method of managing
food safety. It is a method of
recording the actions taken to mange food safety.
As such, it can only be as good as the implementation of those procedures
and the accuracy of the data recorded.
The general
consensus of feeling both in the United Kingdom
and beyond these shores in Europe is that when given the motivation and the need
for profit, that industry will bend the rules to the maximum and if necessary to
obtain the required results will cheat. This can be seen quite clearly in what has happened during
the past year within the United Kingdom where records have been falsified and
unfit food has been moved from the pet food area into the human food chain.
We accept that this will be an ongoing problem for the future, however,
without having the official control body monitoring and responsible for
monitoring the HACCP systems within plants, there will be little or no control.
Reliance will be based on paper-based systems which, as previously
stated, may not represent the full facts.
5.3
If the reason for implementing HACCP principles in meat plant is the
increased recognition of the public health importance of preventing or avoiding
contamination by microbiological agents then where we should be looking is at
the scientific studies that indicate the reasons for the levels of contaminants
on carcasses. A single major influence in this is working practices on the
line. Scientific study and evidence
clearly demonstrates the direct correlation between line speed, operator skill
and contamination levels. While we
persist in basing legislation on outcomes rather than looking at processes we
will not be successful in reducing the level of contaminants on carcasses.
The known direct correlation between line speed and carcass contamination
should be examined in full. The
United Kingdom government and the European Union should adopt a formula for
working out optimum dressing speeds and methods.
The present fall in the number of salmonella cases being currently seen
across the United Kingdom, is the result of Government intervention and control
of the pathogen within the flock. It
is in this area where we can be most successful.
The control and administration of the clean livestock policy by the Meat
Hygiene Service has undoubtably led to an improvement in standards within the
United Kingdom also. We feel that
this demonstrates clearly that it is official intervention and control which can
directly reduce the number of food poisonings within the United Kingdom.
However, we feel that to remove official controls in any form from within
abattoirs would lead to the converse being true and an increase in the potential
for food poisoning cases.
5.4
Scare-mongering of this type to justify a change in legislation gives
little credit to the Agency. If the
Australian exporting plant’s rejection rates for contamination and pathology
changed, this then demonstrates that it was within the scope of those plants to
carry out those changes and improve their procedures prior to as well as
following the introduction of HACCP. Far
from being a demonstration that HACCP works, we would say it is a demonstration
that United States Department of Agriculture set higher targets for those
exporting plants to reach. This
clearly happened after the salmonella outbreaks within the United States.
Quite what the relevance of lowered insurance rates for public rejection
has to public health matters is quite beyond us.
5.5
The Association hopes that the food safety campaign which will be
launched by the FSA in 2002 to promote good practice will include an educational
aspect for the general public in how they should handle meat and avoid the risk
of cross-contamination in their refrigerators at home.
5.6
Does industry not have a commitment to food safety already?
and is not employee awareness of their role an educational matter for
industry to undertake? The
Association believes it is essential that enforcement officers (certainly in the
early years) have the role of keeping records within plants.
Quite what relevance customer complaints, compensation claims or due
diligence events have to bodies responsible for consumer safety quite escapes
us.
6.3 Part 3
Review It is essential that a review of the HACCP plan takes place where the plan is
shown to fail or to be not effective.
6.5
We believe that the meat plant operators’ HACCP Training Manual should
be made available on the Food Standards Agency website at the very least and
that copies should be posted to all relevant organisations in order that they
can examine upon what the pilot plan study is based.
6.6 Pilot
Plant Study We believe
that the details of these studies should be posted on the FSA website at a
maximum monthly basis in order that people can ascertain not only the successes
but problems within the system. The
closed door attitude to this study does little credit to the Food Standards
Agency.
6.7 MHS
Guidance The Association
of Meat inspectors is disappointed that once again the important role which meat
inspectors perform within abattoirs is being relegated to that of a second class
citizen. The Delatouche report recently undertaken by the Meat Hygiene Service
clearly demonstrated there was a need for a delegation of some OVS duties in the
abattoir in order to reduce costs and increase efficiency.
The Association is deeply disappointed that no evidence of proper
training for meat inspectors exists in the performance targets for 2002/03 and
therefore it is proposed that this system will be fully in place prior to any
meat inspectors being properly trained within the United Kingdom.
This is an unacceptable situation.
6.8
The Meat Training Council should be urgently commissioned by Government
to prepare and present a properly accredited scheme in HACCP and microbiological
testing for industry. This could then be used also to train enforcement officers.
7.1
The training for MHS operational staff and contractors consisted of a
half-day HACCP awareness training. This
is entirely inappropriate and unsuitable for enforcement of HACCP based systems.
7.9 Official
Controls The Association
remains firmly opposed to the changed roles of enforcement officers from
supervising to auditing. This will
neither enhance or improve public safety and could very well put the public
health at greater risk.
7.10
As previously stated, there is no proposals within the Meat Hygiene
Service performance targets for 2002/03 on training of meat inspectors in HACCP
or microbiological testing.
8.2
The microbiological testing of carcasses does not demonstrate a measure
of hygiene. It can at best indicate
a trend within the plant and so should not be put forward as a method of
improving public safety.
8.4
If the results from testing were an unacceptable zone this should trigger
an automatic review of the HACCP system. It
should also be remembered that there is a considerable time delay between
testing and obtaining results with the standard reference method.
It should be remembered, therefore, that this meat will be within the
market place.
8.6
The number of carcasses to be tested should be based on the throughput of
the plant. Which carcasses to be test should be the decision of the enforcement
officers available at the time. The
proposals which would allow for a one a month test of a particular species in a
four species plant does little to protect the public health and in the interest
of meat safety cannot be considered adequate. The Association believes that all
these samples should be taken by enforcement officers to ensure competent,
consistent handling. Experience
from America where similar testing regimes were put in place showed that there
were instances where samples had been microwaved prior to sending them to the
lab in order to obtain good results.
8.12
Official Controls Again
we are at a loss to see why the necessary training for enforcement officers is
not extended to meat inspectors when it is shown that practicalities of the
situation is that meat inspectors are the ones who handle these duties on a day
in and day out basis.
Other
guidance issued to enforcement officers also include action to be taken and
judgements which are to be made regarding carcasses showing high levels of
non-visible contamination. Is there
to be a recall system in place?
Annex 16
Why is the
acceptance of animals for slaughter been omitted.
The clean livestock policy which the MHS has endorsed has been one of the
resounding successes of this organisation and it is clearly shown that there is
an influence between dirty stock and contaminated products.
The acceptance of pigs at an abattoir should be included within the
plant.
Procedures
for Conducting Microbiological Checks on Carcasses.
3
Samples awaiting despatch for laboratory analysis should be maintained at
an adequate temperature. There
should also be a method for ensuring that this temperature is maintained
throughout the chain from the abattoir to the laboratory.
Ie. ????? systems.
Schedule 17C
Sampling Sites
2a
There should be provision for the enforcement officers to take random
samples from all sites allocated within the HACCP plant.
This should be built in as a method of control check.
2d
(1)
The hands of
operators should be included within the sampling, particularly where gloves are
worn.
(2)
Overhead
structures should not be dripping moisture in the first place. This is a maintenance issue which should not be happening and
which demonstrates there is a failure in the HACCP plan itself.
3.3 Risk
assessment The meat
industry will claim that there is no risk from meat and that it is a low risk
product because in the United Kingdom meat should be cooked prior to
consumption. This of course ignores the potential of meat to be the
vehicle in cross-contamination of products.
Education of the consumer and the householder could, therefore, play a
major factor in reducing the incidence of food borne diseases.
7.5 Training
There should be a specific requirement for training to undertake HACCP
processes. The proposal that two
experienced staff should undertake a minimum of half a days training is paying
lip service to the problem. This is
entirely inadequate and cannot bring any benefit to public health and is a
direct result of the unseemly haste to rush this piece of legislation through.
Training should be on an approved course and should be for the industry
officers and enforcement officers. It
should be at a minimum nationally recognised in the form of approved courses.
Although it may be a long term aim the requirement to have people in plant with
formal qualifications should be one that should be seriously considered and
would raise the profile of the industry whilst at the same time protecting the
public health. We should follow the
example set by some of our European partners that educational standards in their
meat industry is considered essential. Licence
conditions should be extended, competency levels maintained both in new recruits
and refresher courses being provided and planned which would be verifiable via a
CPD type system.
The
Association feels that there would be little benefit to the general public in
publishing microbiological scores. Members of the public are not capable of
interpreting microbiological scores and would possibly over-react to any
indication of microbiological contamination no matter how low the score, even if
some guidance/education was introduced or provided.
On the
question of HAS, although we accept it does provide a management tool for the
Meat Hygiene Service, in theory a plant with a low
HAS score should cease to operate and it would be seen, this HACCP plant
was not functioning properly. We
see no reference within this plan to withdraw the licence of those plants that
consistently fail in the implementation of HACCP plans or in the result obtained
form those HACCP plans. The
Americans adopted, although never fully put into place, a three strikes and
you’re out – is the Agency proposing to carry this forward?