Welcome extension to scope of hygiene regulations debate
The very interesting comments from leading trade figures in 3 April MTJ questioned some of the basic defects and anomalies in the present set-up of meat hygiene regulations. Increased charges are damaging enough, but it is good to see industry leaders extending the discussion to the technical and legal bases of regulations. These matters should be settled before costs get completely out of control.
Taking just one example, doubts were expressed as to whether slaughterhouse regulations actually have much to do with health. This, alone, is revolutionary stuff and merits close examination.
For a start, carcase meat is all "health-marked". What does this mean? First of all, it does not mean that health-marked meat is fit for human consumption. Very sensibly, the law recognises that raw meat may carry certain pathogenic (harmful) bacteria, which are invisible, and there is no test to guarantee their absence. Consequently, there is no critical control point in abattoirs that will eliminate pathogens. This means there are strict limits to what slaughterhouse inspections can achieve in this respect.
Live animals carry unknown numbers of harmful bacteria. These enter the food chain legally and cannot be eliminated during abattoir processes. This health specification must be taken on board by subsequent processors. So the Meat Hygiene Service (MHS) claims to be "protecting the health of the public" are grossly exaggerated, to put it mildly.
So what does the health mark mean? The law says it shows a carcase has been produced in accordance with certain regulations, which in terms of hazard analysis is virtually meaningless. I suspect the Food Standards Agency is aware of this, which may be one reason why they acknowledge that current regulations are neither risk-based nor proportionate. The only response is to fall back on flimsy arguments about "minimising" contamination. But the present health specification for carcase meat leaving an abattoir is not altered by any amount of "minimising".
Starting from scratch, if it were thought important to apply the rigorous total MHS-type controls anywhere, it would not be at the abattoir stage. The preparation of ready-to-eat food would be a top priority, but of course this would not be either practical or necessary. Nor, for example, would the large retail chains put up with it.
This brings us to Professor Pennington's recent E.coli report. This extensive document castigates those involved. Fair enough, but dare one suggest a lack of proportion? I, for one, am not prepared to accept a severe public dressing down for activities over which I have limited control.
I try to run a clean abattoir, with well-trained staff and excellent standards of carcase dressing. I comply with the law, as verified by an (ambiguous) health mark. I supply a high-quality product that cannot be guaranteed free of pathogens, in common with practice in the rest of the industry. In general terms, minimising bacteria is part of everyday practice - but does not alter the situation as to contamination. Hazard analysis depends on accurate language and known facts.
Surely it is misleading for Professor Pennington to equate an abattoir with establishments preparing ready-to-eat food? The latter is an activity that can be managed in accordance with correct hazard analysis and the identification of control points that will eliminate dangerous bacterial contamination.
A start has been made by the industry to highlight the real issues, which have blighted us for years and the focus is shifting away from "transforming" the MHS. Not long ago, placing abattoirs on the same footing as the rest of the food industry was just a pipe dream. Now it is being openly discussed - and not a moment too soon.
Toby Baker, Bakers of Nailsea
27 October, 2016, 8:30
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