Proposed introduction of mandatory sheep carcase classification: consultation

Proposed Introductions Of Mandatory Sheep Carcase Classification And Price Reporting - Consultation on the Introduction of Mandatory Sheep Carcase Classification and Price Reporting

Dear Sir/Madam

Proposed Introductions Of Mandatory Sheep Carcase Classification And Price Reporting

Introduction

The Scottish Sheep Sector Review - ‘A pathway to a profitable future: a vision for the future of the Scottish sheep industry’ recommended the need for a comprehensive review of price and grade reporting protocols that would result in better reporting of carcase size, appearance and eating quality.

In accepting this recommendation the Scottish Government is proposing to act on the sheep industry request by introducing a mandatory sheep carcase classification system. This will require all Scottish slaughterhouses to follow to a system that will help ensure producers receive consistent information on the confirmation and classification, and be paid per carcase, in a more transparent manner.

European Regulations (Regulation 1308/2013 and Regulation 2017/1182) provide that Member States may apply a Union scale for the classification of sheep carcases. Where a Member State chooses to apply sheep carcase classification, they must follow the relevant classification rules laid down in the Regulations. Any mandatory classification scheme introduced by competent authorities must conform to the European SEUROP payment grid system (see Annex A) and therefore this is the system that would be introduced. Given the fact that the majority of slaughterhouse are already classifying using this system we anticipate the impact being minimum.

We are proposing that the mandatory carcase classification system is introduced by 15 July 2018.

Licensing and Testing

Similar to current beef classification procedures, we are proposing that carcase classification for sheep will be carried out by qualified classifiers who have obtained a licence for visual classification of carcases. Classifiers would require to undergo an assessment before being eligible for a licence. The licensing and testing of the classifier will be carried out by the Scottish Government Meat Inspectors.

The licensing and testing requirement will apply to all authorised grading techniques including automated, semi-automated and manual. Conditions may be imposed on any licences granted, as with beef carcase classifier licences. Where a licence has been issued it is intended the following will apply.

• A licence or any condition can be varied.
• revoke a licence where incorrect classifications or identifications take place
• suspend or revoke a licence if the person has broken the terms or conditions of the licence or where it is no longer appropriate for the licence holder to carry out classifications
• suspend or revoke a licence if the automated grading equipment no longer meets the standards required whether connected with the equipment or the operator’s use of the equipment

Please note that these are the same rules that apply presently to the beef carcase classifiers licences

Throughput Exemption

The Scottish Government have looked at the premises who currently have sheep throughput on a weekly basis. There are 14 abattoirs who meet the criteria of having weekly sheep throughput. Out of these, seven account for nearly 90% of all throughput, with the lowest average around 700 per week.

Given this and allowing for seasonal fluctuations we are suggesting an exemption to mandatory classification and price reporting if there are fewer than 500 sheep per week as an annual average going through the slaughterhouse. However these premises can opt into the classification and price reporting rules at their discretion.

Q: Do you agree that there should be an exemption to mandatory classification and price reporting if there are fewer than 500 sheep per week, as an annual average, going through the slaughterhouse?

Price reporting

For the purpose of establishing market prices of certain categories of animals, market prices shall be reported for all sheep carcases.

Enforcement

Compliance offences

Under the Beef and Pig Carcase Classification (Scotland) Regulations 2010, breach of certain provisions of the relevant EU Regulations in respect of beef and pig carcase classification are offences. It is proposed that similarly for sheep carcase classification, failure to comply with certain requirements of Regulation 1308/2013 and Regulation 2017/1182 relating to sheep carcase classification will be offences.

The proposed offences will relate to failing to comply with the requirements as to the:

• classification
• confirmation
• fat cover
• presentation;
• weighing and
• record keeping
• identification of carcases

The proposed penalty for such offences is a fine not exceeding level 5 on the standard scale, with a fine not exceeding the statutory maximum for the offence of misleading marks.

Notification and licence offences

In line with the regulations for beef and pig carcase classification, it is proposed that where a slaughterhouse used for slaughtering sheep is required to notify details to the Scottish Ministers, failure to comply with the notification requirements will be an offence.

It is also proposed that offences and penalties in line with those relating to licences for beef carcase classification will apply to sheep carcase classification.

The regulations for beef carcase classification provide-

(A) If classification is carried out at an approved slaughterhouse;

• without a licence granted or
• in breach of any term or condition of such a licence,

Both the person who carries out the classification and the operator of that slaughterhouse are each guilty of an offence.

(B) If classification is carried out at an approved slaughterhouse by means of automated grading equipment;

• without a licence granted for the use of that equipment at that slaughterhouse; or
• in breach of any term or condition of such a licence,

Both the person who carries out the classification and the operator of that slaughterhouse are each guilty of an offence.

(C) Any person who makes an alteration to a licence granted with the intent to deceive is guilty of an offence.

The penalties for such offences is a fine not exceeding level 5 on the standard scale, in addition to revoking of individuals licences.

As with the legislation for Beef Carcase Classification inspections will take place at regular intervals and the powers of entry will be as it stands at present, with the explanation as below.

Powers of entry

It is proposed that the powers of entry and powers of entry which apply to Beef and Pig Carcase Classification will also apply to sheep carcase classification. These provide that an authorised officer may at any reasonable hour enter an approved slaughterhouse and any associated premises in which carcases may be handled or records relating to those carcases may be kept, for the purpose of checking whether

• any offence under these Regulations is being or has been committed on the premises; or
• there is on the premises any evidence of any such offence

The officer may be accompanied, including any representative of the European Commission.

If there are reasonable grounds, or a need for urgency a warrant may be authorised allowing an officer to enter the premises, if need be by reasonable force.

All of the above enforcement paragraphs are not new and are already in force with the Beef Carcase Classification Regulations as they presently stand.

I nspections

It is proposed that inspections shall be carried out at regular intervals with varying frequency and relative to the volume of sheep production. It is intended that the powers of authorised officers who enter premises regarding beef and pig carcase classification will also apply in respect of sheep carcase classification. These allow authorised officers to—

• Inspect carcases on the premises;
• Examine records which the operator is required to keep;
• Require copies or extracts of records to be produced; and
• Retain records which the officer believes may be required as evidence.

Q: Do you agree that the Scottish Government should seek to introduce mandatory sheep carcase classification systems and price reporting?

Timings

Subject to the responses of the consultation, the Scottish Government’s aim is to introduce mandatory sheep carcase classification system by the 15 ^th July 2018. This date has to align with changes to the Beef and Pig classification systems (see Annex A)