Application for Bovine Spongiform Encephalopathy (BSE) negligible risk Status for Scotland: consultation

Chapter 2: Implications of Obtaining BSE NR Status: Risks and Benefits

2.1 There are a number of implications to be considered should Scotland acquire BSE NR status. As has been outlined earlier, industry has identified three potential key benefits:

• less tissue would be classified as Specified Risk Material ( SRM), therefore less material would go for destruction, with consequent reduced disposal costs for red meat establishments;
• there would be an opportunity for the red meat industry to generate new domestic and export revenue streams by finding new markets for material previously classified as SRM; and
• there would be the potential for the expanded utlilisation of other tissues e.g. intestines for sausage casings and intestinal fat could also go into the food chain.

Disposal Costs

SRM

2.2 SRM is classified as Category 1 Animal By-Product ( ABP) and is therefore only permitted to go for disposal at a cost currently of approximately £80 per tonne. Table 3 summarises which parts of the carcase are classified as SRM under the different regimes Negligible Risk and Controlled Risk. All disposal costs are borne by industry and through achieving negligible risk, the Scottish industry would be able to save on some of these costs.

Table 3: SRM Material under Controlled Risk and Negligible Risk Status*

Part of Carcase	Controlled Risk	Negligible Risk	Weight Per Head
Tonsil	SRM		0.02kg
Intestine and Intestinal Fat	SRM		30kg (Plus 25kg Contents)
Spinal Cord	SRM	SRM	0.2kg
Skull (excluding Mandible and including Meat)	SRM	SRM	8.67kg
Vertebral Column	SRM		19kg

* data from Scottish Association of Meat Wholesalers ( SAMW)

2.3 In 2015, Scottish abattoirs slaughtered approximately 468,000 cattle with around 85,000 over 30 months ( OTM) at slaughter ^[6] . Based on these figures, the savings on disposal costs would amount to approximately £1.3m per year (assuming that all the former SRM finds new markets and none is sent for disposal). If Scotland were to be upgraded to NR status 4 years ahead of the UK as a whole, this would mean a total saving of £5m for the Scottish industry assuming disposal costs are unchanged (see Table 4). This would be of benefit to the overall beef supply chain.

Table 4: Cost of disposing of intestine, intestinal fat and spinal column

	Under 30 months	Over 30 months	Total
Weight per Carcase	30.2kg	49.2kg	-
Scotland Production (tonnes)	11,566	4,182	15,748
Annual Disposal Cost Saving at current prices	£926,000	£335,000	£1,261,000
Projected Savings over 4 year period	£3.7m	£1.3m	£5m

2.4 By removing some parts of the carcase from the SRM list, an opportunity also emerges to generate an income stream. For example, there would be the potential for the use of intestines (average of 16.8kg per head in bovines) for sausage casings, and intestinal fat (13.4kg per head) could also go into the food-chain. This could potentially bring the total value to £12 -14m over four years. These figures are illustrative only and based on market prices in April 2015.

2.5 Projected figures assume unchanged disposal costs, although it is possible that these could rise on a per unit basis, due to the smaller volumes being rendered. Furthermore, the calculations are based on current approximated prices for ABPs which are subject to market variation. ABPs have had stronger values in the past and may rise or fall in the future.

2.6 The change from CR to NR status could mean the use of a different classification of SRM tissues. The European Commission recently agreed proposals to relax controls on SRM for those countries with NR status (bringing EU rules more in line with OIE requirements for non- EU countries). The classification of what is deemed to be SRM for these countries will change: only the brain, skull, eyes and spinal cord of bovine animals aged over 12 months will remain classified as SRM.

2.7 It should be stressed however that the reduction in SRM controls has only been applicable on a country (Member State), not regional basis in the past, so BSE NR status on a regionalised basis does not inevitably lead to a reduction in SRM controls.

Question 5

In relation to the separation and disposal of SRM from CR and NR animals do you have any further comments?

2.8 The reduction in the volume of tissues designated as SRM would have the effect of reducing the quantity of material going for disposal by rendering. However the rendering sector in Scotland has reported that they fully support a BSE NR application, pointing out that the industry is constantly changing, and that the sector is already accustomed to adjusting to market pressures. It is actively seeking alternative methods of raising revenues in view of a possible reduction in Category 1 capacity, irrespective of whether or not Scotland is upgraded to BSE NR status. Category 2 ABP capacity will continue to be required for disposal of animals killed for control of notifiable diseases; at present category 2 disposal is provided by the existing category 1 rendering plants.

Question 6

Do you have any concerns that the reduction in the amount of SRM for disposal may reduce the capacity for disposal of SRM and fallen stock in Scotland, and may result in:

• increased costs for disposal of SRM and fallen stock of all species?
• disposal constraints in an epizootic disease outbreak?

Trade

2.9 The advantages of NR status for Scotland could provide an improved global image as there is a perception that NR countries have a higher general health status than those with CR status. Industry has argued that obtaining NR status conveys a disease-free image which would provide commercial benefits in terms of gaining entry into new markets and expanding current markets, especially where limited access currently exists. It is however difficult to quantify the impact that NR status would have on trade negotiations given they are contingent on a number of factors including but not limited to, health status across a range of diseases and the ability to comply with a particular importing country's standards.

Question 7

Do you have any comments on or any evidence to support the perception that countries with NR status have an improved global image?

2.10 The existing BSE CR status and the accompanying SRM controls should provide sufficient reassurances on the safety of exported Scottish beef; however, importing countries with BSE NR status are inclined to place further restrictions through various trade agreements. The achievement of BSE NR status would allow negotiations which could facilitate the removal of limiting clauses, such as those which prohibit the export of products from animals over 30 months old.

Question 8

Do you have any comments on the issue of trade being negatively affected in existing markets should Scotland obtain NR status e.g. due to revision of existing export certificates?

2.11 In terms of the value of market opportunities, it is difficult to give a definite figure on what might be achievable if Scotland had full access to all the significant beef markets around the world. Should Scotland be successful in obtaining BSE NR status it would then become necessary to consider potential trade issues and re-negotiate or revise a number of existing health certificates, with the various authorities of the importing countries. Statements relating to BSE are found in a number of export certificates and these vary depending on the requirements of the importing country. The main certificates that would be affected by a change to our BSE status are those relating to beef products and hides and skins certificates. It is difficult to quantify how long these renegotiations would take and therefore, trade to existing markets may be disrupted for a time. Beef and beef products would still need to comply with existing labelling rules.

Question 9

If Scotland is upgraded to NR status can you provide examples of how/where trade will improve? This includes accessing new markets and negotiating existing ones.

Question 10

Do you have any comments on possible advantages or disadvantages to other sectors in Scotland? ( i.e. dairy, sheep, pork, white meat, equine etc?)

Operational Controls

2.12 Food Standards Scotland ( FSS) oversee the delivery of official controls in abattoirs and FSS officials have expressed support in principle for a NR status application as long as industry can provide appropriate assurances in relation to the separate handling of animals and abattoir processes, associated with cattle coming from a CR origin from those from a NR origin. Industry has confirmed that abattoirs already operate robust systems for the batching of animals of different jurisdictions or stock category and that receiving animals of differing BSE risk categorisations would not present any added difficulties for meeting regulatory controls in this area.

Livestock Identification and Traceability

2.13 The purpose of animal identification and movement notification is traceability, to enable efficient and effective disease control and protect public health. Maintaining a healthy cattle herd and supporting consumer confidence in milk and beef are essential for the industry to be successful. There are a number of well-established database systems across the United Kingdom for the registration of livestock keepers, agricultural land, the movement of livestock and for analysis. Many of these have been developed to meet European and domestic legislation and are subject to EU audit and strict veterinary controls.

2.14 The UK Cattle Tracing System ( CTS) rules ensure cattle are individually identified throughout their lives. This is important for supporting the control and eradication of bovine diseases such as Tuberculosis ( TB), Bovine Viral Diarrhoea ( BVD) or Foot and Mouth Disease ( FMD). It protects consumers by ensuring products going into the human food chain are fully traceable and safe. In Scotland the livestock markets support keepers by reporting cattle movements, on their behalf electronically to CTS. Work is ongoing to replace CTS links in Scotland and is taking a wide range of factors into account to design a system which suits industry requirements and enhances traceability.

2.15 For other livestock species significant progress has also been made in Scotland through a stepwise approach via the sheep, goat and pig movements systems developed on Scot EID, the BVD database and more recently the Beef Efficiency Scheme ( BES). Building on this core capability has enabled industry developments such as the Scottish Eligibility Cattle Checker ( SPECC) and work on Porcine Epidemic Diarrhoea ( PED), all of which are accessible through www.scoteid.com.

Loss of NR Status - Publicity, Recall of Meat, Effects etc

2.16 The intermittent nature of BSE cases, both in terms of occurrence and the date of birth of the BSE case, could result in a situation where NR status is lost as happened recently in both the Republic of Ireland and in France. ^[7] This could generate considerable public concern and negative publicity. There is also the possibility that food and feed may need to be recalled, which would bring with it the expense and disruption caused to hard-won contracts, as well as the financial losses involved. The livestock sector is aware of this risk and whilst acknowledging it could cause difficulties, they take the view that they have the ability to deal with any recall situation which may be required and on balance, they do not think that it is sufficient justification not to proceed with an application.

Question 11

If Scotland were successful in achieving NR status, have you any comments on the impact to industry should NR status subsequently be lost?

Question 12

Do you agree that, in order to mitigate the commercial risk in the event of loss of NR status, industry should work towards putting contingency arrangements in place?