Future arrangements to secure food standards and safety in Scotland

Chapter 7 - Official Meat Controls

36. Official Controls

36.1 The Panel's term of reference include a requirement to identify and evaluate alternative delivery options which would allow the meat inspection function (official controls) to be undertaken in a more efficient and cost effective manner than the current GB wide model.

37. History of official controls

37.1 Scotland had a long standing tradition of veterinary supervision in abattoirs to provide public health controls dating back to the late 1800s. That was a time of rapid expansion and structural change within the meat industry, caused in part by the extension of the rail network and the growth in the trade of imported livestock and chilled/frozen meat being shipped to the UK from overseas to meet the demands of the industrial revolution. Around the same time many public health professionals were concerned about the risk to human health from diseased meat.

37.2 The Public Health (Scotland) Act 1867 provided the powers for police officers and authorised vets to seize, detain and where necessary destroy meat deemed unfit for human consumption. Over the intervening years further controls were introduced and updated to reflect the current scientific evidence and advice. In the early 1900s specific training in meat inspection protocols and procedures was introduced and qualified inspectors assumed the statutory functions previously exercised by the police. The Public Health (Meat) Regulations were introduced in 1924 which imposed quality standards and provided enforcement powers to local authorities.

37.3 Prior to the establishment of the Meat Hygiene Service (MHS) in 1995 the delivery of meat inspection function was the responsibility of local authorities across Great Britain. The meat inspectors were employees of the local authority on public service terms & conditions. The MHS was fully merged with the FSA in April 2010, when delivery of official controls in approved meat establishments became part of the FSA Operations Group.

38. Scottish livestock controls and health status

38.1 Scotland has been successfully developing a high health status for its herds and flocks of domestic livestock over the last 10 years. Strategic and economic drivers have contributed to this and it has been achieved though the combined and coordinated efforts and ambitions of the Scottish livestock industry working with the Scottish Government. Evidence for this development in health status, for the proactive approach taken and the lessons learnt in Scotland are outlined below.

38.2 In 2001 Scotland dealt very effectively with Foot and Mouth Disease (FMD). It remained free from FMD and Bluetongue in 2007 and dealt with an Avian Influenza incident and Newcastle Disease outbreak in 2006. Scottish Government has responded effectively to recommendations of the enquiries into disease outbreaks such as the Anderson, Royal Society, Royal Society of Edinburgh and Scudamore reports. In addition, since 2008 Scotland has not reported any cases of BSE and only a handful of scrapie cases while enforcing rigorous surveillance of slaughtered and fallen stock. Scotland gained officially tuberculosis free (OTF) status in 2009. For many years, the majority of bovine tuberculosis (BTb) cases have been successfully traced back to animals moved into Scotland from other parts of the UK and the Republic of Ireland. It is worth noting that a significant proportion of these cases have been detected at post-mortem inspection.

38.3 The experience gained through the above examples has reinforced the need for a proportionate, risk and evidenced based approach to disease control in Scotland. This approach is implemented through disease prevention measures, surveillance and livestock traceability. Disease prevention and control measures include a 13 day standstill for cattle and sheep, a 21 day standstill for pigs; pre- and post-import testing for BTb since 2005 and new risk based on-farm BTb testing regime.

38.4 Scotland's veterinary surveillance system is operated by the Scottish Agricultural College (SAC), it comprises 8 Disease Surveillance Centres (DSCs) whose locations broadly reflect livestock distribution and provide good geographic coverage. Throughput of the DSCs in Scotland is at a higher level per livestock unit than elsewhere in GB and the system has a strong track record of finding new conditions. The overall purpose of the system is to detect exotic diseases, new and emerging conditions and public health threats while complying with EU obligations.

38.5 Scotland's livestock traceability system has been under continuous development for 10 years, using technology to implement systems that are robust, accurate and timely. Scottish cattle farmers rapidly adopted the use of the 'CTS online' system for reporting moves; Scottish markets provide 'four way reporting' (off-farm, on-market; off-market, on-farm) for cattle and sheep which both reduces burden and expedites movement reporting. Scotland implemented sheep electronic identification (EID) through automated collection of electronic tag data at markets and abattoirs, this data populates the ScotEID database in near real-time. The ScotEID database's interoperability with market, abattoir and on-farm software combined with its interrogation function that allows excellent individual animal traceability.

38.6 The database has now been developed to capture pig movements and continues to be developed for other purposes. For example the ScotEID database has the capacity to hold health status information and is being equipped to record BVD status as part of Scotland's BVD eradication scheme. Further opportunities are emerging to link data systems in the food chain, from farm to fork, through the European Commission's proposals to implement bovine EID, although selection of the appropriate technology (High Frequency or Ultra High Frequency - the food chain standard, not Low Frequency - the standard for companion animals), is likely to be key to success in this regard.

38.7 Recent discussions between the Scottish Government, FSA, and the meat processing sector have identified an opportunity to pass CCIR (Collection and Communication of Inspection Results) data back to farmers from abattoirs, via FSAS and the ScotEID database; this could be taken forward relatively quickly. Food Chain Information (FCI) data flow from farms to abattoirs is also becoming a possibility as a consequence of improvements in livestock identification and traceability systems. However it is a more complex proposition than for CCIR data flow that would require detailed scoping work, planning, project working and investment in data/IT systems at abattoirs.

38.8 The above measures are supported in Scotland by a well developed and coordinated farm quality assurance scheme, widespread adoption of annual health planning and provision of consistent, accurate livestock health information and advice through both commercial and publicly supported streams, including novel innovation and education mechanisms such as 'Monitor farms'.

39. EU review of official controls on meat for human consumption

39.1 The objective of meat inspection is to protect public health, animal health and animal welfare. Traditional meat inspection has been conducted for more than 100 years and the meat inspection function is still targeting hazards well known at that time. Today, both in Europe and elsewhere in the world, some of the old hazards have been eradicated and replaced by others with these being described in a scientific report published by EFSA following a mandate from the European Commission (EC). EFSA has been asked to look at: domestic swine, poultry, bovine, domestic sheep and goats, farmed game and domestic solipeds.

39.2 The Scientific Opinions on meat inspection for the different species are to be delivered in a staged basis by EFSA. These Opinions will:

• Identify and rank the main risks for public health that should be addressed by meat inspection at EU level.
• Assess the strengths and weaknesses of the current meat inspection methodology and recommend possible alternative methods, taking into account implications for animal health and welfare.
• Recommend additional inspection methods in case other previously not considered hazards have been identified above (e.g. salmonellosis, campylobacteriosis).
• Recommend possible alternative methods and adaptations of inspection methods and/or frequencies of inspections that provide an equivalent level of protection within the scope of meat inspection or elsewhere in the production chain that may be used by risk managers in case they consider the current methods disproportionate to the risk, e.g. based on the risks or on data obtained using harmonised epidemiological criteria.

39.3 The ongoing EU review for all species will not be completed until 2014. The opinion on pigs was delivered in September 2011 and is currently under discussion between the EC and stakeholders. A series of meetings has been held and the EC will bring forward their proposals in the near future. As the main risks to public health (Salmonella, Yersinia, Toxoplasma and Trichinella) are not detectable by post mortem examination there will be increased emphasis on controls on farm and at other levels of the chain such as at the end of the slaughter line. Whilst there will be changes to post mortem requirements for public health reasons it will still be important for ante mortem examination and also measures in the abattoir to detect animal health and animal welfare problems. The opinions on poultry and other species are expected in the next two years.

40. Wider roles and responsibilities regarding official controls

40.1 The Food Standards Act sets out the Food Standard Agency's (FSA) functions. It has a wide remit for feed and food safety and standards issues from 'farm to fork', including developing policy and representing the UK on feed and food matters at EU level, and responsibility for making and implementing feed and food law. Responsibility for monitoring and verifying compliance with official controls and enforcement is shared between the FSA (including other authorities working on the Agency's behalf), and local authorities.

40.2 The Food Standards Act 1999 and EC Regulation (No.) 882/2004 on official controls performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules, provides the FSA with a package of statutory powers to strengthen its influence over enforcement activity, and to help in the delivery of national priorities and objectives. The Act gives the FSA powers to set standards of performance in relation to enforcement of feed and food law and to monitor and audit enforcement authorities against those standards in order to assess their performance. It also gives the FSA powers to require local authorities to provide information relating to feed and food law enforcement. The FSA may enter local authority premises to inspect records and take samples, and it may make reports to individual authorities which may give guidance on improving performance. It can also require enforcement authorities to publish these reports and to state what action they propose in response.

41. Current arrangements for delivery of controls

41.1 The FSA Director of Operations has overarching responsibility for the implementation and effective delivery of official controls across the UK for all of the Agency's Competent Authority food and feed responsibilities.

41.2 The current high level management structure within the FSA Operations Group is shown in Figure 2.

Figure 2 - FSA Operations Group high level management structure

41.3 The FSA Director of Operations works closely with FSA Directors for Scotland, Wales and Northern Ireland on operational matters in these countries.

41.4 The Head of Operational Delivery and Head of Approvals and Veterinary Advice are members of the FSA Operations Group Senior Management Team, with the Head of Enforcement, Local Authority and Liaison Division and the Head of the Local Authority and Liaison Division and report performance to the FSA Director of Operations.

41.5 April 2012 will see the introduction of a new structure for meat controls, which will include a specific operations group for Scotland.

42. Costs

42.1 In recent years, there has been substantial progress on modernising the delivery of official meat hygiene controls across the UK, in order to ensure that costs are as low as possible.

42.2 Since 2006, efficiencies in delivery have driven the costs of meat controls to industry down by £14.5m in Britain - from £69.9m in 2006/07 to £55.5 million in 2010/11. Costs have primarily been reduced by:

• the closure of five regional offices operated by the former MHS and centralisation of field support.
• introduction of a new field structure in 2009, allowing for more efficient use of resources.
• revised terms and conditions for field staff.
• a move towards more risk-based BSE controls and changes to work carried out for other parts of government under SLAs.
• the merger of the former MHS with the FSA, bringing together corporate service functions and establishing the Operations Group which applies across all aspects of official controls delivery across the feed and food chain within the UK.
• revisions to the approvals process and refusal to approve persistently non-compliant businesses.
  

42.3 In 2010/11, 11.6% of total hours recorded by OVs and MHIs were in premises in Scotland. The table below provides an estimate of charges for Britain (£44.3m) and Scotland (£5.1m) in 2011/12.

Table 2 - Projected charges in Great Britain and Scotland 2011/12

Cost	2011/12 Budget for Great Britain (£m)	2011/12 Scotland £m (based on 2010/11 proportion of total hours)
Industry cost	55.0	6.4
Pension deficit cost	(4.7)	(0.5)
Industry cost (excluding pension deficit costs)	50.3*	5.8
Cost savings	(5.0)	(0.6)
Low throughput support	(2.7)	(0.3)
Target charge to industry 2014/15	42.6	4.9
Plus throughput increase adjustment	1.7	0.2
Rebased target charge to industry 2014/15	44.3	5.1

* Direct costs account for £40.0m and indirect costs for £10.3m.

42.4 The agreed budget for 2011/12 is £55m but this has recently been adjusted to £50.3m, with the recent decision that pension deficit costs would be removed from charges to industry. The FSA is now committed to reducing the costs of meat controls further to £45.4m by 2014/15, thereby limiting costs increases to businesses in the route to full cost recovery.