Technical hearing on meat inspection of small ruminants 1, 2

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1 Supporting Publications 2012:EN-373 EVENT REPORT Technical hearing on meat inspection of small ruminants 1, 2 European Food Safety Authority European Food Safety Authority (EFSA), Parma, Italy SUMMARY The European Commission requested EFSA to issue Scientific Opinions on public health hazards to be covered by inspection of meat in different animal species. In order to support the work of the Panel on Biological Hazards (BIOHAZ) and of its working groups in drafting the Scientific Opinions, the BIOHAZ Unit organised four technical hearings in relation to the following animal species: bovine animals, sheep and goats, farmed game and domestic solipeds. The aim was to collect information and data which are not readily available in scientific literature or in other sources of data at European Union (EU) level. EU stakeholder organisations linked to the remit of the Scientific Opinion on public health hazards to be covered by inspection of meat of small ruminants were invited to participate in a technical hearing which took place on 17 April The organisations invited were: Copa-Cogeca (Committee of Professional Agricultural Organisations General Confederation of Agricultural Cooperatives), FVE (Federation of Veterinarians of Europe) and UECBV (European Livestock and Meat Trading Union). A questionnaire was sent to these organisations in advance to the meeting in order to collect information and data on several issues related to meat inspection of small ruminants. Representatives of these organisations attended the meeting, where they presented a summary of the information provided to EFSA. This was followed by a discussion between the representatives of the stakeholder organisations and experts from the working groups of the EFSA Panels. The main issues covered during the meeting included food chain information, the identification of the main hazards for public health in the context of meat inspection, and slaughtering and inspection procedures. This report summarises the information that was provided by the representatives of the three stakeholder organisations participating in the technical hearing either by means of presentations or by 1 Question No EFSA-Q Disclaimer: The views or positions expressed in this publication do not necessarily represent in legal terms the official position of the European Food Safety Authority. The European Food Safety Authority assumes no responsibility or liability for any errors or inaccuracies that may appear. Any enquiries related to this output should be addressed to biohaz@efsa.europa.eu Suggested citation: European Food Safety Authority; Technical hearing on meat inspection of small ruminants. Supporting Publications 2012:EN-373. [51 pp.]. Available online: European Food Safety Authority, 2012

2 replying to the questionnaire provided a priori by EFSA in relation to production, slaughter, consumption and meat inspection of meat from small ruminants. European Food Safety Authority, 2012 KEY WORDS Sheep, goats, meat inspection, small ruminants, stakeholders Supporting publications 2012:EN-373 2

3 TABLE OF CONTENTS Summary... 1 Table of contents... 3 Background as provided by EFSA... 4 Terms of reference as provided by EFSA... 4 Consideration Introduction Participants Purpose of meeting and background to the mandate on meat inspection Summary presentations on responses to questionnaire previously sent by EFSA to stakeholders Information provided by Copa-Cogeca Information provided by FVE Information provided by UECBV Discussion... 7 Appendices... 8 A. List of questions for stakeholders... 8 B. Additional information provided by Copa-Cogeca C. Additional information provided by FVE D. Additional information provided by UECBV Abbreviations Supporting publications 2012:EN-373 3

4 BACKGROUND AS PROVIDED BY EFSA Technical hearing on meat inspection of small ruminants The European Commission has requested that EFSA issue Scientific Opinions on public health hazards to be covered by inspection of meat in different animal species (mandate number M ). The following species or groups of species should be considered within this mandate: domestic swine, poultry, bovine animals, domestic sheep and goats, farmed game and domestic solipeds. The Scientific Opinions for swine and poultry have been published 3, and the drafting for the other groups of species is currently underway, with a deadline for these Opinions of June TERMS OF REFERENCE AS PROVIDED BY EFSA The biological hazards (BIOHAZ) Unit was invited to organise four technical hearings with experts recommended by stakeholder organisations, who were requested to give presentations and answer questions from EFSA in the field of biological and chemical hazards on different aspects of the meat inspection and slaughtering practices. The Unit on contaminants in the food chain (CONTAM) assisted in the identification of issues in the field of chemical residues and contaminants needed to support the work of the CONTAM Panel and of its working group (WG) in drafting the CONTAM part of the Scientific Opinions. In particular, the BIOHAZ Unit was asked to: Identify issues in the field of biological hazards that were needed for supporting the work of the BIOHAZ Panel and of its WGs in drafting the BIOHAZ Scientific Opinions on public health hazards to be covered by inspection of meat. Those issues relate to information or data which are not readily available in scientific literature or in other sources of data at EU level (e.g. EUROSTAT, EU Summary Report on Trends and Sources of Zoonoses and Zoonotic Agents). The particularities of these issues depend upon the individual groups of species to be considered. Identify experts from EU stakeholder organisations that would be able to provide technical replies to the issues identified above. Organise one-day technical hearings with the identified experts, Panel members and WG members for the following groups of animal species: Bovine animals Sheep and goats Farmed game Solipeds Prepare from these technical hearings four event reports with a summary of the points discussed and the presentations given. 3 and Supporting publications 2012:EN-373 4

5 CONSIDERATION 1. Introduction Following the invitation to organise four technical hearings with experts recommended by stakeholder organisations, the BIOHAZ Unit convened a technical hearing on meat inspection of small ruminants on 17 April 2012 in Parma, Italy. The purpose of this report, as mentioned in the terms of reference above, is to summarise the information that was provided by the representatives of the different stakeholder organisations either by means of presentations or by replying to a questionnaire provided a priori by EFSA (see Appendix A). The information gathered in equivalent technical hearings about meat inspection of bovines, farmed game and solipeds is presented elsewhere Participants Stakeholder organisations: Copa-Cogeca (Committee of Professional Agricultural Organisations General Confederation of Agricultural Cooperatives) UECBV (European Livestock and Meat Trading Union) FVE (Federation of Veterinarians of Europe) EFSA Working groups (WG) on public health hazards to be covered by inspection of meat in small ruminants: BIOHAZ WG, and a representative from the CONTAM WG EFSA staff from the BIOHAZ, CONTAM and Biological Monitoring (BIOMO) Units 3. Purpose of meeting and background to the mandate on meat inspection EFSA briefly presented the background to the meat inspection mandate and described the terms of reference received from the European Commission. The main objectives of the technical hearing were explained i.e. to provide WG experts with an opportunity to seek information from stakeholder representatives about slaughtering practices and meat inspection in small ruminants, based on the answers to a previously distributed questionnaire. 4. Summary presentations on responses to questionnaire previously sent by EFSA to stakeholders Representatives of the three stakeholder organisations presented the main issues to be considered in the context of meat inspection of small ruminants, as follows: 4.1. Information provided by Copa-Cogeca The importance of optimizing the information flow throughout the food chain from the farmer to the slaughterhouse and vice versa was stressed. A better use of the information already available at farm level is possible, including investigating the potential that voluntary quality systems offer. These quality systems are preferred to HACCP systems at primary production. Ante mortem inspection should remain at the slaughterhouse, as this allows for an assessment of health and welfare of animals after transport. Slaughtering processes for sheep and goats in EU differ according to size of the slaughterhouse, but are the same for young sheep and goats, except very young kids that, in France, can also be slaughtered in abattoirs for rabbits and Supporting publications 2012:EN-373 5

6 No evidence was found to suggest that if all dressing operations are carried out by the same person, there could be increased microbiological risks. Although the performance of seasonal workers should not compromise the productivity of the line, hygiene problems may arise in peak demand times (e.g. Eid ul-fitr), usually related to skinning and evisceration. The replies to the questionnaire and the summary of the presentation given by the Copa-Cogeca representative can be found in Appendix B Information provided by FVE An overview of the slaughtering and inspection processes was presented, stressing the importance of clean incoming animals. Some conditions detected at meat inspection were reviewed, and suggestions to improve feedback to producers were given, as at the moment there is little communication of relevant findings to farmers. The importance of flock health programmes and the potential links with food chain information (FCI) were stressed. An improved system of FCI would be beneficial in many aspects e.g. public health, animal health and welfare, and by helping producers to control certain conditions and thus decreasing the costs of production. Sampling for chemical residues and contaminants is random, rather than targeted. The extensive nature of sheep production does not suggest that there is use of illicit substances. There is no evidence for use and no specific training is provided for identifying treated animals. The concerns are related to the withdrawal periods and the misuse of some VMPs prescribed for bovines that are used on sheep and goats. Rules for the prescription of VMP to small ruminants should be followed and applied. It should be noted that use of VMP on sheep and goats is more likely to be under preventive medicines rather than as prophylactic medicines. The replies to the questionnaire and a summary of the information provided in the presentation given by the FVE representative can be found in Appendix C Information provided by UECBV The importance of correctly identifying the relevant hazards for meat inspection of small ruminants was stressed, especially through the use of source attribution. Carcass contamination originating from dirty incoming animals was seen as the main problem, while decontamination treatments were mentioned as a potential solution to be considered, as long as they are not a substitute for good hygiene practices. The current importance of FCI is unclear, as the information that is recorded in at least parts of the EU is very general. There is occasional feedback to producers specific to certain conditions found during slaughter, but this is not considered as part of FCI. The quality of the FCI may suffer where collating/summarising occurs. Where animals go directly from farms to slaughter plant, the FCI may be useful but, when through markets, the FCI may be less reliable. In addition, there is a need to look at risks to public health arising from handling of the meat beyond the chiller, as this can have an impact on the consumer e.g. poor hygiene during transport of carcasses or handling of meat at retail. Sampling for chemical residues and contaminant is probably not very targeted but more random. Sometimes injection sites or abscesses may be identified on the animals/carcasses, but often these may be related to vaccination rather than treatments with other VMPs or illicit substances. It was also considered necessary to understand the balance between food safety, animal health, animal welfare and livestock production issues with regards to meat inspection, as this would impact the responsibility for cost attribution. Supporting publications 2012:EN-373 6

7 The replies to the questionnaire and the presentation given by the UECBV representative can be found in Appendix D. 5. Discussion The presentations were followed by a session of questions and answers, were the experts had the opportunity to seek clarification about a number of issues in the areas of biological and chemical hazards. Some of the issues discussed included the use of process hygiene criteria at abattoirs, potential improvements to inspection procedures, and whether there is any feedback to farmers on results of testing. A long discussion about how to better implement FCI also took place, which revealed a range of different interpretations of this concept. In addition, questions about residues, targeted sampling and illicit substance use were also asked. Supporting publications 2012:EN-373 7

8 APPENDICES A. LIST OF QUESTIONS FOR STAKEHOLDERS Meat inspection of small ruminants Technical hearing with stakeholders: list of questions A. Slaughtering process: Please describe from the time of arrival of the animals to the dispatch of the final product for sheep and goats 1. Are there significant differences in this process between Member States? 2. Are there different slaughtering procedures for young lamb and goats? a. Is there an increased risk during dressing of carcasses if single operator does everything? b. Seasonal slaughtering: could it lead to potential problems with hygiene due to lack of experience/training of seasonal workers? 3. Is there any information about the homogeneity of the batches of animals arriving at the slaughterhouse, same farm, same herd or mix of animals from different herds? Can you provide approximated figures for the proportion of animals that arrive at the abattoir from: 1. Directly from a single farm 2. From several farms e.g. a lorry collecting sheep at different farms 3. From a market as a uniform batch (i.e. all animals from the same farm) 4. From a market as a mixed batch 5. Other 4. What is the percentage of animals undergoing ritual slaughter without stunning? 5. Process hygiene criteria: a. Actual use b. Ways to improve it 6. Describe the Hazard Analysis and Critical Control Points (HACCP) plan in place at the abattoir 7. What kind of hygiene problems are encountered during slaughtering at sheep and goat abattoirs? B. Meat inspection process 1. Food chain information (FCI): a. Actual use of FCI b. Ways to improve FCI 2. How is information on adverse toxicological events and treatment periods, animal/herd health status, feed supplies and controls collected at the primary production stage? 3. What are the main hazards/conditions identified during meat inspection? 4. What is the level of condemnation (whole and part) of carcasses and what are the reasons for these condemnations? 5. Are there any additional tests (e.g. serology, faecal analysis) designed to control specific pathogens at pre-harvest level, provided by national or regional programs that can orientate inspection for a) sheep, b) goats? Supporting publications 2012:EN-373 8

9 6. Are there any additional controls apart from those set out in EU Regulations (EC) No. 852/2004 and (EC) No. 853/2004? 7. What traceability systems are in place? Are there any differences between adults and young lambs and goats? 8. The safety of food is ultimately the responsibility of the food business operator as per Regulation 178/2002. Do industry/slaughterhouses carry out monitoring of bacterial hazards outside of the requirements of Regulation 2073/2005? What measures would industry propose to deal with non-visible risks present on sheep carcasses? 9. How would industry improve the present system of transfer of food chain information between the farm and the slaughterhouse, and back? What system is/could be put in place to send relevant ante/post mortem findings to the farm? 10. Is the categorisation of animal in terms of risk for specific food-borne hazards an approach that industry would support? What criteria does industry think should be used to categorise holdings and animals? 11. How effective does industry think Good Manufacturing Practices, Good Hygiene Practices and HACCP are at achieving process hygiene targets? Should set targets to be achieved on chilled carcasses be adopted to ensure hygiene targets are reached? How could these targets be monitored at food business operator or at official level? What is the industry s opinion on surface decontamination of carcasses as a risk reduction step? 12. Does the industry view ante mortem inspection of animals as important? If so, how could such ante mortem inspection be enhanced to the benefit of public health? 13. Can an estimate be provided on the extent of abuse of illicit substances in small ruminants in the EU? 14. What is the specific training provided to meat inspection personnel for identification of animals potentially treated with illicit substances? 15. With regard to chemical sampling procedures, how are targeted samples chosen (i.e. what criteria are used to ensure that samples selected for testing are targeted rather than random )? 16. Is there a functional reporting system between results of feed analyses and sampling of slaughter animals? 17. To what extent are there precise systems for identifying and quantifying the usage of veterinary medicinal products (VMPs) in small ruminants? Given the many initiatives to monitor all details of the use of antibiotics amongst Member States, why are these efforts not extended to cover all VMPs? C. Can you provide slaughtering figures for sheep and goats in EU Member States 1. (i) at the abattoir and (ii) slaughtered on the farm of origin? 2. Lambs/kids vs adult sheep and goats? Supporting publications 2012:EN-373 9

10 B. ADDITIONAL INFORMATION PROVIDED BY COPA-COGECA O(12)1405:2 WORKING DOCUMENT Meat inspection of small ruminants Technical hearing with stakeholders: - Preliminary responses to the EFSA questions - Meat inspection process 1. Food chain information (FCI): current use of FCI and ways to improve it Farmers ensure the health and welfare of the animals on their farm, and they are responsible for the control of potential sources of contamination relating to their animals or activities under their control. Information flows need to be optimised throughout the food chain in both directions (from the farmer to the slaughterhouse and vice versa). The information received by farmers needs to be improved. Meat inspection is part of an advanced detection system to detect animal diseases that might not be detectable early enough at farm level (particularly infectious diseases with long incubation periods). Farmers must therefore be informed in good time of the health status of their herds so that they are in a position to prevent or better control the spread of diseases. Copa-Cogeca would be in favour of using more of the information already available at farm level in the new meat inspection system. The availability of voluntary quality systems at farm level should be investigated further. This should not, however, lead to any additional cost for farmers. Clear and appropriate rules should be established regarding the exchange of information. We do not believe it would be feasible to apply the HACCP system to primary production. 2. Are there any additional tests (e.g. serology, faecal analysis) designed to control specific pathogens pre-slaughter, provided by national or regional programmes that can orientate inspection for a) sheep, b) goats? We do not have sufficient evidence at EU level. However, there might be provisions in some national or regional surveillance programmes with regards to pathogens like brucellosis, salmonellosis, etc. 3. Are there any additional controls apart from those set out in EU Regulations (EC) No 852/2004 and (EC) No 853/2004? 4. What traceability systems are in place? Are there any differences between adults and young lambs and goats? Regulation 21/2004 is applied to all animals. Animals to be slaughtered before the age of 12 months which are neither to be sold within the EU nor to be exported can be identified in batches (batch system). 5. The safety of food is ultimately the responsibility of the food business operator as per Regulation 178/2002. Do the industry/slaughterhouses carry out monitoring of bacterial hazards outside of the requirements of Regulation 2073/2005? What measures would the industry propose to deal with non-visible risks present on sheep carcases? Regulation 2073/2005 allows a monitoring of the hygiene in the slaughterhouse. Supporting publications 2012:EN

11 6. How would the industry improve the present system for transferring food chain information between the farm and the slaughterhouse and vice versa? What system is/could be put in place to send relevant ante/post mortem findings to the farm? See response to question 1 (Information on the food chain). 7. Is the categorisation of animals in terms of risk for specific food-borne hazards an approach that the industry would support? What criteria does the industry think should be used to categorise holdings and animals? At farm level as operators in the agri-food sector farmers are fully responsible for the health and welfare of the animals on their farm, as well as for the control of potential sources of contamination relating to their animals or activities under their control. Zoonotic pathogens should be controlled first and foremost through hygiene measures in slaughterhouses (particularly protecting carcases from faecal contamination). However, it is important for there to be a certain amount of flexibility in the implementation of EU hygiene requirements regarding meat inspections (use, if necessary, of the results of serological tests based on risk analysis to establish the health status of the herd). The European animal production sector varies greatly from one Member State to another. There are many farms of different sizes using different production systems, some of them situated in remote areas and other facing different environmental conditions. Standardised rules should therefore be avoided and it is important to focus on the objective, namely producing safe foodstuffs from healthy animals. Copa-Cogeca believes that controls could be adopted that take into account the differences between small and large farms. 8. How effective does the industry think Good Manufacturing Practices, Good Hygiene Practices and HACCP are at achieving process hygiene targets? Should 'set targets to be achieved on chilled carcasses' be adopted to ensure hygiene targets are reached? How could these targets be monitored at food business operator or at official level? What is the industry's opinion on surface decontamination of carcasses as a risk reduction step? HACCP seems to be very effective in achieving hygiene targets. Regulation 2073/2005 already refers to chilled carcasses. However, it is considered not to be feasible to apply the HACCP system to primary production. 9. Does the industry view the ante-mortem inspection of animals as important? If so, how could such ante-mortem inspections be enhanced to the benefit of public health? Ante-mortem inspections are of considerable importance. Nevertheless, Copa-Cogeca is NOT in favour of expanding ante-mortem inspections carried out by officials or authorised veterinarians on the farm of origin. The health and welfare of animals also depend on transport conditions. The slaughterhouse remains the most appropriate place to carry out ante-mortem inspections. Slaughtering process: Please describe from the time of arrival of the animals to the dispatch of the final product for sheep and goats. 1. Are there significant differences in this process between Member States? There are various slaughtering processes for sheep and goats. However, the processes used do not necessarily differ by Member State, but depending on the technology available at the slaughterhouse and the slaughter rate. Supporting publications 2012:EN

12 The differences between the processes used relate predominantly to the following: The way animals are restrained at the time of slaughter (for example restrainer, rotating slaughter box, individual slaughter box) Stunning (for example "3 point" anaesthesia, also called "head and back" or "head and legs"; "2 point" anaesthesia, also known as "head only") Pre-skinning (suspension by four legs, conveyor, suspension by hind legs, "inflation" of kids) Skinning 2. Are there different slaughtering procedures for young lambs and goats? There is no difference in the slaughtering procedures between young lambs and goats. For goats and milk fed lambs pre-skinning and skinning are conducted entirely manually as the skinning machines used for other types of sheep or for adult goats would tear up such small carcases. In some Member States, the slaughter of kids is often carried out in specialised slaughterhouses which often also slaughter poultry. a. Is there an increased risk during the dressing of carcasses if a single operator does everything? The dressing of carcases of lamb or adult goats is consistently carried out by several operators, each of whom conducts part of the operation. For milk-fed lambs or kids, given the small size of the carcases, all operations on one carcase could potentially be carried out by a single operator with several operators working in parallel, each on a different carcase. However, there is no robust scientific evidence available to indicate that if all dressing operations were carried out by the same person, there could be increased microbiological risks. Dressing operations are key to the microbiological quality of the end product, as the skin and fur are one of the main sources of carcase contamination. As operators work within strict hygiene standards (change and sterilisation of knives at least between each carcase, washing hands, aprons and cradles, etc.) there is no reason to believe that dressing carried out by a single operator would introduce any additional risk. b. Seasonal slaughtering: could this lead to potential problems with hygiene due to the lack of experience/training of seasonal workers? The key operations that pose the greatest threat of microbiological contamination of the end product are dressing and evisceration. These are highly technical operations which require a prior qualification and as such would preferably only be assigned to experienced operators, not only for hygiene reasons but also in the interests of the productivity of the slaughter line, which is particularly important in the high season. Generally, seasonal workers have either worked at the slaughterhouse regularly for a number of years during busy periods, in which case they have had the opportunity to be trained and gain enough experience to carry out dressing or evisceration operations without compromising the productivity of the slaughter line, or they are occasional workers who are normally limited to operations that do not require a great deal of technical ability and would not risk compromising the productivity of the line (sheepfolds, operating semi-automatic machines, etc.). 3. Is there any information about the homogeneity of the batches of animals arriving at the slaughterhouse: same farm, same herd or mix of animals from different herds? Can you Supporting publications 2012:EN

13 provide approximate figures for the proportion of animals that arrive at the slaughterhouse from: We do not have any figures available. 4. What is the percentage of animals undergoing ritual slaughter without stunning? We do not have figures for the whole of the EU. Nonetheless, of all the animals slaughtered in France in 2010, the percentage of "ritual" slaughters was 26% (13% for calves, 12% for adult cattle and 42% for sheep and goats). In the UK, 100% of animals and birds for "kosher" meat production and 25% of cattle and 7% of sheep for "halal" meat production were slaughtered without stunning. 5. Hygiene criteria: Operators in the food sector are asked to describe their hygiene management system in their health management plan, detailing good hygiene practice, risk assessments and control methods they have established. In terms of verification of the hygiene management systems in place, they are required to use, among other verification methods, micro-organism analysis to indicate the hygiene standards of their processes. For certain products and stages, such as carcases at the slaughter stage, these indicators of the microbiological hygiene of processes are broadly defined in Regulation (EC) No 2073/2005. For others, such as the cutting of meat and offal, the regulation does not define any criteria. a. Current use The slaughterhouses have carried out the tests according to the European regulation. b. Ways to improve In terms of the practicalities of tests, the improvements that would be desirable greatly depend on slaughter structures and the training received by the operator responsible for the operation. Furthermore, many structures still have to face the interpretation, over time, of the results of tests carried out and, as a result, the corrective steps that may potentially be required in the event of abnormalities. It is important to remember that the FAM criterion in Regulation 2073/2005 (regarding freshly slaughtered carcases) carries a penalty. 6. Describe the Hazard Analysis and Critical Control Points (HACCP) plan in place at the slaughterhouse. Like all agri-food sectors, sheep slaughter and cutting operators are encouraged by Regulation (EC) No 852/2004 to create and submit to their supervising authority Guides to Good Hygiene Practice and applying the HACCP principles (GGHP) aimed at risks specific to slaughterhouses. 7. What kind of hygiene problems are encountered during slaughtering at sheep and goat slaughterhouses? Skinning hygiene seems to be the most problematic aspect for sheep as it requires several human interventions during which the carcase can be contaminated by the operators' hands (the "pushing" operation remains inevitable), other material or the skin itself. Evisceration hygiene must also be taken into account in order to avoid so-called "evisceration accident" carcases. Can you provide slaughtering figures for sheep and goats in EU Member States? 1. (i) at the slaughterhouse and (ii) slaughtered on the farm of origin? 2. Lambs/kids vs. adult sheep and goats? Supporting publications 2012:EN

14 Sheep meat: Herd, production and consumption of sheep meat in the EU in 2010: Technical hearing on meat inspection of small ruminants Supporting publications 2012:EN

15 Goat meat: Herd and goat products in the main European countries: Technical hearing on meat inspection of small ruminants Source: Institut de l Elevage (France) Supporting publications 2012:EN

16 Summary of the presentation from Copa-Cogeca Meat inspection of small ruminants Outline Copa-Cogeca s views on the current revision of the meat inspection Food chain information Slaughtering process Copa-Cogeca s views on the current revision of the meat inspection In favour of a risk based meat inspection system Revision should: guarantee constantly high standards of food safety and sustainability in order to increase consumers confidence in the safety and quality of EU food products Improve a better use of available resources and information is needed and further costs at farm level must also be avoided. Holistic approach (stable to table): animal health, animal welfare and food safety (public health) Meat inspection process Food chain information (FCI) Current situation 1. Farmers ensure the health and welfare of the animals on their farm 2. Farmers are responsible for the control of potential sources of contamination relating to their animals or activities under their control. 3. Need for optimizing the information flow throughout the food chain in both directions (from the farmer to the slaughterhouse and vice versa) 4. Need for improving the information received by farmers (prevent or better control the spread of diseases is also an objective of the new EU Community Animal Health Strategy) Meat inspection process - Food chain information (FCI) 2 Ways to improve it? 1. Using more of the information already available at farm level in the new meat inspection system. 2. The availability of voluntary quality systems at farm level should be investigated further. No additional cost for farmers. 3. Clear and appropriate rules should be established regarding the exchange of information. 4. Certain amount of flexibility in the implementation of EU hygiene requirements regarding meat inspections is needed 5. Not feasible to apply the HACCP system to primary production Supporting publications 2012:EN

17 Meat inspection process - Food chain information (FCI) 3 Ante-mortem inspection 1. It is of considerable importance Technical hearing on meat inspection of small ruminants 2. Copa-Cogeca is NOT in favour of expanding ante-mortem inspections carried out by officials or authorised veterinarians on the farm of origin 3. The health and welfare of animals also depend on transport conditions 4. The slaughterhouse remains the most appropriate place to carry out ante mortem inspections Slaughtering process 1. Slaughtering processes for sheep and goats in EU differ according to the available technology (the way animals are restrained at the time of slaughter, stunned, pre-skinned and skinned) 2. No different slaughtering procedures for young lambs and goats 3. No robust scientific evidences available to indicate that if all dressing operations are carried out by the same person, there could be increased microbiological risks 4. Dressing and evisceration are usually performed by experienced operators Slaughtering process - 2 Seasonal workers: 1. are usually trained and have enough experience to carry out dressing or evisceration operations without compromising the productivity of the slaughter line, 2. are occasional workers who are normally limited to operations that do not require a great deal of technical ability and would not risk compromising the productivity of the line Slaughtering process sheep slaughter and cutting operators are encouraged by Regulation (EC) No 852/2004 to create and submit to their supervising authority Guides to Good Hygiene Practice and applying the HACCP principles (GGHP) aimed at risks specific to slaughterhouses 2. hygiene problems may be related to the skinning and evisceration hygiene Supporting publications 2012:EN

18 C. ADDITIONAL INFORMATION PROVIDED BY FVE EFSA technical hearing with stakeholders: questions A. Slaughterhouse process Technical hearing on meat inspection of small ruminants Please describe from the time of arrival of the animals to the dispatch of the final product for sheep and goats. The slaughterhouse process for small ruminants (sheep) is described graphically by the enclosed General Process Flow Diagram, (Annex 1). The process is followed from the lairage, to the lamb line, to the chills and eventually dispatch. 1. Are there significant differences in this process between Members States? 2. Are there different slaughtering procedures for young lambs and goats? The slaughter process is essentially the same for both adult sheep and young lambs and goats. a. Is there an increased risk during dressing of carcasses if single operator does everything? Yes, there are significant risks that need to be considered and managed if a single operator does everything. In larger slaughtering plants, operatives, in addition to being trained in general hygiene and core disciplines, are also trained to specific standard operating procedures (SOPs) relevant to the part of the process they work. They become very efficient at carrying out these SOPs, often at a high line speed. However the single operator, in addition to being trained in general hygiene principles, must train and become competent in many diverse SOPs. Furthermore the slaughtering process will necessitate that single operator maintains hygiene principles between tasks, for instance moving from de-hiding, to evisceration, to trimming etc. Such an individual operator may need to clean properly between the various SOPs during the slaughter process. These issues are normally addressed by the individual HACCP & GMP programs for the small plants. Therefore the training of operators for these plants would have a different emphasis to deal with that particular process and diverse risks individual to that plant. The matter is usually addressed by appropriate risk based training depending on whether they are part of a large team of butchers in a large plant or work as individuals in a small plant. b. Seasonal slaughtering: could it lead to potential problems with hygiene due to lack of experience/training of seasonal workers? Seasonal slaughtering is common in Ireland where spring born lambs are reared on grass based systems with a high percentage of sheep slaughtered from mid summer to autumn. In addition some late born lambs, mountain type breeds (slower growing) and cull ewes are slaughtered in the autumn and winter, ensuring that the slaughter facilities are used all year round. The food safety management system ensures that training and standards are maintained, regardless of the time of year. The following solutions are used; Butchers work five days per week during the busy summer and autumn, but revert to working three days per week in the winter (allowing skills to be maintained). When the slaughterhouse is at full capacity less skilled seasonal workers go through standard induction training, and are often allocated to easier tasks, such as floor cleaning and packing, whereas the more experienced butchers carry out the more difficult tasks. Supporting publications 2012:EN

19 In any case the food safety management system of the sheep factory (HACCP + GMP) identify and anticipate these risks, and others including holidays & sickness, weather changes, price flux, and seasonality, and manage them appropriately. In essence the core staff remains steady throughout the year. 3. Is there any information about the homogeneity of the batches of animals arriving at the slaughterhouse same farm, same herd, or mix of animals from different herds? Can you provide approximated figures for the proportion of animals that arrive at the abattoir: Directly from a single farm: 30% of lambs /sheep come directly from farm increasing to 60% during the peak summer and autumn months as lambs become fit for slaughter. From several farms e.g. a lorry collecting sheep at different farms; 40% are collected by lorries from various centres around the country. The excellent motorway network ensures relatively quick and smooth journey to the processing plants. From a market as uniform batch (i.e. all animals from the same farm): 10%. From a market as mixed batch: (30% rising to 50% in the summer) In Ireland it is common for farmers to bring their groups of lambs/sheep to the market or mart where procurement officers from the slaughterhouse may buy them and transport them to the slaughterhouse. 4. What is the percentage of animals undergoing ritual slaughter without stunning? The number of animals undergoing ritual slaughter is variable depending on market requirements and seasonality. 5. Process hygiene criteria What kind of hygiene problems are encountered during slaughtering at sheep and goats abattoirs? a. Actual use The process hygiene criteria are defined as part of the plant food safety management systems (HACCP plan and pre-requisite; in particular prerequisites such as Cleaning and Sanitation, Personal Hygiene & Training, Management of incidents, Protective clothing and Staff hygiene facilities). b. Ways to improve it The substantial challenge for the plant is to source sheep with a very clean score for fleece cleanliness. This can be particularly challenging during periods of poor and wet weather or during the winter, especially when sheep are housed for fattening. Staff are aware of the need to use the carrot approach where they provide education to farmers via flock health road shows, newsletters and delivering constant messages to their farmer suppliers as to the standards required. Financial incentives for clean sheep have been used to a limited degree. The stick approach has been used where sheep are rejected because of fleece faecal contamination. This is a very powerful tool. 6. Describe the Hazard Analysis and Critical control Points (HACCP) plan in place at the abattoir The food safety management plan at the plant is based on a solid foundation of pre-requisites (GMP). The HACCP team have the constructed the process flows and considered the biological, chemical, and physical risks at each step of the process flow. Such risks identified are managed either by the appropriate pre-requisite or by critical control points. Supporting publications 2012:EN

20 The HACCP plan is reviewed regularly and in doing so over the years the number of CCPs has been reduced to reflect the development of robust pre-requisites. Internal and external (BRC) review and audit has ensured that the HACCP plan is a live process ensuring consistent standards in food safety excellence. Because the plant exports 90% of their product, they use their excellent food safety management systems as a marketing tool and often seek to attain standards higher than the regulatory requirement. The HACCP pre-requisites (GMP) are regularly updated and audited (internally and externally) to BRC standards. These systems recognise that one of the greatest food challenges is the presentation of soiled sheep and risk faecal contamination especially after a period of inclement weather or if the sheep have been housed prior to slaughter. The Plant attempts to reduce this risk in particular via regulation (classification of cleanliness on arrival 1-3 where 1= clean and 3= very dirty).the FBO takes appropriate action depending on the classification at ante mortem. In addition education via regular and constant messages is delivered to farm suppliers and agents as to the need for clean lambs at slaughter. B. Meat inspection process 1. Food chain Information (FCI) Actual use of the FCI The Department of Agriculture, Food and the Marine (DAFM), under its Service Contract with the Food Safety Authority to deliver the requirements of Regulation EC 854/2004, is obliged to feed back certain non-statutory information regarding animal disease to the primary producers. Veterinary Ireland (VI) the organisation representing Veterinary Practitioners in Ireland and all the major stakeholders (Irish Farmers Association, Meat Inspection Ireland, Animal Health Ireland, DAFM) are determined to have this requirement fulfilled. Regulation (EC) No 854/2004, Annex I, Section II, Chapter I SECTION II: ACTION FOLLOWING CONTROLS CHAPTER I: COMMUNICATION OF INSPECTION RESULTS 1. The official veterinarian is to record and to evaluate the results of inspection activities. 2. (a) If inspections reveal the presence of any disease or condition that might affect public or animal health, or compromise animal welfare, the official veterinarian is to inform the food business operator. (b) When the problem identified arose during primary production, the official veterinarian is to inform the veterinarian attending the holding of provenance, the food business operator responsible for the holding of provenance (provided that such information would not prejudice subsequent legal proceedings) and, where appropriate, the competent authority responsible for supervising the holding of provenance or the hunting area. (c) If the animals concerned were raised in another Member State or in a third country, the official veterinarian is to inform to the competent authority of the Member State where the establishment is located. That competent authority is to take appropriate measures in accordance with applicable Community legislation. The situation at present involves self declaration by the farmer who signs the FCI declaration as part of the sheep dispatch movement document. Several FCI statements are made including that: 1) Animals are clean 2) Appropriately tagged Supporting publications 2012:EN

21 3) The farm of origin is not under disease restriction 4) The sheep are healthy 5) Medicinal withdrawal periods have been observed. Technical hearing on meat inspection of small ruminants 6) All animals can walk unaided and are transported without injury or under suffering. If any of the above cannot be signed off by the farmer further FCI explanatory notes are needed. The slaughter plant representative (FBO) checks that the FCI is correct. Furthermore the official veterinarian (OV) declares that he/she is satisfied that the FBO has reviewed and checked the FCI and further certifies ante mortem has been carried out. Self declaration and FCI prompts the farmer to consider key disease processes on farm, to interrogate the withdrawal period issues that may be relevant and to anticipate any transport welfare issues prior to movement to the slaughter house. The FCI has a number of limitations. 1) FCI is essentially a self declaration process. 2) The information flows only in one direction whereas there is huge potential to feed back very useful ante and post mortem information. CAN THE CURRENT SYSTEM BE IMPROVED? Ways to improve it? Currently FCI is essentially a farmer self declaration The Veterinary Practitioner with responsibility for animal health of the holding should have a role in FCI thereby improving the credibility of the flow of information to the abattoir. There also needs to be an audit system in place carried out by the Competent Authority. Factory floors are the biggest post mortem rooms in the country. There are many diseases that can be detected at slaughter. Temporary veterinary inspectors (TVIs- generally they are private veterinary practitioners who work at slaughterhouses for approx. 3 hrs per day carrying out ante and post mortem inspection tasks), are committed to documenting the economically significant production diseases, and report these back to the farmer (primary producer) thus improving the health of the national herd. This is one of the stated goals of Animal Health Ireland and it shows how much more could be gained from the current TVI system, at little or no extra cost apart from a small technology investment. Opportunities for Food Chain Information Healthy Flocks... Healthy Food Food Chain Information (FCI) is an integral part of the Hygiene Package, and allows post mortem findings to be gathered at the point of slaughter and subsequently passed up and down the food chain, not only to assure and provide confidence to the consumer and markets but also to provide critical disease prevention information to the farmer, allowing him/her to make informed decisions for the benefit of flock health. Liver fluke Many farms are challenged with fluke especially during wet years when conditions are ideal for the intermediate host, the mud snail. Clinical manifestations include ill thrift, diarrhoea, and sudden death. Often the farmer is working in a knowledge vacuum, where on one hand under dosing may lead to severe clinical signs or on the other hand overdosing may lead to expensive medicines used inappropriately even prompting development of antihelmintic resistance. Every liver is examined by a vet and there exists the opportunity to provide real-time feedback as to the fluke status of lambs or cull ewes at various times of the year. The farmer can strategically design Supporting publications 2012:EN

22 his fluke program considering such issues as immature/maturity or flukacide resistance or indeed meat withdrawal periods for medicines that may be used. FCI and fluke information feedback would reduce the amount of flukacides used and ensure they are only used when needed. Damaged Liver Parenchyma at Slaughter Lamb Sector: Industry Average Lowest Highest Liver Yield/Head (kg) Edible Liver 59.50% 38.80% 75.80% Condemned Liver (Cat 3) 40.50% 24.20% 61.20% There are currently approximately 2.2 million breeding ewes in Ireland producing approximately 3.1m lambs for slaughter. A lamb s liver weighs approximately 0.62kg and its value is approximately 1 per kilo. The total value of lamb livers is 1.92m. The current value of salvageable lamb livers is only 1.14m so there is a potential improvement in lamb liver value of 0.78m. Supporting publications 2012:EN

23 A far more significant loss from fluke infestation in lambs is the loss in hide value due to poorer quality as a result of fluke infestation. Meat industry Ireland figures attribute a value of 9 on a lamb fleece. If 10% of 3.1m (310,000) fleeces are downgraded to 2 due to fluke infestation then this puts a value of 2.17m on the loss. Severe fluke infestation leads to poorer carcasses at slaughter. This loss is an unquantifiable figure, even by industry. Lung pathology/pneumonia Sheep farmers, especially those who house sheep often report sudden death or ill-thrift and coughing. Lung pathology is readily identifiable during the slaughter process and reporting of this to the farmer and his vet would allow them to consider a differential diagnosis, whether Pasteurella, viral, or indeed lungworm causes. Preventative strategies can then be put into place. Other diseases Occasionally hydronephrotic kidneys (caused by too much magnesium in the ram lambs diet), is a post mortem finding. The urethra becomes blocked with magnesium crystals causing a damming back of urine in the kidney. This usually happens when ram lambs access ewe meal fortified with magnesium for tetany prevention. Post mortem feedback on this condition will save lives as prevention is easy! Arthritis/Polyarthritis When joints are inflamed or infected, this can lead to partial or total condemnation of the lamb or ewe. Feedback would allow the farmer and vet review the causal factors, including hygiene in the lambing shed, where joint infections often begin. The farmer often reports ill-thrift in these lambs. Abscessation at injection sites It is not uncommon to find subcutaneous abscesses subsequent to vaccination programs. Extensive trimming is then often necessary in many lambs in the affected batch resulting in a poorer quality carcass with loss to the factory and the farmer. Feedback from the factory floor to the farmer would allow a review of injection technique and equipment, and prevent such blemishes on the carcasses from happening again. Miscellaneous conditions, such as excessive lameness, eye pathology and excessive faecal contamination of the sheep can be reported back to the farmer both from ante mortem and post mortem examination to allow preventative strategies be put in place on farm. Worms and coccidia opportunities for feedback? These conditions are normally not visible at gross post mortem yet their control is critical to productive sheep farming. A faecal sampling service on request could allow simple laboratory identification of these parasites. This information is critical to managing a sheep farm efficiently. There is precedence within the agri-food industry for feedback of information at harvest or slaughter. For instance bulk milk testing for antibiotics and pathogens is very common in the dairy industry. For instance the Glanbia bulk milk testing program examines for fluke/worms/leptospirosis/johnes disease and BVD. The farmer and his advisors use this information as an early warning for disease and indeed as a monitor for existing control programmes. Furthermore this information is used further down the food chain to assure the customer and markets of disease prevention and control strategies. Similarly, beef plants are providing parasite feedback to their farmer suppliers. Animal Health Ireland provides excellent supportive information on how the vet and farmer can manage these parasitic diseases. This ensures a consistent scientific message throughout the industry. Supporting publications 2012:EN