 |
 |
 |
 |
|
|
|
|
| Report on the circumstances leading to the 1996 outbreak of infection with E.coli 0157 in Central Scotland, the implications for food safety and the lessons to be learned. |
| Chapter 6 Practices and Hygiene in Slaughterhouses |
| 6.1 Slaughterhouses represent the second critical point in the food production process. It may not be possible, for a number of reasons, for a particular slaughterhouse - or indeed a failure of process within a slaughterhouse - to be directly implicated in an outbreak. Nonetheless, the issue was raised with us by a number of those from whom we took evidence. Undoubtedly, meat contaminated with E.coli O157 is entering butchers' premises. That does not, in our view, absolve butchers from any responsibility, but it does imply the need to look further back in the food chain when considering how to deal with the organism. |
| Background |
| 6.2 While Agriculture Departments are responsible for licensing slaughter houses under the Fresh Meat (Hygiene and Inspection) Regulations 1995 as amended, responsibility for food safety in such premises rests with the operator. Enforcement is the responsibility of a Government agency, the Meat Hygiene Service (MHS), with the State Veterinary Service (SVS) providing an advisory and audit function. The MHS was set up in April 1995 and took over responsibility for this area of enforcement from the local authorities. Responsibility for enforcement on a day to day basis is exercised by the Official Veterinary Surgeon (OVS) assisted by meat inspectors. This area of food safety enforcement differs from other food sectors in that the OVS and meat inspector are generally present on a permanent basis while slaughtering is occurring. All meat leaving the slaughterhouse has to be approved by the OVS and health marked. |
| 6.3 The OVS and meat inspectors work alongside the companies' own workforce and have extensive powers and controls over operational and working practices. We were advised, and are satisfied in relation to the operation of slaughterhouses, that the regulatory framework is adequate. |
6.4 We
believe HACCP should apply to the slaughter process. In
this context, we learned of the Australian approach where
slaughterhouses have adopted HACCP in full and accept
their responsibility for food safety. These measures
appear to have largely eliminated the problem of faecal
contamination of carcasses. However, starting from a base
of high standards necessitated by the demands of export
markets, it has taken at least 5 years for Australia to
reach this position. As our interim report made clear,
there are a range of issues relating to our
slaughterhouses and the potential for cross-contamination
at various key stages in the slaughter process, which we
feel need to be tackled. These include:-
|
| The Presentation of Animals for Slaughter |
| 6.5 As identified in Chapter 5, animals must be presented for slaughter in an appropriate, clean condition and there must be a programme of education to ensure that farm workers understand the need for that and the standards to be achieved. |
| 6.6 This needs to be backed up by appropriate enforcement. It is not, currently, an offence to present dirty animals for slaughter nor, indeed, for dirty animals to be slaughtered. This is an area in which targeted regulations may provide one solution. However the practical difficulties - for example in differentiating between clean and dirty animals sufficiently objectively and robustly to stand up in court - need to be recognised. |
| 6.7 It is, however, an offence to slaughter dirty animals if their slaughter has been prohibited. A simpler approach therefore, which could be implemented much more quickly, would be to ensure the more rigorous application and enforcement of these prohibition powers by OVSs when inspecting animals prior to slaughter. One of the problems to date appears to have been a lack of consistency in approach by OVSs as to what standards are acceptable. The improved scoring system and photographic standards produced by the MHS should assist and need to be backed up by appropriate training and reinforcement of the importance of this issue. This should cover both enforcement staff and the trade. There clearly has to be a cultural change amongst slaughterhouse operators and their staff. OVSs should be afforded the comfort of the full support of Government departments and appropriate trade bodies for their enforcement activities. |
| 6.8 We were also advised, during our consideration of these matters, that there is a system in operation in the North East of Scotland whereby if the OVS rejects animals for slaughter at one abattoir, contact is made with nearby abattoirs to ensure they are not simply presented and accepted elsewhere. The shortage of animals for slaughter for human consumption, and financial pressures caused by overcapacity in the slaughter industry, may encourage such an approach and place pressure on OVSs to accept animals. There is a need for consistency and contact between OVSs. The North East system could be formalised and extended throughout the country. Proper consideration needs to be given in all of this, however, to animal welfare considerations. |
| 6.9 An obvious practical alternative to the outright rejection of animals would be to bring them up to an acceptable standard, through cleaning and clipping if necessary, at the slaughterhouse. Indeed, this may be necessary and desirable, particularly for welfare reasons, if animals have been in transit for some time. However, cleaning at the slaughterhouse may be impractical and would carry costs in terms of staff time and resources. It would be unfair for these to be borne by the slaughterhouse without recompense. It may discourage farmers and livestock markets from presenting dirty animals for slaughter if a financial penalty were to be imposed. A system of charging or differential pricing could be one solution to the problem. |
| 6.10 Unfortunately, however, this matter is not straightforward. It has also been suggested to us that cleaning at the abattoir may cause animals additional stress and that the use of wet cleaning processes could further spread infection. The primary objective therefore must be to have clean, dry animals presented for slaughter. |
| Removal of the Animal Hide and Intestines |
| 6.11 Even with clean animals, there is the likelihood of some faecal contamination of the hide and, therefore, the possibility of cross-contamination of carcasses. Care, and training, is needed to minimise the risks associated with that situation. It also seems that some methods of hide removal are inherently safer and more hygienic than others. This was considered to be a critical control point within the abattoir. We therefore see it as absolutely essential to identify and promote good practice in this area. |
| 6.12 Some other, relatively simple measures could be taken to help reduce the possibility of cross-contamination from hides. This includes, for example, allowing adequate space between carcasses hung on conveyer systems to ensure that there is no contact between them - in particular, between those that have had their hides removed and those still to be skinned. Conveyor systems should be designed so as to avoid carcase contact with walls and floors. Notwithstanding commercial considerations and the implications of, for example, piece rates of payment for workers, the speed of the production process within abattoirs needs to be controlled so as to permit the achievement of adequate food safety standards and the OVS must if necessary enforce these standards. Storage of dressed carcasses should also allow adequate space between carcasses. The trade must embrace these sorts of measures and they need to be enforced. |
| 6.13 The process of removing the intestines of animals during slaughter is a further critical stage at which there is significant potential for contamination from the leakage of faecal matter. There are a number of processes and techniques - eg the bagging of the anus and oesophageal sealing - which are designed to help avoid that. We do not wish to take a prescriptive approach to that, but again we conclude that there is scope and a vital need for the identification and promotion of good practice as a means towards safer meat production. The training of abattoir workers and enforcement of hygiene standards at this stage are also crucial to the minimisation of contamination and cross-contamination. |
| End-Process Treatments |
| 6.14 EU legislation does not generally permit them, but there are a number of processes or treatments available - whether during the slaughter process or later in the food chain - to help reduce contamination and produce safer meat. These include, for example, hosing down carcasses, steam pasteurisation or irradiation. |
| 6.15 We do not consider that hosing down carcasses with water (or at least cold, untreated water) to remove faecal material is likely to be beneficial in preventing contamination with E.coli O157 because of the very few organisms required to form an infective dose. Indeed, it has been suggested to us that there could be dangers in that hosing down could simply spread the organism by aerosol, thereby causing wider contamination. In any event, regulations require carcasses to be trimmed and prohibit washing prior to inspection. |
| 6.16 Other processes, such as steam pasteurisation, could perhaps be beneficial in helping to prevent contamination with the organism. However, the issues surrounding such treatments of carcasses are not straightforward. The efficacy of the treatments are unknown and the effects on surface microflora not understood. Treatments may present potential residue problems and/or have a detrimental effect on the characteristics and taste of the meat, whilst not providing a sufficient safeguard to public health. |
| 6.17 On the question of irradiation in particular, we were made aware of the bid for the authorisation and control of the irradiation of red meat currently being considered by the US Food and Drug Administration; and we reviewed information and a number of papers relating to irradiation. Currently in the UK, the use of irradiation equipment requires a licence and irradiated food needs to be labelled accordingly. Nevertheless, our general conclusion was that, because of the potential harmful effects of irradiation on the quality of meat and the uncertainties and concerns about the possible long term effects of ingestion of irradiated foods, there is likely to be very substantial consumer resistance to it. The very high cost of equipment to permit irradiation is likely to be prohibitive for the vast majority of producers. Taken together, these factors probably make irradiation an impractical proposition, at least for all but the very largest operators. |
| 6.18 In summary, we think that there could be benefits in the treatment of carcasses or meat at appropriate stages, including during the slaughter process, as a means of reducing contamination and improving food safety. Further work needs to be done on the efficacy and acceptability of the various alternative methods available. We accept that, ultimately, the introduction of some measures would need to be negotiated through the EU. |
| Transportation |
| 6.19 A number of commentators brought to our attention alleged deficient, or indeed illegal, practices in the transportation of meat from slaughter houses to other premises. We are quite clear that HACCP principles and the need for the highest hygiene standards should apply to the transportation of carcasses and meat. It is pointless promoting hygiene within abattoirs and butchers if meat is permitted to become cross-contaminated during transportation to or from cutting plants or butchers. It is vitally important that, for example, unwrapped meat should be prevented from touching the sides or floors of transport vehicles during loading, carriage and unloading. HACCP principles need to be understood by transport interests and should be reflected in regulations and subsequent enforcement, in this area. |
| 6.20 Responsibility for enforcement of hygiene standards in transportation between licensed premises (ie between abattoirs and cutting plants) lies with the MHS. However, the MHS has no legal responsibility or control over the transportation of meat and carcasses to non-licensed premises such as butcher shops. As loading at the abattoir and cutting premises is a common, easily controlled inspection point for vehicles, we believe that the MHS should be given powers to enforce standards at this point for any vehicle loading or unloading. |
| General Hygiene Standards in Abattoirs and Enforcement Issues |
| 6.21 Responsibility for enforcing hygiene standards in slaughter houses rests with the MHS. Abattoirs are inspected and assessed through Hygiene Assessment Scores (HAS). The position on general standards in abattoirs across Scotland is mixed (as it appears to be in other parts of the UK). |
| 6.22 We are clear that the MHS is acutely aware of the need for high standards to be achieved and maintained in all abattoirs. It is taking steps actively to tackle the issue and has come forward with its own proposals and recommendations - which will reinforce those set out in this report. We would want every support and encouragement to be given to the MHS in its efforts to raise overall standards in abattoirs; and we suggest that, as for broader enforcement activity, there should be resource targeting on poor performers and rigorous encouragement and enforcement of the standards to be achieved. |
| Recommendations |
| 6.23 In
light of all of the above, we recommend in relation to
practices and hygiene in slaughterhouses that:- a. the Meat Hygiene Service should urgently implement its scoring system for clean/dirty animals, should ensure that official veterinary surgeons and the trade are educated and trained in its use, and should pursue consistent and rigorous enforcement; b. the MHS must take forward urgently, with the help and support of Government departments and the industry, the identification and promotion of good practice in slaughterhouses - including specifically in the areas of hide and intestine removal; c. abattoir workers should be trained in good hygiene practice during slaughter and the MHS should concentrate enforcement on slaughter and subsequent handling of carcasses; d. HACCP should be enshrined in the legislation governing slaughterhouses and the transportation of carcasses and meat. Meanwhile, enforcers and the industry should ensure that HACCP principles are observed; e. the MHS should be given additional powers to enforce at the abattoir standards for the transportation of meat and carcasses between licensed and non-licensed premises; f. further consideration should be given, involving the industry and consumer interests, to the potential use and benefits of end-process treatments such as steam pasteurisation; and g. in line with the approach recommended for more general enforcement, the efforts and resources of the MHS should be targeted at higher risk premises - especially those abattoirs with Hygiene Assessment Scores of under 65. |
|
|
|