The Pennington Group

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.

ANNEX V
(Para 7.11 refers)

SUMMARY OF MLC SURVEY AND REPORT, FEBRUARY 1997

1. The MLC undertook a survey of 200 butchers' businesses in Scotland (and 400 in England and Wales) between 20-31 January 1997. The Scottish sample comprised around 20% of butchers handling cooked meat and meat products.

2. The sample was categorised as follows:-

Category		Total No of Butchers in Scotland	Sample in Survey
A	Butchers that manufacture, wholesale and retail cooked meat and meat products	183	30
B	Manufacture a wide range of cooked meat products for sale on their own premises	130	25
C	Manufacture a limited range of cooked meat products for sale on premises	357	65
D	Buying in extensive range of cooked meat products for resale	118	20
E	Buying in limited range of cooked meat products for resale	247	60
	Others - do not sell cooked meat products	182	Not included in survey
	TOTAL	1,217	200

The survey data obtained from England and Wales show no significant differences.

4. The estimated capital costs of compliance in Scotland with the Pennington Group recommendations on physical separation are as follows:-

	Average capital cost of compliance per business for each category (ü'000)
	A	B	C	D	E
Additional equipment	20.0	15.0	9.5	9.0	6.0
Other costs including structural changes	16.5	9.0	10.0	6.0	3.5
Total	36.5	24.0	19.5	15.0	9.5

Grossing up these capital costs on a total Scottish butcher basis amounts to approximately ü21M. In addition to the capital cost above, additional staff would be required as indicated in the survey. On the assumption that the average employment cost is ü15K per annum per person, additional butcher revenue costs in Scotland of ü20M per annum would result.

5. The considerations that the MLC identify as following from the survey are:-

a. The objectives of the Pennington Group under review are supported.

b. Severe measures need to be taken to ensure the control of this particularly virulent bacterium [E.coli O157] which has fundamentally changed the acceptability of continuing to use traditional procedures.

c. The nature of this organism dictates that reducing the incidence of this organism on meat before it reaches the retailer is an important component step in control. This should be followed by thermal kill of the organism and avoidance of downstream contamination. These provide critical control points essential to assure food safety.

d. Adequate separation of raw meat from cooked meat and meat products is essential to avoid cross contamination of the latter. This can only be achieved acceptably by dedicated spatial separation throughout the manufacture and storage chain, and by rigid adherence to appropriate procedures at the point of retail sale.

e. Additional regulatory measures may be necessary to ensure effective enforcement control of hygiene practices. This may lead to selective licensing although this will not necessarily achieve more than the existing system similarly enhanced. Much of the Pennington Group objectives is achievable through non-regulatory modification of existing codes, but existing procedures will require attention to ensure enforceability.

f. Limited measures such as those being considered will not alone ensure food safety. The infective dose of the organism is so low that every opportunity should be taken to reduce exposure to it throughout the production chain. This demands actions throughout the livestock and meat supply chain so that any failure at one stage does not increase the risk to unacceptable levels. Concentrating entirely on retail butchery premises leaves substantial gaps in the overall protection of consumers from this organism.

6. MLC conclude that focus on specific critical control points and further training in the retail sector is essential to ensure food safety for this organism. However, to achieve fully effective consumer protection the prevalence of the micro-organism across the whole food chain must be reduced. Any system which only tackles the problem at the retail level will, in their opinion, not mitigate the risk adequately. Further action is required in other upstream sectors of the industry chain to reduce the prevalence of the microbe. If this can be achieved it would then be possible to make the requisite contribution at the retail level via either of the methods of enforcement examined.