As the great debate on full cost recovery rumbles on, phrases that have now become well and truly established by all commentators, on whichever side of the fence they sit, are that fresh meat regulations are disproportionate to the risk to public health, and that legal requirements should be amended to reflect actual risk.
Over the last twenty years or so, I’ve lost track of how many times this has been stated on this web-site, been quoted in our official responses to Government, featured in numerous consultations, and played the dominant part in REVIEW OF INSPECTION SERVICES, a pamphlet my company commissioned during the time of the Tierney review, and which was circulated widely within industry ( I can send anyone a copy if they contact me on e-mail; viewpoint@tobybaker.com.)
As stated several times on blog, it is the ultimate cost of running a business that decides viability, i.e. whether to carry on or not, but the nitty-gritty of the argument, and potential future success, lies in really getting to grips, and where necessary, going public, with the realities of meat inspection of fresh meat. Paying lip-service to this topic, which too many prominent spokesmen in the trade have done hitherto, is no longer satisfactory.
A comprehensive review of the enforcement roles of meat inspectors and veterinary surgeons was featured, in January 2009, under the technical section of our web-site, www.tobybaker.com. The article highlighted what meat inspectors and vets actually do, or to be more pertinent, what they don’t or can’t do. One conclusion drawn was that, despite all the fictional claims of importance expounded by their unions, meat inspectors do have a quality control part to play in post-mortem meat inspection, but that “it is quite clear that the role of vets in abattoirs must be investigated.”
So what is the nitty-gritty? What does disproportionate mean in this context? Quite simply, the analysis of health risks in slaughtering operations is incorrect, thus unnecessarily severe regulations (i.e. disproportionate) have resulted. This means in turn that excessive enforcement costs will be inevitable. And so here we are.
The current important debate about excessive costs will never be resolved until the apparent consensus on the “risk based and proportionate” question is brought to the forefront: because at present it is merely a misunderstood slogan that is not investigated and acted upon.
(1) Disease statistics and epidemiology must be considered when assessing risk. Compared with major health risks in the population fresh meat hazards must be considered as low risk. The animal herd carries a small, random but unknown incidence of pathogenic organisms. Abattoir processes cannot eliminate these invisible bacteria and therefore it is not possible to identify a critical control point. This means that raw fresh meat despatched from an abattoir carries the same level of pathogens as that of the livestock that entered in the first place.

(2) Fresh meat is a raw material, and further along the meat distribution chain there are processes that carry a greater risk to public health, e.g. restaurants or wholesale sandwich factories. All food businesses are responsible for supplying safe food, and enforcement of hygiene laws takes the form of periodic visits by local authority health officials. Abattoirs alone suffer the full time presence of veterinarians and meat inspectors, enforcing separate hygiene regulations which are more extensive and onerous than any other sector of the industry.
This enforcement model cannot be proportionate to the risks by any criterion.
FSA have been allowed to simply brush these vitally important points aside, and so far, it has been remiss of industry’s leading players to have virtually ignored these obvious facts.
That said, this Government Agency seems to be rattled by recent events, hence outbursts from two very senior officials. In what looks like a tactical move to incite and inflame, FSA Chairman, Lord Rooker, makes it clear that FSA has no intention of relenting saying “we don’t need the money but it is an issue of principle here.” Such a derogatory comment from such a man is really no surprise, but you do wonder – does he really know what’s going on?
Director of Operations at FSA, a Mr Andrew Rhodes, is equally as dismissive - “It is worth remembering that we talking about £30 million of additional charges in comparison with a meat industry with an annual turnover of £6billion.” £30 million. Oh, is that all, Mr Rhodes? With an industry on course for virtual decimation as things stand, such a flippant remark tells you something of the man and the ivory tower world he and his ilk live in. Vacuous statements such as these certainly tell a story.
And hapless FSA chief Executive, Mr Tim Smith just can’t stop putting his foot in it either. His “cause for concern “ crusade has suddenly moved onto introducing health and safety standards in plants as a reason for wanting to publish his “cause for concern “list. Mr Smith should know that health and safety requirements are the responsibility of abattoir owners and management who, in turn, are responsible, by law, to the Health and Safety Executive, i.e., nothing to do with Mr Smith. If any of his staff who work in a British abattoir are not satisfied with H and S standards, and feel that plant management is not responding adequately, then by all means contact H and S Executive, and let them deal with the problem.
Is this man fit for purpose? How can he possibly use a H and S argument to say that this would impinge on any discussion with Europe over health issues relating to meat inspection and any future review of the regulations, which he has suggested recently?
No, let them do the blustering, we need to stick to the facts and the real issues, as addressed above, because it is so important to remind ourselves that that is the last place they want this battle to be fought. It is surely time to press our adversaries hard for some clear answers. (More details on our next blog).
To succeed you have to try.
Toby Baker