For some reason, fresh meat attracts health scare stories that can dominate newspaper storylines like no other. Cigarettes, salt, sugar, alcohol, drugs, etc., yes, get passing comments now and again, but mention fresh meat and hey presto – headline news!
A re-cycled item about links with red meat and bowel cancer was raised this week, this time by a Government sponsored review, and featured in the Sunday Telegraph. I guess it’s a sign of the times to see such a newspaper indulge in tabloid type journalism.
Consumers aren’t overawed anymore, though, and the average person in the street, although not dismissive, is not taken in by the hype, and seems much more relaxed in making up his or her own mind when these stories emerge. Having said that, one can understand why confusion can set in. On the same day, the British Nutrition Foundation issued a statement saying that moderate amounts of red meat offer positive contributions to a person’s diet!
So who do you listen to? Whichever way you look at it, the costs to British Agriculture with such regular negative press probably runs into £millions.
Not so long ago, our friends at the Food Standards Agency (FSA) would have got into the act by saying how the roles of vets and meat inspectors in abattoirs “protects public health”, although they have gone pretty quiet on that subject recently, as they certainly should.
The FSA now concedes that hygiene regulations in abattoirs are not “cost based and proportionate”. This phrase is bandied about as though it is a minor technical offence of no importance. Think about it. Uniquely severe hygiene rules requiring full time attendance of official vets and meat inspectors, at ruinous cost, are not based on analysis of the public health risk, thus excessive for the risk involved, i.e. disproportionate. Put more bluntly, health controls imposed and regulated by our competent authority called the FSA aren’t actually health controls at all!
Instead of searching questions being asked about this state of affairs, on ploughs this discredited agency in pursuing a policy of full cost recovery from the abattoir sector that runs into bankingesque proportions. Or so it seems to me as an abattoir operator.
I run a small family business and here’s the perspective. My company employs five slaughtermen and two butchers as part of its staff. They are top quality professionals who turn approximately six hundred animals per week from livestock into fresh meat ready to sell onto retail butchers or return to private customers.
It’s extremely hard for me to reconcile that when full cost recovery finally arrives, as it stands three FSA officials, i.e., two meat inspectors and a vet, will cost more per hour than those seven tradesmen combined. Imagine how I feel? Imagine how they feel!? Lunatics and asylum springs to mind.
Yet any time now the FSA will be announcing details of full cost inspection charges. And no doubt the industry’s hard work in the “consultation” process will as usual prove to have been a complete waste of time. It will be a sad day for the industry (and farmers and retailers) as another tranche of abattoir businesses face inevitable bankruptcy.
Apparently, proportionality is a key doctrine in EU law. Not so for the bureaucratic ambitions of the FSA. Do they mention it in despatches? Yes. Do they have the slightest intention of making it happen? No. Why oh why has this scandal not been dug into? Why has the FSA and its political bosses not been put under pressure to explain this situation? All they do is to ignore the facts and simply claim that their vets and inspectors “are there to protect public health”. They say this as they continue to put departmental targets above national interests.
We must front up. We have only ourselves to blame. We’re running around seeking support from the farmers and suchlike and indeed, we are going to need all the help we can get. But it shouldn’t have come to this. What’s to be done? Scientific and technical ignorance has been the fresh meat industry’s biggest handicap in failing to expose the glaring inadequacies of the inappropriately named “competent” authority (FSA). Get the right group of people together, and pay them accordingly. Every technical claim and comment should be scrutinised with professional analyses and response. Every time. Develop our own propaganda machine even.
It’s never too late. Let’s start by turning all previous errors on their head and reveal some home truths.
When full cost recovery finally arrives, what will industry do? How will it react? History is in the making for the wrong decisions should they be made.
To succeed you have to try.
Toby Baker.

It could be said that in the big debate on full cost recovery, we are fast approaching the point at where the wholesale meat industry sinks or swims – whether or not to confront the Food Standards Agency (FSA) on the lines suggested in previous blogs, i.e. the technical issues prior to the financial ones.
It’s worth remembering what we’re up against. The bullying tactics of Messrs Rooker, Smith and Rhodes have been well documented, and indeed, for public officials to behave in the manner that these gentlemen have thus far is unworthy of their office, to put it no less politely than that.
If you were trying to do business with a company who treated you like the FSA does, you probably walk away, don’t you?
We have ruthless adversaries, their track record spreads back over many years, so we know the type of people we’re up against. So have we got the nerve to reset agendas and lead the debate for a change? Negotiate the real issues instead of being told what is going to happen under the disguise of consultation. Have we got the nerve to pull out of all discussions unless this format is agreed to? We’ve got so much in our favour, it surely time to show what we’re capable of achieving. After all, basic defects in current abattoir health regulations have been acknowledged by the FSA, so isn’t about time that they were drawn out into the open on this vital subject? This is fundamental to future success for us. It’s time to raise our standard to the top of the mast.
This is surely the way forward for industry strategy as there are other typical issues to be addressed that could so easily bring about an inspection model on a realistic budget:
(1) To treat post mortem inspection procedures as a separate responsibility, carried out by suitably qualified officials: employed if necessary by independent contractors, as is the case with OV’s.
(2) Hygiene supervision to follow more closely the existing statutory requirements. An operator is responsible for complying with the law and must have in place a HACCP system to verify this. Vets are responsible for hygiene supervision and will carry this out through HACCP audit procedures. The meaning of the word “supervision” must be re-visited: legitimate definitions could be more flexible even within EU law. For example one interpretation of the law could be the absurd presence of sufficient vets to oversee every department at all times. Of course that would be silly, but so may any law, if not enforced with common sense.
(3) At present the question of correct HACCP is confused to the point of chaos. Although the regulations are quite clear about the meaning of a HACCP plan, at present the FSA operate a control system that is neither logical nor effective. In all abattoirs there is veterinary and meat inspector presence at all times. The law specifically verifies that if all regulations are complied with, a health mark is attached. Which means that a HACCP system is unnecessary in legal or risk terms.
(4) At the same time the operator is supposed to take responsibility and implement a proper HACCP plan. In practice this is difficult, if not impossible when micro managed by officials, which results in duplication of duties and confusion. Furthermore it is not possible for reason of costs for a company to staff and operate a practical and useful HACCP system as required by law. For one thing official inspection charges soak up whatever funds are available in this field.
(5) At present there is no leeway on veterinary ante mortem inspection. But still some flexibility is necessary. A large plant may well merit a vet permanently on lairage duties. Medium/small outfits should be able to arrange set ante-mortem inspection times for appropriate veterinary attendance. The overall point is that current ante-mortem arrangements are not justified in public health terms.
(6) A great impediment to sensible compliance with the law is “gold plating” on the part of FSA officials. For example, the decree that an operator must earn the privilege of complying with the law without veterinary presence: this seems to be outside the law. The intention of the law (at least as enforced in all food premises except abattoirs) is that a local authority health inspector pays occasional visits to verify conformance through audit of the company HACCP. The FSA have always cast doubt on the ability and trustworthiness of abattoir operators to produce safe meat when actually the evidence points to the need for FSA procedures to be scrutinised.
(7) Another unjustified handicap placed on operators is the unique power of officials to stop production in abattoirs. This enforcement tool (Remedial Action Notice) does not directly remove the right of appeal but in reality renders it ineffective by not requiring the notice to be on hold pending the appeal. This means that a notice to stop work immediately, without proof of risk to health or court decision, is in fact arbitrary closure at the whim of an inspector, which of course puts the business in peril without any reference to the courts. The situation is made worse if FSA officials ignore perfectly reasonable Hygiene Improvement notices that require a notice to be on hold prior to the court hearing. It should be pointed out that no reference to Remedial Action Notices is made in the relevant EU Directives and Regulations.
The FSA has a clearly stated and determined official decision to recover full inspection costs. It is abundantly clear that their departmental agendas play a bigger part in their decision making than UK national interests. There has been no real debate, consultation or discussion. Just smokescreens to hide the truth that it would be quite possible to design an inspection model on a realistic budget that takes account of current law, with the acknowledgement of those regulations that require obvious change in genuine co-operation with Brussels.
Over the last couple of months or so, this blog has tried to cover every facet of the whole debate, and hopefully we haven’t missed any obvious and relevant points of discussion. The FSA are due to release details of the “consultation” very soon, but we know what’s coming. The moment of truth will have finally arrived. There will be nowhere to hide.
The will and backbone of our industry is about to face its biggest ever test. Has it got the stomach for a scrap?
We shall see. To succeed you have to try.
Toby Baker.

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

The full cost recovery debate is certainly occupying a good deal of copy space again in the trade media, this time in the bi-monthly magazine Meat Management (January/February 2011). A six-page spread featuring one Food Standards Agency (FSA) spokesmen, the NFU, and four representatives from the main red and white meat trades all have their say. Covering much ground that this blog has frequently highlighted, it was all good and relevant stuff, prompting the Editor, Mr Graham Yandell, to state that in 29 years of publishing, he had never known such unity within the industry.
Blog has been encouraged by this apparent unity for many weeks and has stated thus.
But is it really true? The recent Big Debate in the Meat Trades Journal(MTJ), which we referred to last week, highlighted once again a curse to genuine unity that has always been there; that is the undertone that the English big red meat boys are, for sectoral advantage, quietly siding with the FSA, to bring about the removal of competitors within industry. Perhaps I have read this wrong, but in the Big Debate, Mr Stuart Roberts, agriculture strategy director at ABP, and a former spokesman for the British Meat Processors Association (BMPA), lets an inevitable mask slip. Despite making some useful and challenging comments towards the FSA, he reverts to type. He said: “The issue isn’t big versus small, its professional versus unprofessional. And there are, I’m sure, some unprofessional businesses in the meat sector, Tim (FSA Chief Executive Mr Tim Smith) highlighted it on Radio 4 relatively recently – there is no place for those businesses in our industry...............”
It is not for Messrs Roberts, Smith or anyone else to comment on any company’s professionalism or suitability to trade. That is down to the licensing authority on whether a company merits a license or not, and for the relevant enforcement authority to decide on whether a company is complying with its legal requirements or not. Its nobodyelse’s business. If Mr X wants to gold-plate his business for whatever commercial reason , but Mr Y doesn’t, those separate decisions are the fundamental right of both parties. It obscures the real issue, much to the delight of the FSA, and certainly puts a wedge into the lauded recent “unity.” What with Tim Smith’s “cause for concern”(see last week’s blog) and Mr Roberts’ above comments, an anti-trade alliance seems to be emerging.
But ABP pays Mr Roberts wages, not Toby Baker, so I fully respect that his stance, he hopes, will bring about an outcome that will suit his employers. No problem with that, because ultimately, we’re all in that particular boat. It is just that it is surely right to acknowledge that there is a divide, recognise it , and proceed accordingly.
It looks something like this could emerge; auctioneers, farmers, small to medium abattoirs, fresh meat wholesalers, butchers shops, livestock procurement agencies and perhaps the Scottish Meat Wholesalers could band together to form one unit, and for the English big red meat boys to fight their own corner? I’m certainly not suggesting this would be a backward step; on the contrary, by being honest in recognising where everybody stands in this debate, it could actually be progressive by bringing clarity in our confrontation with the FSA.
And we can certainly learn much from the FSA, which has strategic objectives that are perfectly clear, and which any major blue-chip company would be proud of. In a perverse sort of way, you have to admire our adversaries, and let’s not forget that is what they are. As over the years regulations have got worse, and are confirmed as being massively disproportionate, the FSA always evades any detailed discussion of what this actually means in practice. Typical quangoism (is there such a word?) from a public sector body that reckons it shouldn’t have to knuckle down like everybodyelse – naked job protectionism, pure and simple.
Mr Roberts is quite right to point out that industry has not got a clear strategy, unlike our opponents, and that is perhaps our biggest challenge. There is so much to piece together to co-ordinate and unify a concerted attack on the FSA. It will be tough. To succeed you have to try.
Toby Baker.