UNISON Scotland is the recognised trade union for all staff working for the Meat Hygiene Service (MHS), including meat inspectors and veterinary staff. Our members are trained professionals who work to a strong public sector ethos in delivering a service to the community. They wish to see effective public protection enhanced as a result of the implementation of the Food (Hygiene) Regulations 2005. Our members are opposed to any measures which would weaken public protection and thereby damage the UK meat industry. Our response should be read in light of this principled position.

UNISON Scotland also hopes that the Government will use the opportunity that the Regulations provide to legislate on a number of staff centred issues which are essential for the continued delivery of an effective meat hygiene inspection service in Scotland.

Our response is therefore presented in two specific sections:

UNISON Scotland agrees with the suggested approach of repeating provisions already existing in the Food Safety Act in these Regulations, for the user friendly reasons stated.

UNISON Scotland agrees with the concept of a single enforcement authority taking responsibility for co-located premises. In the example cited in the consultation paper (co-located slaughterhouse and meat products plant) UNISON has long held the view that the Meat Hygiene Service, as the major enforcement authority on the site, should take over responsibility for inspection and enforcement at both premises thereby ensuring a seamless official function.

One of our concerns about the new range of European hygiene legislation is the lack of clearly expressed measurable criteria, which the food industry must achieve to comply with legislation. This will lead to the regulations being very difficult to enforce.

We therefore welcome the proposal to maintain the current specific requirement for designated temperatures for products of animal origin. We also agree with the specific statement of the method of disinfection being water at 82C or equivalent.

You propose to continue with the current exemption for premises producing small quantities of rabbit and poultry meat. Our view remains that the same standards should apply to food producers regardless of their size. We are disappointed with your decision here, and seriously question the public health reasons for the exemption.

UNISON Scotland was actively involved in contact with MEPs at the time of the passage of this Regulation through the European Parliament.

As the FSA is aware, the Council of Ministers expert working group, particularly its FSA members, wanted much wider use of plant staff to perform official control functions.

The European Parliament rejected the extension of the use of plant staff to red meat plants and significantly tightened up the conditions under which plant staff in poultry meat plants can carry out inspection tasks.

The exact wording of Chapter III of 854/2004 regarding the involvement of slaughterhouse staff in inspection is as follows:

"…the competent authority may authorise staff of the establishment who have been trained in the same way as the official assistants and have passed the same examination to carry out tasks of the official auxiliaries and form part of the competent authority's independent inspection team under the supervision, direction and responsibility of the official veterinarian"

The FSA has tried to interpret the qualification requirement for company inspectors as meaning that part training and part qualification is permissible if company inspectors undertake only part of the tasks of official auxiliaries.

UNISON has major concerns that, by this partial and selective reading of Regulation 854/2004, the FSA will try to justify a lower level of training and qualification for plant inspectors than for official auxiliaries. Having closely monitored the Regulation as it made its way through the European Parliament, UNISON Scotland knows that this is not what MEPs voted for. They voted for parity of training and qualifications, not a clever get out for company inspectors. If the intention of the FSA is not reversed, UNISON will challenge what we see as deliberate under implementation of the intent of the Regulation.

Chapter III of 854/2004 also makes it clear that company inspectors will "… form part of the competent authority's independent inspection team under the supervision, direction and responsibility of the official veterinarian". UNISON is extremely concerned that the FSA appears to have ignored this important change, either in this consultation exercise, or in its advice to poultry meat plants dated 10 November 2004.

In the latter advice, the FSA merely states that company inspectors will be "under the permanent supervision of the official veterinarian". This fails to notify the industry that company staff will be line-managed entirely by the OVS, completely outside of the company's own management chain. The reason for this lies in the European Parliament's decision to place company inspectors in the "competent authority's independent inspection team" and make the OVS, not the company, totally responsible for their conduct, performance and supervision.

Regulation 854/2004 (H3)

In the FSA's Partial Regulatory Impact Assessment, the agency notes at paragraph 11:

"The changes to controls on meat hygiene will take account of the introduction of HACCP-based procedures in slaughterhouses. These changes will also take account of the fact that the traditional meat inspection regime is not equipped to cope with the presence of pathogenic micro-organisms which now account for most food bourne disease incidents."

UNISON nationally has to challenge the out-dated and mis-informed assumptions which have led FSA to make this inaccurate and misleading statement We have repeatedly told the agency that these views are at least 8 and probably 10 years out of date. FSA has never given a reasoned argument to the points UNISON has raised in the past and will now state yet again.

If by "traditional meat inspection," FSA means a system, which has as its priority the detection of physiological or pathological lesions, no such inspection has been practised in the UK for years. Such lesions, as referred to above, are still looked for at inspection, and the skilled process of judgement on the amount of meat that needs to be rejected as a result of what is found is still undertaken by our members. Our members know, however, that the detection of faecal contamination and SRM, and the prevention of these materials entering the food chain, is the priority.

MHS staff also frequently stop production and ensure unhygienic practices are prevented and a cleaner product is produced. If inspectors did not carry out on-line inspection, meat plants would produce a more contaminated product. An FSA microbiologist has confirmed that the US meat industry, which relies heavily on HACCP, produces a much more faecally contaminated product than that found in the UK.

HACCP has been in place in slaughterhouses in Britain for some years now and has made little or no improvement to meat hygiene. UNISON nationally surveyed its MHS members earlier this year. 457 people responded.

We asked members:

"Has HACCP improved the quality of product presented for inspection at your plant?"

91.5% said no, only 8.5% of respondents said yes.

A high percentage of carcasses of all species are still presented for inspection with visible faecal contamination.

MHS operational staff ensure that the product from British abattoirs is clean. The FSA argument about "traditional meat inspection" has not been relevant for years.

We are pleased to see, however, that in the recent, "Report of the 10th Session of the Codex Committee on Meat Hygiene, DRAFT CODE OF HYGIENE PRACTICE FOR MEAT (Agenda Item 3), Point 26, it is stated: "Ante and post-mortem inspection are fundamental for public health"

The "Codex Committee" further state at "Points 58 and 62" of the "PROPOSED DRAFT ANNEX ON RISK-BASED POST-MORTEM EXAMINATION PROCEDURES FOR MEAT (Agenda Item 4)," that the, "Detection of visible contamination," is a function of meat inspection. As we have already stated above the detection of faecal contamination is one of the most important parts of post-mortem inspection. Not only does such detection remove visible contamination from the food chain but also it is the only effective way of applying pressure on slaughterhouse operators to produce clean meat with less invisible contamination, rather than producing a dirty product and then removing the visible contamination later.

It is our view that the above realisation has influenced Codex to make the statement referred to at point 26. We are pleased to see that the "Codex Committee" is more up to date with their view of post mortem meat inspection. The FSA would do well to note this position.

We have also asked the FSA many times to use the results of official post mortem inspection to audit plant HACCP systems. We find our view on this subject also supported by the latest "Codex Committee" opinion. At "9.2 PROCESS CONTROL & 9.2.2 HACCP, Point 92," Codex confirms that post mortem inspection is part of "Process Control." Such inspection, it is stated, should form part of the HACCP or QA system.

"Codex" return to the subject of HACCP at "9.5.1 Design of post-mortem inspection systems Point 136, Bullet point 10" which states that one of the aims of a post mortem system is, "Integration with HACCP plans for other process control activities, e.g., establishment of zero faecal tolerance criteria for faecal contamination of carcasses."

We suggest that the FSA requires the results of post mortem inspection, carried out by the official team, to be compared with the objectives and records of plants' HACCP plans.

The view of our members on the effectiveness of HACCP in the UK is hardly surprising when members also tell us that high percentages of carcasses are still presented every day with visible faecal contamination. How can this be happening if HACCP is such a successful system? What CCP findings are such companies recording? The FSA should conduct an immediate investigation into this divergence between the appearance and reality of HACCP in meat plans.

UNISON Scotland regards the draft Regulations as the opportunity for the Scottish Executive to legislate to improve the MHS inspection regime in meat plants in two specific areas:

Referring to official inspection staff, this Annex states:

"They must have an adequately equipped lockable facility or, where needed, room for the exclusive use of the veterinary service."

Section II, which covers slaughterhouses for poultry and rabbits, contains at Chapter II, 7 an identical statement.

Many MHS teams working in slaughterhouse have very poor facilities for taking their meal and rest breaks. The same area is frequently also used for administration work, the storage of clean and dirty protective clothing and such staffs outside clothes.

The MHS Health and Safety Zoonosis Risk Assessment instructs all staff to wash thoroughly before leaving work and those staff who may have come into contact with zoonotic agents to shower before going home. All MHS staff that work in abattoirs come into contact with such agents every day.

Many MHS teams facilities and also many entire slaughterhouses do not have any facilities for any staff to shower before going home. In those plants that do have showers the facility is frequently dirty or unusable.

We have raised this issue on many occasions with MHS. Please find below a list of the minimum amenities that we feel should be available to MHS teams in meat establishments:

4.1.1 Separate clean/dirty areas for eating/changing

4.1.2 One full size, secure locker per member of staff

4.1.3 A chair and suitable clean table space for each staff member for eating purposes

4.1.4 Sufficient, suitable showering facilities at each site

4.1.5 Suitable refrigerated facilities at each site for the storage of packed lunches

4.1.6 A kettle for the preparation of hot drinks

4.1.7 A microwave or other suitable and sufficient means of heating food

4.1.8 A suitable and convenient supply of palatable drinking water

4.1.9 All facilities to have a suitable and appropriate means of controlling heating/ventilation

4.1.10 The ratio of these facilities to be proportional to the number of staff present at each site.

Article 5.5 (a) of Regulation 854/2004 states clearly that:

"member states shall ensure that they have sufficient official staff to carry out the official controls required …"

UNISON Scotland therefore proposes that the FSA should give expression to this requirement by inserting an appropriate clause in Part III, Administration and Enforcement to the effect that a scientific staffing methodology will apply to staffing levels across the agency

5.1 In summary, what UNISON Scotland is asking for as a result of this consultation is:

All establishment employed inspectors in poultry and rabbit plants should have exactly the same qualifications and pass the same test as official inspectors. The FSA proposal to have such inspectors receiving only 10% of the training required for official auxiliaries, and passing a test only in the tasks an individual plant want them to do, is not what the European Parliament voted for. The UK will be in breach of 854/2004 if it tries to implement this.

5.2 Appropriate amendments should be tabled to Part III of the Regulation to ensure that the requirement of 854/2004 regarding inspection staffing levels is met. MHS staffing levels should be sufficient for a detailed examination to be carried out on every carcass.

5.3 Appropriate Amendments should be tabled to Part III of the proposed Regulation to ensure decent minimum standards of facilities, as detailed above, are available to all MHS staff.