Foodlaw-Reading Dr David Jukes, The University of Reading, UK
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Food Law News - UK - 2017

FSA Consultation Package, 8 December 2017

HYGIENE - Consultation seeks views on the authorisation of the use of alternative systems for the disinfection of cutting tools in abattoirs and game handling establishments

The Food Standards Agency has published a consultation package on this topic.  Responses are required by 12 January 2018.

Consultation Pack: On the authorisation process, guidance and associated documents for the use of alternative systems for the disinfection of tools in Slaughterhouses, Cutting Plants and Approved Game Handling  establishments. A copy of this document is available on the FSA website (click on the image)

The following is the introduction to the consultation:

Who will this consultation be of most interest to?

• Slaughterhouses / Cutting Plants / Approved Game Handling Establishments/ Food Business Operators (FBO’s) / Local Authorities / Service delivery Partners.

What is the subject of this consultation?

• The authorisation process, guidance and associated documents for the use of alternative systems for the disinfection of tools in Slaughterhouses, Cutting Plants and Approved Game Handling Establishments.

What is the purpose of this consultation?

• The purpose of this consultation is to seek the views on the FSA proposed authorisation process, and associated documents. We would welcome any comment on this prior to the final version being published on our website.

PROPOSAL:

On the authorisation process, guidance and associated documents for the use of alternative systems for the disinfection of tools in Slaughterhouses, Cutting Plants and Approved Game Handling Establishments.

DETAIL OF CONSULTATION

Introduction

1. Annex III of Regulation (EC) No 853/2004 lays down specific hygiene rules for food of animal origin. It requires that Slaughterhouses and Cutting Plants processing meat of domestic ungulates and poultry, and AGHE, “have facilities for disinfecting tools with hot water supplied at not less than 82°C, or an alternative system having an equivalent effect.”

2. The Food Standards Agency (FSA) is seeking your views on the process, ‘Guidance on the use of alternative systems for the disinfection of tools in Slaughterhouses, Cutting Plants and Approved Game Handling Establishments (AGHEs)’and the attached documents.

3. The guidance sets out the process for authorising and implementing the use of alternative methods for the disinfection of tools in FSA approved meat establishments. The associated documents are intended to support the process.

Background

4. Slaughterhouses and AGHEs use a variety of tools including knives, cleavers, and saws that require cleaning and subsequent disinfection. In addition, Cutting Plants not only use the same cutting tools but also use automatic cutting equipment such as slicers, filleting machines and dicers.

5. One of the difficulties faced by the competent authority in considering a request for an alternative system of disinfection that has an equivalent effect to the use of water at a temperature of not less than 82°C. The purpose of the guidance and associated documents is therefore to clarify the procedure for the submission of an application by a FBO and to provide some guidance on what will be needed by authorised officers to enable them to determine if an alternative system of disinfection of knives and other tools in Slaughterhouses, Cutting Plants and AGHEs is equivalent to the use of water at 82°C.

6. The FSA is responsible for the approval of Slaughterhouses, AGHEs and Cutting plants as well as any procedure that requires authorisation, and on this particular case, it has a duty to ensure that any alternative system of disinfection has an equivalent effect to the use of water at a temperature of not less than 82°C.

7. In setting out the evidence for equivalence, it is essential that the environment in which the alternative method will be used is assessed, as some environments will have higher risks associated with contamination than others. Consequently, this guidance reflects the different risks in Slaughterhouses, AGHEs and Cutting Plants with the process of proving equivalence separated.

8. Whilst slaughterhouses and AGHEs do require a more thorough authorisation process, cutting plants can implement alternative sanitation systems more simply, provided certain basic criteria are met.

Impact Assessment

Evidence from industry on the impact that the proposed authorisation process is needed in order for the FSA to assess the impact of this measure. We would therefore welcome industry input on the impacts of this measure, in particular:

• How likely are you to take advantage of the proposed authorisation process for authorising an alternative system of disinfection?

• What benefit do you perceive from introducing an alternative system of disinfection?

• Do you perceive any significant burdens from the proposed authorisation process for introducing an alternative system of disinfection?

For all questions, please try to explain your responses so that we may fully understand the likely impact of this measure.

Consultation Process

13. This 5 week consultation on the authorisation process, guidance and associated documents for the use of alternative systems for the disinfection of tools in FSA approved meat establishments closes on 12th January 2018. Please state, in your response whether you are responding as a private individual or on behalf of an organisation / company including details of any stakeholders your organisation represents

14. Response to the consultation received by the closing date on the 12th January, will be taken into account in the final approach taken to the authorisation process and published guidance.

15. Following the consultation, we will review the responses received. A summary of response report will be published on the FSA’s website within 3 months following the end of the consultation period.