In placing this advice in the Library of the House Nick Brown said:
"I am grateful to the JFSSG and the Chairmen of the Independent Advisory Committees for their advice on this matter. In this case I think it appropriate to put this is the public domain a procedure that is intended to be followed by the Food Standards Agency. The summary of their advice confirms that there is no basis for a UK ban on French products on public health grounds. The UK fully supports the action taken by the Commission to ensure that Community rules are enforced."
Ministers received advice from the Joint Food Safety and Standards Group (JFSSG) and the Chairmen of the Advisory Committee on Animal Feedingstuffs (ACAF), the Advisory Committee on the Microbiological Safety of Food (ACMSF) and the Committee on Toxicity (COT).
SEWAGE SLUDGE IN FRENCH ANIMAL FEED: SUMMARY OF PUBLIC HEALTH ADVICE PROVIDED TO MINISTERS BY THE MAFF/DH JOINT FOOD SAFETY AND STANDARDS GROUP
A Reuters report alleging contamination of French animal feed with waste was received on 10 June 1999 by the Joint Food Safety and Standards Group (JFSSG), of the Ministry of the Agriculture, Fisheries and Food and the Department of Health. JFSSG officials received oral assurances from their French counterparts on 15 June that these were isolated incidents and remedial action had been taken. The Commission, in the wake of the Belgian dioxin scandal, formally raised the issue with the French Government in mid-August and sent in a team of veterinary inspectors. Ministers here were then advised by JFSSG that there was not a basis for consumers to do other than continue with normal hygiene precautions in relation to the handling, storing and cooking of meat.
JFSSG recognises that the practice of using sewage sludge is both unacceptable from the consumer's point of view and illegal under European law. It has also kept under review whether this practice would cause any health risks to consumers of meat, milk or eggs obtained from animals fed sludge-containing feedingstuffs.
Food Safety Considerations
The use of sewage sludge in animal feed raises concerns about the potential microbiological and chemical safety of meat and other animal products. JFSSG has made a careful assessment of these potential risks using its own in-house expertise as well as consulting external experts including the Chairmen of three independent advisory committees
The term "sewage sludge" is used in this note to describe the materials recovered from the treatment of waste water produced by plants processing animal waste into products such as gelatine and tallow. The term includes first the solid waste removed by filters, second, material resulting from chemical/physical processing of the waste water (eg using fat traps) and, third, residues resulting from the biological treatment of the waste waters. In some plants, waste water from septic tanks handling human sewage from the plant was mixed with waste processing water which would have led to human waste being incorporated into the sewage sludge. The Commission is seeking to ensure that the current prohibition on the use of sludge in Commission Decision 91/516/EC, which has been fully transposed into UK legislation, covers all three types of material. Domestic legislation in some member states including France currently allows the first and second types of waste to be used in animal feed. Where sewage sludge has been used in this way, it has been mixed with other waste materials and heat treated to produce meat meal for incorporation into animal feed. The sewage sludge concerned is stated to have been derived on site and there has been no suggestion that the output from municipal sewage plants might be involved.
The following assessments were made of the potential risks to consumer safety:
(a). Microbiological: The sewage sludge would be mixed with other raw materials and subjected to heat treatment as part of the process used in the manufacture of meat meal. Pathogenic micro-organisms that might be present in the wastes are sensitive to heat and would be effectively killed by the heat treatment. The Commission report states that the French authorities confirmed that the feed material is heat treated and would not present any microbiological risks.
(b). Chemical: A wide range of chemicals could potentially have contaminated the sewage sludge including heavy metals, organochlorine compounds (e.g. dioxins, PCBs), residues of veterinary medicines, disinfectants and detergents. The French authorities were only able to provide analytical data on certain heavy metals. These data gave rise to no food safety concerns. Organic chemicals, such as dioxins and PCBs, are widespread in the environment. Although they would be expected to be present in these materials at the normal background levels, there is no reason to expect the sludge used in animal feed would contain unusually elevated levels. All member states undertake statutory surveillance programmes for veterinary residues such as hormones and antibiotics and the results of this programme for France do not give rise to any particular concerns. It is possible that residues of detergents and disinfectants used in the plant might occur in sewage sludge but these compounds are of low toxicity and are unlikely to occur at levels of concern. In general, any sewage sludge would not have been a major input into feedingstuffs and any chemical contaminants present would be further diluted by other materials.
The report produced by the Commission's veterinary inspectors states that waste from the biological treatment of waste water is no longer incorporated into animal feed. This change produces an additional reassurance that French animal products do not pose any unacceptable food safety risk.
Overall, it was concluded that chemical contaminants were unlikely to pose immediate health concerns.
Conclusions and JFSSG advice
The practice of adding sewage sludge to animal feed is repugnant to consumers and illegal under Community law. The UK has fully supported the action being taken by the Commission to ensure that Community rules are properly enforced. JFSSG advise strongly that the UK should continue to press for compliance with this law in France and other Member States. JFSSG continue to advise on the basis set out above that there is no immediate public health risk and therefore no basis for seeking a ban of French products at either a Community level, or unilaterally. JFSSG will continue to monitor the situation and will bring to Ministers' attention any future developments of public health concern which may require action.