FSA Consultation Letter, 9 May 2005

HYGIENE - Draft guide to food safety and other regulations for the meat industry

The guide has been produced for UK meat plant operators whose premises require approval, and in some cases veterinary control, under the EU Food Hygiene Regulations. This consultation is therefore intended to cover the UK . Responses are requested by: 5 August 2005

Consultation details

New Food Hygiene Regulations will apply in all Member States from 1 January 2006 . They replace 17 directives, including eight relating specifically to meat. These regulations are:

• Regulation 852/2004 – Hygiene of foodstuffs
• Regulation 853/2004 – Specific hygiene requirements for products of animal origin
• Regulation 854/2004 – Official controls on products of animal origin intended for human consumption

Best practice for the implementation of new legislation requires that Government Departments issue guidance before the application of that legislation. The Agency has produced summary guidance on the application of the new food hygiene legislation, but it has been agreed with key stakeholders that officials and stakeholders would find it beneficial to have more detailed guidance for the meat sector. The Food Standards Agency has, therefore, been working with UK meat industry representatives and other stakeholders to develop a specific guide for the meat sector.

The draft Guide sets out the legal obligations that apply to food business operators in the meat sector. It provides advice on how these obligations can be met. The use of the Guide is voluntary and other ways of achieving compliance may be equally valid. The draft Guide also refers to the obligation placed on enforcement officials to carry out audits of HACCP and good hygiene practices to verify that food business operators apply procedures continuously and properly. Enforcement officers may refer to it when auditing operator's compliance with food hygiene and the other legislation that it covers, but they should always refer back to the legislation itself. The Guide is not an authoritative interpretation of the law as only the Courts have this power.

Regulation on Implementing and Transitional Measures

Please note that the European Commission is preparing a draft Regulation on Implementing and Transitional Measures in respect of Regulations (EC) 853/2004, 854/2004 and 882/2004, which we will need to take into account when reviewing the content of this Guide. The latest version of this document is itself subject to a separate consultation

Details of this Consultation

The draft Guide is expected to have five parts. However, this consultation covers only Part One (Contents and general issues), Part Two (11 chapters concerning hygiene requirements) and Part Five: Definitions, as these contain the information about the new food hygiene legislation.

As shown in the annotated contents page, one chapter of Part Two has not been circulated previously to the industry editorial panel while a number are being completed and will be sent to them shortly.

Part Three: It is proposed to include two sections at Part Three of the Guide. The first would cover the requirement for the application of HACCP principles and would be based on existing guidance produced for the Meat (HACCP) Regulations 2002, and be informed by Commission guidance currently in draft. The second section would be on the forthcoming Microbiological Criteria Regulation, which will itself be the subject of a separate consultation.

Views are sought as to whether the Microbiological Criteria Regulation should be covered in the Guide.

Part Four: It is envisaged that the Guide could include operators' obligations on other existing public health, animal health and welfare legislation.

Views are sought as to whether this other legislation should be covered in the Guide

OPOA: Separate guidance has been prepared concerning the production of rendered animal fat and greaves; treated stomachs, bladders and intestines; gelatine; and collagen. That document is subject to a separate consultation.

Views are sought as to whether these sections on Other Products of Animal Origin (OPOA) should be incorporated in this Guide

Publication and Review: We intend to issue this Guide as a working draft to meat plants operators in October, ahead of the application of the Regulations on 1 January 2006 . This is to enable us to assess the Guide after say, three months' use in practice before its final publication in 2006 in a loose leaf bound A5 format. The Guide will then be revised if there are major changes to policy, legislation or guidance from the European Commission, following consultation with a panel of stakeholders.

Views are sought as to whether this delay in final publication is too short or too long, whether other formats are preferred, and whether you have any comments on the review process

Food Chain Information: The new requirement in Regulation 853/2004 for slaughterhouse operators to request and then evaluate food chain information from animal producers is covered at Part Two Chapter 8 and Annex.

Views are sought on the proposed information requirements for different species set out in the Annex to chapter 8 of the Guide

Other questions

We invite views on the following questions:

Part One

i) Is the purpose and background clearly set out in the Introduction?

General – presentation

ii) Can you suggest improvements to –

• the order of the chapters within the Guide
• the combination or separation of chapters
• the layout of each chapter
• the clarity of the contents

Part Two

iii) Are the legal obligations of operators clearly set out in each chapter?

iv) Can you suggest improvements to the advisory information in each chapter?

v) Is any of the advisory information likely to be difficult to follow in practice, especially in smaller premises?

General – contents

vi) Do you disagree with any information provided, if so what and why?

vii) Have you noticed any errors or omissions, if so where?

viii) Can you suggest additional material that might be included:

• As an extra chapter in Part One, for example an Approvals chapter explaining how to apply for an approval (Note: currently proposed as chapter 7 of Part One)
• As an annex to an existing chapter, for example model cleaning schedule (Note: we would welcome examples of documentation currently in use that could form the basis of a 'model')
• As an extra chapter using material contained in the new Manual for Official Controls (currently subject to a parallel consultation), for example assessment of audit frequency? (Note: the general intention is to avoid duplication where possible)
• As extra sources of information, specialist advice and guidance?

Consultation Documents

The following is a listing of the Contents of the Draft Guide with links to the various documents ncluded in this consultation:

CONTENTS OF DRAFT GUIDE (ANNOTATED)

PART ONE

1. Contents
2. Amendment Record
3. Introduction to the Regulations
4. How to Use the Guide
5. General Obligations for Operators & Official Controls
6. Hazards in Meat Production
7. [Approval Procedures?]

PART TWO

1. Design & Facilities
2. Water Supply
3. Maintenance
4. Cleaning
5. Pest Control
6. Training
7. Personal Hygiene
8. Raw Materials including live animals [first draft]
9. Hygienic Production
10. Waste management [link with By-products/SRM]
11. Traceability, Identification and Health Marking
12. Wrapping & Packaging
13. Temperature Controls
14. Transport Hygiene

PART THREE

1. HACCP [EC guidance to be finalised]
2. Microbiological Testing [legislation to be finalised]

PART FOUR [Information on current legislation to be added?]

1. SRM
2. Animal By-Products
3. BSE/TSE Testing
4. Cattle Identification
5. Animal Welfare
6. Notifiable Disease

PART FIVE

1. Definitions & glossary
2. Index [to be added before publication]