Volume 13: Industry Processes and Controls
3. Head-boning and brain removal
ANNEX TO CHAPTER 3: Brain removal prior to the introduction of the SBO controls
Use of brain in products for human consumption
Head-splitting before 1986

Use of brain in products for human consumption

3.61 The predominant reason for removing bovine brain in 1986 was to use it in food for humans or animals. The use of bovine brain in food was governed by the Meat Products & Spreadable Fish Products Regulations 1984. The position was summarised by Mr Charles Cockbill of MAFF in the period leading up to the introduction of the 1989 SBO Regulations:

. . . the current legal position is that brains can only be used in meat products which are cooked although they would not be prohibited from being sold in their raw state in for example, a butcher shop. In the latter case however they would have to be sold under the name of brain. Where however they are used in a cooked product they may either be indicated in the ingredients list of that product under the name brains or under the generic term offal. This situation is set out clearly in schedule 3 to the Food Labelling Regulations 1984. ¹

(i) Use of brain in processed meat products

3.62 The extent to which bovine brain was used in meat products for humans before 1986 remains a somewhat vexed question. In an article published in the British Medical Journal in June 1986, Dr Timothy Holt and Ms Julie Phillips suggested that the use of bovine brain in food may have been more widespread than previously thought. ² Dr Holt explained the basis for this suggestion:

Julie Phillips was able to provide some evidence that potentially infective [central nervous system] tissue was entering the human food chain and despite a letter from Philip Mobsby of the Bacon and Meat Manufacturers' Association, who stated (1.12.87) that he knew of no examples where cows' brains were used in human food products, we felt we had a strong enough case to argue that human consumers were at risk. ³

3.63 More recently it has been asserted by Mr J Verdrager in The Lancet that:

. . . most adolescents and young adults have eaten liquefied [bovine] brain tissues because industrially prepared bovine brain-pool homogenates were used (before specified bovine offals were banned in the UK in 1989) as binding agents for the preparation of hamburgers, sausages, vol-au-vent, and so on. ⁴

3.64 Information was given to the Southwood Working Party on the question whether bovine brain was being used in products such as pies. ⁵ MAFF's Meat Hygiene Division advised in November 1988 that bovine brains were not used in processed meat products. ⁶ However, later that month Sir Richard Southwood attended a MAFF ministerial meeting at which the Chief Veterinary Officer, Mr Meldrum, said that while most bovine brains were not harvested, 'some were used in meat pies and Cornish pasties'. ⁷

3.65 Some witnesses before the Inquiry made reference to the use of brain 'as packing in certain types of meat pies' ⁸ and to its inclusion in gravies, beefburgers and sausages. ⁹ The Inquiry also heard anecdotal evidence that pâtés, tinned items and stock cubes were composed in part of bovine brain. ¹⁰ Mr Wildman, on behalf of Sainsbury's supermarkets, said that before 1989 Sainsbury's stores sold a 'very few products' containing brain tissue such as 'brawn' (a cooked, potted meat). ¹¹

3.66 A report prepared for MAFF in May 1997 relating to the period between 1980 and 1989 stated that 'no evidence (other than anecdotal) has been found for the use of cattle brain in meat products'. ¹² It found that while it would have been technically feasible to incorporate up to 5 per cent of bovine brain tissue in a meat product, the cost of removing it from the skull would make such practices unlikely on an industrial scale. The report also responded to the claim by Mr Verdrager, noted above, that bovine brain homogenates were used as binding agents. This was dismissed as 'most unlikely', since the poor binding properties of brain tissue would not have justified the considerable effort involved in brain removal. ¹³

3.67 During the consultation period in 1989 before the introduction of the SBO ban, MAFF was told by the Bacon and Meat Manufacturers' Association that a survey of its members (who then produced about 80 per cent of the meat products sold in the UK) confirmed that bovine brain was not used in meat products. ¹⁴ The advice of Mr Cockbill of MAFF at the time regarding the use of brain in human food was as follows:

Information from the trade is that beef brains are not used in meat products. For bovines, heads are removed at the abattoir and sent for rendering; it is understood that there are practical difficulties in extracting bovine brains which thus operates against their use. Therefore, suggestions that they are used in a whole range of uncooked products, such as sausages, burgers and pies are not only probably untrue but also such products are illegal. ¹⁵

3.68 Witnesses involved in the slaughtering industry stated that bovine brain was rarely, if ever, used in processed foods destined for human consumption. Mr Hylton Oberst, the Director-General of the MLC between 1979 and 1992, told the Inquiry that he had no knowledge of bovine brain being used in the manufacture of meat products in his 40 years in the industry. ¹⁶ The evidence from Mr Peter Carrigan of Specialpack Ltd about his 37 years in the meat industry was similar:

I was absolutely amazed that anyone could believe that brain, spinal cord, thymus, spleen or tonsils went into human food anyway. I had worked in the food industry, and every aspect of the meat industry, and for frozen food companies and for national well-known High Street superstores; and I was absolutely amazed that anyone should put that proposal forward, because I can only speak for what I know, but I am totally unaware of any food products being made from brain and spinal cord. ¹⁷

(ii) Sale of brain for human consumption

3.69 In their article in the British Medical Journal, Dr Holt and Ms Phillips stated that:

. . . it has always been possible to buy raw [bovine] brain over the counter in butchers' shops as an ingredient for stews and casseroles, quite popular among elderly people. ¹⁸

3.70 Dr Holt explained the basis for this assertion:

[Ms Phillips] quite simply got on the phone and rang half a dozen butchers in south London and found out whether they sold brains to people, and found out that they did, some of them did. ¹⁹

3.71 Sir Richard Southwood found that one could occasionally purchase an ox brain if one wanted to, but it would be difficult because most were destroyed during the slaughter process. ²⁰ Members of the slaughtering industry told the Inquiry that brains were not consumed in significant numbers in the UK and that the only real market that existed for them required the export of the bovine heads to France. ²¹

3.72 The study undertaken for MAFF in May 1997 surveyed independent and multiple butchers in England and Wales about their use of bovine brains. None of the respondents reported the use of brain in other meat products, but a proportionof them had sold ox-brains direct for human consumption. Based on the survey responses, it was estimated that in the early 1980s some 270,000 ox-brains a year may have been sold for this purpose. According to MAFF statistics on the number of cattle slaughtered in 1980 (4,255,100), this number of brains accounted for 6.34 per cent of the total cattle slaughtered. ²²

3.73 On the European continent it appears that brain was used in the production of German sausages. A survey undertaken by the University of Giessen and reported in 1999 involved a detailed biochemical analysis of over 500 samples of sausage. Based on estimates of the content of brain-specific lipid, it was found that up to 5 per cent by weight could be brain or other material from the central nervous system. It was noted that these sausages contained brain illegally as German Regulations prohibited the use of brain in meat products at that time. ²³ It is possible that, before 1988, similar sausages manufactured by butchers in the UK would have contained the same ingredients.

3.74 The Leatherhead Report estimated that, with the decline in the number of butchers during the 1980s, the number of brains being sold direct for human consumption would have fallen to a figure closer to 100,000 by 1989. Some of these brains (perhaps 25 per cent) might have been fed to pets. The Report also referred to a 1982 estimate that 30 per cent of all cattle brains in 1978 went for retail sale for human consumption or pet food. ²⁴

3.75 There has been speculation as well that some cattle heads were milled whole (including the brain) to produce a slurry for use in pet food. ²⁵ The Inquiry heard no evidence in support of this proposition.

Head-splitting before 1986

3.76 The extent to which brain was used in foods prior to 1986 appears likely to explain the low level of head-splitting during this period. If brains were not often eaten, few would have been removed, particularly when the difficulty of removal is considered. ²⁶

3.77 In evidence provided to the Agriculture Committee of the House of Commons in June 1990, Mr Richard Cawthorne, then Chairman of the British Meat Export Council, had the following to say regarding the prevalence of the practice of head-splitting for the purpose of brain removal:

To begin with, sir, the furore about the splitting of beef heads is very largely a myth. I first went in an abattoir in 1960 and I have been in a great many ever since. I have never seen a split head in an abattoir. I have been in abattoirs in Australia, the USA, all over Europe, North Africa and the Middle East. I have never seen a split head in an abattoir. The head is removed from the carcass by cutting through the last of the neck vertebrae. It is virtually spun off and carried away to a place of refrigeration prior to shipping out of the plant. Or if someone is going to bone the head to recover the cheek meat, it is normally refrigerated overnight in an offal chiller well away from the carcass meat. To split a head would take some saw, because the bone is over ½ inch thick covering the brain. To recover the brain is probably uneconomic even in normal circumstances. There were occasions when the British meat trade was asked to supply brains to certain European pâté manufacturers, but to do it effectively the equipment, which constituted a guillotine, cost £14,000. As the offered price was something less than 70 pence a kilo for brain meat, it was not a runner. I have seen one of these machines, but I do not believe there would be more than one in the UK. ²⁷

3.78 Mr Kevin Taylor, Assistant Chief Veterinary Officer, MAFF, suggested that the practice of head-splitting was limited before the emergence of BSE, citing the 'sheer difficulty of splitting the bovine skull'. ²⁸ The evidence of Mr Colin Maclean of the MLC also suggested that removal of the brain from bovine heads was not common prior to the introduction of the SBO controls:

We did the survey, it was not that common, but it did happen occasionally and we did not like it presentationally. ²⁹

3.79 Mr Keith Baker, Assistant Chief Veterinary Officer, MAFF, told the Inquiry that he had not seen the practice of brain removal before the introduction of the SBO controls. ³⁰ The evidence of Mr Carrigan was similar:

I have never known anyone who contract slaughtered for anyone to give them other than an entire head. I have never known the practice of a brain being removed. ³¹

3.80 Evidence before the Inquiry suggested that the practice of head-splitting for bovine brain removal largely developed in response to the SBO controls and was prompted, to a large extent, by economic considerations. ³² It is noteworthy that the IEHO later referred to the practice as one 'not considered at the time the Regulations were drawn up and implemented.' ³³ Responses to MAFF in the consultation period prior to the introduction of the SBO controls also suggested that, generally speaking, the removal of bovine brains was not common practice at the time. ³⁴