Volume 14: Responsibilities for Human and Animal Health
3. Red meat hygiene at the slaughterhouse
Meat hygiene and inspection
Introduction
The distinction between 'export-approved' and 'domestic' slaughterhouses
Meat inspection in domestic slaughterhouses
Meat inspection in export-approved slaughterhouses
A comparison of post-mortem procedures and inspection requirements in export and domestic plants
The effect of moves towards harmonising slaughterhouse standards across the EU
Post-mortem inspection and the determination of fitness for human consumption
The treatment of meat found to be unfit for human consumption
The role of the Meat and Livestock Commission (MLC) in slaughterhouses
The role of the State Veterinary Service (SVS)

Introduction

3.40 During the period covered by this Report, the legislation controlling the production of meat was largely directed towards the reduction of the risk to humans from diseases or organisms carried in animals. It tended to concentrate on the reduction of salmonella and similar organisms in meat and meat products, and therefore attempted to anticipate the routes by which meat could potentially be contaminated by such organisms.

3.41 Meat hygiene and inspection Regulations provided for the processes of slaughter and cutting of carcasses to be supervised by authorised officers of the local authority trained for the purpose. The Regulations were directed to:

1. the identification before slaughter of sick or distressed animals or animals which might be suffering from a disease which would render their meat unfit for human consumption. These measures were intended to prevent so far as possible animals entering the slaughterhouse if it could be seen in advance that their meat would not be fit for human consumption;
2. the way in which the animal was slaughtered and its carcass was treated. These measures were designed to minimise the risk of cross-contamination in the slaughterhouse, eg, from faecal matter on the hide of an animal; to facilitate the removal of parts considered unfit for human consumption; and to facilitate post-mortem inspection; and
3. the post-mortem inspection of the carcass in order to determine its fitness in terms of quality and the possible presence of pathogens transmissible to man. The identification of carcasses or parts unfit for human consumption lay at the heart of these Regulations and the treatment of meat determined as unfit was the basis of the human SBO ban, one of the most important measures introduced to protect human health from any risk arising from BSE.

3.42 Local authorities were entitled to recoup the full cost of meat inspection from the slaughterhouse operator. The Meat Inspection (Amendment) Regulations 1983 stated that the charges must be based on the actual cost of providing the service at the individual slaughterhouse.

3.43 The Fresh Meat (Hygiene and Inspection) Regulations 1995 transferred responsibility for enforcement in slaughterhouses from the local authorities to the Minister. ¹ In practice, his responsibilities were discharged by the Meat Hygiene Service (MHS). The MHS was launched as an Executive Agency of MAFF on 1 April 1995, and was responsible from that date for meat inspection, supervision of licensed fresh meat premises and enforcement of the legislation relating to meat hygiene, BSE/SBO controls and animal welfare in these premises. ² The background to the establishment of the MHS and its role in the BSE story are described in vol. 6: Human Health, 1989-96.

3.44 The Food Act 1984 provided for Regulations to be made governing the hygienic production of meat. Section 13 provided that the Ministers ³ could make whatever Regulations appeared expedient to ensure the sanitary production of meat for human consumption and particularly the staining or sterilisation of meat considered unfit. Section 118 required Ministers to consult organisations representative of interests likely to be substantially affected. The Regulations were enforced by the local authorities responsible for licensing all slaughterhouses as required by the Slaughterhouses Act 1974. ⁴

The distinction between 'export-approved' and 'domestic' slaughterhouses

3.45 Before the adoption, on 1 January 1993, of the single European standard for meat hygiene, there were two regimes for the control of meat hygiene in slaughterhouses in the UK. Slaughterhouses producing meat that was not intended for export were generally described as 'domestic' slaughterhouses. Meat inspection requirements for these were set out in the Meat Inspection Regulations 1963, made under the Food and Drugs Act 1955 ⁵ and later the Meat Inspection Regulations 1987 and the Meat Inspection (Amendment) Regulations 1990. The procedures to be followed with meat that was found to be unfit for human consumption were set out in the Meat (Sterilisation and Staining) Regulations 1982.

3.46 Slaughterhouses which intended to produce meat for export were described as 'export-approved' slaughterhouses, because they could not do so without specific approval from 'the appropriate Minister' ⁶ under the Fresh Meat Export (Hygiene and Inspection) Regulations 1981. These also prescribed certain inspection and other requirements.

3.47 Before giving approval, the Minister had to be satisfied that the premises complied with certain requirements relating to construction, equipment and facilities ⁷ and to hygiene, ante-mortem health inspection, slaughter and dressing practices, and post-mortem health inspection. ⁸ He had to notify the relevant local authority and to have regard to any representations that it made, and to arrange for a Veterinary Officer to inspect and report on the premises. If he refused approval, he had to give reasons. No significant alteration to the premises, the equipment or the method of operation could be made without consulting the Minister in advance, and the Minister could revoke approval if was no longer satisfied that the specified requirements were being met.

3.48 The procedures to be followed with meat that was found to be unfit for human consumption were set out in the Meat (Sterilisation and Staining) Regulations 1982, and also applied to these slaughterhouses.

3.49 The following sections describe the meat inspection regimes in domestic slaughterhouses; and in export-approved slaughterhouses; and then look at the Meat (Sterilisation and Staining) Regulations.

Meat inspection in domestic slaughterhouses

3.50 The Meat Inspection Regulations placed a duty on the local authority to ensure that carcasses were inspected by Authorised Meat Inspectors (AMIs), who were supervised by Environmental Health Officers (EHOs) employed by the relevant local authority. ⁹

3.51 Before 1991, ante-mortem inspection ¹⁰ in domestic slaughterhouses was not required in England and Wales, unlike Scotland. As noted above, no person could bring into a slaughterhouse an animal which he knew or suspected to be diseased or injured unless the animal was accompanied by a veterinary certificate stating that their condition was not such as to render the whole carcass unfit for human consumption. The Meat Inspection (Amendment) Regulations 1990 made ante-mortem inspection a requirement in domestic slaughterhouses in England and Wales from 1 January 1991, but defined the authorised inspector specifically to exclude a veterinary inspector. In practice, this would have meant that ante-mortem inspection in domestic plants was carried out by an AMI. By contrast, ante-mortem inspection in domestic slaughterhouses in Scotland was carried out by veterinary inspectors.

3.52 The specific provisions of the Meat Inspection Regulations required that each carcass be dressed immediately after slaughter and in such a manner as would not hinder inspection. ¹¹ The requirements as to dressing and inspection of carcasses are set out in detail in a series of schedules to the Regulations. These are reviewed by way of comparison with the similar provision for export plants later in this chapter.

3.53 Meat inspection involved post-mortem examination of the carcass and offal and either

1. passing meat as fit for human consumption and stamping it; or
2. detaining it for further examination.

The carcass was stamped with the health mark after the inspector, having inspected it in accordance with the Regulations, was satisfied that the carcass or part of the carcass was fit for human consumption. The health mark consisted of a stamp identifying the inspector who had carried out the inspection. All officers authorised under the Food Act 1984, including the AMI, could reject meat as unfit for human consumption, or seize it if the owner would not voluntarily surrender it. When meat had been seized, any dispute could be taken before a Justice of the Peace (JP) who could condemn the meat. If the JP decided against condemnation, the local authority would be liable to pay compensation to the owner.

3.54 In large slaughterhouses, a team of AMIs might be present for most or all of the working day. In very small slaughterhouses, there might be no such continuous presence, but authorised officers would visit the plant to inspect the day's kill. For this purpose, the Meat Inspection Regulations required slaughterhouses to inform the local authority of the times at which slaughter was to take place.

3.55 In domestic slaughterhouses, the AMIs were supervised by an EHO who was responsible for checking the hygiene of the premises. The degree of EHO involvement varied, depending on the frequency of their visits to plants. In practice, day-to-day responsibility for hygiene could be delegated to a Senior Meat Inspector or, in small plants, to an AMI. The delegation of hygiene responsibilities had to be authorised by the local authority.

Meat inspection in export-approved slaughterhouses

3.56 Requirements for export slaughterhouses were set out in the Fresh Meat Export (Hygiene and Inspection) Regulations 1981. ¹² Local authorities were responsible for enforcing these Regulations, but the Minister, who had to grant export approval, could suspend or revoke this approval if the plant no longer complied with the Regulations or if a 'significant alteration' had been made without consulting him.

3.57 The 1981 Regulations required local authorities to arrange for every animal intended for slaughter in an export slaughterhouse to undergo an ante-mortem health inspection within 24 hours of arrival at the slaughterhouse and of slaughter. ¹³ Inspections determined whether animals were showing symptoms of diseases or disorders transmissible through meat to humans or animals, or which would be likely to make the meat unfit for human consumption. Such animals could not be slaughtered for production of meat for human consumption. If an inspection determined that an animal was injured, fatigued or stressed, the animal had to be rested for an adequate period of time. ¹⁴ After such a period of rest the animal was required to be re-inspected before it could be admitted for slaughter.

3.58 The application of the health mark was made on the same basis as in domestic premises but the mark itself was different. It carried the letters 'UK' and 'EEC' and the approval number of the export premises.

3.59 Each export slaughterhouse had to be supervised by an Official Veterinary Surgeon (OVS) appointed by the local authority, who was responsible for all hygiene and meat inspection. OVSs were usually private practitioners employed part-time by the local authority, although a few local authorities had full-time OVSs on their staff. Ministers were responsible for designating individual veterinary surgeons as suitable for OVS work and local authorities could only appoint such designated veterinarians as OVSs.

3.60 The AMIs were supervised by the OVS. If a plant was producing meat for the domestic market for some or all of the time, the OVS could attend for as little as one hour a day and delegate much of the responsibility for hygiene in the plant to the EHO. In those plants producing mainly for export, the OVS would be present most of the time to carry out responsibilities for all hygiene and meat inspection in the plant, and had personally to sign the health certificates to accompany export consignments. The OVSs were 'line-managed' by the local authorities' Chief Environmental Health Officers (CEHOs), but also had responsibilities to the Agriculture Departments which designated them and which had ultimate responsibility for export certification.

3.61 The OVS's responsibility generally ended when the meat left the slaughterhouse: if the meat was for export the OVS checked that the lorry was sealed; if it was for the domestic market, it passed into the EHO's sphere of responsibility. However, the OVS was required to provide a 'Health Certificate' to accompany the meat as it was loaded into the means of transport. The certificate stated the name of the exporting country and the relevant Ministry and Department. It also provided details to assist with the identification of the meat; the address of slaughterhouse of origin and address of the OVS; the destination of the meat and means of transport; and the attestation that the meat came entirely from animals slaughtered in an approved slaughterhouse and that they had been inspected in accordance with the relevant intra-Community Directive.

A comparison of post-mortem procedures and inspection requirements in export and domestic plants

3.62 The principal difference between the requirements for export and domestic slaughterhouses before 1991 was in respect of ante-mortem inspection. However, there were also differences in the Regulations relating to the dressing of the carcass.

3.63 As already mentioned, the Meat Inspection Regulations 1987 which applied in domestic slaughterhouses required that dressing of the carcass take place immediately after the animal had been slaughtered. Dressing was required to be carried out in such a way as not to prevent or hinder inspection and in particular:

1. where back bleeding ensued upon the slaughter of an animal the pleura should not be completely detached from the carcass until an inspector authorised their removal;
2. no action should be taken which might alter or destroy any evidence of disease, except on the instructions of an inspector;
3. the offal, other than the feet of any animal, should after removal from the carcass, be so kept as to remain readily identifiable with the carcass until that carcass had been inspected by an inspector; and the feet of an animal should be kept available for inspection in the slaughterhouse until an inspector authorised their removal;
4. any blood intended for human consumption should be collected and placed in a clean receptacle provided for that purpose and be so kept as to remain readily identifiable with the carcass from which it was collected until these carcasses had been inspected by an inspector.

3.64 The Fresh Meat Export (Hygiene and Inspection) Regulations 1981, which applied to export slaughterhouses, included the provisions set out above with the exception of that at (i). The Regulations contained the following additional provisions for dressing bovine carcasses:

1. the removal was required of the hide or skin, the head (save that where retention of the ears on the carcass was necessary for any certification purpose they need be removed only after completion of that certification), the viscera (save that the kidneys could remain attached on the carcass by their natural connections but were removed from their fatty and perirenal coverings), the genital organs, the urinary bladder, the feet up to the carpal and tarsal joints, and, in the case of lactating animals, animals that had given birth or were in advanced pregnancy, the udder;
2. evisceration was to be completed not later than half an hour after completion of bleeding; and
3. bovine animals over 3 months old ¹⁵ were to be split lengthways through the spinal column before being submitted for inspection, and an inspector could require the head to be split lengthways if considered necessary in carrying out the inspection.

The effect of moves towards harmonising slaughterhouse standards across the EU

3.65 The Fresh Meat (Hygiene and Inspection) Regulations 1992 ¹⁶ revoked, inter alia, the Meat Inspection Regulations 1987 and the Fresh Meat Export (Hygiene and Inspection) Regulations 1981, thereby in effect ending the distinction between domestic and export-approved slaughterhouses. This harmonisation of standards for all slaughterhouses in the EU was required by the move to a Single Market.

3.66 The 1992 Regulations transferred the responsibility for the licensing of slaughterhouses from local authorities to the Minister of Agriculture, Fisheries and Food (and the Secretaries of State for Scotland and Wales). The Minister was required to notify the appropriate local authority of each application for a licence, and to take account of any representations made by the authority before determining whether or not to grant a licence.

3.67 In substance, the Regulations introduced a system similar to the one that had previously existed for export-approved slaughterhouses. Local authorities continued to be the enforcement authority with responsibility for ante- and post-mortem checks, while the application of the health mark to show that the carcass was fit for human consumption rested on inspection by an OVS and inspectors employed by the relevant local authority.

3.68 Council Directive 91/498/EEC provided that temporary derogations might be granted to a slaughterhouse, meat-cutting premises or cold store so that the specified construction, layout and equipment requirements did not apply immediately. ¹⁷ Regulation 4(11) of the 1992 Regulations provided that where a Minster had granted such a derogation, the requirements specified in schedules 1-6 of the Regulations should not apply to them before 1 January 1996 or 'any such earlier date as the appropriate Minister may specify'.

3.69 In practice, many slaughterhouses found it difficult to comply with the new requirements, and derogation periods were sometimes exceeded. Mr Keith Baker, a former Assistant Chief Veterinary Officer at MAFF, told the Inquiry that:

Since many of the premises did not, at that time, meet with the standards of the new regulations, the operators were given a 3 year derogation period, subject to them agreeing to, and carrying out, an improvement programme. This threw a considerable burden on all MAFF staff involved in meat hygiene . . . The burden of work continued well beyond the 3 year period, since operators who failed to meet their commitments were delicensed, leading to appeals (to an independent Meat Hygiene tribunal) which took up considerable extra time and resources. ¹⁸

Post-mortem inspection and the determination of fitness for human consumption

Introduction

3.70 In both domestic and export-approved slaughterhouses, post-mortem inspection was required to confirm that the carcass was fit for human consumption or to identify any carcass or part thereof which was unfit. In 1986, inspection was governed by the Meat Inspection Regulations 1963. ¹⁹ These were re-enacted, with amendments, by the Meat Inspection Regulations 1987. ²⁰ The latter replaced the 1963 instructions for inspecting carcasses, which specified that certain parts of any animal should be examined in certain specified ways, with similarly detailed instructions for each of a number of different species. ²¹

Instructions for inspection

3.71 The carcass and offal and blood of each animal had to be examined without delay by an authorised officer of the council to determine fitness for human consumption. He was required to have regard to:

1. the age and sex of the animal;
2. the state of nutrition of the animal;
3. any evidence of bruising or haemorrhage;
4. any local or general oedema;
5. the efficiency of bleeding;
6. any swelling, deformity or other abnormality of bones, joints, musculature or umbilicus;
7. any abnormality in consistency, colour, odour and, where appropriate, taste;
8. the condition of the pleura and peritoneum; and
9. any other evidence of abnormality.

3.72 The inspection had to include:

1. visual examination of the slaughtered animal and the organs belonging to it;
2. palpation of certain organs, in particular the lungs, liver, spleen, and tongue and, in the case of mature animals, the uterus and udder;
3. incisions of organs and lymph nodes as specified in the detailed instructions relating to post-mortem inspection of specific species; and
4. any additional incisions or examinations that an inspector considered necessary.

The 1987 Regulations differentiated in detail between bovine animals over 6 weeks old and those under 6 weeks old.

Determination whether meat was unfit for human consumption

3.73 In summary, if inspection revealed that the animal was suffering from any of certain specified diseases, the whole carcass and all the offal and blood removed from it, was to be declared unfit. The specified conditions were:

Actinobacillosis (generalised) or	Actinomycosis (generalised)
Anaemia (advanced)	Anthrax
Blackleg	Bruising (extensive and severe)
Caseous lymphadenitis with emaciation
Caseous lymphadenitis (generalised)
Cysticercus bovis (generalised)	Cysticercus cellulosae
Cysticercus ovis (generalised)	Decomposition (generalised)
Emaciation (pathological)	Fever
Foot and mouth disease	Glanders
Jaundice	Malignant catarrhal fever
Mastitis (acute septic)	Melanosis (generalised)
Metritis (acute septic)
Abnormal odour associated with disease or other conditions prejudicial to health
Oedema (generalised)	Pericarditis (acute septic)
Peritonitis (acute diffuse septic)	Pleurisy (acute diffuse septic)
Pneumonia (acute septic)	Pyaemia (including joint-ill)
Sarcocysts (generalised)	Septicaemia or toxaemia
Swine erysipelas (acute)	Swine fever
Tetanus	Trichinosis
Tuberculosis (generalised)	Tuberculosis with emaciation
Tumours: (a) malignant with secondary growths; (b) multiple
Uraemia

3.74 Certain specific diseases or conditions (certain forms of tuberculosis, caseus lymphadenitis or any other suppurative condition, localised infestation or cysticercus bovis), did not, if identified, require the whole carcass and all the offal and blood to be declared unfit, but only those parts specified in the Regulations.

3.75 Where an inspector concluded that an animal had been suffering from 'any disease or condition other than one mentioned in the foregoing paragraphs of this Schedule', he was to regard as unfit for human consumption 'the whole carcass and the offal or such lesser part thereof as he may think appropriate to the circumstances of the case' - ie, the decision was at the inspector's discretion. ²²

3.76 Dr Anthony Andrews, Senior Lecturer in Farm Animal Medicine in the Department of Medicine at the Royal Veterinary College from 1979 to 1997, told the Inquiry that in the second half of 1987, when he had been asked for advice on what to do with animals that were showing signs of BSE, he had suggested that local Veterinary Inspection Centres (VI Centres) should be used to confirm the diagnosis, and that the animal should not go into the food chain because in his view it was unfit. He agreed that such advice had been based on his experience of cattle disease and knowledge of scrapie, and that:

. . . in my opinion, these animals were ill, so it depends on one's interpretation of illness and then slaughter regulations.

3.77 He said that if a farmer had come to him and said 'I have a sheep with scrapie, should I have it slaughtered for human consumption?' he would have answered:

. . . 'no'. The reason for that is because the animal had an illness.

In response to the question:

If it was thought to have scrapie, then you would expect the slaughterhouse not to accept it for human consumption?

Dr Andrews said:

That is right, or the [inspector] . . . would have rejected it . . . ²³

3.78 Where an inspector was satisfied that a carcass or part of a carcass was fit for human consumption, he was required to mark it by means of a stamp identifying the inspector who had carried out the inspection. No other person was entitled to make use of such a health mark. ²⁴ There was no requirement to mark any other meat.

The treatment of meat found to be unfit for human consumption

3.79 In 1986, the way in which unfit meat was to be handled to prevent it from entering the human food chain was governed by the Meat (Sterilisation and Staining) Regulations 1982. These provided a model for the Regulations which later introduced the human SBO ban. Because of their importance to the BSE story, a detailed account of the 1982 Regulations, and of their precursors, the Meat (Sterilisation) Regulations 1969, is given in the Annex to this chapter.

3.80 The chart below provides a simplified summary of the system. Keeping unfit material out of the human food chain depended on a whole series of actions from the identification of such material at the slaughterhouse through to its consignment to a suitable destination.

Determination that meat is unfit for human consumption

The role of the Meat and Livestock Commission (MLC) in slaughterhouses

3.81 The MLC was constituted under the Agriculture Act 1967 and charged with 'promoting greater efficiency in the livestock industry and the livestock products industry'. ²⁵ In doing so, it was required to have regard to the interests of consumers as well as to those of the livestock and livestock products industries. ²⁶ The Act empowered the MLC to undertake certain functions in the furtherance of this general duty. These included:

1. advising slaughterhouse owners and operators on the design and operation of their premises;
2. advising on slaughtering and dressing techniques, and advising the Government on slaughterhouse matters; ²⁷
3. promoting or undertaking research into the production, marketing and distribution of livestock and the production, processing, manufacture, marketing and distribution of livestock products; ²⁸ and
4. promoting or undertaking arrangements for advertising the merits, and increasing the sales of livestock and livestock products produced in Great Britain. ²⁹

3.82 The involvement of the MLC's staff within slaughterhouses was limited. The Agriculture Act gave it no inspection powers or functions, except where delegated by the Minister or where invited in by slaughterhouse operators. The MLC told the Inquiry that what in 1989 had been called its Fatstock Service staff had certified carcasses in slaughterhouses as agents of, and under instruction from, the Intervention Board ³⁰ in respect of subsidy schemes. It believed that this had involved 50 per cent of beef cattle slaughtered each year. In addition, its staff provided an independent meat classification system to slaughterhouse operators on a fee-paying basis. ³¹

3.83 The certification work for the Intervention Board took place only at certain slaughterhouses certified by the Board, with the role of the MLC's staff limited to that of ensuring that the dressing standards of the market support scheme were met. This included observing whether spinal cord had been removed. However, spinal cord removal was not at the core of the various classification standards, which concentrated on weight and the dressing of the carcass. ³²

3.84 Members of the MAFF and the Scottish Office Agriculture and Fisheries Department (SOAFD) Fatstock Inspectorate audited the work carried out by the MLC for the Intervention Board. The frequency of these audits changed and diminished with changes in the support schemes and grading requirements. The MLC said in oral evidence that its records of MAFF/SOAFD fatstock inspections suggested that the presence or absence of spinal cord was routinely checked by its inspectors, particularly during the period up to 1993, ³³ and that

. . . we believe on balance that the majority of the spinal cords at that period of time ³⁴ would be out of the animals in the factories we were in. ³⁵

3.85 The independent meat classification system provided by the MLC operated in the abattoir after the post-mortem inspection and the operating rules did not require feedback on any aspect of the treatment of SBO. Feedback was confined to matters associated with grading or dressing specifications. ³⁶

3.86 In addition to this work within slaughterhouses, the MLC provided advice and training to slaughterhouse operators and staff. It offered a general service advising and offering training on slaughterhouse organisation and design. The service did not focus on BSE-related issues (its function was abattoir design and layout, not process control) and, in any event, was discontinued in 1993 due to falling demand. ³⁷ Organisations providing training for slaughterhouse staff also received MLC support, although the task of ensuring that such staff were properly trained remained the responsibility of individual slaughterhouses. ³⁸

3.87 During 1990 and 1991, and again from late 1995 to mid-1998, the MLC investigated methods of removing spinal cord from carcasses safely and effectively. In 1990, at the behest of supermarkets, it attempted to develop a suction device to remove spinal cord. However, this work was abandoned in August 1991 when it became obvious that the work was not technically feasible. In 1995 the MLC began to investigate other methods and got so far as developing a twin blade saw to remove the spinal cord while still encased in the spinal column. This development, however, was overtaken by the discovery of infectivity in the dorsal root ganglia in late 1997. ³⁹

The role of the State Veterinary Service (SVS)

3.88 The State Veterinary Service (SVS) was part of MAFF's Agricultural Development and Advisory Service (ADAS) from 1971 to 1990 and thereafter became part of the Ministry's Animal Health and Veterinary Group. The Veterinary Field Service was the operational arm of the SVS. Designated veterinary officers carried out certain functions in slaughterhouses and similar premises in accordance with MAFF's procedural instructions of March 1988 which were known as 'Inset 31A', ⁴⁰ and its successors.

Domestic slaughterhouses

3.89 The SVS carried out annual inspection visits to domestic slaughterhouses. Inset 31A stated that the express purpose of these visits was:

to provide advice to the local authority about the application of legislation, including welfare aspects, so that the regulations are enforced in a uniform way at all slaughterhouses; and to report to the Ministers on the standards observed. ⁴¹

3.90 Where 'immediate welfare problems' (ie, to animals) were found, entailing 'any unnecessary pain or distress', the SVS officer was required to take 'immediate corrective action'. If the officer found evidence that legal requirements were not being met, section VII of Inset 31A stated that 'discussions should be held with the local authority, and confirmed in writing'. If the authority failed to secure corrective action, Inset 31A provided for 'a full report' to be made to a more senior SVS inspector, the Regional Meat Hygiene Adviser (RMHA). Where necessary, a letter was to be sent to the Chief Executive of the local authority. ⁴²

3.91 However, the SVS was not the enforcement authority. Under the Food and Drugs Act 1955 ⁴³ and its successor, the Food Act 1984, ⁴⁴ SVS officials had a power of entry to premises, but this was for the specific purpose of ascertaining whether there was, or had been, any contravention of the provisions of the Acts or of any Regulations or Orders made under them; the provisions being those 'which the Minister in question is required or empowered to enforce'. Otherwise, enforcement was the responsibility of local authorities.

3.92 After 1 January 1991, the SVS had no power of entry equivalent to that contained in the 1955 and 1984 Acts. The Food Safety Act 1990 confined powers of entry to the authorised officer of the enforcement authority, except that:

The Ministers may direct, in relation to cases of a particular description or a particular case, that any duty imposed on food authorities by subsection (2) above shall be discharged by the Ministers or the Minister and not by those authorities. ⁴⁵

3.93 Witnesses told the Inquiry in oral evidence that in practice this did not prevent monitoring by SVS officials as they would usually visit premises in attendance with local authority inspectors who had the relevant powers of entry. Mrs Elizabeth Attridge, Head of MAFF's Animal Health Group, said that:

. . . the Field Service, the meat hygiene vets, would have had to tag along with the local authority inspector . . . an informal arrangement. ⁴⁶

Mr Iain Crawford, Director of the Veterinary Field Service from 1988 to 1998, described its role as:

. . . rather a monitoring role than a supervisory one. ⁴⁷

He added that SVS staff had 'fairly close relations with the district councils' and would know the EHO responsible for the slaughterhouse concerned. In principle, they could be refused entry although:

I am not aware of any being refused entry, but I know there were some face to face confrontations at times . . . [between] the veterinary officer attending and the environmental health officer and the senior meat inspector. ⁴⁸

3.94 Mr Keith Meldrum, Chief Veterinary Officer from 1988 to 1997, said that:

[SVS officials] had to enter to do our checks with the cooperation of the district council. It did not make life any easier, although on the other hand I do not believe that they obstructed us in our wishes to go in, although they made it quite difficult sometimes, when we were talking about unannounced visits, they would like to be present when we went in. ⁴⁹

SVS visits to export-approved slaughterhouses

3.95 These visits were conducted monthly by the nominated Veterinary Officer (Meat Hygiene - VO(MH)), who had to complete forms detailing the findings of the visit. RMHAs, usually accompanied by a VO(MH), were required to visit export-approved plants at least once every six months. RMHAs were to prepare 'forward plans' in a specified format, setting out any shortcomings identified by local authorities and timetables for their correction. The purpose of the visits by the SVS was to:

(a) assess progress according to the forward plan; and

(b) carry out an inspection and note contraventions and deficiencies . . . ⁵⁰

3.96 The plans were to cover

. . . all aspects of structure and equipment, hygiene practices and inspection and include welfare within the slaughterhouse. ⁵¹

The harmonisation of standards in the EU

3.97 The earlier section of this chapter on the effect of harmonising standards across the EU explained that in 1992 the harmonisation of standards for slaughterhouses in the EU as part of the Single Market ended the distinction between domestic and export-approved slaughterhouses and transferred the licensing responsibility from local authorities to Ministers. MAFF's Animal Health Circular (AHC) 93/6, dated 18 January 1993, noted that export-approved slaughterhouses had 'tended to be larger establishments justifying monthly visits', ⁵² but the Single Market meant that all slaughterhouses ⁵³ would eventually have to be of the same status and such frequent visits would no longer be necessary.

3.98 The Circular therefore introduced new arrangements for visits by the SVS, which varied according to whether a premises was classed as a 'low throughput' or a 'full throughput' slaughterhouse. Under the Fresh Meat (Hygiene and Inspection) Regulations 1992, the two categories had to meet different requirements:

1. a full throughput slaughterhouse had to meet the construction, layout and equipment standards specified in schedules 1 and 2 and the hygiene, health inspection, slaughter and dressing requirements of schedules 7 to 10;
2. a low throughput slaughterhouse had to have been in operation on or before 31 December 1991 and to meet the construction, layout and equipment standards specified in schedule 5 and also the requirements of schedules 7 to 10. In addition, it could not supply meat to other EU Member States. ⁵⁴

3.99 Low throughput slaughterhouses - ie, those processing no more than 600 livestock units a year at a rate not greater than 12 livestock units per week ⁵⁵ - were to be visited at least once a year. Full throughput slaughterhouses - ie, all others - were to be visited at least once every three months. Unannounced visits to either kind of plant were to be made if considered necessary.