Volume 5: Animal Health, 1989-96
4a. Implementation, enforcement and monitoring of the animal SBO ban
Introduction of the 1995 SBO Order
Enforcement of SBO controls: 'keeping up the pressure'
The EC mission to inspect BSE control measures
The Chief Medical Officer expresses his concerns
Further SVS surveillance results and Mr Hogg meets with slaughterhouse operators
Approval of rendering plants

Enforcement of SBO controls: 'keeping up the pressure'

4.536 On 11 October 1995 Dr Cawthorne minuted Mr Meldrum ahead of his meeting with MHS officers that evening. Among other things, Dr Cawthorne advised that the MHS had drawn up an 'action plan' to tackle the problems identified in slaughterhouses. The plan included:

. . . instructions to MHS staff in each abattoir to sign a log book at the end of each day indicating that checks have been carried out on SBO separation and staining and that all is in order. Principal OVSs will be asked to visit problem plants to be sure that MHS staff are doing their job properly: disciplinary measures will be instituted if necessary. Where problems rest with plant management, Investigation Branch will be invited to collect evidence for prosecution. ¹

4.537 The outcome of the meeting between Mr Meldrum and the MHS was described by Dr Cawthorne in a minute sent to Mr Packer on 24 October 1995:

As a consequence, the CVO met the Chief Executive and senior managers of the MHS on 11 October and expressed his serious disquiet at what the SVS was uncovering in the course of their audits. The point was made quite forcibly, that the responsibility for enforcing controls in abattoirs rested with the MHS staff on-the-spot. It was highly unsatisfactory that SVS staff should continue to identify faults which MHS inspectors should have picked up in the course of their duties. The MHS were concerned at the results of these audits and expressed a commitment to ensuring that SBO separation and disposal was properly enforced in plants. ²

4.538 On 12 October 1995 Mr Fleetwood minuted Dr Cawthorne:

In my report of 6 October, I hinted that some of the poor results recorded at slaughterhouses in August/September may have arisen as a result of field staff applying exceptionally strict inspection criteria during their visits. I understand that similar opinions have recently been voiced by the MHS.

. . .

On balance . . . I have to report to you my opinion that some of the SVS results reflect genuine, continuing problems, some reflect differences of opinion which require a firm lead from us and some may reflect over-strict interpretation of the rules by the SVS. ³

4.539 In his evidence to the Inquiry, Mr Eddy commented that, with the benefit of hindsight, the fact that these allegations were made suggested that those directly involved in enforcement work in slaughterhouses might, until this point, have been applying a degree of tolerance of minor failings, which Mr Eddy did not believe was ever asked of them in their instructions. ⁴

4.540 The next day, Dr Cawthorne reported to Ministers on the September round of the SVS's programme of bi-monthly, unannounced slaughterhouse visits. Results of the visits were summarised and were described as, 'to the say the least, disappointing':

The CVO has expressed his concern over these results to MHS senior management in a meeting earlier this week, who, in turn, have acknowledged that faults by plant operators are still evident though not on the scale recorded earlier in the year and not always of the same degree of concern. They have instituted a programme of management checks on their own staff to ensure full compliance and included in this package, disciplinary or enforcement action where this is considered necessary. ⁵

4.541 On 18 October 1995 Mr Soul, who had been MHS Acting Head of Operations since August 1995, wrote to all MHS staff in beef slaughterhouses and head-boning plants about the results of the September round of SVS visits. He said that, whilst the results of the second round of SVS visits had been quite satisfactory, these most recent results were quite disappointing: 52 per cent of plants were found to have satisfactory controls in place, whilst 48 per cent failed to satisfy SBO controls. The most recent failures included:

1. inadequate separation of SBO;
2. failure to stain SBO comprehensively;
3. unsatisfactory record-keeping of SBO by plant management;
4. consignment to inappropriate destinations. ⁶

4.542 Mr Soul stressed that it was imperative that plant management and MHS staff fully appreciate the importance of implementing SBO controls in full as part of the national effort to control BSE. In addition, the OVS was to ensure that he/she or the SMHI or MHI made a daily entry in the MHS daybook at each plant, verifying that the SBO regulations had been fully complied with on that day. ⁷

4.543 On 23 October 1995, AHC 95/163 was issued to all Divisional Veterinary Managers (DVMs) and DVOs cancelling AHC 95/74, 95/101 and 95/119 dealing with instructions for the period of national surveillance of separation, staining and disposal of SBO at all slaughterhouses and boning plants which had now ceased. The circular attached an amendment to Inset 25A providing new instructions on the disposal and processing of SBOs. ⁸ The Inset provided that a tour of the premises should be made in the company of MHS staff and to examine in particular:

1. the methods used to separate SBO from other carcass material;
2. the form in which intestines are consigned off the premises;
3. the staining of SBO;
4. the staining of other material; and
5. the method used to store and consign SBO.

The Inset set out specific instructions, in each of the above cases, to ensure that requirements were being complied with. It also noted that records required by article 13 of the 1995 Order should be examined to ensure that they were appropriate and that SBO was being consigned to appropriate premises.

The EC mission to inspect BSE control measures

4.544 An EC mission to Great Britain to assess the implementation of EC trade and national measures regarding BSE was conducted between 28 August and 1 September 1995. On 13 September 1995 Mr Taylor distributed among MAFF officials his note of the oral report by the EC mission leader, Dr Cavitte, to the Standing Veterinary Committee (SVC). Presenting the team's observations, Dr Cavitte told the SVC that conclusions had not yet been drawn. Mr Taylor recorded that the mission's observations on SBO were that rendering plants visited were in compliance with the new SBO Order, which had introduced additional measures to protect the animal feed chain including:

1. the requirement of separate rendering lines for SBO;
2. the approval of facilities;
3. the introduction of a heat-stable stain; and
4. the replacement of movement permits with the requirement for systematic records. ⁹

4.545 The EC mission's final report was presented to the SVC on 4 October 1995. It concluded in relation to SBOs that:

Controls on the eventual destruction of SBOs have been strengthened considerably. However, the policing of these controls is of paramount importance.

Spot checks combined with local knowledge will provide assurances, but consideration should also be given to the fuller use of computer recording to audit the production and destruction of these tissues. ¹⁰

The Chief Medical Officer expresses his concerns

4.546 On 25 October 1995 Mr Charles Lister, who was responsible for the administrative aspects of BSE in DH, wrote to Baroness Cumberlege, DH Parliamentary Secretary (Lords), outlining DH's current position on the BSE epidemic. ¹¹ His submission stated that it now seemed likely that SBO 'may have been getting into animal feed because of poor controls at slaughterhouses'. He wrote that MAFF had addressed this problem 'at least in part, by transferring responsibility for slaughterhouse inspections from local authorities to the Meat Hygiene Service'. ¹²

4.547 Also on that day, Dr Kenneth Calman, the Chief Medical Officer (CMO), met Mr Packer and Mr Carden to discuss the position on BSE. By this time, Dr Calman had been informed by Mr Meldrum of four instances where spinal cord had been found in bovine carcasses that had been stamped by Meat Inspectors. In a statement to the Inquiry, Dr Calman summarised the discussion as follows:

At that meeting I expressed a number of concerns I had as a result of the lapses in the SBO ban which had been identified. These were the continuing high number of BSE cases being reported, although this was declining, the high number of cases born after the feed ban which implied that controls in feedmills were inadequate and discovery that SBO had not always been properly removed in slaughterhouses and the fact that four farmers had contracted CJD. Despite the fact that I received assurances that enforcement of the SBO ban would be carried out vigorously in feedmills and slaughterhouses and that the Meat Hygiene Service would be left in no doubt of the high priority of this measure I requested an immediate meeting with the Minister. ¹³

4.548 Mr Packer recorded the content of the discussion in a minute to Mr Hogg. ¹⁴ Amongst the measures that Mr Packer said MAFF would pursue 'with vigour' were continued monitoring of feedmills and:

. . . the monitoring of adherence to the regulations in slaughterhouses and in particular the correct treatment of Specified Bovine Offals. I said we would ensure that the Meat Hygiene Service were in no doubt whatsoever as to the priority to be accorded to this objective by a directive from you or some other means . . . ¹⁵

4.549 Mr Packer also proposed that MAFF should 'call in the slaughterhouse owners and, in effect, read the riot act':

I would suggest I might do that myself; if they prove recalcitrant you could then have a word with them. My line would be that unless they improve their performance they were putting the future of the whole industry at risk including their part of it. ¹⁶

4.550 Mr Hogg read Mr Packer's minute 'with concern' and asked for 'an urgent meeting' with officials and a separate meeting with the CMO. ¹⁷ Mr Packer arranged for Dr Calman to meet the Minister on 7 November 1995.

4.551 On 27 October 1995, with the agreement of Mr Meldrum and senior colleagues, Mr Eddy recommended to Mr Hogg that:

1. the SVS double the audit frequency of slaughterhouses;
2. they move more quickly to prosecutions; and
3. the Minister write to the Chief Executive of the MHS to instruct him formally that appropriate steps should be taken to ensure that the MHS staff enforce the regulations properly. ¹⁸

4.552 Three days later, on 30 October, Mr Hogg held a meeting on BSE with Mr Antony Baldry, Minister of State, Mrs Browning and senior officials including Mr Packer, Mr Meldrum and Dr Cawthorne.

The note of the meeting records that a wide range of BSE-related issues were re-examined. In relation to animal health:

Mr Meldrum gave a brief history of what we knew of the origin of BSE, describing the steps we had taken to prevent its spread. He said that we were currently facing difficulties in two areas: in slaughterhouses, where inadequate procedures for separating and staining SBOs appeared to be leading to some leakage into meat and bonemeal; and in feedmills where there appeared to be some cross contamination from feed for pigs and poultry. These developments were against the background of concern about the growing number of infected animals which had been born after the feed ban. Mr Meldrum described the steps we were taking to counter these problems. Tighter controls on SBOs and rendering had been introduced in the summer and the SVS was carrying out unannounced surveillance of SBO handling in slaughterhouses. There would be improved testing for cross-contamination in feedmills, based on unannounced sampling. ¹⁹

4.553 Mrs Browning commented on the 'short-sightedness' of slaughterhouses in concentrating on questions such as the economic impact of controls. The Minister:

. . . agreed that the MHS should launch prosecutions where that was appropriate [and] that he should call in, as a group, the key organisations, telling them clearly that the results of our inspections in September showed that they were not doing well enough . . . The Minister would also want to arrange a visit to a slaughterhouse . . . Mrs Browning should hold separate meetings with the knacker industry and the hunt kennels where some problems with the handling of SBOs had also been seen. ²⁰

4.554 On public presentation, Mr Hogg said that 'he would make plain that the September results of the surveillance exercise to monitor compliance showed that things were not as they should be'. It was agreed that it was 'very important to liaise closely with the Department of Health and to keep Scottish and Welsh Offices informed'. ²¹

4.555 On 1 November 1995 Mr Curry, Chairman of the MLC, wrote to the Minister expressing his concern about the integrity of the controls which were in place to eradicate BSE. He noted the significant number of BABs, which 'can only have occurred because of "leakage" in the feed bans'. He considered it 'necessary for MAFF to send a clear signal to the whole industry that breaking the specified offal or ruminant protein bans will be punished extremely severely by prosecuting one of the offending abattoirs (or others not adhering to the rules)'. ²²

4.556 Mr Hogg wrote to the Deputy Prime Minister Mr Michael Heseltine, copied to members of Cabinet Sub-Committee EDC(P), on 3 November 1995. He provided a short background paper on BSE and also informed them of the discovery of failings in the handling of SBOs from recent SVS surveillance in slaughterhouses. ²³ Three days later, Mr Hogg met Mr Johnston McNeill, Chief Executive of the MHS.

The Minister stressed the importance of our controls on SBOs in our strategy for the control and eradication of BSE. He was very concerned about the results of the most recent SVS audit of SBO handling in slaughterhouses. Clearly there had been a number of failings. We had to consider together how to make the slaughterhouses do better. ²⁴

. . .

The Minister made clear that Mr McNeill should not hesitate, where appropriate, to prosecute.

²⁵

4.557 Mr McNeill said he would immediately 'issue instructions to MHS staff stressing the importance of 100% compliance'. ²⁶ Mr Carden agreed: 'We could not tolerate anything less than 100% compliance'. ²⁷

4.558 Mr McNeill went on to say that, 'in terms of the technology, there was no reason for non-compliance. There were, however, operational implications'. ²⁸ These were likely to slow turnover in some plants significantly and, to avoid this, more inspectors would be needed. This would, in turn, lead to extra costs for MAFF. However, Mr McNeill said that there was no problem for the MHS in terms of recruitment and availability. ²⁹

4.559 On 7 November 1995 Mr John Pratt, President of the Association of Meat Inspectors (GB) Ltd, wrote to all members stressing the importance of full compliance with the SBO regulations. ³⁰

4.560 Concern about the enforcement of the SBO regulations was highlighted by the discovery of shortcomings in the removal of spinal cord at slaughterhouses during this time (see vol. 6: Human Health, 1989-96). Whilst this had obvious implications for human health, the discoveries also raised concerns about the animal health implications.

4.561 On 7 November 1995 Dr Calman and Dr Jeremy Metters, Deputy CMO, met Mr Hogg, Mrs Browning, Mr Packer and Mr Osborne. Mr Hogg informed Dr Calman of 'the likely findings of the October SVS audit of the handling of SBOs in slaughterhouses: this merely confirmed the need to take decisive action'. ³¹ Dr Calman felt that the processes now in place to control SBO were satisfactory, but that those in the past had not been. Dr Calman 'found the attitude of the farming industry and the slaughterhouses astonishing, particularly given the threat to the whole future of the sector'. Dr Metters said that he had noticed MAFF's attitude change significantly over the last six weeks: 'there was now no inclination to tolerate any failure to remove SBOs'. Mr Hogg recounted that he had told Mr McNeill not to hesitate in prosecuting if the evidence justified doing so and that Mr McNeill had said that there were no technical reasons why the industry should not be able to comply with the regulations. Mr Hogg added that he would shortly be seeing representatives from the slaughterhouse industry, and that his message would be 'uncompromising'. ³²

4.562 On 8 November 1995 Mr Hogg issued formal instructions to Mr McNeill regarding the enforcement of the SBO controls. He wrote:

I am, therefore, by this letter, formally instructing you, in accordance with the provisions of paragraph 4.3 of the Meat Hygiene Service's framework document, to ensure that appropriate steps are taken to see that your staff in slaughterhouses enforce the Specified Bovine Offal Order 1995 fully. Failure to comply with these regulations is an extremely serious matter. I must therefore ask you to make every effort to secure 100% compliance. In particular, your staff must ensure that all SBO is removed from a carcase before they give it a health stamp. Failure to do so should be viewed extremely seriously. ³³

4.563 Mr Hogg explained the significance of this action to the Inquiry:

If you take the Meat Hygiene Service, it was possible for Angela and myself to call in Johnston McNeill, which we did in November 1995, and give him formal instructions . . .

Giving a formal instruction, which was under the framework agreement, which we will also find in the papers, is a very rare thing because it is a re-ordering of priorities. ³⁴

4.564 On the same day, Mr Soul wrote to all OVSs:

It has come to my attention that some members of the profession may have adopted a somewhat laissez-faire approach. They seem to believe that a reasonable level of compliance with the SBO Order is acceptable. That is not the case. Only 100% compliance is acceptable. I am confident that the vast majority of OVSs realise just how important it is for farmers and the UK beef industry that we all strive to ensure that there are no deficiencies with respect to SBO controls in our plants.

I know that I do not need to remind you that there are perceived public health as well as actual animal health implications. We have a duty to ensure that all potential risks to public health as well as all animal health risks are eliminated or minimised. ³⁵

4.565 Also on the same day, Mr McNeill wrote to all MHIs and SMHIs about SBO controls. Mr McNeill stressed:

Any failure on your part to comply fully with your responsibilities will be dealt with as a serious disciplinary matter and may ultimately lead to your dismissal.

Further, if you are obstructed in any way by plant management whilst carrying out this instruction, you must record the incident in your day book and report the matter to your OVS who will be expected to note and act on the incident and report it to the Regional Manager as a matter of urgency. ³⁶

4.566 On 9 November 1995 the Veterinary Public Health Association (VPHA) wrote to all OVSs regarding the SBO controls.

Mr Martin Cooke, President of the VPHA, lent his support to the actions being taken by the MHS to ensure fully effective control of the handling, separation and staining of SBO in licensed beef premises. ³⁷

Further SVS surveillance results and Mr Hogg meets with slaughterhouse operators

4.567 Mr Fleetwood's report to Dr Cawthorne on the October round of SVS visits was circulated on 9 November 1995. Mr Fleetwood reported an overall improvement in the controls across the industry, particularly in respect of staining and record-keeping of SBO, and a reduction in the number of premises which recorded more than one fault during a particular visit. There had also been a major reduction in the failure rate at knacker's yards and hunt kennels. However, Mr Fleetwood reported:

Less satisfactory are the continuing incidents at slaughterhouses where SBOs do not seem to be being separated correctly. I have been keeping yourself and Mr [Timothy] Render informed of the incidents where failure to separate SBO has involved spinal cord in carcasses. The remaining incidents primarily seem to involve poor separation of SBO from other animal by-products being sent for rendering. ³⁸

4.568 Also on 9 November 1995, Mr Hogg met slaughterhouse operators to discuss the failings found with the handling of SBO. ³⁹ A note of the meeting recorded that Mr Hogg expressed deep concern at the findings of recent audits of slaughterhouse practice:

The Minister said that he was therefore insisting on 100% compliance with the SBO controls . . . if there was sufficient evidence to substantiate prosecutions, the MHS should not hesitate. The industry should be clear about this: prosecutions would be undertaken. There would be no further warnings. ⁴⁰

4.569 Industry representatives replied that 'the Minister was preaching to the converted'. While they acknowledged that the system had not always operated as it should have in the past, they pointed out that there had been significant improvements since the MHS took over responsibility. They assured the Minister that the industry was right behind MAFF and would comply with the controls, but insisted that 'it was not possible, with the best will in the world, to prevent very small amounts of SBO material passing unnoticed'. ⁴¹

4.570 The industry pressed for SBO removal cost to be borne by Government or by EU funds. The Minister insisted that compliance must be absolute and that slaughterhouses would bear the costs, at least in the first instance. ⁴²

4.571 Mr Duggins, an International Meat Trade Association representative, was recorded in the note as saying:

The Minister had been misled by his scientists. The industry was totally co-operative. However, there was no possibility of guaranteeing that all SBO would be removed. Perfection was impossible. The Minister should hold fire, at least until he had visited an abattoir himself to be aware of the practicalities. If he were to pursue a prosecution based on a very small piece of SBO attached to a single carcass, he would be laughed out of court. In any event there were a number of practices which should never have been authorised in the first place. ⁴³

4.572 In his oral evidence to the Inquiry, Mr Hogg recalled:

I called them in . . . It was a fairly tough meeting. I read the riot act. It is all in the documents. They were pretty hostile to what they were being told, and actually they were saying, broadly speaking, 'We cannot give you 100 per cent compliance, do not be silly, only go for the serious cases'. I was saying, 'That will not do at all. I intend to prosecute, you will comply and I do not want any excuses, thank you very much'. It was a pretty rough meeting; I do not mind that, that was the way it was. ⁴⁴

4.573 In a press release issued afterwards, Mr Hogg said:

I said that I would only be satisfied with 100 per cent compliance with the rules and informed them that the Meat Hygiene Service would enforce the controls most rigorously. ⁴⁵

4.574 The National Farmers' Union (NFU) issued a Position Statement the following day it which it was noted:

The NFU fully supports the Minister's decision to express his concerns to the abattoirs over their failure to enforce the law on specified bovine offals.

. . .

Should the Minister decide to prosecute an abattoir for failing to comply with the SBO legislation, the NFU would fully support that decision. ⁴⁶

4.575 Also on 10 November, Mr Fleetwood minuted Mr Timothy Render, new Head of Branch B, Animal Health (Disease Control) Division, with a summary of findings on the handling of SBO at knacker's yards and hunt kennels in preparation for Mrs Browning's meeting with representatives of those industries. He noted:

Although the SVS has been active in knacker and hunt premises for some time, detailed record keeping at a central level began in September this year when the new Order was introduced. ⁴⁷

4.576 Accordingly he set out the following table:

September 1995

No of visits	No of visits satisfactory	No of visits unsatisfactory	% unsatisfactory	Fail 1	Fail 2	Fail 3	Fail 4	Fail 5	Fail 6	Fail 7
212	75	137	65	51	22	66	17	72	61	75

October 1995

No of visits	No of visits satisfactory	No of visits unsatisfactory	% unsatisfactory	Fail 1	Fail 2	Fail 3	Fail 4	Fail 5	Fail 6	Fail 7
235	165	70	29	21	11	33	6	29	32	17

4.577 The various numbered columns headed 'Fail' recorded the reason that a particular knacker's yard or hunt kennel failed the inspection. The various reasons were:

1 - Problems with identification, removal or separation of SBO.

2 - Storage of SBO unsatisfactory.

3 - Staining of SBO unsatisfactory.

4 - Patent Blue V stain used on wrong material.

5 - Record-keeping unsatisfactory.

6 - SBO not moving to appropriate destination.

7 - Weight of SBO not consistent.

4.578 Mr Fleetwood noted:

The overall picture that emerges from these results is that the failure rate at these premises is high, although it has halved between September and October 1995. This is encouraging, although overall results are still far from satisfactory. As regards the individual reasons for failure, these are fairly evenly scattered across all the possible alternatives, although with a slight preponderance concerning staining, record keeping and movement of SBO off the premises.

The above results mask a more disturbing trend which appears to be unique to hunt kennels. All have been told that they may not feed vertebral columns to hounds, but it is clear that a number of hunts are deliberately infringing these rules. ⁴⁸

4.579 Mr Render provided Mrs Browning with a background briefing and speaking note for her meetings with representatives of the knackery and hunt kennel industries on 13 November 1995. ⁴⁹ Two separate meetings were held the following day. At the first meeting, Mrs Browning, Mrs Attridge and Mr Fleetwood met a number of representatives of hound associations ⁵⁰ to discuss the handling of SBO in hunt kennels. Mrs Browning outlined her concerns over handling of SBOs at those premises and noted there were a number of significant failings.

These included the inadequate separation of SBO material and poor storage, which risked the material leaking into the animal feed chain. There had also been evidence in some cases that the law had been deliberately flouted. In seven cases hunts had fed whole vertebral columns to hounds despite earlier warnings by the SVS that they were contravening the law by doing so. There was also one case - where a prosecution was pending - in which a hunt had appeared deliberately to have hidden SBO material amongst non-SBO waste. ⁵¹

4.580 Further discussion took place on the treatment of the spinal column and the proper separation and staining of SBOs. An industry representative raised the question of the establishment and operation of incinerators at hunts. Mrs Browning agreed to write to hunt kennel representatives to clarify the position in due course.

4.581 Mrs Browning also held a separate meeting with Mr Chris Ashworth, a representative of the Licensed Animal Slaughterers and Salvage Association (LASSA), the same day. A note of the meeting records that:

Mr Ashworth said that LASSA recognised the importance of the SBO controls, and did not wish to see anyone taking shortcuts. Sloppy practices engendered a disease risk, and would undermine confidence in British meat; that was in no-one's interest. He agreed to convey Mrs Browning's concerns to his members and stress the importance of full compliance with the rules. ⁵²

4.582 Mr Ashworth raised the problem of carcasses being disposed of other than through knacker's yards. He noted that while there had been a substantial decline since 1989 there had been a further noticeable drop since the introduction of the new SBO rules in August 1995. He suspected this was as a result of farmers burying carcasses. He expressed concern with problems which could arise as a result and the need to protect groundwater sources. Further discussion was held on splitting of spinal columns, incinerators and the training of knacker-men on SBO handling.

4.583 On 22 November Mr Fleetwood informed Mr Eddy and Mr Soul that a VO, acting on a tip-off, had uncovered quantities of bovine intestines concealed in bins of best fat which was going for normal rendering. The plant manager had allegedly given specific instructions to gut room operators to conceal the intestines in this way. Mr Fleetwood gave instructions that immediate prosecution should be initiated. ⁵³

4.584 Mr Fleetwood provided Mr Cawthorne with the results of the SVS surveillance of SBO for November on 13 December 1995. He noted that the frequency of visits to slaughterhouses and head-boning plants doubled over the course of the month. He said:

. . . the frequency of unsatisfactory visits has fallen significantly, the overall failure rate falling from 31% in October to 13% in November. This reduction has occurred across the whole of the industry and indicates a general tightening up of all procedures involving SBO. ⁵⁴

4.585 AHC 95/193 was issued on 29 December 1995. It annexed a list of all the head-boning plants, incinerators and collection centres approved under the 1995 Order to receive SBO. ⁵⁵

4.586 On 4 January 1996 Mr Fleetwood minuted Dr Cawthorne with the next report on the outcome of SVS surveillance of SBO. Of a total of 535 visits, only at 34 premises were unsatisfactory practices found. Seventeen of these were slaughterhouses, whilst knackers and hunts accounted for 14. Mr Fleetwood commented:

Once again, a significant improvement in SBO disposal has been recorded compared with the previous month. Very few problems are now being recorded other than a few lingering defects in staining and record keeping. The results for rendering plants appear poor at first glance, but with only three plants visited, a single failure has produced an unrepresentative result.

. . .

Looking at the results as a whole, I think that SVS field staff and MHS staff should be congratulated for their excellent performance which has resulted in significant improvements in the industry. ⁵⁶

4.587 A circular letter was issued on 15 January 1996. It noted that SVS staff had a key role in the operation of the 1995 BSE Order by regular inspection of all premises handling SBO. It charted the improvement in the handling of SBO since the introduction of the Order and noted that SVS staff played a key role in bringing about these improvements. It asked SVS staff to maintain their level of effort so that further improvement could be made. ⁵⁷

Approval of rendering plants

4.588 Mr Render wrote to all rendering plants on 19 January, to remind them of the requirement that plants rendering SBOs must be approved by 15 February 1996 and that premises rendering SBO after that date in the absence of approval would be doing so in contravention of the 1995 SBO Order. He asked that they contact SVS staff for advice on approval. ⁵⁸ On 22 January 1996, AHC 96/10 was issued to all DVMs/DVOs ⁵⁹ noting that premises rendering SBOs required approval by 15 February. It set out instructions for DVMs and DVOs to contact rendering plant operators in order to ensure approval. ⁶⁰

4.589 Following an update from Mr Fleetwood on 2 February, Dr Cawthorne minuted Mr Meldrum on 6 February to inform him that most rendering companies would be unlikely to meet the 15 February deadline. He noted that the delays were due to problems in obtaining planning permission and delivery of new equipment. He noted that a mid to late March deadline would be more realistic. Dr Cawthorne advised that of the possible options available the preferable approach would be to issue exemption licences under the Animals (Miscellaneous Provisions) Order 1927 so that individual renderers could meet new deadlines not later than 31 March 1996. He noted that it was quite clear that plants were actively engaged in upgrading equipment and endeavouring to meet deadlines. ⁶¹ In a manuscript note dated 9 March, Mr Meldrum notified Dr Cawthorne that he was content for the proposed option for approval of rendering plants to be pursued subject to Ministerial approval. ⁶² Mrs Browning's approval was sought on 12 February. A manuscript note dated 13 March indicated that she was content with the submission. ⁶³

4.590 AHC 96/35 was issued on 13 March 1996. It listed rendering plants that had been approved to handle SBO under the 1995 SBO Order. It also annexed a list of any further collection centres, head-boning plants, incinerator plants and premises approved to receive SBO under article 18 of the Order, being premises not connected with food or feedstuffs that had been approved since the issue of AHC 95/193. ⁶⁴

4.591 On 22 March 1996 Mr Stephen Wyllie, who had replaced Mr Fleetwood, circulated the fifth report on SVS surveillance for the month of February. He noted that the failure to separate SBO from other animal by-products was now recorded separately from failure to separate SBO from material for human consumption. He said that 'after the rapid improvements made from the high level of unsatisfactory visits at the start of the survey, the situation seems to have bottomed out, with the overall level of unsatisfactory visits running at 5-6%'. He attached a table which indicated that of a total of 557 visits made only 35, or 6.1 per cent, were unsatisfactory. ⁶⁵

4.592 Government activity on the animal health front was overshadowed following the growing concerns about human health implications in the two months before the 20 March announcement (see vol. 6: Human Health, 1989-96).