Volume 5: Animal Health, 1989-96
4a. Implementation, enforcement and monitoring of the animal SBO ban
Introduction

4.1 The previous chapter described what Mr Maslin called the 'haste and secrecy' with which the animal SBO ban was introduced. The anxiety, shared by Mr Keith Meldrum and Mr John Gummer, that news of transmission to a pig should not break until MAFF was in a position to announce its response to this event resulted in drafting in haste and without consultation.

4.2 MAFF officials, however, took the view that the measure involved 'a very simple, straightforward piece of legislation' which would do little more than give statutory force to arrangements already in place under the human SBO ban and the United Kingdom Agriculture Supply and Trade Association (UKASTA) voluntary ban. ¹ As would become clear, the complexities of extending the ban on SBO to animal feed were far more extensive than MAFF officials had envisaged.

4.3 The 1990 Order, which imposed the ban, made no provisions in relation to the handling and disposal of SBOs, other than that they should not be supplied or used for feeding to animals. There already existed, however, under the Bovine Offal (Prohibition) Regulations 1989 (the 1989 Regulations) detailed regulations governing the handling and disposal of SBOs both in the slaughterhouse and upon removal from the slaughterhouse. These regulations had been made under the Food Act 1984 in order to protect human health. The manner in which they operated in relation to the achievement of that object is considered in vol. 6: Human Health 1989-96. MAFF officials saw those regulations, however, not merely as serving the object of keeping SBOs out of the human food chain, but as providing vital assistance in ensuring that they did not enter the animal feed chain.

4.4 Chapters 4a and 4b consider the implementation, enforcement and monitoring of the animal SBO ban. We shall also see that MAFF looked to enforcement by District Councils of the human SBO regulations as a key element in attempting to ensure that SBO did not enter the animal feed chain. Accordingly, Annex A, which follows Chapter 4b, sets out in detail the provisions of the statutory regime under which both unfit meat and SBO were kept out of the human food chain.

4.5 It was the task of the Veterinary Field Service to monitor the implementation and enforcement of the SBO regulations. As the reader follows the narrative in this chapter, it may not be clear precisely what statutory obligations the Field Service was being expected to monitor. We believe that this may not always have been clear to the officers of the Field Service either.