Volume 6: Human Health, 1989-96
Annex 1 to Chapter 4: Unfit meat and human food
CIEH criticisms of the system

4.854 The Chartered Institute of Environmental Health (CIEH) was one of the groups at the forefront of the lobbying for legislative change which took place in the wake of 'Operation Meathook'. However, whilst the regime set up by the 1982 MSSR built upon suggestions of the CIEH, its suggestions were not adopted in their entirety and the CIEH continued to have serious concerns about the scope and terms of the regime into the 1990s. ¹

4.855 The CIEH submission to the Inquiry attached the transcript of a talk given by Mr K J Tyler, the CIEH Secretary, speaking at the CIEH Congress in 1982. Mr Tyler quoted from a letter sent by the Meat Legislation Review Group of the CIEH to MAFF on 7 June 1982 commenting upon the draft proposals for the 1982 MSSR:

The institution raises as a fundamental objection the proposed exclusion of offal and poultry meat from the full requirements of the Regulations, and in particular to staining and sterilisation. However, following consultations with various sections of the food trade and the Pet Food Manufacturers Association, the Institution may be prepared to make some concessions in respect of offal. The Institution is adamant that all offal emanating from knacker yards and unfit offal from slaughterhouses should be included within the staining and sterilisation requirements. In relation to imported offal for use by the pet food trade the Institution is prepared to consider foregoing the staining and sterilisation requirements but only if the licensing requirements for this importation are tightened up, i.e. that only bonafide petfood processors of this inedible offal are licensed to import. In other words the institution would be opposed to a dealer importing this product and then hawking it around the market in the hope of finding a buyer. ²

4.856 However, in the event, as has been seen, a decision was taken to exempt 'non-specified offal' from the stricter requirements applied to carcass meat and 'specified offal'. ³ Consequently, a regime came into being, about which Mr Tyler said the following:

We now have three different types of offal:- specified, green, any other. Some is stained, some is not; some is sterilised, some is not; dependant on where it is going. Some whether it is stained, sterilised or not requires a movement permit. I hope that all local authorities understand and interpret the Regulations in the same manner or confusion may well reign. Perhaps I am being rather too pessimistic: yes, the Regulations are complicated and the paperwork which the institution wanted, 'the 'paper' control', but only when the Ministry did not meet our original demands for all meat and offal to be either stained or sterilised and for there to be no exemptions to that rule. Had that been the case no paperwork would have been required. ⁴

4.857 Moreover, even after the 1982 MSSR were introduced, the CIEH continued to harbour concerns about the broader unfit meat regime. In a 1990 paper entitled 'The Illegal Trade in Unfit Meat for Human Consumption' they drew attention to a number of these:

LEGISLATIVE FRAMEWORK

The original report called for changes in legislation available to enforcement authorities. Yet subsequent changes in the Meat (Staining and Sterilisation) Regulations and the Food Act 1984 failed to effectively control unfit meat.

- There were no changes in the existing unsatisfactory system of meat marking. The IEHO recommended a system of roller marking.

- It is still not an offence to possess an unauthorised meat inspection stamp.

- There has been no change in the reference to 'for sale' in the Meat Inspection Regulations. Constant enforcement problems are experienced when the 'owner' insists that a carcass is not intended for sale for human consumption. (This will change with the inception of the Food Safety Act).

- The BVA has introduced a new form for the Veterinary Certificate for Slaughterhouse Admission for Sick and Injured Animals, yet there is no legal requirement for proper documentation, and vets may continue to submit 'back of cigarette packet' certificates. There are still instances where vets certify dead animals for admission to a slaughterhouse, although this is illegal.

- There are no inspection requirements for knacker's yards, which may be adjacent to slaughterhouses and which should be under similar control.

- Knacker activities at unfit meat places such as zoos and hunt kennels are still outside the scope of licensing requirements.

- There are no requirements for the labelling of boxed meat at the wholesale stage despite stringent controls at the later, retail stage.

RECOMMENDATIONS

A. All local authorities should urgently seek to identify areas of potential risk. In particular, EHOs should step up their checks of meat arriving at school and hospital kitchens and other institutions. Core samples should be taken for bacteriological examination and checks made back through the meat supply chain.

B. The Institution should set up a liaison network with other involved professions to establish closer working relationships.

C. Legislative controls must be introduced to cover knacker's yards and other associated activities, including hunt kennels. Legislation must be quickly introduced to alter the meat stamping system.

D. Casualty slaughter must carefully controlled, while preserving the prime motive of preventing suffering to the animal.

E. Collection areas of knacker men/fallen stock collectors must be defined, with fixed unfit meat labelling to vehicles and it made an offence to sell dead animals to anyone other than a licensed operator.

F. Careful consideration should be given to the effectiveness of the Meat (Staining and Sterilisation) Regulations and to seek changes where necessary. ⁵