Volume 6: Human Health, 1989-96
5. Human health developments: 1 January 1991 to 31 March 1995
Hygiene standards and enforcement arrangements in slaughterhouses between 1991 and March 1995
Introduction
Hygiene standards at slaughterhouses during 1991 to 31 March 1995

Introduction

5.13 Chapter 4 provides a brief description of the arrangements for enforcing meat hygiene standards in slaughterhouses, and the extent to which hygiene standards were achieved during 1990. ¹ In essence, enforcement of meat hygiene in slaughterhouses was the responsibility of local authorities and delivered through their Authorised Meat Inspectors (AMIs) and Environmental Health Officers (EHOs) in domestic slaughterhouses and through AMIs and Official Veterinary Surgeons (OVSs) in slaughterhouses licensed for export to the EU. ² Monitoring of these enforcement activities was undertaken by the State Veterinary Service (SVS). We saw that hygiene standards were unsatisfactory during 1990 - a situation that had changed little, if at all, since the Preston Report in 1985. ³

5.14 In this section we look first at evidence - a combination of reports and the views of witnesses - in relation to hygiene standards in slaughterhouses during 1991 to March 1995; the evidence suggests a similar picture to the one we saw in 1990. Then we look at certain aspects of the enforcement arrangements in slaughterhouses, particularly those aspects that received greater attention during this period, largely as a consequence of two particular developments. We cover these two developments in more detail later in this chapter, but mention them here to provide necessary context and background to the issues we propose to cover in the current section.

5.15 The first development was the introduction of the European Single Market (also referred to as the Single Market) on 1 January 1993. Among other things, the Single Market extended the enforcement regime that existed in export-approved slaughterhouses to domestic slaughterhouses, thus requiring higher standards for slaughterhouse buildings and equipment and OVS supervision of AMIs in all slaughterhouses. ⁴ However, it was possible for premises to be granted either temporary or permanent derogations in certain cases. The second development was one of the consequences of the European Single Market, and involved the formulation of proposals, starting in late 1991, for a national system of meat hygiene that was eventually established on 1 April 1995. ⁵

Hygiene standards at slaughterhouses during 1991 to 31 March 1995

5.16 In the following paragraphs we set out evidence on meat hygiene standards at slaughterhouses from 1991 to 31 March 1995. We do not intend to provide a comprehensive account of the standards achieved, as there is limited information on this. Instead we set out the hygiene problems identified as a result of three inspection exercises undertaken for various purposes during the period: in March 1993 by Dr A M Johnston and Mr B J Spurr, in early 1994 by EC veterinary inspectors and in July 1994 by SVS inspectors. We also describe examples of what MAFF Ministers, officials and others knew about hygiene standards during the period. Finally, we look at the deregulatory pressures in play during this period and their effect on those seeking to implement meat hygiene requirements.

Evidence available early in the period

5.17 A summary of results of SVS monitoring of red meat premises for 1988-91 showed that the percentage of red meat slaughterhouses with satisfactory hygiene standards were as follows:

	1988-89	1989-90	1990-91
Domestic	60%	57%	37%
Export	73%	71%	85%

5.18 A footnote to the summary noted:

Method of assessing domestic plants has increasingly taken account of impending single market requirements. The % drop in satisfactory domestic plants reflects, to a certain extent, this change to a stricter assessment. The sharp drop in standards in 1990-91 may also be due to a lack of commitment by plants who think that they will not continue in business after 1992. However, the standard in domestic plants has consistently been lower overall. ⁶

Evidence available from various inspection exercises undertaken during the period

5.19 In October 1992, MAFF commissioned a review by Dr A M Johnston, a senior lecturer at the Royal College of Veterinary Surgeons, and Mr B J Spurr on the progress made towards compliance with European Single Market requirements, in a small sample of slaughterhouses that had applied for temporary derogations. In March 1993, Dr Johnston and Mr Spurr completed their report, entitled Review of hygiene and structural requirements in a sample of slaughterhouses which have applied for temporary derogations under the Fresh Meat (Hygiene and Inspection) Regulations 1992. In relation to hygiene standards in the small number of slaughterhouses which they visited, the report stated:

We found a wide range of structural and hygiene standards in the plants which we examined.

Some plants clearly did not comply with the previous (1977 Regulations) domestic meat hygiene legislation existing before 1 January 1993. In our view, these plants should not have been put forward for derogations and in fact should have been closed many years ago on public health grounds.

Others fell far short of the previous domestic regulations and have serious shortcomings in their operation when measured against the full requirements.

. . .

Overall, the general level of structure and hygienic operation in the plants which we examined fell below what we would regard as a reasonable interpretation of the new Regulations. Even some plants which have made a significant effort to meet the new requirements still have some way to go. The net result of the completion of the current exercise should be a real improvement in standards. ⁷

5.20 From February to May 1994, EU veterinary inspectors undertook surveillance missions to samples of temporarily and permanently derogated slaughterhouses to report on their compliance with derogation and European Single Market requirements. In all, the inspectors visited 57 of the 207 premises operating under temporary derogation at that time, and 16 of the 216 premises operating under permanent derogation at that time. ⁸ (For further information on EU trade with the UK see vol. 10: Economic Impact and International Trade.) Their findings were reported in a general report on The Position in the United Kingdom in Relation to Temporarily and Permanently Derogated Fresh Meat Establishments. ⁹ The findings of the report in relation to hygiene standards were as follows:

Overall 68.5% of the derogated slaughterhouses inspected were of some concern. The 31.5% of the slaughterhouses falling in the 'other' category were not without deficiencies but these shortcomings were estimated to be of less significance.

A further analysis shows that 25% of the permanently derogated slaughterhouses were of some concern whereas 80.7% of the temporarily derogated plants fell into this category. The vast majority of the latter were in England.

. . .

1. Poor overall standards

- 68.5% of the derogated establishments visited were classified as being of concern or of grave concern: this is of particular significance in England where 63.5% of the national kill takes place in the derogated establishments.

. . .

5. Temporarily-permanently derogated establishments

- Many of these low-capacity slaughterhouses, which do not comply with the reduced structural requirements and which have been granted 'derogations' until 31.12.1995, do not aspire to reach the full requirements.

. . .

8. Staff training programmes

- These programmes do not appear to have been generally established.

9. Hygiene checks

- Checks on the general hygiene of the establishments were not, for the most part, carried out.

. . .

11. Visibly contaminated carcases were health marked. ¹⁰

5.21 The report also described a meeting with SVS officials on 20 May, when the Commission inspectors emphasised the general difficulties faced by the UK, and in particular (among other things):

(1) the very low standard of the plants seen and the high/frequent occurrence of gross contamination;

. . .

(5) the system (non-centralised, contractual, extremely limiting insofar as the official veterinarian [OV] is concerned) which was clearly not working in an effective manner. ¹¹

5.22 The report states that, in response, the SVS officials:

(1) did not question the facts as reported on-the-spot but disputed the significance of contaminated meat;

. . .

(5) in answer to the criticism of the present system, claimed that the advent on 1.4.1995 of the Meat Hygiene Service, which will be an agency of MAFF . . . would resolve the difficulties as it would be centralised. The Chief Executive has been recently selected. ¹²

5.23 In respect of the forthcoming transfer of enforcement responsibility to the Meat Hygiene Service (MHS), the report stated:

. . . it is likely that some of the basic problems will not be resolved because the OVs will continue to be employed on a contractual basis, the small amount of time spent by OVs in the plants will hardly alter, it is unclear if regional managers will be veterinarians and the UK does not seem fully ready to achieve the objectives prescribed by the Directive. ¹³

5.24 During 1994, MAFF introduced a new Hygiene Assessment System (HAS) for slaughterhouse inspections by the SVS. The preliminary findings indicated widespread deficiencies. As a result, on 8 July 1994, the MAFF Parliamentary Secretary, Mr Nicholas Soames, ¹⁴ wrote to Mr Paul Cheale, President of the Federation of Fresh Meat Wholesalers from 1993 to 1995, and to Mr John Vernon, President of the National Federation of Meat Traders. Copies of the letters were sent to Mr Don Curry, the Meat and Livestock Commission (MLC) Chairman and to Mr Peter Huntington, the Chief Executive of the Meat Training Council. Mr Soames wrote:

I have been considering with officials of the State Veterinary Service and Meat Hygiene Division the results of slaughterhouse inspections using MAFF's new Hygiene Assessment System. These are, of course, only preliminary findings and further inspections will be needed to provide comprehensive data which can be used to publish meaningful statistics, as we have undertaken to do as part of the move towards greater openness in Government. I am however so concerned about these early results that I think it necessary to write to you now.

The SVS inspectors are finding widespread deficiencies, particularly in the areas of slaughter and dressing and personnel and practices . . . Problems in these areas frequently result in gross contamination of the carcase. They tend to reflect poor standards of workmanship on the part of the slaughtering staff and, very often, lack of management control by the slaughterhouse operators. The HAS scores support the criticisms made by the Commission's inspectors on their recent visit to derogated plants.

Those plants which received the lowest scores are being revisited urgently and revocation of their licence will be considered if they fail to show a substantial improvement. But there is a real need for improvement in hygiene standards in the majority of premises inspected, not just the worst cases. I hope that your Federation will encourage your members to take this seriously. If we cannot achieve a general improvement there will inevitably be an adverse reaction from the public when statistics on hygiene standards are published towards the end of this year.

Many of the problems which the HAS has identified could be dealt with by better training of operatives on the slaughter line. This is a matter for the industry itself to pursue, but MAFF will of course be very ready to provide assistance and advice. Meat Hygiene Division will be in touch with your Federation very shortly to arrange a meeting to discuss this further; I am sure that I can be confident of your strong support. ¹⁵

Examples of what MAFF Ministers knew about meat hygiene standards during the period

5.25 In November 1991, Mr John Gummer, Minister of Agriculture, Fisheries and Food, sent a minute to the Prime Minister, Mr John Major, recommending the creation of a national meat hygiene service in the light of requirements under the European Single Market (as discussed in more detail in paragraphs 5.84-5.93 in this chapter). The minute described, among other things, hygiene standards in slaughterhouses:

At present under the complicated and fragmented arrangements for enforcement, hygiene standards are variable and in a number of cases unsatisfactory. ¹⁶

5.26 With his minute Mr Gummer enclosed a detailed paper on meat hygiene enforcement prepared by MAFF, setting out the background and reasons for his recommendation. One section of the paper, entitled 'Problems with present arrangements', included the following 'difficulties':

iv) Plant standards

SVS monitoring indicates that about 55 per cent of poultry meat plants and some 60 per cent of red meat slaughterhouses do not meet the required standards. Of the plants which are not approved for export to the EC, only 37% of red meat slaughterhouses and 31% of poultry meat slaughterhouses were recorded as satisfactory in 1990. Many plants recorded as satisfactory are only just acceptable, even with regular monitoring and advice from the SVS. In some cases, basic hygiene problems such as failure to sterilise equipment and poor handling of carcases leading to cross-contamination have persisted after repeated written advice from the SVS to the local authority . . .

vi) Inconsistency

Standards of enforcement are uneven across the country. Guidance can of course be given from the centre - and has been given in the past - but liaison arrangements can be cumbersome and costly. Previous attempts to set up Regional Liaison Committees following an earlier review have failed . . .

6. Most of these difficulties have been apparent for some time. They were last examined by the Preston Committee in 1985. At that time the Committee felt that radical changes to the system were not justified and a number of more minor changes were recommended. Not all of these were accepted as practicable by the Government, but those changes which have been made have brought no significant improvements. ¹⁷

5.27 In October 1992, Mr Gummer gave evidence about hygiene standards to the House of Commons Agriculture Committee, which was reporting on 'Progress on the British Presidency and other matters'. He said:

We have real problems with our slaughterhouses. I am not going to name any names, that would be wrong, but I have decided to give an example or two of recent inspections within the last year. On Slaughterhouse A it was reported: 'Slaughter hall floor heavily soiled with blood, gut contents and other debris - no attempt to clean up between carcasses. Car cleaning brush heavily contaminated with blood and fat being used to wash carcasses. Knives and utensils not being sterilised. Offal rack and carcass rails encrusted with dirt. Missing window panes in roof - birds, flies and vermin entering'. Another slaughterhouse report: 'Filthy equipment and surfaces - congealed and dry blood on offal racks. Effluent discharging across floor under dressed carcasses - risk of contamination. Slaughterman at cattle sticking point not sterilising knife. No sterilisers or wash basins in pig slaughter hall. No fly screening on open windows'.

He continued

I will not go on any more. There was the presence of cats in one slaughter house, no vermin or fly proofing. I say this to the Committee because I am as unbelievably enthusiastic about not having regulations if you do not need them but the truth is, and I discovered much of this when I had to face the BSE issue, I needed to be able to stand up in front of the public and say when we suggest certain things that they do happen, they have to happen, in slaughterhouses. Those examples have been put right and our inspections get them put right. I cannot derogate from the general standards of the European Community rules because they are necessary to enable the public to have confidence. ¹⁸

Examples of what MAFF officials knew about meat hygiene standards during the period

5.28 Mr Peter Soul, MAFF Regional Meat Hygiene Adviser, told us about the differing standards in slaughterhouses. He said that during his time in this post:

I visited a large number of premises and I had a very good idea of what the standards were. At that time, of course, there were a number of export approved premises and in general they tended to have much better standards than the domestic plants, but we had visits from Commission Inspectors to the export approved premises, who inspected them and told us what they thought of the standards in those parts and in their view, again in general, the standards in our export approved plants were not as good as they believed they should be. ¹⁹

5.29 Mr Soul was asked whether he agreed with the findings of a visit by EU inspectors to derogated ²⁰ slaughterhouses in 1994, which found that 68.5 per cent of these slaughterhouses had poor overall standards, and were classified by the inspectors as being of concern or of grave concern. He told us:

In terms of the standard against which they were being assessed by the Commission Inspectors, then I would have to agree with that. ²¹

5.30 When asked a further question about the standards Mr Soul himself would have used to assess these premises, he said:

My belief is that the standard that the Commission use to assess premises is the correct standard. ²²

5.31 Ms Bronwen Jones told us that from late 1989 to April 1992, when she was Head of the Red Meat Hygiene section (Branch C) of MAFF's Meat Hygiene Division:

We were certainly conscious that hygiene standards in slaughterhouses were not good . . . So I think we were aware of poor standards, but I could not say whether those were entirely attributable to enforcement or to plant management. ²³

5.32 When asked about whether standards had changed, if at all, during the period when she was in post, Ms Jones replied:

I do not think they got worse, to the extent that over the period we did introduce some of the pre-single market requirements. For example, ante-mortem inspection was introduced [to domestic slaughterhouses] prior to the single market. To that extent, standards ought to have improved, but I certainly do not think there was any more decline. ²⁴

5.33 Ms Jones told the Inquiry in oral evidence that she had never visited an abattoir while Head of Branch C. ²⁵

5.34 Mrs Jane Brown (Head of Meat Hygiene Division since September 1990) told us that in the early 1990s MAFF was becoming increasingly concerned about hygiene standards in red meat slaughterhouses because of the emergence of E-coli 0157:

At around the time that I came into the Meat Hygiene Division I think there was another factor which was making us increasingly concerned about hygiene standards in red meat slaughterhouses, which was the emergence of E-coli 0157, which was a new problem. It caused a severe outbreak in the United States and it was something that we did not know a great deal about at that time, but we realised that here was a problem from which a very small dose could cause very serious illness. So that was a new factor which made us look with more concern than perhaps we might have done five or ten years earlier at hygiene standards in red meat slaughterhouses. ²⁶

Examples of what others knew about meat hygiene standards during the period

5.35 We have set out in Chapter 4 the graphic evidence of Dr Alan Long, of VEGA.