Volume 6: Human Health, 1989-96
6. Events from 1 April to 31 December 1995: human health returns to the agenda
The Meat Hygiene Service (MHS)
The transfer of staff from local authorities to the MHS
Surveys of standards at slaughterhouses commissioned by the MHS from April to December 1995
Discussion

6.23 In Chapter 5 we described the background to the decision by Ministers to establish a national system of regulation of meat hygiene, and developments in relation to this up to the end of March 1995. The new national MHS was launched as an Executive Agency of MAFF on 1 April 1995, with Headquarters at York and operating in England, Wales and Scotland. From that date responsibility for meat inspection activities at slaughterhouses and certain other premises was transferred from local authorities to central government. Under the Bovine Offal (Prohibition) (Amendment) Regulations 1995, central government's enforcement role was to include the ban on SBO in human food. ¹ It was the task of the MHS to carry out this enforcement role on behalf of central government.

6.24 Mr Johnston McNeill was the Chief Executive of the MHS, reporting to Mr Carden, who as well as being the Head of Food Safety Directorate at MAFF was the Chairman of the MHS Ownership Board. ² Mr Philip Corrigan was Head of Operations until August 1995, when Mr Peter Soul became Acting Head of Operations. In December 1995 Mr Soul became Director of Operations.

6.25 The MHS Framework Document set out various details about the Service, including the legal framework in which it operated, how it was organised, its aims and functions:

Legal Framework

1.3 The MHS is an agency established by the Minister of Agriculture, Fisheries and Food ('the Minister') to fulfil the functions of the Minister and Secretaries of State for Scotland and Wales in relation to hygiene, inspection and welfare enforcement in licensed fresh meat establishments required by relevant European Community Directives. These statutory functions may additionally be supplemented by the Ministers' common law powers.

Organisation

2.1 The MHS is headed by a Chief Executive who is responsible for the day to day management of the Agency in accordance with this Framework Document. He is supported by a senior management team and a total of some 950 staff at 1 April 1995. The MHS is organised on a regional basis and most of its staff work in licensed fresh meat premises.

Aim

3.1 The aim of the MHS is to safeguard public health and animal welfare through fair, consistent and effective enforcement of hygiene, inspection and welfare regulations.

Functions

3.3 The MHS discharges the responsibilities of the Minister and Secretaries of State for supervision, inspection and enforcement of meat hygiene and animal welfare in fresh meat establishments licensed by the Agriculture Departments. The principal functions of the MHS are:

(a) the enforcement of hygiene rules in licensed fresh meat premises

(b) meat inspection and health marking in licensed fresh meat premises

(c) the enforcement of hygiene controls in meat products plants which are integrated or co-located (on the same site) with licensed fresh meat premises

(d) the enforcement of welfare at slaughter rules in licensed red and poultry meat slaughterhouses

(e) the collection and despatch of samples for statutory veterinary medicines residue testing on behalf of the Veterinary Medicines Directorate

(f) the collection and despatch of samples for examination and testing on behalf of the State Veterinary Service

(g) the enforcement in licensed slaughterhouses of controls on veterinary medicines residues

(h) the enforcement in licensed fresh meat premises of controls over specified bovine offals and other animal by-products, and

(i) to provide export certification when required either by the importing country or by Community rules.

3.4 The Minister will provide the Chief Executive with guidance on carrying out these functions in an Operations Manual. ³

6.26 The Framework Document also described the role of the Chief Veterinary Officer (CVO) in relation to the MHS and its staff:

3.5 The Chief Veterinary Officer (CVO) is head of the State Veterinary Service (SVS) and is responsible to Ministers for the protection of public and animal health. In particular, the CVO must be able to demonstrate that the health mark is applied only to meat produced in accordance with European Community rules and that meat exported to third countries complies with the conditions imposed by the importing country and is accompanied by any necessary veterinary certification.

3.6 The CVO and the Chief Executive will agree each year arrangements for the State Veterinary Service to audit compliance with the legislation and the professional/technical performance of the MHS.

3.7 The SVS designates Official Veterinary Surgeons (OVSs) and Local Veterinary Inspectors (LVIs) on behalf of Ministers and may recommend suspension of that designation. Export conditions are negotiated and certificates are issued by the Animal Health and Veterinary Group of the Department and OVSs/LVIs employed by the MHS must abide by any instructions in relation to such certificates. On rare occasions it may be necessary for the CVO to issue instructions directly to Official Veterinary Surgeons where, for example, a major disease outbreak may require an export certificate to be withdrawn or modified. ⁴

6.27 The foreword to the Framework Document was signed by the Minister of Agriculture, Mr William Waldegrave, and included the following comments:

. . . The MHS was not previously a part of the Ministry of Agriculture, Fisheries and Food. Its establishment has involved not only the development of a completely new management organisation but also the transfer of staff from local authorities.

In March 1992 the then Minister, John Gummer, announced the intention, following a major review, to create a single agency to be responsible for enforcement of meat hygiene in Great Britain. In the three years since that announcement a great deal of effort has been put into creating a new, single management and operational structure to take on work carried out previously by local authorities. The great majority of MHS staff transferred to the agency on its establishment. They have come from some 300 local authority employers and bring with them a wealth of different experience. I welcome them to the new national service . . .

Operating throughout Great Britain the MHS will provide common and consistent standards of enforcement and provide the fresh meat industry, for the first time, with the opportunity to discuss issues with a single enforcement agency. This consistent service, on a standard basis for all operators, is something for which the industry's representative organisations have long pressed. The organisation and operation of the MHS has been established to ensure that it provides high quality services in a cost effective manner to the industry it serves. ⁵

6.28 Mr Alan Lawrence, who headed the MHS Project Team, described the strengths of implementing the MHS in his statements to us:

Some of the strengths and opportunities identified in adopting this option were that the responsibilities would rest with one organisation, which would be accountable to Government, a pool of trained, experienced staff would be available for enforcement; uniformity of national standards by starting with a new organisation; best practice, standards and structure could be instituted; recruits could be inculcated with the spirit of the Agency. ⁶

. . .

. . . in my opinion the key features to a successful launch and development of the MHS were: -

- the operations manual (to provide consistency through written procedures and be subject to continuous review);

- the provision of training in all aspects of the MHS's activities;

- the hygiene assessment system;

- the ability to respond rapidly to any new guidance/instructions from MAFF.

. . . I thought none of this would have been possible under the old regime.

I think all of these key features are in fact elements in a move towards the introduction and implementation of quality assurance/HACCP [Hazard Analysis Critical Control Point] techniques, both for plant management and the enforcement authorities (MHS (as the delivery arm) and MAFF (auditing the performance of the delivery arm)). ⁷

6.29 Mr Lawrence also told us:

In my view, the MHS is delivering what it set out to do, which is 'to safeguard public health and animal welfare through fair, consistent and effective enforcement of hygiene, Inspection and welfare regulations'. I think too, that the organisation which the Project Team developed has, to a large extent, been vindicated.

To quote a recent article:

'When the MHS was established in 1995, the concept of a nationwide service taking over from the local authorities in the inspection of meat in abattoirs and cutting plants was greeted with some scepticism. There were fears about bureaucracy and increased costs to the industry.

Three years on, the MHS has become an integral part of the industry that has undergone turbulent times and faced one crisis after another. With the burden of inspection increasing through BSE, clean livestock regimes and srm regulations, there are doubts whether the fragmental system that ran before the centralised national service could have coped with current pressures.' ⁸

6.30 Mr Richard Packer, Permanent Secretary of MAFF, was asked during oral evidence about the delay in establishing the MHS, bearing in mind that the proposal to introduce a national meat hygiene inspection system had been made by Mr Gummer in July 1991, when he was Minister of Agriculture. In his reply he commented on the effect of the MHS on standards of SBO controls within slaughterhouses.

MR WALKER: . . . Can you say whether that may have had an effect on the BSE story? Would things have been different if the Meat Hygiene Service had been up and running at the time planned rather than one year later?

MR PACKER: That I could not say. What I could say is that the decision to go ahead with the Meat Hygiene Service has, in my view, proved to be a very well founded one, and standards of SBO controls across the board have been driven up in a way which would - SBO controls of course being an important but a relatively small part of the duties of enforcement in slaughterhouses. The standards have been driven up in a way which would - which I doubt whether it would have been possible under the previous system.

MR WALKER: Do you think that the existence of those standards helped in dealing with BSE?

MR PACKER: I think there must be a lot in the proposition that the higher standards are across the board, the more comfortable one feels. ⁹

6.31 Mr Richard Carden, MAFF Deputy Secretary and Head of Food Safety Directorate, was also of the opinion that the MHS had improved standards in slaughterhouses.

The Meat Hygiene Service quickly came to serve a key role in helping MAFF to step up the effectiveness of BSE-related (SBO) controls in slaughterhouses, as well as to move standards of hygiene in slaughterhouses to a markedly higher level than had been achieved under the previous (local authority operated) system. ¹⁰

The transfer of staff from local authorities to the MHS

6.32 Mr Peter Soul discussed the transfer of staff from local authorities to the MHS in his statement to us:

It was clear that many local authority staff working in licensed abattoirs had not been trained in enforcement and had not had an enforcement culture instilled into them. Most of these individuals transferred into the MHS on 1 April 1995 under the Transfer of Undertakings (Protection of Employment) legislation (TUPE). MHS management was faced with a major challenge to change the culture of these same individuals in order to achieve effective enforcement of all the legislation (not just the SBO Order).

This cultural change is being brought about by means of various training initiatives, better, clearer and more comprehensive instructions, more effective management, incentives in key areas, the introduction of quality systems and audit and a strict, firm but fair disciplinary code for all MHS staff. ¹¹

6.33 Mr Johnston McNeill, Chief Executive of the MHS, discussed the attitude to the SBO Regulations of meat inspectors transferring into the MHS:

. . . some scepticism prevailed . . . that perhaps this was an animal health issue and whilst the regulations were there, there was no chance of a risk to public health, and was it really essential and a bit of apathy existed which concerned us at that time. ¹²

Surveys of standards at slaughterhouses commissioned by the MHS from April to December 1995

6.34 In this section we look at two surveys on slaughterhouse standards commissioned by the MHS. First, we note a report about standards at slaughterhouses from a partnership of private veterinarians which provided Official Veterinary Surgeon (OVS) inspection services - Eville & Jones. ¹³ This report was furnished in August 1995, but we look at it first because its aim was to describe the position as they were aware of it on 1 April 1995. Second, shortly after its launch the MHS started 'a major benchmarking exercise to assess standards within the industry'. ¹⁴ This exercise was taken forward within the MHS by Hygiene Advice Teams (HATs).

Report to MHS from Eville & Jones - Veterinary Meat Hygiene - on deficiencies in SBO controls at slaughterhouses

6.35 On 17 August 1995 Eville & Jones submitted a report to Mr Corrigan summarising deficiencies in SBO controls as at 1 April 1995 in slaughterhouses they had visited. The report was recorded as being prepared in response to a request from the MHS and noted (among others) the following deficiencies:

1. Northern England and Scotland

a. Glasgow

- Incomplete removal of spinal cords

- Pieces of intestines removed with mesenteric fat and not treated as SBO

- Lack of awareness of SBO legislative requirements and poor understanding of SBO control . . .

c. Huddersfield

- Incomplete removal of spinal cord

- Obvious lymphatic tissue and nervous tissue not removed during boning

d. Derbyshire

- Poor spinal cord removal

- Bovine intestines being included in bins of fat and not stained

2. Eastern England

a. Norfolk

- Incomplete removal of all SBO from carcasses . . .

3. South West England and Wales

- Lack of awareness from plant staff as to what constitutes SBO

- Poor removal and separation of SBO

- Cutting plants uncertain as to SBO legislative requirements

6.36 The report noted in conclusion that 'most of the points outlined in this report have undergone significant improvement over the last five months since 1 April 1995'. ¹⁵

6.37 Mr Corrigan forwarded the report to Dr Richard Cawthorne, the Veterinary Head of MAFF's Notifiable Diseases Section, on 23 August 1995. He noted that the report supported 'the viewpoint that the general level of compliance was very poor'.

However, through the combined efforts of the SVS and MHS, I am now confident that there is at present a far greater (hopefully 100%) level of understanding and compliance in this regard.

As you are aware, the MHS continues to give the highest priority to SBO control and to the imminent EU review. ¹⁶

6.38 On 24 August Dr Cawthorne forwarded a copy of the report to Mr Soul of MAFF's Meat Hygiene Section, Dr Danny Matthews, Senior Veterinary Officer, and Mr Andrew Fleetwood. He said:

You will be interested to see the results of this survey carried out by Eville and Jones on behalf of the MHS prior to April 1995.

The results are historical and events have overtaken them. However, I have to ask myself why the deficiencies identified were not brought to the attention of the SVS or MHD. ¹⁷

6.39 Mr Fleetwood commented on the report in his statement to us:

These findings corroborated (and had been superseded by) our own investigations, in which every plant in the UK had been visited. However, as Dr. Cawthorne recorded, neither the SVS nor Meat Hygiene Division at MAFF (and certainly not myself) had previously received this information. I found that very surprising. ¹⁸

The MHS HAT survey to assess various aspects of slaughterhouse standards

6.40 At the time of its establishment, the MHS had limited information about the standards in licensed fresh meat premises that it had inherited from the local authorities. Consequently it initiated a survey shortly after its launch to provide more comprehensive information. The survey was undertaken by its OVSs and meat inspectors organised into HATs, as described by Mr Soul in a statement to the Inquiry:

Following the launch of the MHS on 1 April 1995, a major exercise was undertaken to benchmark standards in the meat industry. This exercise was dubbed the 'Hygiene Advice Team' or 'HAT'.

Teams of experienced Official Veterinarians and Senior Meat Hygiene Inspectors visited all full throughput abattoirs during 1995 and conducted a thorough and detailed inspection of hygiene and animal welfare standards and made an assessment of manning levels.

A detailed report was produced by each team following each visit to a premises and sent to the relevant Regional Manager and copied to MHS HQ in York. ¹⁹

6.41 Mr Soul also told us about the purpose of the survey:

To assess operational hygiene and animal welfare standards as soon as possible after launch. The HAT provided a detailed database of information and baseline standards against which the MHS's progress could then be measured.

To review staffing levels in order to correct anomalies which had existed between different local authorities and to achieve consistency of inspection levels within plants. The HATs reviewed the level of Official Veterinary Surgeons (OVS) supervision and meat inspection hours for each plant and made recommendations to the Regional Managers and Head of Operations.

To provide technical advice to plant operators and MHS staff in order to promote best practice and improvements in standards where appropriate. ²⁰

6.42 Mr McNeill told us that the HAT teams spent a day at each slaughterhouse:

. . . assessing standards of operation, considering the appropriateness of the Inspection levels and advising MHS operational staff and plant management on how standards could be improved. Most of the HAT assessment focused on the hygiene and animal welfare standards but two points on the assessment form were relevant to SBO controls:

point 7.26 - 'MHI's involvement in trimming before health marking';

point 7.27 - 'Cattle: spinal cord removal before inspection'. ²¹

6.43 The HAT survey assessed the slaughterhouses using a hygiene performance indicator known as the Hygiene Assessment System (HAS), giving a score out of 100 to each of the premises visited. The aim was to provide a basis for comparing standards in slaughterhouses, and for monitoring progress in improvements of hygiene standards. ²²

Results of the HAT survey in relation to removal of SBO

6.44 On 13 July 1995 Mr Corrigan circulated a minute on SBO controls to MHS inspection teams. He reported that monitoring results from the HAT teams had indicated that 'at some beef processing plants further improvements in SBO control and certification practices are still required'. He continued:

Included please find a SBO Control Responsibility Check List. Once again I request that necessary steps are taken to ensure that each member of the plant MHS team (OVS, SMHI and MHIs) and relevant plant personnel are fully aware of the detail and requirements of SBO controls and ensure that they are being fully complied with. ²³

6.45 The SBO Control Responsibility Check List was given as follows:

The handling, identification and control of SBO is part of the national BSE control strategy.				MAFF/MHS/INDUSTRY
SBO must be correctly separated from other material.				INDUSTRY
SBO material is:-	spinal cord brain spleen tonsils		of bovine animal over the age of six months at the time of slaugter	INDUSTRY
	intestines thymus		of bovine animal (irrespective of age at the time of slaugter)
All SBO (particularly spinal cords and tonsils) must be removed completely.				INDUSTRY
SBO material must be stained (whole of the surface of the material is covered) with Patent Blue V stain. - Patent Blue V stain must be supplied by Industry.				INDUSTRY INDUSTRY
Pending removal from the premises SBO must be stored in containers or a room set aside for this purpose.				INDUSTRY
SBO may not be removed from the premises of origin Unless accompanied by a Movement Permit (England/Wales), Consignment Note (Scotland).				INDUSTRY
The MHS is responsible for issue of Movement Permits/Consignment Notes for SBO moved from the premises. - ultimately a copy of the permit with the relevant sections completed should be returned to the point of origins and acquitted with the original.				MHSS
Details are outlined in Chapter 10 MHS Operations Manual				INDUSTRY/MHS
Promotion/Extension/Education of national importance and details of SBO control procedures.				MAFF/MHS/INDUSTRY
Monitoring of effectiveness of SBO controls				MHS/MAFF a

a YB95/7.13/2.2

6.46 Mr McNeill told us about the results of the HAT survey in relation to removal of SBO:

Approximately 14% of the HAT reports indicated that HAT team members gave advice on SBO controls in the 7.27 category ['Cattle: spinal cord removal before inspection'] during their visits. In addition it was identified that in some plants SBOs such as tonsils, thymus and spinal cord were not fully removed from all beef carcasses before presentation for inspection by MHS staff. In some plants, MHIs routinely removed SBO as part of the accepted practice. This practice was not accepted by the MHS. ²⁴

6.47 Mr William Swann, a member of the HAT team, told us that 'early in the HAT exercise, the level of non-compliance with SBO control regulations caused MHS Head of Operations to issue memoranda to all OVSs and MHIs to instruct them to be particularly diligent in this area'. Mr Swann described the deficiencies in SBO controls he had encountered:

Specifically, incomplete removal of spinal cord, failure to remove thymus, failure to separate spleen, failure to stain SBOs, failure to mark SBO containers, deficiencies in paperwork and failure to remove SBO spillage from abattoir floors were all noted. More than 40% of all plants showed some degree of non-compliance with SBO regulations; this represents a higher level of non-compliance in beef plants. ²⁵

6.48 Mr Swann also said that:

The HATs found deficiencies in the ability of some regulating staff to recognise SBO control irregularities. Some OVSs were unable to identify bovine thymus, some MHIs were not aware of the importance of the need for complete removal of spinal cord. ²⁶

6.49 Another member of the HAT team, Mr Christopher Clark (an experienced MHI) ²⁷ provided us with a summary of the notes he had made in relation to SBO controls during his HAT survey visits to 57 beef slaughterhouses. ²⁸ For category 7.26 [MHIs' involvement in trimming before health marking] of the HAT assessment form, Mr Clark recorded that 56 slaughterhouses were satisfactory and one was unsatisfactory because the MHI was removing tonsils. For category 7.27 [Cattle spinal cord removal before inspection] he recorded that 46 slaughterhouses were satisfactory and 11 were unsatisfactory. Of these 11 plants, ten were unsatisfactory because there was incomplete removal of spinal cord, and one because the spinal cord remained after health marking.

6.50 Mr Clark also told us that the reports and assessment forms from the HAT teams' visits were sent to the Regional Director, who would then forward it to the MHS Headquarters, which then sent the reports and the results of the HAT assessment to the slaughterhouses. ²⁹ He told us that in relation to the hygiene and other deficiencies recorded by the HAT survey:

. . . clear instructions in the form of a standard letter were issued to all MHIs and SMHIs by the Director of Operations as to how the Regulations must be interpreted and compliance enforced. ³⁰

6.51 Mr Clark also commented on the impact of the HAT survey on the compliance with the relevant regulations:

Audits of the nature carried out by HATs were a new experience for the management and staff in many plants. Previous experience was for auditing inspectors such as MAFF veterinary officers, on their periodic inspections, to arrive mid morning and to depart, in many cases, a few hours later. A written report would follow. In my experience, although these auditing inspectors would speak to the management of the plant and the Principal Environmental Health Officer/Environmental Health Officers, very often the Authorised Meat Inspectors and plant staff would not be involved in any discussions, or advised of the content of these reports.

It is my view as a result of the HAT visits, a significant improvement in compliance with the Regulations was achieved. The main reasons for the improvement, in my opinion, may be attributed to the following factors.

(a) Many of the deficiencies identified by the HAT audit would have been present prior to 1 April 1995, but had not been identified or dealt with by visiting auditors prior to the establishment of the MHS. It is my understanding, from discussions with MHIs on HAT visits, that in some instances Authorised Meat Inspectors had not been supported by their Environmental Health Officers in their efforts to enforce the Regulations. In other cases, prior to the MHS, I was told that some Local Authorities had failed to give clear instructions to their staff with regard to SBO controls. In contrast, the MHS provided (and still provide) a great deal of information to MHIs (and HATs) on the relevant Regulations in force by way of loose-leaf updates to the MHS Operations Manual and Regulation book.

(b) The HAT checklist was very detailed and therefore highlighted any problems (including those relating to SBOs even though this was not the main concern of the HAT audit)

(c) The follow-up procedures after each visit were, I believe, effective in bringing about improvements through a combination of education and rigorous enforcement. ³¹

Preparation of the HAT report

6.52 By October 1995 most of the HAT visits were complete. On 5 October Mr McNeill, Mr Corrigan, others from the MHS and a representative from MAFF (Tolworth) met to discuss the preparation for publication of the final report of the HAT survey. ³² The meeting agreed, among other things, to set up a technical group to write 'discrete parts of the Core Elements of the Report to be adopted and worked to by the rest of the Technical Group'. ³³ Included in this group was Mr William Swann, who was to act as the editor for the section of the report on the red meat audit. ³⁴

6.53 Mr Soul told us:

The remit given to the Technical Group was to produce a report covering all aspects of the HAT exercise together with a summary of the main findings from all the HAT visits and the main recommendations resulting from the whole exercise. Separate sections of the report were to be produced on red meat and white meat. The remit called for a balanced summary of the findings of the HAT exercise. ³⁵

6.54 On 14 December Mr Swann presented his draft report on the MHS HAT exercise in red meat slaughterhouses to the editorial group.

6.55 On SBO the draft report stated as follows:

Meat Inspectors are frequently expected to trim visible contamination, remove SBO, expose kidneys and strip pleura. It is recommended that, with the possible exception of bovine tonsil removal, all these practices should be the responsibility of the plant staff.

Spinal cord was not fully removed from all bovine carcases. Bones containing spinal cord may be processed into animal feed, providing a possible source of infection to cattle. ³⁶

6.56 The draft report continued:

Inspection deficiencies included procedural irregularities and SBO retention, in a number of plants, especially those with fast line speeds. ³⁷

6.57 Mr Soul told us that the technical group had reflected on Mr Swann's draft and:

The group was largely content with Mr Cooke's draft on the white meat sector but considered that Mr Swann's draft on the red meat sector did not reflect a balanced summary of the findings of the other members of the Technical Group and hence of the whole HAT exercise. Although Mr Swann personally undertook many HAT visits (albeit in only a limited area of the country) the editorial group considered that his draft placed too much emphasis on his own opinions rather than the overall findings of all the HATs. As a result, Mr Swann's draft was considered by all the other members of the editorial group to be excessively negative and critical of much of the meat industry. It was proposed at the meeting on 14 December 1995 that he should revise the text. He declined and I received the typed copy of his completed draft on 19 December 1995.

In addition, the editorial group and I had other wider concerns about some aspects of Mr Swann's first draft of the red meat part of the report relating to the false conclusions that readers of the report might draw based on information in the report that I and others considered to be open to misinterpretation . . . The drafts were also copied to Mrs Jane Brown of Meat Hygiene Division (MHD) of MAFF on 22 December. MHD agreed that some aspects of the report fell outside the original remit given to the Technical Group and should be re-written. I believe there was general agreement within MHD that Mr Swann's draft was excessively negative and unfairly critical of much of the meat industry. I received confirmation that MHD shared the concerns of the editorial group by telephone around January 1996.

. . .

The overall impression given by Mr Swann's draft was misleading because many readers would infer that all or most of the deficiencies listed were observed by HATs at all or most plants. This was not the case. Mr Swann's draft was also misleading because he did not make clear that much of the advice given by the HATs concerned recommendations regarding best practice rather than identifying statutory non-compliances. ³⁸

6.58 As a result of these perceived difficulties Mr Swann was asked to revise the text. He declined to do so. ³⁹ Mr Martin Cooke, who had written the white meat section of the report, then redrafted the red meat section at the request of Mr Soul. ⁴⁰

6.59 The final summary report of the HAT exercise was published in August 1996. ⁴¹ In relation to SBO the report stated:

SBO removal in the slaughterhall was carried out in accordance with the legislation. ⁴²

6.60 Mr Swann considered that the final report:

omitted key recommendations considered of paramount importance by the original editorial group. ⁴³

Discussion

6.61 We have considered carefully the evidence in relation to the HAT survey and, in particular, that provided by Mr Swann and Mr Clark. So far as removal of SBO is concerned, we have found the evidence consistent with the results of the Eville & Jones survey (see paragraphs 3.35-3.36) and the subsequent SVS surveillance. Shortcomings were isolated rather than widespread.

6.62 We have concluded that Mr Soul, the Technical Group and Meat Hygiene Division acted fairly and objectively in concluding that Mr Swann's draft report should be revised in order to present a more balanced picture; this was not an exercise of censorship.

6.63 In the revised report it was stated baldly that SBO removal in the slaughterhall was carried out in accordance with the legislation (see paragraph 6.59). This presented a fair summary of the overall position, although a more precise picture would have been presented had the words 'in general' been added.