ORGANISATION

PREFERRED OPTION

The Royal Welsh Agricultural Society Ltd

1. Agree that there is a risk, and that steps need to be taken - though there may be difficulties.
2. Possible high cost in policing, and in dealing with surplus meat excluded from pet food use. Result: increased taxation or increased retail prices.

Favour staining unfit meat - but concerned about the possible cost to the pet food industry.

Chartered Institute of Environmental Health (North Wales Centre)

1. Pressed for this, for 10 years - but MAFF resisted, in interests of pet-food manufacturers. Now looking to FSA to put public health first!
2. Unfit meat and associated by-products entering food-chain on a "substantial scale".
3. Stain both 'high-risk' and 'low-risk' poultry by-products (Option 2), and similarly treat low risk red meat by-products (Option 3). Treating all unfit red & white meats the same removes grey areas between the categories.
4. Under Option 1: include in the list of 'high risk' poultry meat by-products any poultry meat or products that subsequently become unfit (e.g. by decomposition or contamination), after being passed as fit.
5. Unacceptability of stained meat to pet owners (Option 3 (8) refers) is secondary to protection of public health. Stains are available, for pet-food, that degrade at high processing temperatures - but use of these might be counterproductive (a potential loophole for the abusers of the system).
6. Legislate against importation of unstained, unfit meat for pet-food use.
7. Provide additional EHO resources, to deal with the problems.
8. No argument in favour of extending staining to cutting plants & cold stores.
9. Documentation: use a similar system to that applied to 'Special Wastes', and rigorously audit.

Options 2 and 3.

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Environment & Health Department, City and County of Swansea

1. Review the definitions of 'high' and 'low' risk, to ensure that all material which could present a risk to human or animal health is included in the 'high risk' category.
2. Some 'low risk' material might enter the human food chain, but by definition this would not present a serious health hazard. This would be preferable to the scenarios outlined in paragraph 8 of the consultation letter, and would be proportionate to the risks involved.

Option 1.

Bob Bell, Advisory Committee for Wales

1. Two different points are being mixed together: (a) the Rotherham and Derbyshire cases - these need to be dealt with; (b) the issue of whether low-risk material is entering the food chain.
2. High-risk poultry meat should be stained, and this should be implemented immediately.
3. At the moment there is insufficient baseline data to confirm whether low-risk material poses a real hazard: this should be considered over the next 6 months and reviewed again.
4. High-risk white meat could be policed by the MHS, along similar line to their current policing of high-risk red meat.
5. The foregoing has no implications for the pet-food or retail industries, and would mean only minor changes for the white meat industry.

Option 1, with a review in 6 months, to consider the need (or not) for option 2.

Public Health Laboratory Service (Wales)

1. Under option 1 pet-food industry could continue using low-risk by-product.
2. The staining requirement could be extended to include any premises producing or handling animal by-products: all high-risk material would then be clearly marked and recognisable. (Effective staining might necessitate some form of pressure treatment or injection.)
3. Staining of pet-food would probably be unacceptable to owners: this might lower demand for home products and "attract imports of uncertain provenance". The latter, if fraudulently diverted into the human food-chain might represent an even greater hazard to human health.
4. Sufficient resources will need to be "available to enforcement and inspection agencies": if these are forthcoming, other approaches might be possible, such as "establishing audit trails for animal by-products from production though to utilisation and disposal".

Option 1.

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The Farmers' Union of Wales

1. Agreed that action is required, and that it must be based on sound science, that it must be drawn up only after consultation, and that it must be adequately funded.
2. However, in view of the increasing amounts of imported meat now entering the food chain via both retail and catering outlets, unilateral measures applied to UK-produced meat would be unjust and might be ineffective.
3. Greater resources need to be allocated to inspection of imported material. (Local Authorities also need more resources to administer Food Standard issues in general.)
4. If a decision was made to stain poultry by-products there would have to be full consultation specifically on amendment of the ABPI Regulations: this would permit the Industry to comment further. The FSA should consider carefully the consequences for businesses.

Not in favour of unilateral UK measures