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Further Written Evidence Submitted by the British Meat Processors Association

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Further Written Evidence Submitted by the British Meat Processors Association House of Commons Environment, Food and Rural Affairs Committee Food contamination Written Evidence Only those submissions written specifically for the Committee and accepted by the Committee as evidence for its continuing inquiry into Food Contamination are included in this document. Evidence relating to the Committee’s interim report on Contamination of beef products is available in volumes II and III of the Eighth Report, on the Committee’s webpages here: www.publications.parliament.uk/pa/cm201213/cmselect/cmenvfru/946/946ii.pdf www.publications.parliament.uk/pa/cm201213/cmselect/cmenvfru/946/946iii.pdf List of written evidence 1 British Meat Processors Association (further written evidence) 1 2 Bob Forsyth 2 3 National Pig Association 3 4 Local Government Association 5 5 ABP Food Group (supplementary written evidence) 7 6 Association of Public Analysts 9 7 The European Commission 12 8 McAdam Food Products Ltd 36 9 Greencore Group PLC 38 10 Food Standards Agency (supplementary written evidence) 41 11 ZooTrack Systems 49 12 Food Safety Authority of Ireland 54 Further written evidence submitted by the British Meat Processors Association The incidents of gross contamination of some beef products and mislabelling have undermined consumer confidence and trust in the meat industry, and have caused reputational damage to it. We take the matter most seriously. It is important to fully establish the facts as the basis for identifying effective ways to address the issues raised. The BMPA and its members are cooperating with the FSA in carrying out tests on a wide range of products and publishing the results. We have also urged our members to be vigilant, and to review their raw material and ingredients sourcing policies in order to ensure that they meet their responsibilities to produce safe food and to describe and label their products accurately. The FSA has quite rightly made a clear distinction between gross contamination due to negligence or fraud, and incidents where powerful DNA testing technology is able to detect low level traces of unintended material in normal manufacturing operations. It is very important to recognise that all the evidence to date regarding the instances of gross contamination points to fraud – unlawful behaviour on a serious scale, but in a comparatively small number of product lines and supply chains. We look to police authorities to find and prosecute the perpetrators. There is not a systemic breakdown of the meat supply chain; it would be misleading and would not serve the best interests of consumers or the food industry to suggest this in any way. Some have suggested that modern food supply chains are too dependent on trust. To a considerable extent, the system must rely on a high element of trust, and the assumption that operators adhere to the relevant legislation. It would be unworkable to found a modern livestock and meat production system on the basis that everyone is or may be a crook. The great, great majority of food businesses have very high technical and ethical standards. They meet their responsibilities 365 days, year in, year out. They should not be tarred with the brush of crooked operators. These incidents will no doubt lead to wider use of testing, and calls for more regulation. On testing, it is important to ensure that the thresholds of properly validated DNA testing are consistent with good hygiene and manufacturing practices. We must also recognise that at low threshold levels, the tests are not completely reliable. The tests are also costly. Any further measures – whether required by regulators or initiated by industry – must be relevant, workable, risk-based, proportionate and affordable. We will achieve little if we knee- jerk respond to recent events and simply add further cost into the supply chain, and so exacerbate the very problems that some point to as part of the explanation for the current incidents. There will also be calls for blanket country-of-origin labelling, not only of fresh meat, but also of processed products using meat as an ingredient. However, country-of-origin labelling of processed products would be very onerous to apply. And, in any case, it would not, of itself, have detected or prevented the incidents of fraudulent contamination. When media interest is calmer, the real issues remain, and it will be important for all parties in the food industry, together with government and regulators, to sit down to identify the sensible way forward. February 2013 1 Written evidence submitted by Bob Forsyth As a former supermarket supplier I have been following the current food fiasco with great interest; our experience of regulation in the "food chain" was as follows:- 1. Defra has lots of regulations, controls like tagging & animal passports to ensure that animal for food production is safe - there will always be the rogue producer but on the whole the system is pretty resilient. 2. Food processors supplying retailers are almost invariably required to adhere to the British Retail Consortium Global Food Standard, this is a really tiresome form filling & box ticking farce that is policed by independent auditors - usually at highly variable levels of stringency & focus e.g. if the auditor you get has a bee in his bonnet about risk assessments you will be in trouble!! The main problems with this standard are it looks good & credible but:- a) It is designed specifically to enable retailers to push responsibility for any problems onto those lower down the chain, ideally all the way down to the primary producer who is usually the safest link in the chain. b) Any scheduled audit once a year is ludicrously easy to falsify results for. c) Any food testing carried out is arranged by & paid for by the processor being audited - they won't test anything that's wrong. d) All product should be fully traceable through production codes, back trace was always down to the audited, there were never any "secret shopper" tests where product was bought off the shelf, tested & traced back to the primary producer. 3.Environmental Health only do pre-arranged look & see inspection for obvious problems & check that paperwork is up to date their role in crises is reactive not pro-active. They simply don't have the resources or the levels of expertise required to do a proper food safety regulation job & shouldn't be made the scapegoat in this. 4. The Food Standards Agency - the real culprits - they have systematically abdicated their responsibilities to the retail and food industry power blocks. They have allowed the BRC Global Food Standard charade to flourish as "The Standard" when it has little to do with actual food safety - it was a standing joke that the most dangerous place in the supply chain was the supermarket itself -. They have allowed their standards to be dictated by industry blocks - I questioned them about why the FSA has ruled that red meat cannot be sold as fresh if it has ever been frozen while fish, a far more volatile meat, can be frozen & thawed as often as you like but still sold as fresh fish - I was told that the responsible FSA manager had an "agreement" with the White Fish Industry. If food standards are to be enforced you need a properly co-ordinated enforcer independent of but paid for by the food industry and there must be criminal penalties & severe sanctions. No more cosy relationships with pre-arranged audits, start at the shop counter & work backwards thoroughly & without notice. It isn't rocket science but it is not going to be easy given the entrenched influence the power blocks have gained within the FSA. February 2013 2 Written evidence submitted by the National Pig Association The National Pig Association (NPA) is the representative trade association for British commercial pig producers and is affiliated to the National Farmers Union (NFU) and represents the interests of NFU members who produce pigs. We welcome the opportunity to make a submission to the Environment, Food and Rural Affairs Committee’s inquiry on the contamination of beef products. 1. General remarks The NPA fully supports the comments made by the National Farmers Union in their submission and wishes to reiterate them via our own submission. We also have some additional points that we would like to raise. 1.1 Traceability of product – the search for cheaper meat The fact that beef products have been found to contain both horsemeat and pork over the last few weeks has shaken the food industry, compromised integrity and undermined consumer confidence. Although, aside from possible ‘bute’ contamination, this has largely not been a human or animal health issue, we believe that it could have been and still could be. If products of unknown origin are being substituted, what is to stop meat contaminated with notifiable disease from entering the food chain? This may not cause undue concern for consumer health but would certainly be of great concern to the livestock industry. There are all manner of diseases circulating from Foot and Mouth Disease in Turkey to African Swine Fever and Classical Swine Fever in Russia. Retention times of these diseases in meat vary but in the case of ASF, the virus can live for up to 1000 days in frozen meat. We believe that this is a risk which we cannot afford to overlook. In addition the apparent ineffectiveness of current systems to reliably and rapidly trace the source of such illegal meat does not bode well if it did indeed contain exotic disease. 1.2 Shorter, dedicated supply chains The fundamental issue throughout the recent beef contamination debacle is undoubtedly the long and convoluted supply chains involved (through many different countries) which have assisted any intended deception and prevented accurate traceability processes.
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