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Brussels, 24 September 2001
Euro Coop ASKS FOR A FURTHER STRENGTHENING OF
THE EU MEAT INSPECTION LEGISLATION
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 4 Central and Eastern European countries.
Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe. Euro Coop's major objectives have been to promote, defend and represent consumer interests at European level.
It is on the basis of this expertise that Euro Coop has prepared the following comments on the recent Commission's draft proposal on EU meat inspection legislation.
Euro Coop welcomes the opportunity to comment on the draft proposal on the organisation of official controls on products of animal origin intended for human consumption. We support the Commission's initiative to revise the Community meat inspection legislation.
Recent large-scale food scares such as the BSE and the dioxin crisis, and the Foot and Mouth Disease could have been prevented if official control systems had been more effective. In Euro Coop's view, a strengthening of the traditional inspection system is necessary to ensure consumer safety. Euro Coop welcomes the aim to establish a science and risk-based meat inspection system throughout the whole chain, from farm to fork. We also support the initiative to make a clear division of responsibilities between slaughterhouse operators and competent authorities.
However, we have identified a number of points, which could hamper the effectiveness of the new inspection system. We are in particular very concerned that the draft proposal does not properly implement the farm to table principle. It will indeed be in line with the Commission's proposal on the hygiene of foodstuffs , which exempts farmers from the HACCP system. Furthermore, the information flow system does not seem to embrace the "end" of the food chain, from slaughterhouses to final consumers. Also, Euro Coop is very disappointed that the draft proposal does not sufficiently guarantee the transparency and independence of the risk analysis process and that it does not tackle the issue of emergency crises. Finally, we feel that certain practical measures need further consideration to ensure the success of the reform.
We offer the following comments as a contribution to the development of the Commission's legislative proposal on meat inspection.
1. Euro Coop welcomes the risk-based inspection system
Euro Coop has always expressed its support to the extension of the Hazard Analysis Critical Control Point System (HACCP) system to all food producers. HACCP is a modern method of securing food safety and it is accepted internationally. As a risk-based control system, HACCP will ensure food producers are assessing and addressing the likely hazards within their complete production system.
We therefore support the initiative of the Commission to set up a risk-based EU inspection system. However, we wish to underline that putting more responsibilities over producers should in no way remove the official authorities overall responsibilities to fully enforce the rules and to supervise the own-check system.
We are pleased to see that the initial proposals of the Commission services in charge meat inspection legislation, which aim was to "conditionally, gradually and reversibly transfer competence for carrying out specific meat inspection activities from competent authorities to slaughterhouses operators" does not appear in the draft proposal. In Euro Coop's view, such a possibility would have hampered the whole inspection system and endangered consumer safety. A clear division of responsibilities is crucial. Euro Coop underlines that the role of independent competent authorities should never be neglected if consumer confidence is to be restored. We find it crucial to require the presence of official veterinarians during post-mortem inspections. The Commission's intention is to leave this responsibility to auxiliaries. We stress that, in this case, auxiliaries should remain under the supervision of the official veterinarians.
2. Euro Coop welcomes the "stable to table" principle but is concerned about its effective implementation in the draft Regulation on meat inspection
Euro Coop welcomes the stable-to-table approach of the Commission, in particular the statement that "official controls on products of animal origin must be carried out throughout the production chain" . Euro Coop has always argued for an integrated approach, which it has reiterated in its comments on the Commission's proposal on the general principles of food law and establishing the European Food Authority . The recent food scares have proved that contaminated animal feeds have been an indirect cause of food hazards and need to be strictly controlled to prevent future problems occurring.
However, Euro Coop is very concerned that the draft proposal on the organisation of official controls on products of animal origin intended for human consumption may impede the full implementation of the farm to table principle. This draft proposal indeed refers to the Commission's proposal on the hygiene of foodstuffs , which exempts farmers from the HACCP system . Euro Coop reiterates its opposition to this exemption and urges the Commission to take appropriate measures to implement the farm to table principle. Exempting farmers is in contradiction to the "farm to table" principle.
Also, Euro Coop is concerned that the draft proposal establishes a flow of information system only from primary production to slaughterhouses level, and not from farmers to consumers. Traceability of all food and food ingredients along the food chain is a vital element in ensuring food safety. We ask the Commission to ensure that the implementation of the farm to table in the final proposal on EU meat inspection. We would also like the Commission to give more details about the method of implementation of traceability.
Euro Coop stresses that the new EU meat inspection legislation must implement the general EU food law principles, which include traceability and responsibility as general principles of food law. This would guarantee the consistency of EU food legislation.
3. Euro Coop asks for more details on sanctions in case of irregularities or non-compliance
Euro Coop agrees that appropriate measures shall be taken when irregularities or non-compliance are found. However, we feel that the section on "Decision following controls" does not ensure that appropriate sanctions will be taken in case of bad hygienic practices. We would like the Commission to provide with more details on the following statement: ""Where appropriate, the official veterinarians shall order a recall, withdrawal and/destruction of meat".
Also, Euro Coop is disappointed that the draft Regulation does not deal with the situation that would occur if a meat hygiene problem in one Member State, could affect the health of citizens in a neighbouring Member States. The draft Regulation offers no procedure whereby a neighbouring Member State can stop a food product entering its territory if it has information that it could be a risk for human health. This omission in the draft Regulation leaves an important loophole in the protection of the health of consumers by Member States, in relation to food hygiene matters.
Finally, Euro Coop is very concerned that the draft Regulation does not make any reference to the European Food Authority itself, nor tackles the problem of emergency crises. A link to the Rapid Alert System should also be established to avoid the spreading of new food scares in the future.
4. Euro Coop believes that inspection procedure must be transparent and independent to regain consumer confidence
Euro Coop considers that the Commission's proposal does not contain effective measures that would ensure the transparency and independence of the inspection procedure. Consumers should be given the possibility to be fully informed about the implementation and working of the HACCP system. This is vital to regain consumer confidence as well as to encourage effective implementation of the HACCP principles.
This argument has already been put forward by the Scientific Committee on Veterinary Measures relating to Public Health in its Opinion on Identification of species/categories of meat-producing animals in integrated production systems where meat inspection may be revised of 20-21 June 2001 . It states that "the good functioning of an integrated system require full accountability, and transparency in all parts".
Finally, Euro Coop insists on the need to have a flexible procedure to amend legislation, in particular given technical progress or new insights on detailed provisions. We consider that the Standing Committee on the Food Chain procedure does not allow for such flexibility and transparency. When addressing health rules, it is preferable to increase the joint role of the Council and of the European Parliament.
5. Euro Coop welcomes the Commission's initiative to harmonise EU food legislation, but is concerned about its actual implementation
Euro Coop is concerned that the implementation of the future EU meat inspection legislation, 12 months from the time of adoption, will precede the implementation of the general food hygiene Regulation scheduled for adoption from 1st January 2004. This will have the effect of introducing full HACCP requirements for meat operators before their general introduction across the rest of the food sector. In our opinion, it would be more appropriate to align HACCP introduction to that of the new proposals through either omission here or a change to the implementation timetable.
To ensure EU food legislation's consistency, Euro Coop stresses that the new EU food and feed legislation announced in the White Paper on Food Safety should be rapidly adopted to ensure EU legislation's consistency.
6. Euro Coop believes that supporting measures should be planned for the small and medium enterprises
Euro Coop is very concerned about the managerial and financial problems the small and medium enterprises (SMEs) will encounter to implement the new EU legislation on meat inspection.
Euro Coop strongly believes that supporting measures should be planned for the SMEs to ensure the effective implementation of the farm to table principle. We consider that the Commission should make sure that all stakeholders involved in the food chain are able to implement the HACCP scheme and that the new meat inspection legislation has no exception.
Euro Coop believes that European funding and training would be required for the SMEs. Such supporting measures are vital to ensure the effective implementation of the new meat inspection measures, and therefore consumer safety.
Contact: Aude L'hirondel, Food Officer
Tel: +32.2.285.00.70 - Fax: +32.2.231.07.57 - E-mail: alhirondel@eurocoop.org
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