Clean Livestock Policy
The Hygiene Package, which came into force in all European Union Member States on 1 January 2006, provides the following in relation to cleanliness of livestock being presented for slaughter:
Regulation (EC) No. 852/2004
Food business operators rearing animals or producing primary products of animal origin are to take adequate measures, as appropriate and as far as possible to ensure the cleanliness of animals going to slaughter and, where necessary, production animals.
Regulation (EC) No. 853/2004
Food business operators operating slaughterhouses must have HACCP-based intake procedures to guarantee that each animal or, where appropriate, each lot of animals accepted onto the slaughterhouse premises is clean. In the event of failure to comply with any of the requirements the food business operator must notify the official veterinarian and take appropriate measures.
Regulation (EC) No. 854/2002
The official veterinarian is to verify compliance with the food business operators’ duty under Regulation (EC) No 853/2004; to ensure that animals that have such hide conditions that there is an unacceptable risk of contamination of the meat during slaughter are not slaughtered for human consumption unless they are cleaned beforehand.
CLEAN LIVESTOCK POLICY – NEXT STEPS
DAFM has operated a formal Clean Livestock Policy (CLP), focusing on bovines going to slaughter, since 1998.This policy is underpinned by EU and national regulatory requirements.
FoodWise 2025, which sets out the strategic direction for the agri-food area over the next decade, identifies the need to develop a uniform approach to the supply of clean cattle, supported by research in this area.
The Department has also identified a need to develop an equivalent policy for sheep going to slaughter.
An effective CLP is very important not just in terms of basic food safety but also as a reputational issue for Ireland’s meat industry and to safeguard our ongoing major export trade in meat and hides.
The Department applies a 3-category system, requiring food business operators at slaughtering establishments to categorise cattle as follows:
- A – Satisfactory - Cattle that can be slaughtered, without an unacceptable risk of contaminating the meat during the slaughter process, by using the standard hygienic dressing procedures routinely employed by the plant;
- B – Acceptable - Cattle that can only be slaughtered, without an unacceptable risk of contamination of the meat during the slaughter process, by putting in place extra defined hygienic dressing controls;
- C – Unacceptable - Cattle unfit for slaughter because of hide condition. These cattle must not be presented for ante mortem in this condition and it is the responsibility of the FBO to take the required remedial action.
The Department has publicised the requirements for primary producers to ensure that animals being sent for slaughter are clean, and provides guidance in that regard. Actions have also included publication of articles in the farming press, production of leaflets (in tandem with Teagasc and FSAI) and mailshots to producers who have repeatedly supplied animals that were categorised as less than compliant.
Unfortunately current arrangements are not seen as functioning as effectively as is required.
The Irish climate plays a part in this, but it is generally accepted also that some operators could make a much better effort in this area. While most cattle are classified as Category A (satisfactory), those classified as Category B (acceptable but subject to additional hygienic dressing controls) account for about a quarter of total slaughter numbers each year. And the number in Category C (unacceptable) has grown from 17,376 to 29,246 over the past three years. It is also the case that a small proportion of suppliers are accounting for a disproportionately high number of the dirtiest animals.
Based on recent evaluation by DAFM of sheep carcase hygiene in slaughter plants, it is clear that there is a need to significantly improve performance in relation to the cleanliness of incoming animals, to ensure the continuation and expansion of this trade. Accordingly it is intended to introduce a formal Clean Livestock Policy for sheep shortly, and work in that regard has commenced. It is intended that the sheep CLP will be broadly similar to the bovine equivalent.
Next steps/options under consideration
The ‘menu’ of possible options for next steps, which could be applied on an incremental basis, includes:
- Stepping up the CLP awareness campaign - including dissemination of information through stakeholders, updating advice leaflets, channelling information on CLP to farmers via Teagasc/discussion groups and ongoing issue of mailshots to repeat offenders;
- Additional on-site DAFM inspections targeted at largescale offenders;
- Processing industry to consider measures designed to reduce intake of Category Cs;
- As a last resort, consideration of application of compliance action by DAFM, with a view to avoiding recurrence of ongoing significant CLP non-conformance.
The development and implementation of policy in this area is currently the subject of consultation with stakeholders with a view to making real progress on a collaborative basis.