Memorandum submitted by the Food Standards
Agency (W17)
SUMMARY
The UK Food Standards Agency (FSA) remit is
to protect public health and the interest of consumers in relation
to food; the role extends from farm to fork on food safety matters.
Veterinarians are involved in the production of food of animal
origin at the farming and processing stages of the food chain.
In the last decade the involvement of veterinarians in supervision
and enforcement of meat safety has increased to meet European
legal requirements, and has led to specialist veterinary practices
employing many non-UK veterinary graduates. However meat borne
pathogens such as Salmonella, Campylobacter and E. coli are not
readily detected by the current system. Thus, further change to
controls on the production of food of animal origin is needed
to protect consumers.
Future changes are expected in European food
safety regulations, particularly those concerned with the hygienic
production of meat. This will mean that controls, currently concentrated
at the slaughterhouse, may also be carried out at the farm, where
they can be more effective. The farmer, as a food business operator,
will be required to control hazards that can enter the food chain
on the farm and, in turn, this will require the farm veterinarian
to accept a share of the responsibility for safe production of
food. There are related controls on dairy hygiene and imports.
Historically, food safety and public health
has not been an attractive career choice for UK veterinary graduates.
However progress is now being made in veterinary schools to strengthen
curricula, to place the emphasis on food safety rather than issues
concerning meat and thereby improve the interest in this aspect
of veterinary work.
Incidents that may have an adverse effect on
food produced from animals can come to light due to veterinary
involvement on farm. A network of state and private veterinary
services assists the FSA to identify and control the risk to public
health.
The future role of vets and veterinary services
on farm is likely to alter in the coming years through the new
approach to farm hygiene and food safety.
REMIT OF
THE FOOD
STANDARDS AGENCY
1. The remit of the FSA is set out in Annex
A. The FSA's UK role is "from farm to fork"; beyond
the farm gate the Department for Environment, Food and Rural Affairs
(Defra) and Agriculture departments in the devolved administrations
are responsible for most government aspects of on farm food safety.
There are 14 veterinarians in the Agency, who lead policy, provide
veterinary advice and undertake audit and licensing of meat plants.
The Agency has a Working Agreement with the State Veterinary Service,
which provides information and emergency resource to deal with
specific incidents on farm.
2. The Meat Hygiene Service is an Executive
Agency of the FSA and its remit is set out in Annex B. The MHS
employs 48 veterinarians and has contracts with veterinary practices
to secure the services of approximately 650 private veterinarians.
The MHS does not work on-farm, but works to protect public health
and animal welfare by improving the quality of its services and
standards in licensed meat plants in Great Britain.
PRESENT INVOLVEMENT
OF VETERINARIANS
IN OFFICIAL
CONTROLS ON
FOOD PRODUCTION
3. Veterinarians are involved in the production
of food of animal origin at both the farming and processing stages
of the food chain. On the farm they are involved in maintaining
the health of food producing animals, whilst in the meat area,
European legislation requires slaughterhouses and cutting plants
to be supervised by veterinarians. In the latter they are known
as Official Veterinary Surgeons (OVS), and carry out ante-mortem
inspection of animals and are responsible for post-mortem inspection
of carcases, supervision of hygiene and enforcement of regulations.
4. Veterinary involvement in food processing
extends beyond meat production in many other European Member States,
where veterinarians are considered to be food hygiene experts
as well as animal doctors. In the UK, veterinarians were not required
to supervise meat production for the domestic market prior to
the EU Single Market in 1991, though agricultural veterinary practices
did provide veterinary supervision of export approved plants,
and provided official veterinary certification of meat for export
on behalf of the Chief Veterinary Officer
5. Since the advent of the Single Market
the number of veterinary man-years involved in the supervision
of meat production in the UK has increased enormously. Initially
local authorities, often making use of agricultural veterinary
practices, provided this supervision. In 1995, in response to
concerns about the effectiveness of enforcement of BSE controls,
the meat hygiene responsibilities of local authorities were transferred
to the newly formed Meat Hygiene Service, initially an Executive
Agency of MAFF, then transferred to FSA from 2000. The MHS are
required to provide a cost efficient service while delivering
the permanent veterinary presence required by European law in
full throughput slaughterhouses. This has led to the majority
of veterinary manpower in meat plants being provided by specialist
meat hygiene veterinary practices, which do not provide services
at the farm level. In the main veterinarians are recruited by
the specialist practices from overseas, principally Spain.
6. Dairy hygiene legislation at the primary
production end of the chain is enforced by the Dairy Hygiene Inspectorate
(DHI) in the UK. However, this legislation also has animal health
requirements, for example milk must come from "healthy"
animals and animals on production holdings must undergo regular
veterinary inspections to ensure animal health requirements of
the current directive are being complied with. This leads to two
features:
(a) Although the DHI check the farm's medicine
records and storage, and undertake general inspection of the animals,
they are not vets and thus cannot perform diagnosis. The DHI assume
that if a veterinary medicine has been prescribed within the last
12 months, then the herd has been under veterinary supervision
within that period.
(b) The EU requires that any animal reacting
to a test for TB or Brucella is segregated from the rest of the
herd. Whilst the veterinarian performs the test, it is a DHI responsibility
to check that the animals have been segregated from the herd.
7. Veterinarians are involved in food safety
at Border Inspection Posts. They are employed by local authorities
or Port Health Authorities to check all consignments of Products
of Animal Origin entering the country from third countries. Although
relatively small in numerical terms, it is a very important food
safety function. In addition, for live animals, the farms of destination
and the resulting food animals may come into the UK food chain.
FUTURE INVOLVEMENT
OF VETERINARIANS
IN FOOD
PRODUCTION
8. The European legislation governing the
production of food is being revised, simplified and consolidated.
This will make more explicit that operators are primarily responsible
for the safe production of food and make the legislation less
prescriptive and more risk based. Rules are being developed which
apply to the whole of the food chain and require controls to be
put in place at points along the chain where they will be most
effective. These rules will include controls at farm level on
some zoonoses. Currently controls start mainly at the slaughterhouse
gate, and rely on veterinary ante and post-mortem inspection to
assess the fitness of an animal for slaughter. Information from
the farm relevant to food safety is only required to accompany
poultry and animals killed on the farm. This regime needs improvement
to protect the consumer from many meat borne human pathogens,
such as Salmonella, Campylobacter and E. coli 0157.
9. The changes to clarify legislation are
due to be implemented and apply from 2005 at the earliest. They
will affect veterinary involvement in both parts of the food chain.
Some ante-mortem inspection may be transferred from the slaughterhouse
to the farm. More significantly farmers, as food businesses, will
be required to operate good hygienic practices and a Regulation
on Official Feed and Food Controls will require official controls
to be carried out on farm. This includes the full range of official
control activities including for example, inspection, audit, monitoring,
surveillance, and sampling and analysis. Large animal veterinary
practice may be well placed to play a part in carrying out audits
for government. These changes will require the farm veterinarian
to accept a share of the responsibility for the safe production
of food.
10. At the slaughterhouse, the veterinarian
may no longer be required to be permanently present during production,
but will be expected to make decisions as to whether animals are
fit to slaughter for human consumption based on information supplied
by farmers and their veterinary surgeons. This will mean the slaughterhouse
veterinarian will need to have greater input than at present to
livestock production and disease control, and may also provide
an opportunity for more involvement in slaughterhouse work by
agricultural veterinary practices.
11. Lines of communication between veterinarians
on farms and other inspectorates, including Dairy Hygiene Inspectors
are desirable. This will be even more important after implementation
of European consolidated hygiene regulations.
FOOD SAFETY
AS A
CAREER FOR
VETERINARY SURGEONS
12. The FSA recognises there is a demand
for veterinary surgeons with knowledge skill and ability in food
safety to work in Government services and help protect consumers.
However, small animal private practice attracts the majority of
veterinary graduates and the majority do not generally opt into
public health and food safety related work.
13. In an attempt to understand the reasons
behind this and to find out what needs to be done to address the
problem, the Agency has been carrying out an initial scoping study
involving key stakeholders. They include from Government, veterinary
schools and institutions such as the Royal College of Veterinary
Surgeons and British Veterinary Association. Findings so far confirm
the Government as an employer is not looked upon favourably by
graduates leaving university, partly as it does not pay as well
as private practice and also because work conditions in meat premises
are not seen as favourable. In addition, it was felt by some that
vets wanting to work in Government are being affected before leaving
college because the curriculum is not strong on food safety, public
health is not well represented and other work is viewed as being
more challenging. As one stakeholder put it, "In the veterinary
profession today, public health is seen as a minority interest
. . . and that should not continue."
14. There is evidence of some progress—the
curriculum for undergraduates and post-graduates is being revised
and the trend in professional education (and work) is towards
greater specialisation, such as in public health. But there is
also uncertainly over the future and the changes that will be
made with the implementation of the EU food hygiene Regulations.
The prevailing view is that the curriculum should be demand led,
not supply led.
RELATIONS WITH
OTHER PROFESSIONAL
GROUPS
15. Authorised officers from Local Authorities
carry out food hygiene enforcement work on farms and in food premises
other than licensed slaughterhouses, cutting plants and cold stores.
This is in the hands of Trading Standards and Environmental Health
Officers. The Chartered Institute of Environmental Health and
Trading Standards Institute are experiencing recruitment and retention
problems and have begun to develop a strategy to address this.
16. The roles of veterinary and environmental
health professionals on farm differ. Veterinarians offer the ability
to prevent, detect, diagnose and treat disease and to advise on
livestock production systems to manage hazards to the food chain.
Environmental health officers are trained to enforce food law.
But the supply pipeline of both professions will both be influenced
by the future strategy for veterinary services, including enforcement,
on farms.
FOOD SAFETY
INCIDENTS
17. Food incidents, which involve possible
contamination of a food source of animal origin, may come to light
due to the presence of vets on farms. The FSA has built a network
of links with other organisations to ensure we are notified of
incidents that have potential effects on food safety wherever
in the food chain they occur. These links include the Veterinary
Laboratories Agency (VLA), an Executive Agency of Defra, which
in this instance works closely with the State Veterinary Service.
The VLA will notify the FSA of incidents that occur on-farm that
have a potential to affect food safety.
18. Currently the most common incidents
relate to lead, heavy metals, copper poisoning and botulism in
animals. Once notified of these cases, the FSA will consider the
circumstances leading to the incident and may propose restrictions.
Where possible the FSA prefers to take action through voluntary
restrictions on animals until any toxicants have cleared from
their meat or milk. In severe circumstances, restrictions may
include orders made under the Food and Environment Protection
Act 1985, prohibiting the movement and/or sale of animals and
food from defined geographical locations. In the future, new rules
on the monitoring and control of zoonoses will require close working
between veterinary practitioners, the Departments responsible
for work on farms and the Food Standards Agency.
CONCLUSION
19. A changing role is anticipated for vets
and veterinary services in food safety. This will be part of the
European agenda for change in food hygiene and provide a stronger
"farm to fork" continuum. The precise arrangements are
still under development, but there is likely to be an effect on
the role of vets and veterinary services in the future.
Food Standards Agency
28 April 2003
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