Memorandum submitted by N E Horrox BA,
BVM&S, MRCVS, FRIPHH (X09)
1. This evidence is submitted by Nigel Horrox
who is, and has been, a practising poultry veterinarian for over
25 years and is a Fellow of the Royal Society of Health. He has
consulted widely in the British and international poultry sectors.
In addition Nigel Horrox owns one of the largest independently
owned food testing laboratories in the United Kingdom and is a
leading international technical magazine publisher in the livestock
and food safety fields. With this background Nigel has had a detailed
insight into poultry farming in the United Kingdom and around
the world.
2. For the purpose of this evidence poultry
farming will include the processing of birds at the abattoir as
this is an integral part of the farming and marketing process.
Without processors there will be no poultry farmers. To appreciate
the current situation one has to first look at the history of
poultry farming in Britain. Many of today's poultry farms were
built in the 1960's and 1970's in response to government's desire
to produce cheap food and for the country to be self-sufficient
in food production. The British poultry sector, unlike many other
aspects of British agriculture achieved this without government
financial support. Poultry farming was the success story of British
agriculture.
3. The second phase of the history of poultry
production centres on the evolution of supermarkets and their
buying power in the United Kingdom over the last 20 years. In
the 1990's some 70-80% of poultry meat consumed in the home was
purchased from one of five or six supermarket chains. A similar
scenario occurs for table eggs. In essence to satisfy major customers
and obtain orders from them British producers accepted lower margins
and, as a consequence, had less to reinvest in an industry that
was ageing and requiring reinvestment. Needless to say, this scenario
does not yet occur in countries in which the advent of poultry
production occurred later, for example, some countries in Europe,
Thailand and Brazil.
4. Thus, the United Kingdom has paid a price
for being a leader or pioneer in poultry production in Europe
and for being a country in which much of the final market is in
the hands of a very few, very professional and very demanding
customers. On top of this there have been undesirable occurrences
in the processing stage where the Meat Hygiene Service is responsible
for the implementation of EU meat inspection requirements. This
agency sub-contracts this work out and much of it is handled by
a limited number of contract holders who seem to feel their responsibility
is to justify the contracts they hold by unreasonable requests
on the processors. A variation in application of standards exists.
Many of these problems and the associated bureaucracy would be
removed if the Meat Hygiene Service employed the inspectors and
applied uniform standards across the board. This is what occurs
in many other countries.
5. Currently the Meat Hygiene Service (via
its subcontractors) is looking at applying the HACP approach to
risk management to poultry processing. HACCP is a good food safety
tool and its introduction is to be applauded. However, its success
is based on its simplicity and it is of great concern that the
Meat Hygiene Service appears to be over complicating the whole
issue and in so doing is making it incomprehensible to many poultry
processors. I have been told that poultry meat inspectors are
being trained on how to use HACCP to gain prosecutions. If this
is the case, this is totally wrong as inspectors and processors
should be working together to maintain or even improve the current
excellent standards of British poultry products. In addition microbiological
standards are being incorporated and the current lack of pertinent,
quantitative microbiological knowledge amongst many inspectors
is such that this is going to cause problems. This microbiological
knowledge is present in the poultry industry and its advisers.
6. My experience of poultry meat inspection
is that it is not working and that the recent Hygiene Service
should review the current situation and decide how it can be improved
before focussing on new issues such as HACCP. In my opinion a
single employer, ideally the Meat Hygiene Service, of all meat
inspectors should be a priority.
7. On the veterinary front many excellent
and perfectly safe medicinal products have been withdrawn on an
emotional rather than a factual bases. A classic example of this
are the nitrofuran antimicrobials (furazolidone and furaltadone)
which were very effective tools against certain important poultry
diseases. These were withdrawn because of a possible risk to man—I
am not aware of any scientifically documented case of such problems!
8. Similarly, the growth enhancer avoparcin
was withdrawn because of perceived cross resistence problems with
some bacteria that cause problems in man. This move resulted in
major problems due to necrotic enteritis in chickens which necessitated
excessive use of amoxycillin in poultry. Amoxycillin is an important
antibiotic that is used widely in man.
9. The cost of withdrawing avoparcin and
a whole host of other antibiotic growth enhancers has, and will
be, a signficant one on the poultry sector. There is evidence
to support the scientific banning of these growth enhancers but
the decision was taken on the crest of a wave of human emotion
rather than after a detailed scientific review and a cost benefit
analysis.
10. There are numerous pieces of British
and/or EU legislation which are fully adhered to in the United
Kingdom but, in the case of the latter, not necessarily so in
the EU. Typical of this is the ban on battery cages in the EU
which the British will be enforcing on time as "good Europeans"
but which at least five other member countries of the EU have
not yet given any serious consideration to!
Areas on which legislation impacts include:—
— Planning legislation—the current
planning process can be protracted and applications from poultry
farmers can be delayed if the "anti lobby" wishes to
use "the system" to their advantages. The more protracted
a planning application becomes, the higher the costs are.
— Medicines licensing. Delays and costs.
— Welfare legislation. Every addition
to this legislation is accompanied by costs. The legislation is
not uniformly applied across the EU.
— Waste tax. The implications of this,
especially since it will be virtually impossible to pass it on,
will be catastrophic to some companies.
— Costs of employment. These are rising
under the current government and adversely affects the labour
cost differential when we look at other poultry producing countries
that export products to the UK.
11. However, when considering all of these
pieces of legislation, which other submissions will no doubt cover
in detail, they need to be considered against the following backcloth:—
— The British market place has very
few major customers who over the years have removed margin from
poultry products and thereby left the producers with reduced funds
for reinvestment.
— Many farm and processing plant facilities
in the United Kingdom are relatively old and, therefore, relatively
less efficient than those in many major poultry producing countries.
— The poultry industry in this country
is not recruiting good young people because they perceive the
industry negatively and as providing poor prospects for a career.
As a consequence the main core of expertise in the industry is
ageing and slowly disappearing.
— The current popular and political
opinion in this country is against agriculture and the farming
of animals.
— The agricultural vote is under 1%
and so consumer related issues are favoured. For example, I have
been advised that current British Government policy is to favour
cheap food imports into the EU but to ensure that as many of those
imports as possible enter the EU via the United Kingdom so as
to create as many jobs as possible in the United Kingdom in further
processing and the distribution of products to the rest of the
EU.
— Finally, I have visited many farms
and processing plants around the world and it is imperative that
the United Kingdom does not kid itself about their quality and
capabilities. Some of the best operations I have seen anywhere
in the world are in Thailand and Brazil. If these two countries
can produce to the United Kingdom's quality standards, and there
are already companies there that can, and if they can do this
at a relatively lower cost, then surely imports will be inevitable?
12. Perhaps in considering the future of
poultry production in the United Kingdom one should be looking
at the broader picture in international trade and asking what
lessons can be learnt from the coal, iron and steel, shipbuilding,
car, television and similar industries that have moved from the
United Kingdom.
13. In addition the Committee should ask
why are British agencies reluctant to champion "good news"
about the British poultry sector when it occurs. For example,
the Food Standards Agency was rather slow in implicating Spanish
eggs, and hence exonerating British Lion eggs, in recent Salmonella
enteritidis outbreaks that occurred in this country. In other
words the British egg industry invested millions of pounds in
measures arising from all the salmonella regulations and controls
of the 1990's and when it could have capitalised on this, it could
not because of the Food Standards Agency's lethargy.
14. Regulations to the poultry industry
are like salmonella to the consumer—if the consumer is fit
and well he will shake off the salmonella infection, if not he
will succumb to it and the salmonella could be the final nail
in his coffin. That is, a fit and healthy poultry industry might
be able to cope with the demands and costs of legislation and
bureaucracy—and unfit one (which is what we have on the
whole in Britain) will not, and more imports will occur with the
resulting demise of the British poultry industry.
N E Horrox BA, BVM&S, MRCVS, FRIPHH
8 April 2003
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