Joint Committee on Statutory Instruments Fourth Report


Memorandum by the Ministry of Agriculture, Fisheries and Food


  1. This memorandum is submitted in response to the Committee's request for a memorandum on the following point:

    Regulation 5(1)(c) requires a registered tannery controller to ensure that places and equipment used for storage are "thoroughly cleaned" before being used again for those purposes. Explain what cleaning measures are envisaged for meeting this requirement and how it will be determined that a thorough cleaning has taken place.

  2. Firstly, it should be noted that the obligation imposed by regulation 5(1)(c) is an obligation to clean thoroughly places and equipment used for processing controlled hides, before the place/equipment can be used for processing other hides/anything else. The reason for this requirement is that controlled hides are the hides of animals slaughtered under the "over 30 month" scheme established pursuant to Commission Regulation 716/96 (or under the selective cull, established pursuant to Commission Regulation 1484/96, which is subject to similar conditions). This requires the entire animal except the hide (where this has been treated so as to be suitable only for leather production) to be destroyed in a manner "which poses no risk to public health or the health of other animals". Accordingly, a cleaning requirement is necessary to ensure that there is no possibility of "clean" hides (the trimmings and fleshings from which may be used in the production of products for human or animal consumption) being contaminated by scheme hides and the products resulting from the processing thereof.

  3. "Thoroughly cleaned" is not defined in the Regulations, and is to be interpreted in accordance with the usual meaning given to these words. Thus "thorough cleaning", means that all visible debris, dust and slurry derived from controlled hides should be removed, and an appropriate cleaning compound applied and rinsed off. The Intervention Board, which administers the Bovine Hides Scheme, has issued a trade circular confirming this.

  4. Since hides and associated material do not contain any of the tissues identified by the Spongiform Enchephalopthany Advisory Committee (SEAC) as potentially containing the BSE-causing prion, we did not consider it necessary to include more elaborate controls on cleaning, such as those set out at article 20(8) of the Specified Bovine Material Order 1997.

  5. Regulation 8(1) of the Bovine Hides Regulations provides that authorised officers may inspect premises in order to ascertain whether there has been any breach of the Regulations (including of course the cleaning requirement under regulation 5(1)(c)). In practice, tanneries are visited at least twice a month by officials of the Meat and Livestock Commission acting on behalf of the Intervention Board. They are able to determine whether thorough cleaning has occurred by visual inspection, which will be readily possible just before a storage area or equipment is reused, or where controlled waste (dyed green) has been processed there. In the event of problems being identified, they would inform the Intervention Board who would initiate formal action as necessary.

17th June 1997

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