Document Sample

      Dr Michael Desheild, Belize Agricultural Health Authority, Belize
    Caribbean Poultry Association, Broiler Processing & Marketing School,
                      1 – 3 July 2004, CASE, Jamaica


Fresh meat (Beef, Pork, Poultry) has traditionally been viewed as a vehicle for a
significant proportion of human food-borne disease. Although the spectrum of meat-
borne diseases of public health importance has changed with changing production and
processing systems, continuation of the problem has been well illustrated in recent years
by human surveillance studies of specific meat-borne pathogens such as Escherichia coli
O157:H7, Salmonella spp., Campylobacter spp. and Yersinia enterocolitica. In addition
to existing biological and chemical hazards such as veterinary drugs and pesticides, new
hazards are also appearing e.g., the agent of bovine spongiform encephalopathy (BSE).
A contemporary approach to meat hygiene requires that hygiene measures should be
applied at those points in the food chain where they will be of greatest value in reducing
food-borne risks to consumers. This should be reflected in application of specific
measures that are based on science and risk assessment, greater emphasis on prevention
and control of unseen microbiological contamination during processing, and a reduced
reliance on organoleptic post-mortem inspection. Application of HACCP principles is
an essential element. Any legislation (Parent Act or Regulations), standards, code of
practice or guidelines developed for use by the meat industry in Caricom should
incorporate and promote the use of food safety systems based on HACCP.
The measure of success of contemporary programmes is objective on demonstration of
levels of hazard control in food that are correlated with required levels of consumer
protection, rather than by concentrating on detailed and prescriptive measures that give
an unknown outcome. At present, there is room for a significant improvement in many
aspects of food safety control in terms of cost and efficacy, especially during ante- and
post-mortem abattoir inspections and microbiological control processes. Measures should
be tailor-made for the range and prevalence of hazards in the particular animal
population. Management of all these hazards by the Veterinary Services needs to be
carried out in a way that optimises the use of available resources in both the public health
and the animal health sector.
A number of national governments are implementing systems that redefine the respective
roles of industry and government in delivering meat hygiene activities. In such cases, the
competent authority is responsible for defining the competencies of all personnel
involved in regulatory meat hygiene activities, and verifying that all regulatory
requirements are met.
The principles of food safety risk management should be incorporated wherever
appropriate in the design and implementation of meat hygiene programmes. Further,
newly recognized meat-borne risks to human health may require additional measures to
those usually applied in meat hygiene, e.g., the potential for zoonotic transmission of

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practice: central nervous system disorders of slaughtered livestock means that additional
animal health surveillance programmes may need to be undertaken.
Given these new developments and focus for the protection of consumers health, the
development and implementation of an effective and efficient code of hygienic practice
for fresh meat (“meat inspection”), in Caricom should follow the following principle as
outlined by CODEX Alimentarius:

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  1. Fresh meat must be safe and suitable for human consumption and all
     interested parties [including government, industry and consumers] have a
     role in achieving this outcome.

                       In a risk-based, “ farm- to-plate” meat hygiene system, all
                       interested parties i.e. industry, government and consumers,
                       have a role to play in ensuring safety and suitability.

  2. The competent authority should have the legal power to set and enforce
     regulatory meat hygiene requirements, and there should be a legal obligation
     on the establishment operator to comply with hygiene requirements and to
     provide such information and assistance as may be reasonably required by
     the competent authority. Final responsibility for ensuring that all regulatory
     requirements are met should lie with the competent authority.

                   Although all interested parties have a role in meat hygiene, the
                   competent authority in collaboration with it’s [other] regulatory
                   partners, is responsible for setting standards and has the final
                   responsibility for ensuring that safety and suitability requirements
                   as specified in regulations are met.

  3. Meat hygiene programmes should be based on a scientific evaluation of
     meat-borne risks to human health and take into account all relevant food
     safety hazards, as identified by research, monitoring and other relevant

                   For food in international trade, the WTO SPS Agreement requires
                   that sanitary measures be based on scientific principles and as
                   assessment of the risks to human health, using risk assessment
                   techniques developed by the relevant international organizations.
                   It is now generally accepted at both the international level i.e.
                   Codex, and the national level i.e. Member government competent
                   authorities, that food hygiene standards should be based on science
                   and risk assessment to the extent possible and practicable.

  4. The principles of food safety risk management should be incorporated
     wherever possible and appropriate in the design and implementation of meat
     hygiene programmes.

                   The Codex system is working on several fronts to develop practical
                   guidelines for incorporating risk assessment into the design and
                   implementation of food hygiene standards. Development of a
                   framework for management of food-borne risks to human health is
                   based on four steps: risk evaluation (including risk assessment),

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                    assessment of options for managing risks, implementation of
                    hygiene measures, and monitoring and review.

  5. Meat hygiene requirements should involve the “farm-to-plate” continuum to
     the greatest extent practicable so as to optimize control of hazards
     throughout the food chain. Information available from the farm should be
     taken into account wherever possible and practical so as to tailor meat
     hygiene processing requirements to the spectrum and prevalence of hazards
     in the animal population from which the meat is sourced.

            Food safety measures can be implemented at many points in the food
            chain and an optimal meat hygiene system will apply available measures
            at those points where they are the most efficient and effective in terms of
            reducing food-borne risks to human health. Because of the particular
            nature of fresh meat production systems, optimization of meat hygiene
            activities at the processing level requires appropriate information to be
            supplied from the primary production level.
            Primary production is a significant source of hazards associated with fresh
            meat. A number of microbiological hazards are present in animal
            populations intended for slaughter and their control at farm level often
            presents considerable challenges, e.g. E. coli O157:H7, Salmonella spp.
            and Campylobacter spp. A risk management approach to meat hygiene
            includes consideration of risk management options that may have a
            significant impact on risk reduction when applied at the level of primary
            production. The development of “On Farm Food Safety” programme that
            are tailored to the individual industry including provisions for small scale
            or “cottage” operators provide for the monitoring of primary production
            risk factors in meat hygiene.
            Many developing countries do not yet have the resources to conduct on-
            farm surveillance of animal diseases and zoonoses, and hence often
            depend upon cases detected at the abattoir, notably during ante- and post-
            mortem inspections. Regardless of the way in which these functions are
            organised within a country, it is important that relevant public health and
            animal health activities are integrated as fully as possible, so as to achieve
            cost-effectiveness and efficiency gains.
             The Veterinary Services should continue to play a predominant role
            firstly in defining how ante-mortem and post-mortem inspections are to be
            conducted, including identification and management of those controls that
            may be applied at the primary production stage, and secondly in
            implementing ante- and post-mortem inspection

  6. Wherever possible and practical, competent authorities should formulate
     food safety objectives (FSOs) according a risk-based approach so as to
     objectively express the level of hazard control that is required to meet public
     health goals.

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            FSO are a relatively new concept in Codex. Given the primary of HACCP
            systems in food control, it is apparent that achievement of risk-based food
            safety goals requires a “bridge” between the level of protection desired for
            the consumer population (“appropriate level of protection”) and the level
            of hazard control that the HACCP system must necessarily deliver. The
            concept of a FSO is founded on the need for objective measure of the level
            of control of hazards in the food that is required to achieve a desired level
            of consumer protection.

  7. The establishment operator should apply HACCP principles in the design
     and implementation of hygiene measures wherever appropriate.

            HACCP is now acknowledged as the food hygiene system of choice, and
            the establishment operator has the primary responsibility for its

  8. Wherever possible and practical, the establishment operator should
     implement quality assurance (QA) systems so as to improve the effectiveness
     and efficiency of meat hygiene. Competent authorities should take the
     contribution of such systems into account during on-going verification of
     regulatory requirements, and this may include official recognition of a QA

            QA systems are widespread in the food industry. Voluntary inclusion of
            meat hygiene activities in an overarching QA system by the establishment
            operator is likely to result in enhanced delivery, and competent authorities
            may take properly-functioning QA systems into account when carrying
            out their regulatory responsibilities e.g. by decreasing the frequency of
            HACCP verification checks. The Codex Committee on Import and Export
            Inspection and Certification Systems is currently considering a discussion
            paper entitled “Proposed Draft Guidelines for the Utilization of Quality
            Assurance Systems to Meet Requirements in Relation to Food” which
            explores the possible role of the competent authority in officially
            recognizing such QA systems.

  9. The range of activities involved in meat hygiene should be carried out by
     personnel with the appropriate training and competencies. The competent
     authority has responsibility for defining the competencies required for
     different activities, including the role of the veterinary inspector in those

            Meat hygiene involves a complex range of activities and the personnel
            carrying out those activities are not always directly employed by the

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             competent authority e.g. a number of countries are trailing ante-mortem
             and post-mortem inspection systems that partly involve industry
             personnel. The training and competency of all personnel involved in meat
             hygiene is a key element in ensuring food safety and suitability, and
             defining competencies and roles of appropriately trained personnel
             remains the responsibility of the competent authority.

  10. The establishment operator should ensure that adequate systems are in place
      to trace and withdraw fresh meat from the food chain if it is the case that
      such product constitutes an unacceptable level of risk to the consumer.

             Adequate systems for recall of product are an increasingly recognized
             requirement of industry.

  11. Meat hygiene should include monitoring and surveillance of animal and
      human populations for food safety purposes as appropriate to the
      circumstances, with review of meat hygiene requirements wherever
                   A framework for effectively managing food-borne risks to human
                   health requires monitoring and surveillance of the consumer
                   population to determine if hygiene measures are achieving the
                   required level of consumer protection. Further, monitoring of the
                   animal population for specified hazards may be required to
                   determine the prevalence of infected or contaminated animals
                   entering the food chain.

  12. The competent authority should facilitate adoption of new processing
      technologies and other developments in meat hygiene where scientific
      evaluation has shown that they achieve required outcomes in terms of the
      safety and suitability of fresh meat.

                    In an out-come and risk-based food safety environment, competent
                    authorities should be flexible when specifying meat processing
                    technologies and practices as long as they achieve required
                    performance parameters, including FSOs.

  13. Competent authorities should recognize the equivalence of alternative
      hygiene measures where appropriate, and promulgate meat hygiene
      measures that facilitate fair practices in the international trading of fresh

                    The equivalence of food hygiene measures is an increasingly
                    important issue in the international trade in foods. “Equivalence is
                    the state wherein sanitary measures applied in an exporting
                    country, though different from the measures applied in an

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                           importing country, achieve, as demonstrated by the exporting
                           country, the importing country’s appropriate level of protection”
                           (Codex Committee on Import and Export Inspection and
                           Certification Systems; ALINORM 01/30A. Appendix III)

Meat Hygiene is by nature a complex activity that requires the implementation of specific
standards, codes of practices and regulatory action by the competent authority if
consumers are to be assured of “safety and suitability” of the meat they eat. In addition, it
is only natural to expect a departure from some of the recommended actions when
traditional practices are applied for the local trade in meat.

It is only by consulting all interested parties (government, industry and consumers) and
working out the measures and conditions that will be needed to be applied that Caricom
member states can ensure that the safety and suitability of food at all stages of the food
chain is met.

M De Shield BVSc MSc
Director, Food Safety Services
June 25, 2004

Additional Info

The food safety regulatory reforms undertaken by a number of countries have sometimes
led to changes in the traditional roles of the official veterinarian. In some countries,
industry has now been given the primary responsibility for implementing food safety
measures, with the Veterinary Services moving sometimes towards a verification and
audit role. This also provides sometimes the official veterinarian with new opportunities,
and the added responsibilities that they entail, for example in the international
certification of meat.
In this context, the OIE still considers abattoirs to be key points in epidemiological
surveillance for zoonoses as well as other animal diseases.
The fact that the first case detected during the foot and mouth disease epizootic in the
United Kingdom in 2001 was in a pig abattoir clearly illustrates the relevance of this
approach and the danger should it be called into question. The OIE must therefore
continue to provide its Member Countries with standards and guidelines on ante-
and post-mortem inspection in the production of meat in order to reduce hazards of
public health and animal health significance, including in developing countries. The
government authority should determine the requirements for the training and skills of all
personnel involved and define clearly the key role of the veterinary inspector.

-” The role of the veterinarian at the abattoir” - Editorial from the Director General of the OIE, June 2003

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Problems With Current Inspection
FSIS has identified several problems with the current approach [to meat inspection]. One
major problem is that as slaughter establishments have come to rely on FSIS personnel to
sort acceptable from unacceptable product, the establishments have no mandate or
incentive to remove carcasses and parts prior to presentation for inspection. Thus, the
proper roles of industry and inspection personnel are obscured. FSIS’ resources are
inappropriately and inefficiently used when FSIS slaughter inspectors take on the
industry’s responsibility for finding defects, identifying corrective actions, and solving
production control problems.
A much more significant problem with the current inspection system is that it does not
permit FSIS to allocate resources according to public health risk. For instance, the current
line inspection system required by regulation in meat and poultry slaughter
establishments focuses substantial FSIS inspection resources on areas that do not present
significant food safety risks. The carcass inspection procedures carried out by FSIS
inspectors today were designed many years ago in response to a higher prevalence of
disease in the animal populations of that era. Over the years, significant advancements
have been made in the control or eradication of many animal diseases, especially those
that are transmissible to humans, such as tuberculosis and brucellosis. Also, animal
production practices have become more efficient so that most livestock and poultry are
slaughtered at a young age, generally free of diseases more common in older animals.
Nonetheless, inspection methods have not changed. Inspection methods have also not
been modified sufficiently to address the microbial causes of foodborne illness. Current
inspection methods continue to rely on organoleptic identification of defects as indicators
of possible microbial risk. Measuring microbial hazards in the design of HACCP plans
through testing for actual microbial levels and validation of control measures will occur
during implementation of the PR/HACCP final rule. Since new inspection models should
reflect this focus on pathogen reduction and microbial monitoring and verification, the
current reliance on organoleptic inspection should be carefully reassessed.
- HACCP-Based Meat and Poultry Inspection Concepts, USDA Food Safety and Inspection Service
Federal Register: June 10, 1997 (Volume 62, Number 111)][Notices] [Docket No. 96-008N]

Supplementary Information on Codex Committee on Meat Hygiene:
The Codex Alimentarius Commission was established in 1962 by two United Nations
organizations, the Food and Agriculture Organization (FAO) and the World Health
Organization (WHO). Codex is the major international organization for encouraging fair
international trade in food and protecting the health and economic interests of consumers.
Through adoption of food standards, codes of practice, and other guidelines developed by
its committees, and by promoting their adoption and implementation by governments,
Codex seeks to ensure that the world’s food supply is sound, wholesome, free from
adulteration, and correctly labeled. Codex Contact Points in most Caricom member states
are responsible for codex activities in the respective countries.

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The Codex Executive Committee (CEC), at its 47th Session in 2000, asked that the Codex
Committee on Meat Hygiene reconvene to redraft the existing codes on meat hygiene so
that they reflect contemporary developments. The CEC also asked that the scope of the
existing codes be broadened so as to include poultry meat hygiene. These
recommendations were confirmed by the 24th Session of the Codex Alimentarius
Commission in July 2001.

Decisions of the Codex Alimentarius Commission concerning the work of the Committee
The Committee was informed that the 26 Session of the Codex Alimentarius
Commission adopted the revised terms of reference of the Committee as proposed and
agreed that its name should read “Codex Committee on Meat Hygiene”. The Commission
adopted the draft General Principles of Meat Hygiene at Step 8 and the proposed draft
Code of Hygienic Practice for Meat at Step 5 as proposed.
The Tenth Session of the Codex Committee on Meat Hygiene reached the following
The Committee agreed:
• to incorporate the Hygiene Provisions for Processed Meat in the draft Code of
    Hygienic Practice for Meat for discussion in Agenda Item 3 (para. 106);
• to attach the two proposed draft Annexes on Risk-Based Evaluation of Organolepetic
    Post-Mortem Examination Procedures for Meat and on Microbiological Verification
    of Process Control of Meat Hygiene to the draft Code of Hygienic Practice for Meat
    as Annex I and II respectively (paras 66 and 77);
• to circulate the entire draft Code of Hygienic Practice for Meat for comments and
    further finalization at its next meeting (ALINORM 04/27/16, para. 49 and Appendix

- The report of the Tenth Session of the Codex Committee on Meat Hygiene (CCMH)


The Committee noted that considerable progress was made on the revision of the draft
Code of Hygienic Practice for Meat, which now encompassed also provisions for
processed meat. However some issues, especially on the fundamental definition of
Veterinary Inspector and on Recall System required further consideration. It therefore
agreed to return the draft Code to Step 6 for comments and further consideration at its
next session (see Appendix II). The Committee also agreed that Annexes on Risk Based
Evaluation of Organoleptic Post-Mortem Inspection Procedures for Meat and on
Microbiological Verification of Process for Control of Meat Hygiene would constitute an
integral part of the draft Code and attached them to Appendix II (see paras 66 and 77).

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The report of the Tenth Session of the Codex Committee on Meat Hygiene (CCMH) will
be considered by the 27 Session of the Codex Alimentarius Commission (Geneva, 28
June - 2 July 2004).

Governments and interested international organizations are invited to provide their
comments. Comments should be forwarded to Ms. Cindy Newman, Codex Committee on
Meat Hygiene, New Zealand Food Safety Authority, P.O. Box 2835 Wellington, New
Zealand Fax +64 4 463 2583 - E-mail: with a copy to the
Secretary, Codex Alimentarius Commission, Viale delle Terme di Caracalla, 00100
Rome, Italy (fax +39 06 57054593; e-mail for not later than 30
September 2004.

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