Age of meat for mincing

10th September 2009

Steve Hardie
Animal Food Chain & Novel Foods Branch
Food Standards Agency Scotland
6th Floor, St Magnus House
25 Guild Street
Aberdeen
AB11 6NJ

Dear Steve

Number of days between the slaughter and mincing of chilled fresh meat

Thank you for the opportunity to make this response to you on what could be a very emotive topic.

Scotland has built a worldwide reputation for quality foods and meat is prominent in the list of recognized and requested products. This to no small extent is based on the fact that we hang our meat on the bone often for up to a month. Supermarkets in the 1980's questioned the need for this but now nearly all are offering premium products based on the fact that carcasses have been hung.

Unfortunately we have to hang the whole carcass to get the maximum benefit from this process but often it is only the better cuts that enjoy the premium especially if the meat is going to be exported.

It is vital to the economics that all fit meat can be marketed and a proportion of that will be minced. To lose this ability would be to undermine the very process that makes our products so sought after, often to countries without the breeding base or discipline to follow such traditional methods.

With the best will in the world sourcing sufficient meat to mince within the number of days restriction is extremely difficult and bound to create supply problems.

The logistics of wholesalers and abattoirs delivering meat fresh enough to comply with the number of days between slaughter and mincing is very hard and near impossible at times of public holidays that stretch over weekends.

Those contractors delivering meat to butchers are now looking closely at their transport costs and can limit deliveries, even to those of the size of approved premises, to weekly. An increase in frequency of deliveries would be contrary to climate change objectives.

Restricting supply will put pressure on price with meat more than six days old being down valued since it is not suitable for approved premises to mince. Further pressure comes on supply should there be a downturn in demand for mincing beef for reasons of weather or festive period.

A build up of mincing beef usually occurs in late December but at the start of January the opposite is the case. Minimum days until mincing severely distorts the traditional and efficient operation of the market.

Farmers and those supplying farmers markets very often have their beef boned and processed at approved premises. We would anticipate that their beef would require mincing within the stipulated time period.

The stipulation over number of days until mincing will greatly disadvantage catering butchers who are approved in competition with smaller retail butchers who are not. Cost of compliance will force up mince prices from approved premises. A hotel or restaurant might change to sourcing its mince from a smaller supplier so at the end of the day the consumer would still be supplied minced meat over six days from slaughter. What one might ask is the point of such regulation?

There is also to my knowledge no pathological or epidemiological evidence to link this process with ill health. The regulation exists because of the nature of consuming mince on the continent. Mince in the UK is not eaten raw and I would be extremely surprised is minced meat is ever exported out of the country. For that reason in itself we see no need for the regulation.

In short we would be substantially economically and logistically compromised should this derogation not be allowed.

Yours sincerely
Douglas Scott
Chief Executive