FSA Consultation on Mince

The FSA is writing to industry to highlight the urgency of submitting to us the evidence and data being collected regards the number of days between slaughter and mincing of chilled meat.

I am writing to give you more background on the reasons why this issue has now become urgent, and to invite you to submit any evidence from SFMTA and your members regarding the impact on business
and consumer choice in Scotland of no longer allowing the national derogation.

FSA HQ has also written to Stuart Roberts at BMPA on this issue.

You will be aware that, in May this year the Commission's Food and Veterinary Office (FVO) carried out a mission in the UK to look at official controls related to the safety of food of animal origin and in particular at meat and meat products, and milk and dairy products. You will note however that the mission did not cover Scotland on this occasion.

We have now received an early draft of their report. In it they have noted that 'the UK authorities apply national measures for the quality of fresh red meat used for the
production of minced meat due to special eating habits.

The derogation allows the use of fresh meat from animals other than poultry for a longer period instead of within no more than six days of their slaughter (Regulation (EC) No 853/2004, Annex III, Section V, Chapter III, 2(b)(ii)).

The UK authorities are still in the process of carrying out the hazard analysis before notifying the Commission and other Member States.'

Whilst this observation relates to red meat there is also a white meat aspect, and BMPA are discussing these issues with the British Poultry Council.

The FVO has also included in their draft report a list of draft recommendations which makes it clear that action is required as a matter of urgency. One recommendation asks
the UK to 'Ensure that national measures and derogations are implemented only after following the requirements laid down in Article 10 of Regulation (EC) No 853/2004 and
Article 7 of Regulation (EC) No 2074/2005.'

If the UK is to present the Commission with a good, strong argument for a technical standard for a national measure we must have the evidence to back this up. We must
also be very specific about the type/species of meat and the type of production for which we are seeking a technical standard – for both red and white meat. As you know from previous attempts to seek a technical standard for this aspect of meat production, we cannot seek a blanket 'disapplication' of the legislation.

The BMPA have been collecting micro details for us as technical evidence, and have been written to in similar terms requesting information on the likely impact on business and consumer choice of losing our national derogation. As part of this evidence gathering process it would be very helpful to have information about the likely number of producers of minced meat from aged meat in Scotland, the quantity they produce (including as a
percentage of their overall business) and any other specific evidence that might be relevant to a UK case. If the evidence is not strong enough we will not be able to
proceed.

We have a deadline of 25 August for responding to the Commission on the draft FVO report. In our response, we will have to give an indication of what we propose to do on
minced meat, including target dates. It would be helpful to have by then an idea of the evidence base for proceeding with this application and whether the data presented by industry is good enough to take to the Commission. We will need completed evidence and data by 30 September.

I hope you will appreciate the reasons for urgency in this matter. I have written to Ian Anderson of SAMW in similar terms.
Yours Sincerely
Elspeth Macdonald