Scottish Food Enforcement Liaison Committee 12 February 2016

FSS Audit review – update by Marion McArthur, Food Standards Scotland (FSS).
The power to set standards monitor and audit delivery of official controls is now responsibility of FSS as was the requirement under FSA. The FSS Review is a recalibration of the audit scheme against the current food law code of practice. Other changes on audits (reality checks) will be unannounced. Preventive as well as corrective.
A root cause analysis for any deficiencies raised will be expected as part of the development of an action plan. This could highlight lack of commitment to food safety by a local authority. Budgets are now causing compulsory redundancies in some authorities so it was felt this review was timely. Quality of inspection comes into this but audit is more strategic. System will help disseminate best practice and promote consistency of approach to inspections.

Subcommittees and FLGs update considered remit, terms of reference, work plans, targets, objectives what the group do, current membership, current view of where it as a group / committee is going.

Regulatory Strategy for Food Standards Scotland is being developed with an aim to allow food businesses to flourish. DS attended stakeholder day earlier this year and fed in our thoughts.

SFELC Food Standards Sub Committee (FSSC) tabled a paper on the composition of Steak Mince. SFELC had previously discussed this and agreed that it should be the same as that for lean mince.

The Food Information to Consumers Regulations (FIC) have introduced compositional standards for lean minced meat. FSSC recommends that steak mince should comply with the compositional standards in FIC for lean minced meat

Background
Steak mince is commonly thought of as the “premium” beef mince description by Scottish consumers. Customers arguably, are looking for quality meat with low levels of fat and connective tissue. Steak mince is more commonly available at retailers, particularly amongst independent butchers than lean or extra lean mince. Whilst steak mince is undoubtedly a customary name for this quality of mince there is no legal standard for the composition of the product.

The results of the SFELC Survey SF20 (1) and previous work summarised in the report of Survey SF1 (2), show that steak mince has a lower fat content than standard mince. In 2010 SFEC adopted the same standard for steak mince as it did for lean mince, namely a maximum fat content of 10%

Current legislation
Under the EU Food Information to Consumers Regulations 1169/2011 (FIC), which came into force in December 2014, designations of minced meat may only be used where the minced meat complies with certain compositional standards, checked on the basis of a daily average, as set out in the following table (Annex VI Part B point 1);

Type”‹”‹”‹”‹”‹ Fat content “‹Collagen/Meat protein ratio
Lean minced meat “‹”‹”‹â‰¤7% “‹”‹â‰¤12%
Minced pure beef “‹”‹”‹â‰¤20%”‹”‹ ≤15%
Minced meat containing pigmeat”‹â‰¤30% “‹”‹â‰¤18%
Minced meat of other species “‹”‹â‰¤25% “‹”‹â‰¤15%
Table 1- FIC minced meat composition standards

In addition, the following expression must appear on the labelling; 'percentage of fat content under …' and 'collagen/meat protein ratio under …'

Member States may allow the placing on their national market of minced meat which does not comply with these criteria under a national mark and, in the case of prepacked mince, the declaration of fat and collagen/protein values. The UK allowed this under domestic legislation.
The standards are welcomed by FSSC but steak mince, not surprisingly for EU legislation, remains undefined.
However, it is arguable that “steak mince” is a customary name in Scotland for beef mince with a low fat and connective tissue level and, as such, that the composition is controlled.

A standard for steak mince
The need for a standard for steak mince persists. It assures consumers that they are buying a premium product with a controlled fat content; it encourages a level playing field for traders and provides an efficient enforcement standard for food authorities.

Steak mince is a particularly important component of the Scottish diet and it is appropriate that SFELC considers a standard. SFELC's current position is that steak mince should have the same fat standard as SFELC proposed for lean mince, i.e. a maximum of 10%. The EU regulations have now defined lean beef mince as having a maximum fat content of 7%.

Interrogation of UKFSS for samples of beef steak mince taken and reported in 2015 yielded the data shown in Table 2 and Graph 1. Not all samples were analysed for connective tissue and insufficient data exists to draw any firm conclusions. Previous work indicates a general relationship between fat and connective tissue levels in mince.

Fat content
Number of samples
Percentage of samples
≤7%
40
55%
>7% – ≤10%
14
19%
>10% – ≤20%
19
26%
Table 2 – Fat levels in 73 samples of beef steak mince taken and reported in Scotland during 2015
Graph 1 – Fat levels in 73 samples of beef steak mince taken and reported in Scotland during 2015

The average fat level in the samples was 7.3%. 55% of the samples had a fat content of 7% or less. 66% of the samples had a fat content of less than 8%
SFELC's previous view that steak mince is a premium product with lower levels of fat and connective tissue would, logically, now lead to that standard being at least as tight as that for lean minced beef.

There is no reason not to specify the connective tissue criteria as well as the fat level criteria.
The data above shows that most samples would comply with a maximum fat level of 7%. It is important to note that the samples interrogated were not taken as part of a survey or focussed sampling of steak mince. In particular there is insufficient data to investigate any difference between samples obtained from multiple retailers/large producers and independent retailers/local producers.

Work would be required to communicate this standard to the trade and it would be appropriate to state a transition period for compliance.

Recommendations
FSSC recommends that
• “Steak mince” is recognised as a customary name in Scotland for minced beef with a lower fat and connective tissue level than standard mince
• The composition of steak mince should be the same as that set out in the Food Information to Consumers Regulations 1169/2011 for lean minced meat
• FSS should work with the trade to promote this standard
• It would be appropriate to enter a transition period of six months before the standard is employed.

DS commended the paper, its clarity and its recommendations. EHO Craig Easson from Angus highlighted a potential problem in that some supermarkets are currently labelling steak mince as maximum 15% fat!

Date of next meeting:
Friday 15 April 2016. Venue: Malmaison, Dundee (provisionally)