Historial: en5R2004853

__5. TECHNICAL ISSUES__

===__MEAT__===

__5.1. Clean animals__

The requirement for animals to be clean is referred to in several parts of the new Hygiene rules:
*Farmers must take adequate measures, as far as possible, to ensure the cleanliness of the animals going to slaughter (Annex I, Part A, point II. 4(c) of Regulation (EC) No 852/2004);

*Slaughterhouse operators must ensure that animals are clean (Annex III, Section I, Chapter IV, point 4 of Regulation (EC) No 853/2004);

*The official veterinarian is to verify compliance with the requirement to ensure that animals that have such hide, skin or fleece conditions that there is an unacceptable risk of contamination of the meat during slaughter are not slaughtered unless they are cleaned beforehand (Annex I, Section II, Chapter III, point 3 of Regulation (EC) No 854/2004)

The background for this requirement is that there is substantial proof that unclean animals have been at the source of carcase contamination and subsequent food poisoning.

The objective of the requirement is to avoid contamination of the meat during slaughter so as to ensure that the microbiological quality required by Community law is achieved.
Developing the means for reaching the objective is a task to be achieved by the food business operators concerned. There are different means of reaching the objective, including:
*The effective cleaning of animals, or

*The sorting of the animals in accordance with cleanliness and developing an appropriate slaughter scheme, or

*Developing procedures for the hygienic dressing of animals that must protect carcasses from unnecessary contamination, or

*Other appropriate procedures.

Guides to good practice may be an appropriate tool to assist slaughterhouse operators in defining these means.

It is the task of the competent authority to verify whether the procedures developed by the operators are carried out properly.

5.2. Lairage facilities and waiting pens

Annex III, Section I, Chapter II, point 1(a) of the Regulation lays down that “Slaughterhouses must have adequate and hygienic lairage facilities or, climate permitting, waiting pens that are easy to clean and disinfect. These facilities must be equipped for watering the animals and, if necessary, feeding them.”

As is the case for other requirements, the principle of proportionality must be respected in deciding about the nature of lairages or waiting pens. For small slaughterhouses, slaughtering few animals, there is no need to require sophisticated or extensive infrastructures, and the equipment for watering and if necessary for feeding the animals may be simple (e.g. movable equipment).

5.3. Equipment for the sterilisation of knives

Annex III, Section I, Chapter II, point 3 of the Regulation lays down that slaughterhouses “must have facilities for disinfecting tools with hot water supplied at not less than 82°C or an alternative system having an equivalent effect.”

Worries have been expressed by operators of small slaughterhouses that this requirement, with regard to the sterilisation of knives, may create the need for having available multiple facilities in the slaughter room.

The objective of the requirement is to ensure that meat is not contaminated through equipment, e.g. knives. This objective can be achieved through different means, such as:
*Having sterilising equipment for knives at key places in the slaughterhouses directly accessible by the workers. Such equipment may be the appropriate choice in the bigger slaughterhouses.

*Sterilising in a single operation a number of knives sufficient to ensure that clean knives are available throughout the slaughter operations. This solution may be appropriate in low capacity slaughterhouses.

5.4. Transport of meat at temperatures that must enable the production of specific products

Annex I, Chapter XIV, point 66 of Directive 64/433/EEC lays down that:

“Fresh meat must be chilled immediately after the post-mortem inspection and kept at a constant internal temperature of not more than + 7 °C for carcases and cuts and + 3 °C for offal.

Derogations from this requirements may, for technical reasons relating to the maturation of meat, be granted by the competent authority on a case-by-case basis for the transportation of meat to cutting plants or butcher shops in the immediate vicinity of the slaughterhouse, provided that such transport takes not more than two hours”.

At several occasions, the Commission has been questioned by food business operators who fear that this possibility has not been carried over in Regulation (EC) No 853/2004. However, the possibility of temperature derogations for the transport of meat has been maintained, and has even been broadened in Annex III, Section I, Chapter VII, point 3 of that Regulation which lays down that:

“Meat must attain the temperature specified in point 1 before transport, and remain at that temperature during transport. However, transport may also take place if the competent authority so authorises to enable production of specific products, provided that:

(a) such transport takes place in accordance with the requirements that the competent authority specifies in respect of the transport from one given establishment to another, and

(b) the meat leaves the slaughterhouse, or a cutting room on the same site as the slaughter premises immediately and transport takes no more than two hours.”

“Specific products” must be understood as any product for which the competent authority grants an authorisation and specifies the requirements to be respected.

5.5. Scrap trimmings and scrap cuttings

Annex III, Section V, Chapter II, point 1(c)(i) lays down that “the raw material used to prepare minced meat must not derive from scrap trimmings and scrap cuttings (other than whole muscle cuttings)”.

Since the word “scrap” may mean either “small pieces” or “waste”, several requests have been made to clarify what is to be understood under the terms “scrap trimmings and scrap cuttings”.

In general terms, it would not seem logical to ban products fit for human consumption from being used for human consumption. The use of small pieces (trimmings and cuttings) of meat that are fit for human consumption for the preparation of minced meat should therefore not pose a problem, it being understood that the microbiological quality of the minced meat must be guaranteed at all times, and that they have been obtained from whole muscle.

5.6. The evaluation of the food chain information by the slaughterhouse operator

With regard to the food chain information, Annex II, Section III, point 5 of Regulation (EC) No 853/2004 lays down that the slaughterhouse operators must, in order to check whether or not to accept animals on their premises, evaluate the relevant information before making it available to the official veterinarian.

In practice, the slaughterhouse operator shall check that the food chain information that is presented is complete with no obvious errors or omissions, and can be deemed effective to support his decision. It does not impose on the slaughterhouse operator to make a professional evaluation of the information since such evaluation can only be performed in a professional way by the official veterinarian.

MILK AND MILK PRODUCTS

5.7. Identification mark

It seems to be common in the dairy sector to apply several identification marks on a single package with and indication as to what mark is the valid one.

The wording of Regulation (EC) No 853/2004 does not seem to prevent such practice.

5.8. Automatic milking installations

Annex III, Section IX, Chapter I, Part II, Subpart B, Point 1(b) of Regulation (EC) No 853/2004 lays down that milk from each animal must be “checked for organoleptic or physico-chemical abnormalities by the milker or a method achieving similar results”.

Traditionally the milker checks the milk from each animal by visual inspection. Other methods achieving similar results may be used.

Other methods are necessary if milking is performed using fully automated milking installations. In particular, it would be good practice that automatic milking installations should be able to detect abnormal milk automatically and separate it from the human consumption supply. An internationally recognised ISO standard concerning the requirements for automated milking installations is being developed and is expected to be finalised in the autumn of 2005. It will include the methods used to check for organoleptic or physico-chemical abnormalities in the milk.

Draft ISO document on automated milking installations:
*Automatic milking installations – Requirements and testing (ISO/CD 20966)

5.9. Labelling

Chapter IV of Annex III, Section IX of Regulation 853/2004 prescribes the labelling of raw milk and products made with raw milk intended for human consumption in the context of labelling Directive 2000/13. This entails that the labelling information concerning products made from raw milk applies up to the point of sale. They shall be given to the consumer to allow him to make his choice. They may be provided with packaging, document, notice, label, ring or collar accompanying or referring to the concerned products.

The terms “physical or chemical treatment” referred to in point 1(b) of the same chapter should be understood as treatments to reduce possible microbiological hazards linked to raw milk or raw milk products (e.g. microfiltration).

5.10. Criteria for cow’s milk

Annex III, Section IX, Chapter II, III (1) (b) lays down that processed cow's milk used to prepare dairy products has a plate count of less than 100 000 per ml. The background of this requirement is that processed milk (e.g. pasteurised milk) that is used as a raw material has to comply with this limit before entering into a new processing step. It is not the intention therefore to require milk that has already entered into a new processing step (e.g. to which additional flora has been added for processing reasons - production of yoghurt or cheese) to comply with this criterion.