Summary of Consultation Responses on Changes to BSE Testing
Thank you to all the respondents who took the time to respond to the consultation. Every reply has been examined thoroughly and every effort has been made to represent the views and opinions received.
The consultation on changes to BSE testing was published jointly by the Food Standards Agency Scotland and the Scottish Government on 31 October 2008. It asked for comments on raising the minimum age for BSE testing cattle slaughtered for human consumption and fallen stock to 48 months and on amending the Transmissible Spongiform Encephalopathy (Scotland) Regulations 2006 to administer this change. The consultation follows a series of public meetings held throughout the UK organised by the Food Standards Agency.
The consultation received Ministerial clearance to proceed over a reduced time period in order to meet the EU's expected timetable and allow the possibility of applying these proposals from 1 January 2009. The official closing date of the consultation was 3 December 2008.
The consultation paper was distributed by e-mail to the majority of the 220 consultees. Those consultees that did not have an e-mail address received a hard copy in the post. It was also made available on the Scottish Government website, and there was a link to the paper from the FSA website. The list of those consulted is given at Annex A.
The consultation attracted 6 responses. Where respondents gave permission, their responses have been published on the Scottish Government website at www.scotland.gov.uk/publications. All respondents are listed in Annex B.
All non-confidential responses are available to the public in hard copy at the Scottish Government Library, K Spur, Saughton House, Broomhouse Drive, Edinburgh, EH11 3XD. Charges for photocopies are made on a cost recovery basis. To request copies by post, enquire about charges or make an appointment to view responses, please telephone the Library on 0131 244 4552.
The findings from the consultation are discussed under the two questions asked in the consultation document.
The responses also added comments in addition to answering the two questions. These responses have been included under general comments on the consultation on changes to BSE testing.
Q1: Do you agree that it would be acceptable to increase to 48 months the age above which cattle slaughtered for human consumption must be tested for BSE? If not can you explain why?
All 6 respondents agreed with the increase. It was noted by one respondent that the proposals were based on sound risk assessment procedures.
One respondent highlighted that increasing the age to 48 months will reduce costs among the abattoir sector but combined with SRM controls will create 3 streams of cattle and added logistic and administrative requirements within plants.
Q2: Do you agree that it would be acceptable to increase to 48 months the age above which fallen and other 'risk' cattle are tested for BSE? If not, can you explain why?
All 6 respondents agreed with the increase. One respondent pointed out that the science based evidence is compelling.
General comments on the consultation on changes to BSE testing
It was stressed by one respondent that it is very important the proposals be implemented without delay and must be in force by start of 2009.
There was concern that costs may be passed on to the producers. As from 1 January 2009, abattoirs will be required to pay for BSE testing of bovines for human consumption. From 12 January 2009 free collection and disposal of fallen stock for BSE surveillance will cease.
It was suggested that it would not be unreasonable that TSE testing costs are covered centrally rather than by farmers and others. Surveillance and monitoring of disease that poses a risk to human health should be Government funded.
Three respondents would welcome a review of the current SRM rules urgently to harmonise with the BSE testing age.