Appendix 4: Regulatory Review Data
Recent abattoir closures in Scotland have been considered in the context of the extent to which regulations impacted on these (discussion with Scottish Government) and there are varying degrees of influence in terms of how these could be viewed to having been impacted with no specific common thread. This section of the report considers the impacts, opportunities and areas of uncertainty in terms of how existing regulations may impact on the viability of mobile abattoir infrastructure operating in Scotland in the future.
The regulatory review is split into two steps:
- Desk-based research to identify questions/matters to be subsequently covered with the key stakeholders.
- Engagement with the key stakeholders responsible for implementing regulations, policy and developing this in the future.
The FSS website provides a full list of the pertinent legislation with respect to relevant regulations which do not need to be repeated here, but for indicative purposes the following represents a significant body of these regulations with respect to MSU operations:
- Welfare of Animals (Slaughter or Killing) Regulations 1995
- EU Regulation (EC) No 853/2004 laying down specific hygiene rules for food of animal origin
- Animal Health and Welfare (Scotland) Act 2006
- Food Hygiene (Scotland) Regulations 2006
- Cattle Identification (Scotland) Regulations 2007
- EU Regulation (EC) No 1069/2009 laying down health rules as regards animal by-products and derived products not intended for human consumption (Animal by-products Regulation)
- EU Regulation (EC) No 1099/2009 on the protection of animals at the time of killing
- Transmissible Spongiform Encephalopathies (Scotland) Regulations 2010
- Welfare of Animals at the Time of Killing (Scotland) Regulations 2012
- Animal By-Products (Enforcement) (Scotland) Regulations 2013
It should be noted that Regulation (EC) 1099/2009 on the protection of animals at the time of killing which came into force across Europe on 1 January 2013 involved some measures in relation to layout, construction and equipment in existing slaughterhouses which do not come into effect until December 2019. Although written for England, the DEFRA Information Note “Welfare of Animals at the Time of Killing in England” has a summary of the implications. For illustrative purposes, some of the areas impacted by this include stunning methods, lairage facilities, restraining equipment, slaughterhouse approvals, etc.
There have not been discussions with the British Veterinary Association (BVA) and Veterinary Public Health Association (VPHA) as part of this project. However, reference is made here to a joint response to the UK All-Party Parliamentary Group for Animal Welfare (APGAW) abattoir provision enquiry (in March 2019) which stated the following, in terms of its position on mobile abattoirs (emphasis added is ours):
- “We are aware that stakeholders are currently exploring the feasibility of mobile abattoirs as a means to increase local abattoir provision.
- BVA is supportive of exploring options to provide more opportunities for farm animal slaughter as close to the point of production as possible, in turn reducing the need for animals to be transported over longer distances.
- The role of mobile abattoirs should be further explored to create more opportunities for on-farm slaughter of animals destined for human consumption.
- Mobile abattoirs would need to comply with current legislative requirements for animal health and welfare at slaughter, biosecurity, food safety and hygiene checks, including ante- and post-mortem inspections performed by Official Veterinarians. In addition, there would be a need for safe lairage facilities, a potable supply of water, facilities for the disposal of animal by-products, as well as suitable facilities for the dressing and movement of carcases.
- As emphasised in the above section, any growth in mobile abattoirs should not represent a downgrading of animal health and welfare or public health standards and we could only support the use of mobile abattoirs where appropriate supervision from Official Veterinarians was in place.”
The aspects underlined above, very much related to the operational aspects of any future mobile abattoir service, are used as the headings in the next section, to focus this review of regulations.
The views of other potential key stakeholders, such as QMS, Soil Association and the Scottish Organic Producers Association (SOPA) are also provided for further information, to offer a range of views in terms of requirements, not only in terms of regulations, but to meet the standards of these organisations. The Soil Association and SOPA are included because they have the potential to reflect niche supply chain drivers that could support future mobile abattoir development.
Desk-based Assessment of Regulations and Standards
Animal health and welfare at slaughter
Two key regulations in this context are:
- The Welfare of Animals at the Time of Killing (Scotland) Regulations 2012
- The Welfare of Animals (Transport) (Scotland) Regulations, 2006
There are arguments, and a range of online publications, from a number of parties, that mobile abattoirs are more likely to facilitate higher animal welfare, in particular related to the transportation distances. The “Soil Association Standards - Abattoir and Slaughtering, Version 18”, in terms of “arrival and unloading” describes a key statutory welfare requirement:
“Slaughterhouses must have suitable equipment and facilities for unloading animals. Animals must be carefully unloaded from vehicles as soon as possible after they arrive. The welfare and health of animals must be assessed upon arrival in order to prioritise those animals with specific welfare needs. If an animal has been injured during transportation and cannot be unloaded without causing it pain, it must be humanely killed or slaughtered on the vehicle, using an appropriate emergency method.”
The standard mentioned above, in terms of “stunning and killing equipment” summarises a key statutory welfare requirement below:
“Any method of stunning used must cause an animal to lose consciousness immediately without distress and remain unconscious until the animal has died from blood loss. The WATOK and EC Regulation 1099/2009 stipulate the permitted methods of stunning or killing animals and lays down specific requirements for their operation. The Soil Association standards require that all animals are pre-stunned before slaughter and also set higher requirements for the gas killing of pigs.”
The guidance “Red meat slaughterhouses: unloading, handling and holding animals” describes the methods to be used, relating to the above. An understanding of the procedures to be followed comes from having trained/qualified personnel in place, however, there are design and logistical aspects that are emphasised here, because locations which are intermittently involved in animal slaughter have different challenges. Areas for consideration in this respect include:
- Responsibility – the slaughter site will be managed by a local party (farmer, abattoir, butcher etc) who must co-ordinate with the veterinarian, producer and MSUs, with systems in place which manage situations such as severe weather, break-downs (of the MSU vehicle), sickness (e.g. of the OV), etc.
- Set-up – an additional consideration which will require familiarity, developed over time, which fixed facilities are potentially less challenged by. For example, to have additional bedding if animals remain in lairage for 12 hours or more).
- Timing – procedures need to be in place to manage issues that develop, for example:
- If animals arrive before the MSU does, and/or the OV.
- Emergency slaughter requirements, with timing issues complicating this.
Many of this issues referred to above can be mitigated against by employing a docking station approach, where the locations visited by MSUs are familiar, and in effect are part of the operational and management framework for the MSU business – with scheduled, repeat business and visits on an ongoing basis.
The following are highlighted as examples of where there could be particular impacts in terms of MSUs compared to fixed facilities:
- Disease outbreak
- Dirty livestock
The guidance “Controlling disease in farm animals” states:
“Meat from establishments where a disease outbreak is suspected or confirmed may not enter the human food chain. Instead, it must be disposed of by slaughterhouses as a Category 2 animal by-product, i.e. high-risk material containing potential contamination.”
Observations/questions related to the above are indicated below:
- The potential to have MSUs at farms may be considered a risk, in terms of the impact on the rest of the animals - measures to mitigate against potential impacts, perceived or significant, would need to be developed.
- There is some published data indicating that the slaughter of animals locally, rather than moving them over larger distances to fixed abattoirs, may be a positive development in terms of traceability, identifying the source of diseases, and speeding up the process of addressing the issues and mitigating against their spread and severity. The Swedish and Australian case studies both discuss how they use the mobile abattoir to provide the consumer with information on what farm the meat has originated from. This is a key selling point (QR codes): “Utilising the latest traceability technology, our digital provenance platform connects you with the origin of your food. A simple scan of the QR code reveals insights into the true provenance of your beef; the breed of cattle, the land on which is was raised, how it was farmed and by whom.”
With regards to traceability, and managing the cleanliness of animals presented to abattoirs, the QMS “2018 Cattle & Sheep Standards Quality Meat Scotland Assurance Scheme” provides an example of action with implications for brand eligibility, stating:
“Traceability of product is key and checker systems are available to farmers, auction markets and abattoirs, for determining the brand eligibility of Scotch assured livestock. For members’ information, abattoirs receiving dirty livestock may report this to Trading Standards or Animal and Plant Health Agency (APHA) and according to industry feedback, improvements are needed in the presentation of clean animals for slaughter.”
Observations/questions related to the above are:
- Because of their much smaller size and confined spaces, the importance of animals being presented “clean” to MSUs may be even greater than to fixed infrastructure and therefore awareness-raising, pre-haul procedures may need to be considered.
- In addition to the above, it should be noted that in terms of the Scottish Organic Producers Association (SOPA) publication, “SOPA Standards for Processors, Importers & Animal Feed Compounders Section 12 – Abattoir Standards” there would appear to be no further information (in addition to the regulations) provided, with respect to additional biosecurity requirements.
- The Soil Association Standard (Abattoir and slaughtering Version 18) appears to make no additional, specific mention of biosecurity requirements.
- Should an animal/ meat be considered by the OV as being unsuitable for human consumption during the ante/ post hygiene check, there are considerations that would need to be addressed on how to keep the animal/ meat separate.
There is now a body of research that describes improved meat quality associated with animals that have been slaughtered locally, where stress associated with haulage over significant distances is avoided, however it is difficult to describe, at this point in the project, aspects of MSU operations that are likely to improve food safety standards. However, this is an aspect of the work which will receive some focus.
In terms of effective operational measures, the 2008 FAO report on Abattoir Development describes how:
“Effective process control in abattoir operations on the basis of Good Hygiene Practices (GHP) and Hazard Analysis and Critical Control Point Schemes must be the ultimate target to be achieved.”
Hygiene checks, ante and post-mortem inspections by OVs are requirements of the industry.
This review has identified that recruiting and retaining suitably qualified staff has been an issue for the operation of MSUs. Discussions with two stakeholders (Purdis and Abattoir Equipment Supplies) have indicated that they are hoping to operate MSUs with two members of staff (Purdis have stated that one member of staff would be an animal health inspector). Several consultees have indicated that the requirement to have a vet on site was an economic restriction, however, as described elsewhere in this document, low throughput facilities have significant discounts applied to OV and MHI costs, and their contribution to the overall operational costs is minimal (see the cost benefit analysis later in this report).
Key to delivering the required food safety standards is therefore the competence of the members of staff and in 2013 new EU legislation came into force, introducing Certificates of Competence (CoC), replacing slaughterman licences issued under the “Welfare of Animals (Slaughter or killing) Regulations 1995 (WASK). The implementing regulations in Scotland were “The Welfare of Animals at the Time of Killing (Scotland) Regulations 2012.”
In terms of food safety, a review of SOPA and the Soil Association standards indicated the following:
- SOPA Standards for Processors, Importers & Animal Feed Compounders Section 12 – Abattoir Standards” - no specific mention of food safety.
- Soil Association Standards Abattoir and slaughtering Version 18 - Only references to safety are with respect to lairage, cleaning chemicals, bleeding, sticking and monitoring.
There are many, key statutory welfare requirements in terms of lairage, including:
- Animals not taken directly to the place of slaughter must be kept in lairage, for as short a time as possible and slaughtered without undue delay. Every animal should be protected from adverse weather conditions and provided with adequate ventilation. Every animal kept in the lairage must have enough space to stand up, lie down and turn around without difficulty.
- Water must always be available to all animals in the lairage. Any animal that has been on the site for 12 hours or more must be provided with food, for organic animals this must be organic feed. If animals are kept in the lairage for more than 12 hours, they must be given bedding (such as straw), or equivalent material (such as rubber slats), suitable to the species of animals, their number and what they are accustomed to.
- The condition and state of health of every animal must be inspected at least every morning and evening by a competent person. Any animal judged to be experiencing pain for any reason must be slaughtered immediately. Animals that are unable to walk must not be moved or made to move, but must be killed where they are.
Scottish Regulations will be introduced in 2019 in terms of mandatory use of CCTV. The Mandatory Use of Closed-Circuit Television in Slaughterhouses (England) Regulations 2018 requires slaughterhouse operators to install and operate a CCTV system that can cover the areas where live animals are present. These areas include unloading, lairage, handling, restraint, stunning and killing areas. MSUs will also need to provide the same functionality, and as such it is anticipated that there should be little/no difference between them and fixed abattoirs.
A review of SOPA and the Soil Association standards indicated the following:
- SOPA Standards for Processors, Importers & Animal Feed Compounders Section 12 – Abattoir Standards: sections 12.4.1 to 12.4.8 provide the requirements for lairage. Other references made in terms of lairage are the statutory welfare requirements.
- Soil Association Standards Abattoir and slaughtering Version 18 - references to lairage are with respect to CCTV, Certificate of Competence (CoC) for workers, labelling with respect to organics animals, organic feed for animals held more than 12 hours.
Potable Supply of Water
In addition to the requirements set out in the animal welfare regulations, SOPA and the Soil Association standards state:
- SOPA, Standards for Processors, Importers & Animal Feed Compounders Section 12 – Abattoir Standards”: references to drinking water at lairage and water sprays for pigs.
- Soil Association Standards Abattoir and slaughtering Version 18 – references to water for animals in the lairage, rinsing to remove residues (cold water may not be sufficient) and for disinfection (water and steam).
Facilities for the disposal of animal by-products
Key European and Scottish animal by-products regulations (ABPRs) related to waste/mortalities are as summarised below:
- EC No 1069/2009 – laying down health rules as regards animal by-products and derived products not intended for human consumption and repealing Regulation (EC) No 1774/2002 (Animal by-products Regulation).
- EU No. 142/2011 - The EU ABP Implementing Regulation (implementing EC No. 1069/2009).
- EU Reg No 2015/9 –amending Regulation (EU) No 142/2011 implementing Regulation (EC) No 1069/2009.
- Animal By-Products (Enforcement) (Scotland) Regulations 2013 – referred to below as the ABP (E) (S).
In terms of SOPA and Soil Association standards, the following is pertinent in terms of how the management of ABP waste is considered:
- SOPA Standards for Processors, Importers & Animal Feed Compounders Section 12 – Abattoir Standards: no specific mention of animal by-products.
- Soil Association Standards Abattoir and slaughtering Version 18 – reference to the EC No. 1069/2009 above, only.
The FSS Manual for Official Controls (Amendment 13) states that:
- Premises, machinery and implements used in SRM removal are clean before operations begin and during processing to prevent cross contamination
- Storage and transport bins are clean, leak free and impervious, indelibly marked/ labelled with well-fitting lids which are used when the bin is used to store or transport SRM
- Bins are washed and disinfected when required and not used for any other purpose
- Bin liners, if used to line SRM bins, are used once only and disposed of entirely as SRM
In terms of the above, and the management of ABPs generally, a number of key considerations and questions for regulators (e.g. FSS and SEPA) are identified and summarised below:
- For a mobile abattoir docking system/approach, ABPs from slaughter would most likely have to remain at the docking station location, categorised under Cat 1, 2 and 3, and stored until an authorised collector arrives. Acceptable, secure conditions would be required to facilitate this.
- Does the regulator have a view on storage infrastructure requirements (other than what has been commented on above), the timeliness of subsequent uplifts etc for different types of docking station? For example, these could be co-located at farms, butchers’ premises, auction marts, etc.
Both FSS and the APHA have been engaged on these questions, with their responses shown in the stakeholder engagement section later.
Suitable facilities for the dressing and movement of carcases
Observations in terms of dressing and the movement of carcases are summarised below:
- In addition to ABP storage, docking station locations could be set up to have chilling infrastructure located on site e.g. at auction marts, butchers’ premises, farms.
- The FSS Manual for Official Controls (Amendment 13) describes verification and inspection requirements for food chain information and the collection and communication of inspection results.
In addition to the above, the SOPA and Soil Association have the following standards which will need to be taken into consideration by any future MSU operator:
- SOPA Standards for Processors, Importers & Animal Feed Compounders Section 12 – Abattoir Standards: sections 12.6, 12.7 and 12.8 refer to requirements Processing, Storage and Labelling respectively.
- Soil Association Standards Abattoir and slaughtering Version 18: Processing organic and non-organic:
- If you process organic and non-organic products, either using the same equipment or at the same site, you must: a) assess the risk of contamination and mixtures or exchanges, and put in place controls to avoid those risks
- Process and store organic products separately, in time or space, from non-organic products
- Ensure that the cleaning of your facilities and equipment is sufficient to remove residues of non-organic product before you start processing
- Finish the whole run of organic products before you start to process non-organic products
- Keep a record of all organic and non-organic operations and the quantities processed.
Engagement with Stakeholders
Scottish Government: Rural & Environment Science & Analytical Services (RESAS)
Steering group meetings, hosted by RESAS, were attended by a range of interested Scottish Government teams. It is important to emphasise up-front that there were no regulatory issues raised at the RESAS hosted meetings that would prevent the potential operation of a mobile abattoir in Scotland.
An initial desk-top review and stakeholder engagement work, prior to the first meeting, had identified that there may be a number of issues that make an MSU less economically viable (than a conventional static abattoir) - common issues raised were associated with waste disposal, chilling, processing capacity and throughput. To overcome some of these issues, some overseas examples have developed “docking stations”, which are areas that have some level of static infrastructure in place and typically enable a number of farmers within a local area to bring stock to in order to increase throughput at the MSU.
Overseas examples are typically based at larger farms or at purpose built locations, however the question was whether it would be possible to site an MSU at a range of docking stations by utilising the existing supply chain (e.g. farms, marts, abattoirs, butchers, etc), to reduce capital and operational costs and encourage buy-in throughout the supply chain. The key comments regarding this approach are summarised below:
1. There should be no significant issues co-locating a mobile abattoir beside a mart, however time or physical separation would be essential. Disease control would need to be managed. For a low-throughput mart it could work and would make sense for an MSU to be co-located. It was noted that a potential business risk would be restricted movements during disease outbreaks (this would be an issue for an MSU regardless of whether marts were used as potential docking stations).
2. The mobile abattoir could potentially be located at an existing abattoir site, provided each operator specified responsibilities (the thinking behind existing at a local abattoir was that the MSU could process private/ organic kill). If the mobile abattoir was to be located at a butchers, this would need to be discussed with FSS.
3. No significant issues associated with an MSU locating on a farm, however it was noted that the farm would need to have QMS membership/supervision in order to retain “Scotch Beef” label (further discussion with QMS was recommended).
4. With regards to the subsequent use of land that had been used as lairage the Scottish Government confirmed that the following would apply:
a. Standstill period – 13 days (cows and sheep), 20 days for pigs. For disease control.
b. Maximum in Scotland would be 28 days (lands that could not be cleaned and disinfected).
5. Other potential docking stations were identified as game and deer handling facilities – common throughout Scotland.
6. The issue of waste generation and storage was raised, whilst this is not the specific remit of this team (FSS are the appropriate body). For a mobile abattoir docking system/approach, ABPs from slaughter would most likely have to remain at the docking station location, categorised under Cat 1, 2 and 3, and stored until an authorised collector arrives. Acceptable, secure conditions would be required to facilitate this. Note: Subsequent discussions with mobile abattoir manufacturers have indicated that ALL waste is typically bulked at the MSU and would either need to all be treated as Cat 1 or separated by operatives. Later in this report the benefits associated with leaving stomache/intestine content at a location, for spreading to land, rather than hauling as waste, is considered.
7. It had been noted that MSU’s rarely contained a detain rail for carcases that are deemed unfit for human consumption after slaughter. Clarification of the procedures was sought, should this occur. This is very rare, however it is anticipated that slaughter would need to stop, this was later checked with MSU manufacturer’s, that confirmed this would be the case, due to a lack of space.
8. Hygiene requirements are specified within the regulations - whilst these would be made more difficult with the limited space, they should be do-able e.g. using disposable overalls. It would be easier if these types of facilities could be shared e.g if a docking station approach is adopted. Other key points that would need to be considered include drivers hours, hygiene facilities, secure facility for OV, getting appropriate staff.
9. No restrictions on the MSU being used for multi-species. Important to maximise value and ensure that there are markets for all products. It was noted that landfill would not be a favoured option.
10.There is a requirement to transport casualty animals to an abattoir within 2 hours if not using active refrigeration, therefore this may only work if the MSU is already scheduled to be in the area, and the animal has a minor injury.
11.There was some discussion around seasonal/ modular abattoirs and whether these should be considered. Modular abattoirs are typically a number of porta-cabins that can be moved from site-to-site, but on a less frequent basis than a traditional MSU.
12.With regards to regulation of a potential MSU, all of the key bodies are national and therefore an MSU should not present any significant issues. The reporting requirements would be the same as a conventional abattoir, however there would need to be a separate County Parish Holding (CPH) number movement that would be recorded to the CPH, which would need to know where the MSU was at that time. However could potentially use a Scottie ID. There is no specific reporting mechanism set up at the moment, and therefore a new one would need to be created, whilst this would take time, it was not percieved to be a significant factor. Sheep movements require abattoirs to report to a central database, however a hand-held scanner can be purchased. Connectivity to internet may be an issue, but have 24 hours to report.
Food Standards Scotland (FSS)
The FSS guidance manual, the Manual for Official Controls (MOC), contains details of the tasks, responsibilities and duties FSS staff and veterinary contractors undertake in approved meat establishments. The Food Standards Agency (FSA) “Meat Industry Guide” (MIG) was discussed and confirmed as a key document in terms of the considerations required in abattoir design.
Overall, in terms of MSU design and operation, the key aspects to be considered are:
- Separation between activities – clean and dirty.
- Separation in space and time.
- Advise the Official Veterinarian (OV) of the steps
All OVs in the future will be managed through FSS and the OV on small plants will be able to do both ante and post mortem inpsections
It was commented that a 2017 amendment (EC No. 853/2004, Annex III, Section 1, Chapter VII paragraphs 1 to 3) allows FSS to authorise slaughterhouses to transport warm meat from domestic ungulates. This does not provide any operational advantages or exemptions, however, in terms of MSUs, as explained in the FSS guidance/policy document – see Box 1.
Box 1. FSS, Policy on Transportation of Warm (above temperature) Red Meat from Slaughterhouses in Scotland
The following is a key extract from the above policy document with reference to “warm meat”:
“…meat of domestic ungulates is to be immediately chilled after post-mortem inspection to a core temperature of not more than 7ºC
the meat must leave the slaughterhouse, or a cutting room on the same site as the slaughterhouse, immediately (i.e. a guideline 3 hour period from the completion of the post-mortem inspection of the first animal slaughtered to be transported warm, to the departure of the vehicle) and the transport takes no more than two hours; and (iii) is justified for technological reasons.
This derogation must not be used for operational reasons unless there is an associated technological reason – i.e. where chilling is not recommended as it may not contribute to the hygienic and technically most appropriate processing of the product, for example: foie gras. The specific product also needs to undergo a step (further processing) for which it is better that the product is not chilled before starting or carrying out the transport.”
In a general discussion about the operational challenges and opportunities, the following was covered:
- Chill space is a key challenge. Refrigerated containers – approvals are straightforward. The use of temporary covers/curtains are possible, between adjoining process locations. A central belt abattoir is using 2 such containers and configurations.
- Lairage sharing could be a potential opportunity – depends on the site.
- The slaughter box will be one of the the costliest aspects of an MSU’s design and build. The question was asked about the potential for using the slaughtering facility of existing facilities where appropriate, with the MSUs providing other services.
- Saturday and Sunday working is a possibility in terms of collaboration with existing abattoirs.
It was commented that in terms of animal welfare officers, there is the threshold, below which no animal welfare officer is required, the threshold defined as:
“The animal welfare officer is not required for slaughterhouses slaughtering less than 1,000 livestock units of mammals or 150,000 birds or rabbits per year. However, obligations related to their tasks as previously described remain and have to be implemented by the slaughterhouse operator.”
Council Regulation No. 1099/20098 provides additional context on the animal welfare position – see Box 2.
Box 2. Council Regulation (EC) No 1099/2009 “on the protection of animals at the time of killing” states:
(47) Small slaughterhouses predominantly involved in the direct sale of food to the final consumer do not require a complex system of management to implement the general principles of this Regulation. The requirement to have an animal welfare officer in place would therefore be disproportionate to the objectives pursued in those cases and this Regulation should provide for a derogation from that requirement for such slaughterhouses.
A key guidance document in terms of understanding how costs would be applied for veterinary and meat inspection controls with MSUs is the 2018 FSS “Guidance Charges for Official Controls in Approved Meat Establishments in Scotland”. This guidance describes the need for charges, and where the regulatory requirements set this out. A fundamentally important aspect of this, with respect to a small throughput MSU operation is how the OV and MHI charges would be discounted, as explained in paragraph 46 of the guidance:In terms of the costs associated with regulations and the impacts specifically on MSUs, these are comparable to small-scale abattoirs currently operating (e.g. the island abattoirs). An important example of how costs are applied concerns the OV and MHI requirements, where there are significant differences in the fee
“The discount is applied accumulatively to LSU levels: an FBO producing 6,000 LSU would receive 85% discount for the first 1000, 70% discount for the next 4000 and 21% discount for the remaining 1000.”
In addition to the above, the contracting model for OVs and (MHIs has changed September 2019, with FSS now directly employing all OVs and contracting the MHIs. The rates applied at the moment (October 2019) are set out in this guidance and are £40.55/hr for OVs and £30.05/hr for MHIs.
In effect, when calculating the OV and MHI costs where discounts apply, expenses (flights, accommodation etc) are covered within the hourly rate above i.e. for an OV flying to a remote location, and staying overnight at a hotel, the cost for an MSU operating below 1,000 LSU per annum would be 15% of the hourly rate (no additional costs for expenses). This is the same charging situation with the island abattoirs at the moment.
A worked example is shown on the basis of the above, where an OV does the ante mortem inspection, taking, for illustrative purposes 1.0 hour and then also does the MHI’s work for the remainder of the day, say 6.0 hours (cheaper for the FSS to do this rather than send one OV plus and MHI to a site). In other words, the OV does the work required for an MHI, but at the lower rate (£30/hour) for the remainder of the time. i.e. the cost to the abattoir would be:
15% x [(1 x £40) + (6 x £30)] = £33 per day (7.0-hour day).
If an MSU is considered to have issues in terms of how it is operating (performance/standards) then the subsidy cannot be used to maintain and support FBOs in this situation and so the FSS is at liberty to then charge the full fee.
Trichinella testing was discussed for pigs not in controlled housing, for which no FBOs are charged (the cost is borne by the FSS) - only applies to boars and sows. It was commented that it was reasonable to assume that setting up a British Standard-certified laboratory for this would be very expensive (there are significantly equipped laboratories, in place at larger abattoirs). Where there are such laboratories in place the FSS pays the FBOs £0.60 for every sample tested - it is much cheaper for the FSS to do this than pay the £48.50 cost for the samples that an MSU may be required to have tested. In terms of the logistics and timescales for testing it is understood that an OV would be able to arrange for a courier to collect samples on the day of the slaughter, with the results coming back a day or two later. The chilled carcases would need to be stored until the results come back at which point they could be released.
In terms of the percentage of pigs that are considered to not be in controlled housing, it is believe that this applies to a minority of livestock, but the FSS are surveying farmers for this data, and if the results are available during the timescale of this study they will be shared. In general, the process of testing for trichinella did not cause any particular concerns as along as the requirements are followed.
The EU Official Controls Regulation (OCR) was mentioned, and its implications in terms of future process. The implementation of this has the potential to be impacted on, depending on the outcomes of BREXIT negotiations. At this stage, therefore, only a brief summary of this is provided in the box below, until a clearer picture is available.
Box 3. Summary of the New EU Official Controls Regulation (OCR)
Regulation (EU) 2017/625 on official controls and other official activities performed to ensure the application of food and feed law, rules on animal health and welfare, plant health and plant protection products – referred to as the Official Controls Regulation (OCR) – is a directly applicable EU regulation that sets operational standards for the performance of official controls and other official activities by competent authorities (CAs) across the EU. Although the OCR entered into force on 27 April 2017, the main date of application is 14 December 2019.
As of that date, the OCR will repeal and replace existing legislation which is integral to the activities of FSS, as the national CA responsible for the delivery of official food and feed controls in Scotland, and enforcement bodies. This includes Regulation (EC) No 882/2004 and Regulation (EC) No 854/2004. Rules in the Delegated Regulation (EU) 2019/624 and Implementing Regulation (EU) 2019/627 made under Article 18 of the OCR repeal and replace Regulation 854/2004.
Local Authority Planning Team
General planning requirements were discussed for a mobile abattoir potentially operating in Scotland. The key points are summarised below:
- If the mobile abattoir is to be located at a site for more than 28 days within a year, then each of the sites that the MSU visits will require full planning permission. If the mobile abattoir will be present on a site for less than 28 days, then it will be classed as a permitted development, and will not require planning permission (however Environmental Health will have an input).
- If planning permission is required, the following are typical timeframes:
- Pre-application process: 4 – 8 weeks
- Full planning process: 2 months
- The planners would assess the standard issues e.g. i) parking, ii) Access, iii) Hard standing, iv) drainage v) vehicle access, etc.
- The fee can be calculated on-line and is based on floor space of the MSU.
An assessment of the potential impacts of the planning requirements will be carried out for the final report, because the requirements are likely to be impacted by the operational model e.g. it is anticipated that docking stations would require full planning permission, however if the MSU is travelling between host farms, then it is possible that it could be exempt from planning requirements.
Local Authority Animal Welfare & Environmental Health Officer
It was assumed that ian MSU would be similar to having a mini-market/mini-abattoir within the area and would anticipate occassional inspections. Would need to attend if there was an issue with farmers potentially using the MSU for casualty slaughter (when livestock should have been shot in the field for animal health) or if either the wrong animal or documentation was provided to the MSU.
A second enquiry was made with the Environmental Health team, who believed that local authorities would be the main regulators if a very small number of animals are slaughtered per month, and above a threshold, FSS are the main regulator. If the local authority are the main regulator they would do an initial inspection to determine the number of inspections required per year. The officer felt that an MSU would be relatively low-risk, because all of the products are raw. In terms of potential issues, the local authority team would have some involvement in waste and odour complaints, however from a regulatory point of view, it was considered suitable.
Local Authority Building Standards Officer
The officer believed that because an MSU is not technically a “building” it would not be covered by Building Standards. If the MSU was to utilise the existing drainage network for example, at a docking station, then they may have some input, however it would be in relation to the fixed infrastructure.
Local Authority Roads Manager
The roads manager indicated that there may be some restrictions on movements dependent upon the size and weight of the MSU, and this may influence potential routes that can be taken. An example was provided in Mull, where, for example empty vehicles are permitted down certain roads, but once full (and exceeding the weight requirements), an alternative route must be taken. All local authorities have details of the various restrictions and permits/ exemption maps and procedures for information.
Scottish Environment Protection Agency (SEPA) - Waste
The waste team believed that SEPA would not have a role in the regulation of an MSU from a waste management perspective. There may be other requirements, site specific, if there are emissions, nuisance etc.
The Animal and Plant Health Agency (APHA)
The regulation of ABP waste is controlled by the APHA and it is understood that an MSU would need approval by the APHA as would locations identified for the storage of ABP waste (docking stations holding waste). Initial feedback is that there will be several variables to consider, for example Auction Marts already have biosecurity protocols in place whilst industrial units would need a new licence.
The 2018 Animal By-products and Pet Passport Fees (Scotland) Regulations 2018 describe how the APHA charges for the assessment of applications concerning the processing, storage and other treatment of ABPs. In terms of the appropriate fee, on the basis of Table 1 in the regulations, this is currently considered to be:
- MSU Fee: £485 for consideration of “an application, for approval of an establishment or plant carrying out the handling of animal by-products after their collection, by way of operations such as sorting, cutting, chilling, freezing, salting, removal of hides and skins, or removal of specified risk material, that includes a site visit of up to 60 minutes.”
- Docking station (unlicensed) Fee: £485 - Consideration of “an application for approval of an establishment or plant carrying out the storage of animal by-products and or derived products that includes a site visit of up to 60 minutes.”
If a mobile abattoir unit and the storage locations are approved, there would be inspections costs as defined in Table 2 of the regulations. It is understood that that a cost of £157 per visit would apply for annual/biennial visits, £561 for quarterly visits etc. MSU and the storage sites (frequency of site visits will be informed by a risk assessment process).
Scottish Water commented that trade effluent is defined by The Sewerage (Scotland) Act 1968 as "any wastewater discharged during the operation of a business or industrial process". Examples of trade effluent are process waters, cooling waters, contaminated surface water runoff, and wash water from vehicles, machinery and floors. Therefore effluent from a mobile slaughter unit would be deemed to be trade effluent and as such each site at which the unit would be operated would need to apply for consent, the granting of which will be dependent on the local capacity in the network and local treatment works. The Consent will stipulate limits which needs to be adhered to and will include a maximum volume, suspended solids, biological material etc. Other key points are:
- Consent is only granted for discharges to the foul or combined sewer at a designated point and it would not be possible to collect the waste and discharge for example down a road gully.
- It is not permissible to discard whole blood to sewer and Scottish Water only accepts blood which arises from washing floors, utensils or similar activities
- Pre-treatment of the effluent would be required prior to discharge and as a minimum this is screening (through a 4 mm mesh sieve).
- Some large sites have full biological treatment to meet the Consent conditions.
- There must be nothing in the effluent which contravenes the Animal By-Products (Enforcement) (Scotland) Regulations 2011.
Quality Meat Scotland (QMS)
The development of docking stations was believed to be the most practical and economic method of operating an MSU. There were some concerns raised about the availability of slaughtermen and vets, but QMS believe that there should be no issues that are insurmountable.
In relation to the quality assurance scheme, in principle there should be no issues, but in practice, this has never been tested.
Critical to consider market demand for products - not all butchers have outlets for the whole carcase, some prefer to order just the products/cuts that they know they can sell. There is also the added cost of employing an extra butcher to break down the carcase, but this depends on the operational model employed by the MSU.
When selecting from a wholesaler, the butcher is able to stipulate the quality of the meat required - it will be important for the MSU to offer a similar service. However, it was believed that an MSU could offer a range of opportunities for butchers looking for contract kill to serve local markets etc.
Further discussion highlighted the importance of the QMS Scottish brands (Scotch Beef PGI, Scotch Lamb PGI and Specially Selected Pork) and the preference for meat to go through the QMS quality assurance channels these channels wherever possible. The quality assurance scheme, ensures that must have been born, reared and slaughtered in Scotland and spent their entire life on QMS Assured holdings.
This whole of life brand eligibility is delivered by a suite of assurance schemes: two livestock for (i) Cattle & Sheep; and (ii) Pigs, as well as four non-livestock schemes: (i) Feeds; (ii) Haulage; (iii) Auction Market; and (iv) Processor.
QMS were specifically asked about anything that may limit or restrict the viability of an MSU. The following points were raised as as being particular aspects that require consideration up-front:
- Livestock movement records: static abattoirs/markets are critical points in registering deaths with the BCMS or equivalent and have this functionality built-in, and the MSU would also need to perform this function.
- Detainment of carcases not-fit-for human consumption e.g. where would these be stored? What would the procedures be, and more widely how would waste, specifically SRM, be handled/stored?
- Hygiene requirements.
- Lairage requirements, including separation of stock.
- Ability to recruit/obtain suitably qualified staff.
- Would need to ensure that the layout was suitable to ensure compliance with all regulations e.g. the maximum stunning to stick time must be 60 seconds for cattle, etc.
More generally, the wider issues of what farmers actually want was raised e.g. what are the benefits of a mobile abattoir versus a local abattoir.
There was a short discussion around island/ seasonal abattoirs and their demand. It was noted that it is important to consider where livestock is finished to ensure that there is a demand for the MSU.
A further discussion was held with the marketing development manager regarding the potential demand for higher welfare/ known provenance meat. QMS stated that they have conducted a survey which indicated that 7 out of 10 respondents would be willing to pay more for a premium product/ higher welfare product, however how much extra is unknown, and QMS are not aware of any research that has been carried out to try to quantify this (further information on consumer demand is outlined later in this report).
QMS does not hold any information on the size of the market with respect to “farm shops” or “direct sales”. There is some interest in the “Pasture for Life” scheme, however it is still very early in terms of understanding and take-up.
With regards to potential interest from large retailers on this type of product, it was felt that the price of the product may be a barrier, and that it may be better to look at alternative outlets. In particular, having discussions with secondary processors may help to ensure that there are markets for all products and provide access to markets.