Dr Michel COURAT Policy Officer

The NGO’s position

24/10/2013

Main positive changesOther changesSlaughter without stunningMember States Obligations Implementation and enforcement Questions and conclusions

Overview

- IG 24/10/2013-

Certificate of competence and AW Officer

Monitoring procedures: especially important for slaughter without stunning.

Guides of Good Practice (article 13)

Standard Operating Procedures

Equivalent rules for importing third countries.

Stricter national rules

New rules for slaughter without stunning

Main positive changes

1stJanuary

2013

Reg (EC)1099/2009

Other Changes It is a regulation, not a directive

AW Business operators responsibility

Stunning and restraining equipment

Approved stunning/killing methods listed: Annex I

Creation of a scientific support in each MSaughter

Other Changes

New standards on construction, layout, and equipment integrated in the approval process

Possible controls of Technical indicators

Killing for disease controls

Slaughter without stunning Scope:

Amphibians, reptiles, cephalopods, decapod crustaceans out Fish: general provisions only Cultural or sportive events out of scope

Killing on farm Use of aversive CO2 for pigs Water bath stunners not phased out

( use of live shackling, prestun shocks, inconsistent stunning, inconsistent bleeding, etc)

1) Still allowed : Article 10 Charter of Fundamental

rights of the EU

2) Use of Rotative box study due before 8 December 2012…

°°°°°

Slaughter without stunning

BUT

Specific training for sacrificators Certificate of competence AW Officer Guides of Good Practice ( article 13) Standard Operating Procedures Individually restrained Ruminants mecanically restrained Two carotids to be severed Equivalent rules for importing third countries Stricter national rules

Slaughter without stunning

Main point: Monitoring procedures SYSTEMATIC Controls showing loss of consciousness or

sensibility before animals are released from the restraining system, and no signs of life before start of dressing* must be systematic

It means that if this provision is strictly respected, as it could take several mns (up to 14!), before the animal dies, the speed of the line for ritually slaughtered animals without stunning will be very slow, and thus incompatible with usual commercial speeds

Slaughter without stunning

Obligations of MS

Establishing new system of training + Issuing Certificates of Competence

Encouraging preparation Guides of Good practice and assessing them

Establishing the scientific support and the contact point

Establishing rules on penalties

Obligations of MS

Adapting the national law as necessary Assessing standard operating procedures

(SOPs) Assessing Monitoring procedures Developing information with business operators

regarding restraining and stunning equipment

Implementation & Enforcement

Conference organised by Commission and UECBV late October 2012

Evaluation of preparation : 19/27 responses ! 0 Guide Good Practices validated ( 1 in

February 2013) 80 % ( out of 19 MS) have a system of

certificate of competence 50% ( out of 19 MS) have established a

scientific support

Implementation & Enforcement

Real situation in some countries unknown Very limited info from equipment manufacturers Training of inspection services still incomplete On 1st January 2013, only 4 countries were

considering they were almost ready: DK, DE, SE, UK

EXAMPLES OCTOBER 2013 UK: AW regularly checked by OVs, COC in place, AWO in place,

slaughter without stunning not frequent

Sweden: no slaughter without stunning; GGPs?, AW NGOs not consulted; no info regarding COC; scientific support established

Slovenia: slaughter without stunning forbidden (small Jewish and Muslim communities)

Germany: GGPs ?

EXAMPLES OCTOBER 2013 Finland : slaughter without stunning does not exist: animals

are stunned at the time of slaughter, under vet supervision; COC just started ; GGPs exist for bovines, pigs, poultry , fur animals, but AW NGOs not associated

Greece: GGPs exist, AW NGOs not consulted; COC: ministry not aware; monitoring stunning or slaughter without stunning done by vets not staff; no scientific support

(Denmark), Austria: Post cut stunning

EXAMPLES OCTOBER 2013 France: No GGP validated, NGOs consulted only to

comment draft for bovines ; certificate of competence: not enough staff to do the trainings; slaughter without stunning normally only for religious customers, but controls? Monitoring procedures: apparently no change but transparency?

Netherlands: only 1 guide GGP validated: AW NGOs not associated to the preparation; slaughter without stunning: was about to be banned, but the procedure failed; procedures must be in place, with supervision by the OV; certificates of competence (COC): courses exist also for AW Officer, staff without COC will be sanctioned from this autumn onwards; scientific support?

Questions et conclusions 1

1) No country is 100% complying, some are very far from compliance:

“ Most MS are still in the process of adapting the existing programmes or implementing new training programmes according to the new requirements” ( FVO)

“Most MS have initiated modifications to their supervisory systems ( FBO Ownership)”(FVO)

8 hygiene audits in 2013 including slaughter: only 1 problem Only 1 FVO audit on AW ( Estonia) in 2013 Why different attitude compared with Laying hens or

sows??

Questions et conclusions 1

2) On the whole , on the paper, it is rather a good text (except slaughter without stunning). BUT WHO WILL ENFORCE IT ? Less and less vets, threats on their future role ( “Modernization of meat inspection”) ?

3) Slaughter without stunning: if the legislation is strictly implemented, commercial speed cannot be respected any longer, and thus an evolution will be necessary ( lobbying on religious communities to accept prior or post cut stunning, or …not respecting the law !)

Questions & conclusions

4) Is the text applicable ? compatible with line speed ( esp birds) ?? Signs of unconsciousness or death not yet determined

(EFSA)

5) Is it reasonable to transfer the ownership of AW to the FBO ?

HACCP example: serious or farce? Various scandals or frauds: horsegate; pork instead of beef,

forbidden sheep in cutting plants… Waiting for food poisoning??

Questions & conclusions

6) CCAs and OVs have a key role to play to enforce the new legislation and to improve AW in abattoirs. Do they have the willingness and the means to do it ? Will they have the willingness and the means to do it?

7) With such an uncertainty, is it reasonable to prepare a programme of modernisation of meat inspection which will fragilise the role of veterinarians..?

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