The NGO’s position

Dr Michel COURAT Policy Officer 24/10/2013

Overview



Main positive changes



Other changes



Slaughter without stunning



Member States Obligations



Implementation and enforcement



Questions and conclusions

- IG 24/10/2013-

Main positive changes

1st January 2013 Reg (EC) 1099/2009



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

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 MS

aughter

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)

Slaughter without stunning

1) Still allowed :

   Article 10 Charter of Fundamental rights of the EU

2) Use of Rotative box

 study due before 8 December 2012…

°°°°° BUT

Slaughter without stunning

          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

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 1 st 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..?

Thank you for your attention

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