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Dr Michel COURAT Policy Officer. The NGO’s position . 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.
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Dr Michel COURAT Policy Officer The NGO’s position • 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 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 1st January 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)
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
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
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 Obligations of MS
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 Implementation & Enforcement
UK: AW regularly checked by OVs, COC in place, AWO in place, slaughter without stunningnot 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? EXAMPLES OCTOBER 2013
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 et conclusions 1
Is the text applicable? compatible with line speed ( esp birds) ?? Signs of unconsciousness or death not yet determined (EFSA) 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..? Questions & conclusions