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General Q&A

Section 6: Public Health Issues (ii) - Specified Risk Materials

6.1 SRM - UK CONTROLS

Q.1. When and why were controls for Specified Risk Material (SRM) first introduced?
Q.2. When and why were controls extended to cover Sheep and Goat SRM?
Q.3. What is the purpose of the SRM controls?
Q.4. Is there any evidence of a risk from eating lamb/sheep meat?
Q.5. What is the current legislation on Specified Risk Material?
Q.6. What tissues are designated as Specified Risk Material in the UK?
Q.7. How can we be sure that the current list of SRM removes BSE risk?
Q.8. What happens to the SRM after removal and how do we know it is disposed of safely?
Q.9. Might effluent waste contain SRM?

Enforcement

Q.10. Who enforces the SRM controls?
Q.11. What action is being taken to ensure full compliance with the existing SRM controls?
Q.12. What action would be taken if SRM were discovered as being available for retail sale?
Q.13. Who pays for the enforcement of SRM controls?

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6.2 CONTROLS ON IMPORTS AND SPECIFIED RISK MATERIAL

Q.14. Is imported beef produced to the standards of hygiene which apply in the UK?
Q.15. Who is responsible for checking that standards are complied with in other countries?
Q.16. What are the SRM controls on imports?
Q.17. Are there any exemptions from the SRM rules?
Q.18. What will happen if consignments are not accompanied by the necessary certification?
Q.19. How often are consignments from third countries checked to ensure they have SRM certification?
Q.20. What will happen if consignments without SRM certification are discovered?
Q.21. What about checks on imports from, or via, other EU Member States?

6.3 EU WIDE CONTROLS ON SPECIFIED RISK MATERIAL

Q.22. What progress has been made on Community-wide SRM controls?
Q.23. What effect does the Regulation have?
Q.24. Are the controls the same throughout the EU?
Q.25. Why stricter controls in UK and Portugal?
Q.26. Is the Regulation scientifically based?
Q.27. What methods of disposal can be used for SRM?

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6.1 SRM - UK CONTROLS

Q.1. When and why were controls for Specified Risk Material (SRM) first introduced?
A.
Controls banning the use of certain bovine offals in human food were first introduced in November 1989. This followed scientific advice on tissues which were known to, or might potentially, harbour detectable BSE infectivity in infected animals. These controls have been regularly reviewed and extended since that time on the basis of developing scientific evidence. The use of these tissues, now known as specified risk material (SRM) is now controlled by directly applicable EU TSE Regulations.

Q.2. When and why were controls extended to cover Sheep and Goat SRM?
A.
In September 1996 controls were introduced to prohibit the sale of any part of sheep and goat heads (apart from the tongue) for human consumption. This followed advice from the Spongiform Encephalopathy Advisory Committee (SEAC) after consideration of research, published in July 1996, which confirmed that sheep could be experimentally infected with BSE.

Q.3. What is the purpose of the SRM controls?
A.
There is a small risk that cattle sub-clinically infected with BSE (i.e. showing no outward signs of the disease) might be slaughtered for food. With the decline in the BSE epidemic and the introduction of BSE testing of older cattle, the estimated risk from animals currently entering the human food chain is very low. The SRM controls are in place in order to reduce potential human exposure to BSE infectivity by removing the tissues that might contain infectivity from the food chain.

Q.4. Is there any evidence of a risk from eating lamb/sheep meat?
A.
BSE has never been found to occur naturally in the UK sheep flock. However, some sheep ate the same feed (MBM) which is thought to have given cattle BSE and sheep can be artificially infected with BSE. Sheep are also known to suffer from a similar disease, scrapie which could possibly be masking BSE. There is, therefore, a possible risk that BSE exists in sheep. Sheep SRM is therefore removed on a purely precautionary basis.

Q.5. What is the current legislation on Specified Risk Material?
A.
The EC Regulation 999/2001 (as amended), lays down rules for the prevention, control and eradication of certain transmissible encephalopathies. It is directly applicable in UK law and in force throughout the EU. It defines SRM and requires all Member States to take measures to remove all SRM from cattle, sheep and goats. The TSE (England) Regulation 2006 (as amended) sets out the requirements for enforcing the EC Regulation 999/2001 in England. Equivalent legislation exists in Scotland, Wales and Northern Ireland.

Q.6. What tissues are designated as Specified Risk Material in the UK?
A.
Details are available on the FSA website.

Q.7. How can we be sure that the current list of SRM removes BSE risk?
A.
The SRM controls have been and are, regularly reviewed and strengthened on the basis of developing scientific evidence. In the UK the Spongiform Encephalopathy Advisory Committee is the main scientific advisory body.

In the EU, SCoFAH (Standing Committee on the Food Chain and Animal Health) provide scientific advice to the Commission and discuss all legislation on TSEs. Advice and recommendations are also provided by the European Food Safety Authority (EFSA). New EC wide controls are introduced only after examination of scientific evidence and assessment of the risk.

Research undertaken for the Review of the former Over Thirty Months Rule, published in 2003 and undertaken on behalf of the FSA, assessed that the current SRM controls removed 99% of infectivity that may be present. (The Over Thirty Months rule was replaced by testing of older animals on 7 November 2005).

Q.8. What happens to the SRM after removal and how do we know it is disposed of safely?
A.
Once SRM has been removed from a carcase, it must be stained in accordance with the TSE Regulation. It must then be consigned without undue delay to a premises approved to handle SRM. In most instances, this will be an incinerator, where it will be destroyed, or a rendering plant where the SRM will be processed prior to incineration, co-incineration or disposal in an approved landfill site. However, SRM may also be used in research premises and some SRM can be used in technical plants (See 6.3 Q.28). There are strict rules relating to the handling and storage of SRM at these premises, and during transit between them.

Q.9. Might effluent waste contain SRM?
A.
All particulate material recovered from drainage traps in slaughterhalls is disposed of as SRM. Enforcement of controls on effluent waste is a matter for the relevant regulatory body (that is the relevant water services company for discharges to sewers; or the Environment Agency for discharges to rivers or lakes).

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Enforcement

Q.10. Who enforces the SRM controls?
A.
The Meat Hygiene Service (MHS), an Executive Agency of the Food Standards Agency (FSA), rigorously enforces the SRM controls on a day to day basis in licensed slaughterhouses and cutting plants in England, Scotland and Wales. In other food premises the SRM controls are enforced by the local authorities (these premises are not supposed to handle SRM but LAs enforce rules if SRM is found). In Northern Ireland SRM controls in licensed premises are enforced by the Department of Agriculture and Rural Development (DARD)

Q.11. What action is being taken to ensure full compliance with the existing SRM controls?
A. SRM controls are rigorously enforced by the MHS which is present in slaughterhouses on a permanent basis and makes daily visits to cutting premises. MHS inspectors supervise the removal of SRM by the plant operator. Where slaughterhouses and licensed cutting plants fail to comply with the regulations, the MHS will initiate prosecution if there are sufficient grounds for doing so. Local authorities enforce the SRM controls at other premises. Any premises failing to comply may face prosecution by the appropriate local authority if there is sufficient evidence.

Q.12. What action would be taken if SRM were discovered as being available for retail sale?
A.
Outside of licensed abattoirs and cutting premises, the SRM controls are enforced by the local authority. Were SRM (e.g. sheep head or brain or other SRM still attached to other cuts of meat) to be discovered on retail sale, the local authority would have the power to seize the material and may prosecute the owner of the business if there is sufficient evidence to do so.

Discovery of SRM for retail sale would suggest that the meat had not been obtained from a licensed slaughterhouse, and should not legally be sold for human consumption, since all meat from licensed premises is checked and health marked to certify that it is fit for human consumption (and has therefore had all SRM removed).

Q.13. Who pays for the enforcement of SRM controls?
A.
At present the cost of MHS enforcement of the SRM controls at licensed premises is met by the Food Standards Agency. The cost for the year ending 31 March 2005 is expected to be around £14m.

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6.2 CONTROLS ON IMPORTS AND SPECIFIED RISK MATERIAL

Q.14. Is imported beef produced to the standards of hygiene which apply in the UK?
A.
All consignments of fresh meat imported into the UK, from other Member States must be produced in accordance with the Community TSE Regulations (EC 999/2001 (as amended)). Specified risk material must be removed in the country of origin (with the exception of vertebral column in over 12 months of age imported cattle which must be removed at a licensed cutting plant in the UK). The risk to public health from BSE in third countries, is minimised through the application of these existing EU rules. Imports of beef and beef products are permitted only if EU rules requiring the removal of specified risk material are met and veterinary certification of this is provided.

Q15. Who is responsible for checking that standards are complied with in other countries?
A.
Ensuring that all Member States comply with their Community obligations in properly implementing and applying the Directive is the responsibility of the European Commission, whose Food and Veterinary Office carries out regular programmes of inspection visits to all Member States. Their reports are considered by the Standing Committee on the Food Chain and Animal Health (SCOFCAH) in Brussels, and, if necessary, the Commission will take infraction proceedings against Member States whose arrangements are considered inadequate.

Q.16. What are the SRM controls on imports?
A.
A. Imports of SRM are generally prohibited. However, bovine carcases containing vertebral column may be imported provided they are transported directly, with advance notice, to approved premises for the removal of vertebral column.

Q.17. Are there any exemptions from the SRM rules?
A.
Details are available on the FSA website.

Q.18. What will happen if consignments are not accompanied by the necessary certification?
A.
They will not be allowed into the country. The maximum penalty for imports in contravention of the Order is an unlimited fine and/or up to 12 months imprisonment.

Q.19. How often are consignments from third countries checked to ensure they have SRM certification?
A.
Instructions to UK Border Inspection Post (BIP) operators require them to check that every consignment of animal products which requires SRM import certification has it.

Q.20. What will happen if consignments without SRM certification are discovered?
A.
Where it is discovered that products have been imported without the necessary SRM certification an inspector may seize and destroy the product. Alternatively, if appropriate, the importer may be offered the option of re-exporting the consignment. In addition, the relevant local authority responsible for enforcement action would be informed so that they could carry out further investigations and consider prosecution action.

Q.21. What about checks on imports from, or via, other EU Member States?
A.
Single Market rules only permit random spot-checks at destination on products traded within the Community. However, following a number of finds of SRM in meat imported from some Member States, FSA has instructed the MHS to check all consignments of imported beef and this policy remains current within the UK. Following the reduction in cases, the policy of 100% checks is to be reviewed.

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6.3 EU WIDE CONTROLS ON SPECIFIED RISK MATERIAL

Q.22. What progress has been made on Community-wide SRM controls?
A.
EU wide SRM controls set out in Commission Decision 2000/418 first entered into force on October 1st 2000. The Decision has now been replaced by Council Regulation 999/2000 (as amended), which lays down rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies. The Regulation is directly applicable in all Member States.

Q.23. What effect does the Regulation have?
A.
The Regulation provides harmonised EU-wide controls on the removal of SRM, the monitoring of TSEs and the feeding of animal protein to livestock.

Q.24. Are the SRM controls the same throughout the EU?
A.
Currently the same SRM controls are applicable in most Member States. However a slightly longer list of bovine SRM applies to the UK.

Q.25. Why are there stricter controls in UK?
A.
The UK historically had the most cases of BSE but the incidence of BSE in UK cattle has declined markedly and is now below the internationally agreed threshold for moderate BSE risk status.

Q.26. Is the Regulation scientifically based?
A.
The Regulation is based on advice from the European Food Safety Authority (EFSA) and the EC Standing Committee on the Food Chain and Animal Health (SCoFAH).

Q.27. What methods of disposal can be used for SRM?
A. Permissible disposal routes for SRM under the EU Animal By-Products Regulations 1774/2002 are:

  • Incineration in an approved plant
  • Rendering in an approved rendering plant, followed by incineration or co-incineration in an approved incinerator
  • Rendering in an approved rendering plant to the EU pressure-rendering standard (minimum 133°C for 20 minutes at 3-bar pressure), followed by landfill in an approved landfill site

Some types of SRM may also be used in certain technical products (e.g. bovine horns may be used in the production of walking sticks, bovine intestine is used in the manufacture of musical instrument strings). SRM may also be used for research or educational purposes in an authorised premises.

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Page last modified: 19 December, 2006

Department for Environment, Food and Rural Affairs