BSE:
Over Thirty Month rule - Guidance for OTM abattoir approval
To be able to slaughter OTM cattle born after July 1996 for human consumption, abattoirs must be approved by the MHS. It is an offence to slaughter OTM cattle in a non-approved abattoir. The approval process is explained in more detail below. The approval process involves a series of steps. Each abattoir will complete each step to a different timescale (reflecting the work needed in each plant, and differing commercial priorities). We recommend that cattle keepers wishing to find out whether their local abattoir(s) are approved to slaughter OTM cattle for human consumption should contact their local abattoir(s) to establish whether they are approved or are intending to become approved in the future. OTM cattle sent to a non-approved abattoir will normally be treated as fallen stock (i.e. destroyed and no compensation paid).
Because of these uncertainties, the following list of approved abattoirs is not definitive, and it only reflects the known situation on the date shown for each update.
As at 14 July 2008 there are 75 approved abattoirs
Plant Number |
Plant Name |
1101 |
Anglo-Beef Processors (ABP) (Perth) |
1106 |
McIntosh Donald (Aberdeenshire) |
1108 |
Mathers (Inverurie) Ltd) |
1118 |
Western Isles Council (Stornoway) |
1121 |
Scotch Premier Meat Ltd (Aberdeenshire) |
1156 |
Orkney Meats Ltd (Orkney) |
1160 |
R Miller Meat Wholesaler (Morayshire) |
1528 |
Scottish Borders (Ettrick and Lauderdale) |
1535 |
Sandyford Abattoir (Paisley) Ltd |
1541 |
AK Stoddarts (Ayr) |
1560 |
Scotbeef Ltd (Stirling) |
1585 |
MULL Slaughterhouse (Argyll & Butt) |
1598 |
Highland Meats (Saltcoats) |
1686 |
Lochmaddy Slaughterhouse (Western Isles) |
2056 |
Linden Foods Burradon (Tyne and Wear) |
2079 |
Stockton Butchers (Cleveland) |
2091 |
Spenborough Abattoir Ltd (West Yorkshire) |
2100 |
Dawn (Carnaby) Ltd (Humberside) |
2102 |
N Bramall and Son (S. Yorks) |
2138 |
West Scottish Lamb (Cumbria) |
2141 |
Anglo-Beef Processors (ABP) (York) |
2158 |
Kepak (Wakefield) |
2161 |
JA Jewitt (Meat) Ltd (County Durham) |
2241 |
Woolley Bros (Wholesale Meats) Ltd |
2343 |
J&E Medcalf Ltd (West Yorks.) |
4071 |
Kepak UK Ltd (Preston) |
4073 |
Anglo-Beef Processors (ABP) (Ellesmere) |
4109 |
Anglo-Beef Processors (ABP) (Shrewsbury) |
4140 |
G & GB Hewitt (Cheshire) |
4152 |
Beesons Ltd (Cheshire) |
4168 |
RB Elliot & Son (Derbyshire) |
4185 |
Cheshire Equine Services (Cheshire) |
4236 |
Long Compton Abattoir Ltd (Warwickshire) |
4256 |
Farmers Fresh (Chase Terrace) (West Midlands) |
4269 |
J & B Fitton Ltd (Lancashire) |
4331 |
W Nixon & Sons Ltd (Lancashire) |
4367 |
T G Sargeant & Sons (Staffordshire) |
4373 |
Staffordshire Meat Packers (Staffordshire) |
4376 |
Harvey Ashworth (Lancashire) |
4405 |
ABP Blackburn (Lancashire) |
4414 |
G. Wood & Sons Ltd (Notts.) |
4486 |
Dunbia Sawley Ltd (Lancashire) |
4786 |
Pickstock (Ashby) Ltd (Derbyshire) |
5106 |
Dawn Cardington (Bedfordshire) |
5184 |
A Wright & Son (Lincoln) |
5207 |
H G Blake Ltd (Norfolk) |
6060 |
R W Newman & Partners (Hampshire) |
6150 |
Simply Halal (Buckinghamshire) |
6207 |
Mutch Meats Ltd (Oxfordshire) |
6238 |
Chitty Wholesale Ltd (Guildford) |
6342 |
Southern Traditional Meats (West Sussex) |
6359 |
Laverstoke Park Abattoir (Hampshire) |
7069 |
W Lloyd Williams & Sons (Powys) |
7162 |
Cig Cibyn Ltd (Gwynedd) |
7176 |
St Merryn Meat Ltd (Merthyr Tydfil) |
7190 |
The Pembrokeshire Meat Company (Pembrokeshire) |
7198 |
Cig Calon Cymru CYF (Camarthenshire) |
7204 |
HMD Butchers (Camarthenshire) |
8035 |
Ensors Abattoir (Gloucester) |
8043 |
Southern Counties Fresh Foods Limited (Somerset) |
8046 |
Jaspers (Treburley) Ltd (Cornwall) |
8068 |
Combe Martin Meats (Devon) |
8070 |
P J Hayman & Sons (Devon) |
8071 |
West Devon Meats (Devon) |
8072 |
P J King & Son (Gloucestershire) |
8073 |
St Merryn Meat (Bodmin) Ltd |
8101 |
East Hill Pride (J Coles) (Devon) |
8119 |
Alec Jarrett Ltd (Avon) |
8122 |
Nanteague Abattoir (CDV George) (Cornwall) |
8201 |
F Drury & Sons Ltd (Wiltshire) |
8216 |
Romford Wholesale Meats (Dorset) Ltd |
8217 |
S J Norman (Dorset) |
8231 |
Stillmans Somerset Ltd (Somerset) |
8308 |
J V Richards Ltd (Cornwall) |
8354 |
C & S Meats Ltd (Dorset) |
A list of OTM licensed cutting plants can be found on the Food Standards Agency website.
In order to access some of the documents below you will
require adobe reader. Further information about downloading Adobe
Acrobat
documents can be found on our help page.
The Veterinary Laboratories Agency (VLA) also has published
guidance on Bovine Brain Stem
Removal and Sampling
(81 KB).
The following text is taken from the MHS’s
OTM abattoir application pack.
Please note that the following is for information only:
1.0 Abattoir Approval Process Guidance
2.0 Abattoir Occupier OTM Pre-requisites
3.0 Hazard Identification and Control Plan
4.0 Abattoir Guidance – RMOP
5.0 Abattoir Guidance – Protocol
6.0 Blank RMOP
7.0 Abattoir guidance - Hides
8.0 Controlling the risk of exposure to Bovine Spongiform
Encephalopathy (BSE)
9.0 Guidance notes formal 2 day trial assessment
10.0 List of Consumables
1.0 Abattoir Approval Process Guidance - Specimen copy-information only
Please read the following instructions in conjunction
with the flowchart,
(21 KB) this will help give you a broad understanding of each individual
step in the process. Please be aware that this is not an exhaustive
list but is a guide that may help simplify the procedures you will have
to go through in your approval to slaughter Over thirty Month Cattle
for Human Consumption.
Step 1 – As the Plant Occupier, you must ensure that all of the prerequisites for OTM processing are in place before attempting the approval process (see Chapters 2 and 3 for prerequisites). The prerequisites underpin the OTM process and therefore if any are not fully implemented your application will not go forward for approval.
Step 2 – When satisfied that you are sufficiently informed regarding the process and your responsibility as an Occupier, you must plan how you propose to process OTM bovines. When you have sufficiently detailed plans of what you propose, you may find it helpful to discuss these with the OVS who following their training, will be able to give guidance on whether these meet the requirements of the regulations (see Chapters 4 and 5).
Step 3 – The procedure for OTM processing must be documented in the “Required Method of Operation” (RMOP) (see Chapter 6 for a sample of the approved blank RMOP) in sufficient detail to allow someone walking into the plant for the first time, to fully understand the processes you have in place. Do not underestimate the length of time it will take you to complete this section of the approvals process. You may find it beneficial to discuss these procedures with your OVS before committing resources. An oversight here could lead to a delay which in turn may delay or even cause you to fail your assessment trial.
Please be aware that you can get electronic copies of the RMOP for completion on a computer from the following email address: otm.enquiries@mhs.foodstandards.gsi.gov.uk
Please ensure that you request the slaughterhouse RMOP. Please note that plants that were involved in earlier trials will be required to complete an RMOP in the enclosed format (Approved OTM Slaughterhouse RMOP v1.0 issued 15/09/2005) which is enclosed in your pack.
Step 4 – When you are of the opinion that your RMOP is sufficiently detailed you should sign it and present it to the OVS for formal assessment. This can be checked against a number of agreed criteria. If the OVS is satisfied with the contents of the RMOP they will inform you. The OVS will then forward your submitted RMOP to the Area Official Veterinarian (AOV) and MHS Headquarters in York for further validation, logging onto the computerised system, for MHS quality assurance and checks on consistency. Please be aware that there may be a high demand for OTM approval so please allow sufficient time (a maximum of 3 weeks) for its return. However, the MHS will endeavour to return the RMOP to the OVS well before this, wherever possible. At this stage, it may be worth forward planning to allow sufficient time to carry out dummy runs as appropriate, and time to complete the assessment trial prior to the date you wish to start. These dates will need to be pre-booked in advance with the MHS AOV.
If your RMOP is not sufficiently detailed, or omissions are present, it will be passed back to you and you will not progress to the next stage until corrections have been made. At which point you will need to sign the new version and hand it to the OVS.
Step 5 – If no further amendments are identified, your original RMOP will be returned to the OVS in your plant and you will be notified by MHS Headquarters.
Step 6 – You will need to agree dates with the Area Official Veterinarian and arrange the days that you wish to undertake the formal 2 day assessment trial. You will need to allow yourself sufficient time to train your staff and work with MHS to facilitate MHS OTM training.
Step 7 – If required by MHS (and an IAG requirement) you must agree to close down slaughterhouse production for sufficient time to facilitate training of all MHS personnel as well as operator staff to be involved in processing of OTM cattle. Experience from the previous trials show that a lack of operator staff training created problems that in an assessment trial could result in failure. Please consider this carefully.
Step 8 – You may choose to carry out dummy runs, in consultation with your OVS, to highlight any problems that may arise (see Chapter 9 for guidance). This is not mandatory but it is highly recommended, this will give you the ability to identify any issues before the formal 2 day assessment trial. These can be carried out during normal hours of production.
Step 9 – You will carry out the formal assessment trial for 2 days using Under Thirty Month Bovines to simulate OTM procedures. If you are an existing OTMS plant you may use OTM bovines provided all clean kill processing requirements are met. However, please ensure that you notify the Rural Payments Agency prior to any assessment taking place.
This assessment trial must mirror exactly what you have agreed in your RMOP, with the exception of a simulated 30 month cut off date (the date / age you choose must produce a reasonably representative number of the likely throughput of OTM animals at the plant). These procedures will be assessed by the AOV during the course of the trial. Please refer to the Chapters 9 and 10 in your application pack, concerning preparation for the formal 2 day assessment trial and a letter from Defra regarding consumables supply.
A major non compliance at this point will be deemed a failure of the assessment trial and will mean that you must start the approval process again by submitting an improved RMOP at step 4. Please be aware that if you are not successful at this stage, and changes are required through resubmission, any subsequent formal 2 day assessment trial will be dealt with in order of submission, taking into account the availability of appropriate MHS personnel.
If you are dissatisfied with a specific aspect of your application which you are unable to conclude locally, in line with current instructions, you should first appeal in writing to the MHS Regional Director in your area, detailing the basis of your appeal. The relevant Regional Director will then consider an appropriate course of action and may appoint someone to investigate.
Step 10 – After successful completion of the formal 2 day assessment trial, you will then be in a position to discuss and agree a date with the AOV for your first days actual OTM processing.
Step 11 – On the first agreed day of OTM processing and prior to commencing OTM processing, the OVS will sign the RMOP. An FSA Board recommendation to Ministers was that the AOV must be present during day 1 and part of day 2 at every plants first day of processing.
There will be ongoing monitoring of OTM processing by MHS plant based staff in addition to Monthly audits which will be carried out by MHS veterinary staff. In most cases this will be the AOV.
If at any stage the RMOP is required to be amended, for example due to changes in plant practices or facilities, the OVS or Occupier may request that such amendments are made to the RMOP. As the Occupier you must inform the OVS of intended amendments. You must allow sufficient time for the OVS to discuss these changes with the AOV. Amendments must be agreed and signed by both parties in a new RMOP before being implemented.
Should the OVS require changes to the RMOP, these will be required in accordance with the amended TSE regulations. In particular, failure to amend the RMOP will be dealt with in accordance with 10A(3) of the TSE (Amendment) (No. 2) Regulations 2005.
Any breaches of the RMOP will be a regulatory offence in accordance with the aforementioned regulations.
2.0 Abattoir Occupier OTM Pre-requisites - Specimen copy-information only
Introduction
Abbattoir Occupiers wishing to slaughter OTM cattle for human consumption
will need to comply with the following pre-requisites, as a minimum.
Training
Where necessary, Plant Occupiers must agree to a closedown of slaughterhouse
production for sufficient time to allow training of all MHS personnel
as well as plant staff to be involved in processing of OTM cattle. Experience
during earlier trials has proved the value of full operator training.
Sampling cannot be undertaken unless the Occupier provides staff suitably trained by VLA and competent to carry out brain stem sampling. This training can be arranged through Defra by contacting 0207 904 6324. Names of all trained plant staff must be notified to Defra (plant staff already trained for OTMS / BAS / 24 – 30Months casualty bovine brain stem sampling need not undergo retraining). Staff leaving your employment should also be notified to Defra to enable their names to be removed.
Hazard Identification and Control Plan
A plant “Hazard Identification and Control Plan” (HICP)
will need to be drafted to include the associated risks for OTM processing
and what control measures are to be put in place. A HICP template is
included courtesy of Defra, for assistance.
Lairage facilities
The slaughterhouse will need adequate lairage capacity and facilities
that:
-
Are suitable to ensure correct identification of animals prior to slaughter
-
Allow segregation of OTM cattle requiring testing and cattle that do not require testing.
In complying with the above requirements, animal welfare must not be compromised.
Health & Safety
All necessary Health and Safety precautions must be in place for the
protection of personnel on site during OTM processing. Operators should
refer to the Advisory Committee on Dangerous Pathogens (ACDP) guidance
contained in Chapter 8.
Sampling area
Suitably safe and hygienic facilities are required for the taking of
brain stem samples, e.g. a separate room or a dedicated table for sampling,
situated a suitable distance from the line so that cross contamination
cannot occur. On-line sampling can be undertaken as long as there is
no risk posed from the sampling technique.
Traceability system
A robust traceability system must be provided through which the kill
number (or another number) is associated with the sample, carcase and
body parts.
This system must also:
-
Define the criteria by which the plant identifies the batch size
-
Provide differentiation between OTM and UTM carcases. Identify all UTM carcases by the use of separate blue stripe labels
-
A system to reconcile the number of bovines tested and the number of samples dispatched to the laboratory.·
Storage facilities
Suitable and secure facilities will be required to retain the carcase,
body parts, including hide, blood, and by-products under official control,
until the test results are received.
Note: hides can be delivered to a hide premises before
the test result is received if a separate hide Protocol is produced
specifying all the relevant details.
Note: body parts can be disposed of as Category 1 SRM
by incineration prior to receipt of test results
Note: ABP must be held in lidded and lockable containers
Office equipment
Suitable office facilities must be supplied with:
-
A system for the receipt of the correct test results from the laboratory, either by fax, or by other electronic means (web access), printer.
-
Photocopying facilities – if a manual identification system is to be used
Required Method of Operation
Plant Occupiers is required to provide an RMOP in the prescribed format
in sufficient detail for approval documenting the procedures they will
use to process OTM bovines. This must be agreed and signed by representatives
of the Plant Occupier and the MHS.
Formal 2 day assessment trial
This assessment trial will be carried out using UTM cattle (except in
current OTMS plants) to simulate the proposed OTM procedures documented
in the RMOP. During this assessment the procedures employed will be
monitored by MHS staff. All areas must comply with both written instructions
contained in the RMOP and legal requirements. Assessment trial dates
will need to be agreed with the AOV.
OTM Production
Before OTM production will be permitted to start, the Plant Occupier
will need to be able to produce a physical copy of the approval letter
from the MHS, on behalf of Defra. You may not start to process OTM cattle
until:
- The relevant legislation comes into force
- The date of commencement for your plant has been agreed with the AOV
-
The AOV is present on days 1 and 2 of OTM processing
-
The OVS has signed the RMOP prior to commencement of OTM processing on the first agreed day
3.0 Hazard Identification and Control Plan (As required by the Independent Advisory Group) - Specimen copy-information only
Before having an RMOP approved for the slaughter of OTM animals a plant will need to produce a process step identification and control plan. This plan must set out the major hazards involved in the processing of OTM cattle and the controls identified to minimise them.
A number of points should be noted prior to starting to draft your plan:
- As a food producer you must have demonstrable competence in HACCP as set out in Regulation 20 of the Fresh Meat (Hygiene & Inspection) Regulations 1995 (as amended) and in line with Regulation (EC) No. 854/2004 (reference Hygiene 3) when this comes into force in 2006. .
- A fundamental requirement in the drafting of your plan is the involvement of all the relevant personnel from your plant where applicable including both technical and production teams, and MHS staff.
- Ownership of the plan will always remain with the plant Occupier although if required you may choose to use external bodies to assist in the development of the plan.
- Where individuals or staff positions are responsible for controls or monitoring of controls the relevant individual/s must be clearly identified and trained to carry out the task competently.
- The RMOP must take account of the process steps and controls identified in the plan.
- The plan must be regularly reviewed with those people mentioned above and amended as required.
- As a general rule if corrective action is required it should be brought to the attention of the MHS who will verify that the corrective action will be in compliance with the legislation.
The Abattoir process
flow chart
(24 KB) and table
(21 KB) set out the process steps that should be considered when drafting
your plan. An outline of a hazard identification and control plan can
be found at Annex A
(45 KB). It should be noted that this plan is a guidance template only
and individual plants will need to modify the control and monitoring
procedures to suit their own local circumstances.
The plan should be used to consider relevant amendments to your HACCP
plan.
4.0 Abattoir Guidance – RMOP - Specimen
copy-information only
Please see the following document
(46 KB) that gives instructions for drafting of the RMOP.
5.0 Abattoir Guidance – Protocol - Specimen copy-information only
This document
(72 KB) sets out the procedures an abattoir needs to have in place before
they can start processing OTM cattle for human consumption. This guidance
should be used when preparing a plant specific RMOP document.
6.0 Blank RMOP - Specimen copy-information only
An example blank RMOP can be found here
(27 KB)
7.0 Abattoir guidance - Hides - Specimen copy-information only
1. These guidelines concern the movement off-site of hides derived from
cattle which have been tested for BSE and where a test result is pending.
In many cases, abattoirs will choose to retain hides from tested animals
at the abattoir under the official control of the Meat Hygiene Service
(MHS), until results are obtained from the approved testing laboratory.
However, as explained below, you may transport hides to hide premises,
before a test result is received, subject to the procedures explained
below.
2. Where hides are to be retained at the abattoir, procedures must be set down in the Required Methods of Operation (RMOP) agreed between the Abattoir Occupier and the MHS. The rest of this document concerns the procedures for hides moved to external hide premises pending a test result, only.
3. It is recognised that it is not always possible for abattoirs to retain hides on their premises beyond the day of slaughter. If you wish to move hides from BSE tested animals to a hide premises, you will first need to have prepared and signed an agreed hide protocol (see attached template at Annex A).
4. A hide protocol contains details of the procedures to be followed when moving hides from the originating abattoir to a hide premises. A hide protocol template is at annex A. The protocol must be agreed and signed by the abattoir, the hide premises operator, and the Meat and Livestock Commission (MLC), who will be responsible for any enforcement action at the hide premises. The MLC is empowered, under the domestic TSE Regulations, to order the destruction of hides from positively tested and ‘no test’ cattle. If the hides are not separately identified, they are also empowered to order the destruction of the whole batch.
5. If you wish to consign hides to more than one hide premises, you will need to agree separate hide protocols for each premises.
Identification of Hides
6. Hides must be individually identified, or, sent to hide premises in clearly marked batches. The agreed system of hide identification must enable the correlation of BSE test results to individual hides, or a batch of hides. It is up to the Abattoir Occupier to devise and agree the identification system in conjunction with the hide premises operator and the MLC, who will act as the enforcement agency in the case of any hides from BSE positive or ‘no test’ animals. The system must be approved by the three signatories to the hide protocol.
7. With any agreed hide identification system it must be possible for a specific hide to be easily identified (unless hides are held in batches without individual identification – see below). This means that individually identified hides must be stored in such a way that individual identification labels/tags are clearly visible. In the case of any positive or ‘no test’ result the MLC will require the operator to identify the hide, or its batch, so that it can be directed for disposal at the disposal site detailed in Section 3 of the hides protocol.
8. It is vital that you adhere to the agreed hide identification system, since any doubt over the identity of positive or ‘no test’ hides will necessitate the destruction of the whole consignment. If this is required, compensation will only be paid on the hide from the BSE-positive animal, not for the others. Persistent failure to implement the terms of the agreed hides protocol will result in its revocation, with the result that you will be unable to move hides from your abattoir until test results are known.
9. Containers of hides being transported to hide premises pending test results should be clearly marked ‘Controlled hides – awaiting BSE clearance’ and must bear the details of the originating abattoir and the relevant slaughter date. If a consignment consists of hides from tested OTM cattle and hides from untested UTM cattle, the sequence of kill numbers for the hides from tested animals where results are pending, must also be shown on the container. In addition, the commercial document accompanying the hides under the Animal By-Products Regulations, should be clearly marked ‘Subject to TSE test results’.
10. Basically you have 2 options: you can either choose to individually identify each hide, so that it can be correlated with its respective test result; or you can identify controlled hides in batches, without individual marking. The advantage of individually identifying hides is that, in the event of a BSE positive test result, only the ‘positive’ hide need be destroyed. As noted above, under a batch identification system the entire batch containing the ‘positive’ hide would need to be destroyed, with compensation only being available for the ‘positive’ hide.
11. Where controlled hides are to be individually identified, this must be by means of a tag of robust specification or by another secure method, which is not reusable and will not become obliterated during processing and storage. Spray paint is not an acceptable means of identification. The means of hide identification must ensure that the animal of origin can be clearly and indisputably confirmed. Tags must be durable in the hide processing environment and must not tear or become detached during handling or storage. Synthetic top coated direct thermal printable looped labels have been found to be of acceptable robustness and durability:
12. Examples of acceptable identification systems include (a) eartag reference, (b) a combination of abattoir ID, kill date and kill number or (c) another serial number correlated to the carcase through abattoir records.
13. The positioning of the tag on the hide is important to aid its easy identification when stored with other hides. During the above-mentioned trails the tail root was found to be the most easily accessible place for a tag to be inserted.
14. A batch may be any group of hides, stored consecutively and derived from cattle slaughtered on one day. The batch must be clearly identified so that it can be easily determined whether the batch contains hides from animals subject to BSE testing which are pending a result (see paragraph 8 above).
Completion of the Hides Protocol
15. The hide protocol template is at Annex A. It should
be drafted by you, and then discussed and agreed with the hide premises
operator, who will subsequently discuss it and agree it with the MLC.
Once it has been agreed and signed by all three parties, you should
bring it to the attention of the OVS, who will be instructed to check
that an agreed hides protocol is in place, before permitting hides to
be sent off-site without a test result.
16. During the drafting and agreement process (and prior
to ‘live’ testing of OTM animals for human consumption)
we recommend that you undertake a dry run of the hide protocol arrangements.
This will enable you, and the other parties to the protocol, to satisfy
yourselves that the proposed arrangements are effective. Experience
gained during this dummy run should be reflected in the final version
of the protocol.
18. Once the draft protocol has been agreed , copies should be retained by all parties to the agreement. In the case of a positive or ‘no-test’ result, it is your responsibility to notify the hide premises by e-mail or by fax. No notification action is necessary on your part, if all test results for the slaughter day, are negative.
19. Although an abattoir may consign hides awaiting a
result to more than one hide premises, hides from animals killed on
a single day pending a test result, may only be consigned to a single
hide premises. On no account can hides awaiting a test result are moved
on from the premises identified in Section 3, unless it is authorised
by the MLC.
ANNEX A HIDE PROTOCOL
TEMPLATE
(15 KB)
8.0 Controlling the risk of exposure to Bovine Spongiform Encephalopathy (BSE)- Specimen copy-information only
Advice from BSE Occupational Guidance Drafting Group for Abattoir Workers Processing OTM Cattle Born After 1 August 1996.
Note: this guidance is not intended for abattoirs processing other cattle (e.g. those known to have BSE – see http://www.hse.gov.uk/pubns/indg85.htm), which should continue to follow existing guidelines on controlling the risks from BSE.
Abattoir Workers: Guidelines to Minimise the Risk of Exposure to BSE
A. Introduction
1. Following a review of the Over Thirty Months (OTM) rule Health and Rural Affairs Ministers have agreed that cattle born after 1 August 1996 may now enter the food chain. This will depend on each animal testing negative for BSE before release. Thereafter, these cattle will be processed in the same way as those under thirty months old intended for human consumption.
2. Cattle born before 1 August 1996 will still be excluded from the food chain, and will continue to be processed in dedicated OTMS abattoirs to the existing HSE guidelines.
What is the risk of cattle now entering the food chain having BSE?
3. Cattle born in the UK after 1 August 1996 should not have been exposed to feed contaminated in the UK. The incidence of BSE in these cattle is significantly lower than for those born before August 1996. Modelling suggests that 40-60 cattle destined for processing in fresh meat abattoirs will test positive for BSE in the first year after the OTM rule changes, but these numbers would be expected to decline year on year. However, this is a worse-case scenario as it assumes that all casualty cattle, many of which will be excluded from the food chain, would also be sent to abattoirs.
4. If any cattle (including pregnant cows and those about to calve) are suspected of having BSE, they must be reported to Department for Environment, Food and Rural Affairs (Defra) immediately. They must not be slaughtered in a conventional abattoir. Defra will assume responsibility for the destruction and disposal of BSE suspects and further information can be found on the Defra website.
So should I be concerned about handling a BSE positive animal?
5. Every OTM healthy animal and every over 24 months old casualty animal processed for human consumption will be tested for BSE post slaughter. Any positive carcasses will be removed and destroyed (this will also include the carcass before and two after on the slaughter line, unless there are alternative procedures in place). This is to ensure no potentially contaminated meat enters the human food chain. However, you will not know if an animal is positive until after you have handled it. So you will need to take certain precautions when handling all cattle, just in case a positive animal is processed.
How could I be exposed to the BSE agent if I process a positive animal?
6. The main risk of exposure is from an inoculation injury (i.e. a skin penetrating injury by a sharp object) potentially contaminated with the animal material most likely to contain the BSE agent or via broken skin and splashing of mucous membranes (i.e. your mouth, nose or eyes). Such animal material is classed as specified risk material (SRM), the most important for potential exposure being
-
The brain; and
-
Spinal cord(It is important you take care to avoid cutting yourself with knives, bone fragments or other sharp objects.)
7. Exposure to contaminated equipment or clothing could also occur, so good hygiene practices in your abattoir are essential.
8. To avoid contamination you will need to avoid splashes and cover up cuts, and wear appropriate Personal Protective Equipment (PPE). This guideline gives advice on good hygiene and PPE.
What precautions should I take when processing cattle in my abattoir?
9. The Advisory Committee on Dangerous Pathogens (ACDP) has issued new advice on how to control the risk of exposure to BSE when processing cattle in fresh meat abattoirs (see pages 3-5)
Are there guidelines for taking the brain samples used to test for BSE?
10. Yes – these have been produced by the Veterinary
Laboratories Agency, in collaboration with the Health and Safety Executive,
the Meat Hygiene Service and trade unions. The guidelines can be accessed here
(1.07 MB *this is a very large file).
Are there other guidelines for people working with BSE?
11. Yes – the ACDP has produced guidance for people working with all types of transmissible spongiform encephalopathies (TSEs) in the laboratory and in healthcare.The ACDP have also published guidance for other professions working with BSE called ‘BSE (Bovine Spongiform Encephalopathy): Background and general occupational guidance’, which is available from HSE Books – an updated version of this last document (which will incorporate the advice in this leaflet) is due in late 2005/early 2006.
B. BSE: Control Measures for Abattoir Workers - Specimen copy-information
only
Even though the following paragraphs suggest control measures for some abattoir activities, you must conduct a risk assessment to assess the hazards present in your workplace and evaluate the potential risks to staff from each activity. This risk assessment will help you decided which control measures are suitable and appropriate to put in place.
Your own risk assessment for a specific work activity may reveal that different controls are more appropriate and provide the same level of protection as those indicated here. If this is the case you are legally able to use the measures dictated by your risk assessment instead.
1. PPE that should be worn during all abattoir work
- Overalls, protected by a waterproof apron or waterproof leggings.
- Chain mail aprons and/or leggings should be worn where a risk assessment shows that there is a risk of stabbing or cutting injuries.
- Impervious and washable boots.
- Impervious gloves that cover hands and arms if exposed.
- Protective clothing should be disposable, or if this is not practical must be washable, and stored separately from personal clothing. This protective clothing must be cleaned before storage.
- When a risk assessment shows the need for face protection to avoid risks from splashing provision should be made for visors/face protection equipment to be cleaned as necessary during the working day.
2. Good hygiene
It is essential that workers follow good hygiene practices to ensure they are not exposed to any infectious agents the cattle processed in your abattoir may be carrying. The Fresh Meat (Hygiene and Inspection) Regulations 1995 and associated guidance already provide the basis for good practice in abattoirs
- Avoid hand-mouth or hand-eye contact while working.
- Take rest breaks and meal breaks away from the main work area, after removing PPE, and any other contaminated clothing, in a separate, designated area.
- Wash hands (and arms and face if necessary) and remove PPE before eating, drinking, smoking, using the telephone, taking medication, or touching contact lenses.
- Cover all new and existing cuts and grazes with waterproof dressings and/or gloves before starting work. If cuts or grazes occur at work, wash immediately with soap and running water and apply a waterproof dressing.
- Avoid hand-mouth or hand-eye contact while working.
- Take rest breaks and meal breaks away from the main work area, after removing PPE, and any other contaminated clothing, in a separate, designated area.
- Wash hands (and arms and face if necessary) and remove PPE before eating, drinking, smoking, using the telephone, taking medication, or touching contact lenses.
- Cover all new and existing cuts and grazes with waterproof dressings and/or gloves before starting work. If cuts or grazes occur at work, wash immediately with soap and running water and apply a waterproof dressing.
4. Cleaning the abattoir
- Make sure heavy debris has been removed from the work area before pressure cleaning.
- During cleaning, use as low a pressure as practicable when hosing down the area. (Hosing must not be undertaken if it contravenes the Fresh Meat (Hygiene and Inspection) Regulations 1995.)- for example, if carcasses are nearby.
- (Note: it is essential that you carry out a risk assessment for all cleaning work in your abattoir, using low and high pressure, and put appropriate controls in place.)
Annex 1: Safeguarding against possible exposure to the BSE agent in OTMS cull abattoirs
Introduction
This guidance was produced by HSE following discussions with the Interventions Board (represented by the Rural Payments Agency (RPA)), and based on a similar document prepared by the HSE in 1997/98. This version was issued in August 2001, and circulated to all cull abattoirs and RPA inspectors.
Advice on control measures
Due to concerns that abattoir workers may be exposed to the BSE agent during the cull of animals in the Over Thirty Month and associated schemes it has been agreed that technical inspectors with the Intervention Board (IB) should have information on what HSE considers the main risk areas to be.
The main risk is splashing of broken skin or mucous membranes with materials containing the agent. Action must be taken to avoid cuts and to ensure the wearing of Personal Protective Equipment (PPE).
This checklist is intended to highlight the main precautionary measures required to prevent and control possible exposure to the BSE agent during the slaughtering and carcass handling process in abattoirs. Failure to comply with the advice given in this checklist is likely to be in breach of the Control of Substances Hazardous to Health Regulations 2002 (as amended).
Abattoirs must NOT:
1. *Pith
2. *Centre split carcasses (this does not apply to OTM carcasses for
human consumption).
3. Use high pressure water jets (1)
4. Allow employees to eat, drink or smoke in the workplace
(1) Water pressure should be as low as practicable consistent with hygiene needs but not more than 500 psi
Abattoirs MUST:
5. *Use bungs to plug the captive bolt hole after stunning.
6. Use PPE appropriate to the task (see BMMA Guidance Note 55), which
will include
-
Impervious overalls and boots
-
Impervious gloves that cover hands and arms
- Chain mail or equivalent cut protection
- Full face visors during back splitting and stunning (a fixed guard may be substituted for a visor during stunning but such a guard must be shown to be effective as there is evidence that neural material from stunning may be ejected up to 2 metres)
8. Ensure that skips used for disposal of carcasses are in good condition and do not leak.
*These measures are required by the contract between IB and the cull abattoirs
9.0 Guidance notes formal 2 day trial assessment - Specimen copy-information only
NOTES FOR GUIDANCE ON THE USE OF UNDER 30 MONTH CATTLE FOR ANY DRY RUN ASSESSMENT TRIALLING AND FOR THE 2 DAY OFFICIAL ASSESSMENT TRIAL
Note – Many of the points made below will be requirements for real ‘live’ testing of OTM cattle, as well as being requirements for the official assessment trial. Those requirements which are unique to the assessment trials are underlined
Initial Preparations
- You will need to agree the date for any dry run assessment trial, and the dates for the official assessment trial with both your OVS and your Area Official Veterinarian (AOV). Please give as much notice as you can, when agreeing these arrangements.
- Choose a cut off age (this must produce a reasonably representative number of the likely throughput of OTM animals at the plant) which will mean the majority of animals will need to be tested, and only a small number will not. This needs to be agreed with the OVS ahead of the assessment trial taking place.
- You will also need to calculate an age cut-off reflecting 30 months before the date of the assessment trials, to replicate the OTM age restriction and the ability to ‘count back’ thirty months. This also needs to be agreed with the OVS ahead of the assessment trial taking place.
- You will need to order sufficient consumables, including barcode labels (see below). You can use one of the companies on the list included in the Application Pack, or from another source, providing this source can supply consumables, which comply with UN Standard 650 (transport of diagnostic samples).
- Decide whether you are going to use the manual or electronic sample identification system (see below and at Annex A for further information). You will need to contact the Approved Test Laboratory (LGC) on their Customer Help Line - 01928 511678 - to inform LGC when you intend to submit samples; and, to discuss the way in which you intend to transport your samples including which one of the 3 LGC laboratories (Teddington, Runcorn or Edinburgh) you intend to use. You should also discuss with LGC when (at what time) you anticipate despatching samples, and what this might mean in terms of when your samples can be tested and when you can expect to obtain your results.
- Remember to always notify the testing laboratory on the day, in advance of despatching samples, so that they are alerted to your testing needs (see the testing guidelines in your application pack for further information).
Manual Barcode System
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If using the manual system, the duplicate barcode labels should have a 13 character number. The first 4-6 digits being the plant licence number, followed by the letter ‘D’ in the case of a 6 figure license number, or ‘DDD’ if the plant licence number is only 4 figures. This signifies to the laboratory that the sample is a dummy sample originating from an under 30 month animal. The final 6 figures are simply a consecutive number code. For example, the first set of duplicate barcode labels used for your trial could read 1134DDD000001, with the next set of labels being 1134DDD000002, etc.
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Having placed one of these duplicate barcodes on the sample pot relating to the animal being tested, the second identical label should be attached to a movement card taken from the animal passport of the animal being tested, placed in such a way as to avoid any obliteration of other barcode or text information on the card. In addition, the following information needs to be stamped on the movement card - Occupier Initials, Date, Kill Number, and category of sample i.e. OTM 24-30 month casualty.Attached below is an example of a stamped movement card taken from an OTMS plant.
Note: The above example involved an OTMS plant. The boxes for ‘MHS initials’ and ‘Cohort’ will not be needed in fresh meat abattoirs slaughtering OTM cattle for human consumption. However, there will need to be a tick box for 'Casualty' and one for 'OTM-HC'.
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The rubber stamp and ink pads can be obtained from the address(es) included in the list of possible suppliers of consumables included in your application pack. Alternatively, these items can be supplied from any other commercial supplier. Please ensure that the stamp contains the box details laid down above.
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In situations where there is no movement card left in the passport, you should use a copy of the front page of the passport instead, attaching the duplicate barcode label and stamp as appropriate.
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The above barcode requirements relate specifically to any dry assessment runs and the 2 day official assessment trial. When testing is ‘live’ you should follow the same instructions for either the Manual system (described above) or the electronic system described below. The only difference is that the D needs to be replaced by either E (if you are using an Electronic barcode system -see below) or, M if you are using the Manual a system described above. This enables LGC to process the barcode information more efficiently, and it also enables them to spot any missing paperwork at an early stage. Annex A provides further guidance.
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The change in the use of formatted barcode labels between those needed for the trials, and those needed for a ‘live’ testing situation, will be a key control issue for the MHS.
Electronic Barcode System
Using an electronic barcode system gives you greater freedom on the information you can include in the barcode, so that, for example, it can be integrated into your existing abattoir traceability system. However, the information required by the testing laboratory (LGC) is very similar to the data used for the manual system (i.e.. Kill number, plant number, consecutive number, etc.). In most cases, the use of an electronic system will obviate the need for movement cards or other paper forms needing to be sent with the samples to the testing laboratory. However, you will need to send this information electronically, at the same time as the samples are submitted. Again, you should talk this through with LGC using the information in Annex A as your starting point. You will also need to ensure that for any dry run and for the official assessment trials, ‘D’ (denoting dummy) is included in the barcode information, so that LGC are aware that the sample should not be tested and recorded for BSE surveillance purposes.
Before designing your own barcode system it is very important that you speak to LGC on the telephone number given at the bottom of Annex A. Please note that in a real life testing system, a breakdown in traceability caused by poor or inappropriate sample labelling, could result in the issue of a ‘no test’ result and the destruction of the tested animal and the 1b2a animals, or, in some situations, the destruction of the entire batch of animals being tested.
In talking to LGC, you should also discuss whether or not you wish to receive your test results electronically via their results web-site. If you do, you will be given a unique password and user reference number. If you do not have the necessary IT facilities, your results will be faxed to you.
Attached at Annex A is a summary of the above barcode requirements prepared by LGC. It also provides some key advice on formatting and design parameters for the barcode, not covered above.
Generation of Dummy Test Results
Disposal of carcases/parts of body
ANNEX A - Information on Barcode Format
For abattoirs with a 6 character abattoir licence number the format is:
AAAAAAENNNNNN or
AAAAAAMNNNNNN or
AAAAAADNNNNNN
Where AAAAAA is the 6 character abattoir licence number:
E Indicates that the sample data has been captured and sent
electronically
M Indicates that LGC are to manually enter the sample data
D Indicates Dummy data, used for sampling trials
NNNNNN is a sequential number starting with 000001, 000002,
000003 etc
For abattoirs with a 4 character abattoir licence number the format is:
AAAAEEENNNNNN or
AAAAMMMNNNNNN or
AAAADDDNNNNNN
Where AAAA is the 4 character abattoir licence number:
EEE Indicates that the sample data has been captured and sent
electronically
MMM Indicates that LGC are to manually enter the sample data
DDD Indicates Dummy data, used for sampling trials
NNNNNN is a sequential number starting with 000001, 000002,
000003 which, should ideally start from number 000001 on a daily basis.
Where samples use the AAAAAAENNNNNN or AAAAEEENNNNNN, we would expect to have received a file via e-mail that has all the sample details for the samples submitted. At a minimum these details should include kill number and kill date. If possible eartag number should also be included as well. A test file should be sent before the trial commences to ensure that data is compatible.
The barcodes should be printed using Standard Code 128.
The labels should be acrylic based and should be 50mm x 25mm. It is important that there is a 5mm gap or 'quiet zone' around the barcode, and the barcode height should be a minimum of 12mm. The barcode number should be printed in human readable form below the barcode. It is essential that the barcodes are unique, as LGC will not be able to accept any duplicate barcoded samples. It is essential that abattoirs check that barcode labels they produce are readable by LGC. Example labels should be sent to LGC, prior to starting any trial.
For queries on this information please contact: The BSE
Services team on Tel: 01928 511678
10.0 Consumables including packaging - Specimen copy-information only
OTM approved abattoirs participating in the OTM cattle trade for human consumption will be responsible for sourcing their own supply of BSE sampling consumables (plastic spoons, forceps, and sample pots) and packaging (ice pack / ice sheets, packaging bottle / packaging box).
Any BSE sampling consumables used should comply with basic specifications as described below
Plastic Spoons: |
Must be able to remove the brain stem intact, without damage to the obex area, and without danger of injury to the operator. Appropriate spoons should be available from your supplier of testing consumables |
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|
Forceps: |
Disposable, single use plastic dressing forceps, preferably blunt ended |
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Sample pots: |
95Kilopascals standard 100ml polypropylene pots with spin seal cap |
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Ice pack: |
Reusable leakproof plastic pouch containing a non-toxic, non-caustic refrigerant gel |
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Ice Sheet: |
Fits packaging box covering all sample pots |
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Packaging bottle: |
UN602 and UN650 compliant container with outer packaging and labels, large enough to carry an ice pack and several 100ml sample pots |
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Packaging box: |
UN602 and UN650 compliant packaging with leakproof bags able to carry multiple samples pots and one ice sheet |
Packaging must comply with UN packaging standards (see Chapter 4.1 of ADR 2005 which can be found at http://www.unece.org/ in the transport section of the website) and HSE guidance. Please note that the testing laboratory (LGC) may not handle samples that have not been packaged to the required standard, in such a situation a ‘no-test’ result will be issued and the ‘one before, two after’ rule will have to be applied.
LGC have confirmed that sampling consumables and packaging will be included as part of their proposed integrated delivery service option (this option involves the delivery of consumables and the collection of samples in one integrated package). Abattoirs not wishing to use this service may find the following list of suppliers helpful (please note that this list is not definitive and you may wish to undertake your own search for suitable suppliers):
Sampling consumables
Bio-Rad Laboratories Ltd
Bio-Rad House
Maxted Road
Hemel Hempstead
Hertfordshire
HP2 7DX
Tel: 0800 181 134
Fax: 0208 328 2550
Web: http://www.foodscience.bio-rad.com/
DGP (UK) Ltd
1 Harrier Court
Elvington
York
YO41 4AU
Tel: 01904 607 390
Fax: 01904 607 391
Web: http://www.dgpgroup.com/
Lab Pak
Mill House
Mill Lane
Fillongley
Coventry
CV7 8EE
Tel: 01676 540 022
Fax: 01676 541 818
VWR International
Hunter Boulevard
Magna Park
Lutterworth
Leicestershire
LE17 4XN
Tel: 01202 664 984
Fax: 01202 664 984
Web: http://www.vwr.com/
Barcode Labels, Stamps and Inkpads
Abattoirs will also be responsible for sourcing their own supply of barcode labels, stamps and inkpads as required. Guidance on the format and specifications of these items can be found in the document ‘Preparations for OTM assessment trials’, which forms part of this application pack.
Abattoirs may find the following list of suppliers helpful (please note that this list is not definitive and you may wish to undertake your own search for suitable suppliers):
Barcode Labels:
Computer Imprintable Label Systems Ltd.
2 Southdownview Way
Broadwater Business Park
Worthing, West Sussex
BN14 8NL
Tel: 01903 219 000
Fax: 01903 219 111
Web: http://www.cils-labels.com/
DGP (UK) Ltd
1 Harrier Court
Elvington
York
YO41 4AU
Tel: 01904 607 390
Fax: 01904 607 391
Web: http://www.dgpgroup.com/
Stamps and Inkpads
Stamps Direct
111 Eade Road
Norwich
Norfolk
NR3 3EP
Tel: 01603 624 407
Fax: 01603 665 983
Web: http://www.stampsdirect.co.uk/
Page last modified:
14 July, 2008
Page last reviewed:
18 September, 2006
