Presentation on theme: "Advisory | Testing | Innovation Topical Meat Law Issues by Neil Griffiths Chief Executive for SVA Ltd BMPA Conference May 2013."— Presentation transcript:
Advisory | Testing | Innovation firstname.lastname@example.org Topical Meat Law Issues by Neil Griffiths Chief Executive for SVA Ltd BMPA Conference May 2013
SVA will help provide a guarantee of product integrity and brand assurance because we offer :- A complete set of testing and advisory services Experienced professionals who identify but also help solve issues. Leading IT systems that improve and simplify product management A forward looking horizon scan service enabling you to future proof your brand The SVA Promise
AGENDA 1.The Horse Crisis Update – Lessons? 2.Authenticity Testing – What is now available? 3.FIC Update – Front of Pack Labelling. 4.Product Recall – A new Standard. 5.Additives – to include Flavourings and Enzymes and Phosphates in food re-appraisal. 6.Animal Welfare – New Guide and Update on Sow Stalls.
The Horse Crisis Legal Issues This Crisis was driven by the use of a new technology involving DNA detection and claimed quantification of equine DNA. The high levels of horse DNA claimed to be found in a number of products lead to allegation of fraud and criminal conspiracy.
The Horse Crisis Legal Issues The European Commission is currently reviewing the EU food chain legislation (the ‘animal and health package’). This includes proposals to restore consumer confidence. This is suggested will be achieved by strengthening legislation which will apply to the whole European food industry. It is proposed to improve enforcement as well as provide increased financial sanctions on food fraudsters.
The causes of this crisis have primarily involved fraudulent practices but can also be caused by inadvertent contamination of one meat by another. The possibility of fraud and inadvertent contamination can occur in businesses both large and small. The Horse Crisis Legal Issues
Inadvertent Contamination (Threshold 1%?). Enforcement Action re Mince ongoing for years. Previously Studied in the 1985/6. Extremely difficult to fully resolve in mixed species sites and distribution. Allergen Comparison. The Horse Crisis Legal Issues
The Horse Crisis Testing The FSA demanded that the food industry tests meat products containing minced beef for the presence of horse and pork and report the findings. This is similar to other Crisis (Dioxin, Sudan 1) where Traceability and Systems had appeared to have broken down Testing becomes an emergency measure. This is not sustainable in the long run. It is better to make sure products are right in the first place than test and reject/recall.
The Scientists View of Meat Analytical assessment of Meat Content or Added Water Content in Meat Products is dependent on Nitrogen in fat free meat being reasonably consistent. Fat Free Beef (dependent on cut) contains.22.3% to 23.2% Protein or 3.57% to 3.71% Nitrogen. DNA molecules have a consistent width of about 2.5 nanometers (a nanometer is one billionth of a meter; human hair has a thickness of roughly 20,000 nm to 180,000 nm. Immunoassay ELISA – Direct Detection LOD 1.0% DNA PCR - Requires amplification millions of times for detection. LOD typically 0.1% or better
Current Meat Speciation Tests DNA Versus Immunoassay Immunoassay been around longer. DNA methods typically have lower limits of detection. Immunoassays direct detection of proteins were DNA method require amplification. DNA methods more specific. Both are semi quantitative. Can they demonstrate non compliance beyond reasonable doubt?
Skeletal muscles of mammalian and bird species recognised as fit for human consumption with naturally included or adherent tissue. ‘Meat’ maxima for fat and connective tissue Offal is not meat, MSM is not Meat Techniques that determine the level of DNA of a specific meat species do not in themselves, if found positive for a particular species of DNA, enable the assumption to be drawn that meat is present or the quantity of meat. Unless skeletal muscle DNA can be identified and naturally included or adherent tissue (fat, rind etc) the presence of meat, as defined, cannot be assumed or quantified.
The Definition of Meat Maximum fat and connective tissue content for ingredients designated by the term “..meat ” They have gone mad!
Total Fat Total Connective Tissue Limit for Connective Tissue Red is core Meat Protein (no fat and no Connective tissue) Outer Square =Total Meat Ingredient FSA Guidelines – Labelling and Composition of Meat Products – Sept 2003 Shaded area is the QUID declaration. Limit for Fat
Other Proteins that are not Meat Protein Cereals such as Wheat or Soya. Excess Connective Tissue Offal Added Blood MSM Other Species of Meat that are not declared. Total Protein – (Cereal Protein + Offal Protein + Excess Connective Tissue Protein + Added Blood Protein + Other Non Declared Meat Species Protein) = Protein present in Declared Meat. Which of these will have new technologies applied to them in the future??
Authenticity Testing To determine the country of origin, production system and variety of products using isotope analysis and DNA technologies. This will confirm or otherwise the claims made on label such as British, Free Range, Aberdeen Angus etc. Product categories have been chosen based on current availability of tests. Will these new technologies have a significant impact on the food industry in the near future???
Stable Isotope Reference Analysis Project Report on Authentication of Country of Origin of Pork and Pig Meat in England & Scotland using Isotope Reference Analysis August 2010
The Environmental Fingerprint 2 H / 1 H 13 C / 12 C 34 S / 32 S 15 N / 14 N 18 O / 16 O
Confidence in the Results Results will be presented as a percentage score representing the confidence of any particular stable isotopic test signature being of the reference database. 1.A score in the range 95-100% means the isotopic signature puts the test sample as being definitely from the database. 2. A score in the range 90-95% means the isotopic signature puts the test sample as being typical for the database. 3. A score in the range 40-90% means the signature puts the test sample as being unlikely to be from the database. 4. A score in the range 0-40% means the signature puts the test sample as being definitely not of the database Ref: BPEX Project Report on Authentication of Country of Origin of Pork and Pig Meat in England & Scotland using Isotope Reference Analysis August 2010
FIC Update DEFRA had expressed the desire to publish the England, Scotland, Northern Ireland and Wales Statutory Instruments on the Food Information to Consumers by the common commencement date of beginning of April. The horsemeat incident and the active involvement of DEFRA in the labelling of meat has meant that this timescale has been delayed. They are aiming to have the SI’s published by this summer (July).
FIC Update The mincemeat provisions (compositional standards relating to fat and connective tissue linked to label claim) apply from December 2013. DEFRA understand that publishing the final UK Regulation in July will only give companies a very short period of time to understand whether the final decision by the 4 Governments is to allow the national exemption or not. The 4 nations are determined to allow the national exemption and they will work to this unless there is strong general concern expressed in the responses to the consultation.
Added Water Declarations FSA Scotland draft guidance on the FIC clause 12.3.6 on ‘Added Water’ currently states: If any water has been added to meat products, meat preparations, fishery products or prepared fishery products with the appearance of a cut, joint, slice or portion of a carcase of meat, a fillet of fish or of a whole fishery product above the level of 5%, then this must be stated in the name of the food and therefore, by default, in the ingredients list with a QUID declaration.
My counter argument to the FSA Scotland draft guidance is that Annex V Part A of the FIC is headed Mandatory Particulars accompanying the name of the food. As such these particulars do not appear in the name of the food but accompanies it. As such Article 22 1 (a) does not apply. Added Water Declarations
FOP New Traffic Light criteria have been set for foods and drink. Green and amber have been set to match low claims (EC reg 1924/2006) Large portion caps set at 30% of RI for food and 15% of RI for drinks (i.e. would be red rated) affects products such as ready meals, sandwiches and pizzas. Products most affected by the changed criteria are meat products, cakes and biscuits, going from amber to red.
FOP FOP formatting Current guidance will be amended and issued (June?) along with the DOH guidance on Traffic Light scheme. Key changes are: 5 lozenges and energy per 100g detailed below lozenges Colours must be vibrant and pantones to be aimed for will be provided At least 1/3 of lozenge must be coloured Contrast must be given between background (i.e. lozenges cannot "float" on artwork) Minimum font size of 1.2 mm Location on FOP and type face are flexible Both the presentational guidance and the section of the national recommendation developed by DH including the cut off points have now been signed off by Ministers in all the UK regions.
Product Recall ISO has been developing new standards for product safety and recall. ISO 10393:2013, Consumer product recall – Guidelines for suppliers, provides guidance on how to establish, implement and manage a consumer product recall programme. ISO 10393 will help organizations plan and execute timely and cost-effective recall programmes, minimize legal risks, protect consumers from unsafe or dangerous products, and build customer satisfaction and loyalty. Using ISO 10393, retailers and manufacturers will have consistent and repeatable processes for handling product recalls within one or across multiple retail jurisdictions.
Food Additives A new draft guide to compliance sets out the general requirements and scope of revised EU harmonised legislation on food additives (Regulation No. 1333/2008), which will in the main apply from 1 June 2013, and describes individual provisions within Regulation No. 1333/2008 in detail. The purpose of the consultation is to ascertain the relevance and acceptability of the proposed guide to compliance and comment on its content and presentation. The consultation closes on 15 July and there are two separate consultations running for England and Wales.
Food Additives The FSA are conducting consultations to seek comments from interested parties and obtain their views on the proposal to revoke and re-enact the national legislation on food additives, flavourings, enzymes and extraction solvents in a single consolidated instrument. The aim of this will be to reduce the number of national regulations on ‘food additive’ type legislation that businesses and enforcement authorities have to refer. Minor amendments are also required to the food additives and flavourings national legislation to reflect changes to the European legislation in these areas.
Food Additives The European Commission has asked the European Food Safety Authority (EFSA) to reassess the safety of phosphates as food additives, after researchers suggested excessive phosphate consumption could be damaging to health.
Animal Welfare The European Commission has decided to take Greece and Italy to the Court of Justice of the European Union over the failure to correctly implement Directive 1999/74/EC banning "un-enriched cages" (battery cages). The political decision for the ban on "un-enriched" cages was taken in 1999. Greece and Italy had twelve years to ensure a smooth transition to the new system and to implement the Directive. As from 1 January 2013, Directive 1999/74/EC requires that all laying hens are kept in "enriched cages" with extra space to nest, scratch and roost, or in alternative systems. Greece and Italy so far, despite repeated calls by the Commission to address the situation, have failed to adequately comply with applicable EU law. The Commission looks forward to these Member States ensuring compliance.
Animal Welfare Defra advice and guidance on protecting animal welfare on farms, in transport, at markets and at slaughter. This guide provides advice on the legislation and codes of practice designed to protect animal welfare.
Neil Griffiths Tel: 01530 56 1000 For information contact: Email: email@example.com Web: www.svaltd.com Contact SVA