Response from the
Welsh Agri-food Partnership Organic Strategy Group
prepared by
Organic Centre
(
6th December 2005
to the Welsh
Assembly Government consultation on
Consultation
on BSE: Lifting the export ban and harmonising SRM controls applicable in the
http://www.countryside.wales.gov.uk/fe/master.asp?n1=797&n2=123&n3=885
On reading the
documentation provided, including the partial Regulatory Appraisal, this group
would be in favour of Option 3 – Amending Welsh legislation to administer and
enforce EU legislation, making use of EU derogations. This does have certain implications for Welsh
organic farmers which are outlined below, but it appears to be the best option
for the industry as whole. Most of the
comments below relate specifically to the information provided in the
Regulatory Appraisal as these are the issues most relevant for Welsh organic
farmers and meat processors.
Impact
of the increase requirement to remove the vertebral column (VC) as Specified
Risk Material (SRM) at 24 months rather than 30 months.
Welsh organic farmers
would be affected by this change specifically for two reasons:
1) Organic beef farmers are more disposed to
using traditional breeds that are often slow growing and prone to taking longer
to finish. This may then put them in the
24-30 month slaughtering category, which would require VC removal under the
proposed regulation.
2) The market for
organically produced traditional beef breeds is relatively small and often
there can be delays of two or three months from when an animal is finished
until it can be sold – again, possibly putting it in the 24-30 month
slaughtering category.
Any increase in the age
necessary for VC removal in the future (over the proposed 24 months) would be
of benefit to the organic meat industry.
Derogation allowing butchers to become authorised
to remove VC as SRM.
Butchers who source
locally produced meat in order to reduce the welfare and environmental impacts
of transporting animal’s long distances for slaughter should be permitted to
remove VC material. Whilst this will
result in increased material disposal costs for these local butchers it will
enable them to act independently of larger abattoirs and cutting plants and
reduce the need for additional animal transportation.
Prepared by Dr Phillipa
6 December 2005