In December 2019 regulation 854/2004 will be repealed. This legislation created the current detail of official controls on food of animal origin. EWFC have always known that the replacement for 854 would have to be created by Implementing and Delegated Acts added to the new regulation 2017/625. We have followed the creation of these proposals with great interest as it is our members, amongst other officials, that enforce them.

The EWFC Managing Board met in Vienna on the 4th and 5th of October to review the proposals, our comments to the Commission and their response.

The Board of EWFC are very concerned by some of the proposals, our comments on them are posted in an abbreviated form on the Commission forum for public consultation. You can read the detailed version below.

You can also find, on this website, the reaction to the proposals of the British Journal, “The Guardian”.

EWFC Comments and objections to

“COMMISSION IMPLEMENTING REGULATION (EU)…/... of XXX laying down uniform practical arrangements for the performance of official controls on products of animal origin intended for human consumption in accordance with Regulation (EU) 2017/625 of the European Parliament and of the Council and amending Commission Regulation (EC) No 2074/2005 as regards official controls”

(Sections in this statement in italics are quotes from the proposed legislation, correspondence or relevant scientific work.)



Article 7 Additional requirements for audits in establishments handling fresh meat

  1. (b)” contains the following statement:

“does not bear faecal or other contamination considered to pose an unacceptable

human health risk;”

EWFC believes that any visible faecal contamination on food will always pose an unacceptable health risk.  We have asked the Commission that the wording of this section is changed so that it reads, “does not bear any visible faecal contamination”. We believe this better reflects the requirements of 853/2004. We believe that this section could lead to FBO's with meat contaminated with visible faeces maintaining that it does not pose an unacceptable human health risk.


Article 11 Requirements as regards ante-mortem inspection at the slaughterhouse

  1. All animals shall be subjected to ante-mortem inspection before slaughter. However, inspection can be limited to a representative sample of each poultry flock, as defined in Article 2(3)(b) of Regulation (EC) No 2160/2003, and a representative sample of each holding of provenance of lagomorphs”.

The Board are surprised the Commission have decided to reduce ante mortem inspection to a batch of poultry only.  This is contrary to the European Food Safety Authority (EFSA) recommendation in, “Scientific Opinion on the public health hazards to be covered by inspection of meat (poultry) EFSA Panel on Biological Hazards (BIOHAZ), EFSA Panel on Contaminants in the Food Chain (CONTAM) and EFSA Panel on Animal Health and Welfare (AHAW) 2, 3”

Proposed change poses a serious risk to public health

We consider the above two points to be minor, however, compared to the proposal in Article 25 of the Implementing act, which poses a serious risk to consumers.

When considering the Commission proposal below please bear in mind:

In the European Union around nine million people each year suffer from Campylobacter food poisoning whose usual source is poultry related. The cost of campylobacteriosis to public health systems and to lost productivity in the EU is estimated to be around EUR 2.4 billion a year.

In spite of this, the Commission propose:

“Practical arrangements for post-mortem inspection of poultry

  1. All poultry shall undergo post-mortem inspection which may include the assistance of slaughterhouse staff in accordance with Article 18(3) of Regulation (EU) 2017/625. The official veterinarian or official auxiliary, in accordance with Article 18(2)(c) of that Regulation shall personally carry out the following checks:

(a) daily inspection of the viscera and body cavities of a representative sample of each poultry flock;

(b) a detailed inspection of a random sample of parts of birds or entire birds declared unfit for human consumption following post-mortem inspection from each poultry flock;

(c) any further investigations necessary where there is reason to suspect that the meat from the birds concerned could be unfit for human consumption.

  1. By way of derogation from paragraph 1, the competent authorities may decide that only a representative sample of poultry from each flock undergoes post-mortem inspection if:”

EWFC believes the Commission is relying on the EFSA work cited above, for this proposal. But they rejected its recommendation to continue ante mortem of all birds. We also believe the Commission relies on a study of 7 poultry slaughterhouses, 5 in Italy and 2 in Denmark carried out for EFSA by Cibin et al in 2014 entitled,

“EXTERNAL SCIENTIFIC REPORT Usefulness of Escherichia coli and Enterobacteriaceae as Process Hygiene Criteria in poultry: experimental study”

At our Vienna meeting the EWFC Board reminded itself that when this was published we contacted Members of the European Parliament (MEP) on the Environment committee. We told them we were surprised that Italy was chosen to carry out the majority of it, as we had just completed analysis of Food and Veterinary Office (FVO) audits to all member states poultry slaughterhouses, in which Italy was heavily criticised for its poor official controls.

The inspection procedures in this study suggest that the failings, seen by the FVO, were still taking place during the study. We believe this made its results unrepresentative of correct EU practice.

EWFC asked MEPs to contact the Commission and raise this question. Below is part of the response received from Mrs. Carmen Garau (Head of Unit at European Commission), dated 08.07.15

“With regard to the visual inspection after evisceration, we have requested the contractor to confirm the position of the person visually assessing the contamination. They provided the following information:

"the study was carefully designed and implemented in order to avoid differences and biases due to different behaviours in the selected slaughterhouses. For this reason, in Italy there was only one veterinarian (a poultry meat inspector hired specifically for this study) who performed the sampling and the visual examination, in all the slaughterhouses”.

The Board ensured that, following the Commission’s latest proposal, the Cibin study was reread. We believe there has been some confusion, contrary to the above assertion, we are convinced the Italian official inspection service carried out the work, as the study contains the following statements,

“To avoid biases due to lack of experience, only trained personnel were enrolled to collect samples and relevant data”, and, “Despite the effort to collect dirty carcasses without affecting the randomization criteria, only 97 out of the 3777 sampled carcasses were classified as dirty, 86 belonging to the post evisceration group and 11 to the post chilling group.

There was complete agreement between the samplers and the veterinarians responsible in the slaughterhouses over classifying the carcasses”.

If, despite the above evidence, only one vet was used for the sampling process in five Italian slaughterhouses, it does not indicate that official post mortem controls cannot detect visible faecal contamination on carcases with high bacterial contamination, only that this one vet could not.

The first mentioned EFSA study is contradictory stating ante mortem is valuable as it enables birds with heavy faecal contamination to be spotted and, presumably, not slaughtered but post mortem inspection is not useful, as it is not certain that visible faeces can be associated with zoonotic bacteria.

The Ewa Pacholewewicz et al “Utrecht study”

By contrast with the questionable EFSA work, a thorough scientific trial was carried out during 2016, by Ewa Pacholewewicz et al of Utrecht university, entitled:

“Influence of food handlers' compliance with procedures of poultry carcasses contamination: A case study concerning evisceration in broiler slaughterhouses”.

It took place in two poultry slaughterhouses and examined, amongst other things, whether visible faecal contamination was an indicator of high bacterial contamination.

It contains the following statement:

“Our results Fig. 3 demonstrate that the visibly contaminated carcasses after evisceration have higher E. coli concentrations than visibly clean carcasses (Fig. 4). This is in agreement with previous studies (Burfoot & Allen, 2013; Cibin et al., 2014). In the present study, carcasses with even small spots of faecal and caecal content after evisceration carried on average a significantly higher load of E. coli (p ¼ 0.001). Similar findings were reported with respect to Campylobacter (Berrang, Smith, Windham, & Feldner, 2004)”.

The study goes on:

“The compliance of food handlers with the criteria on evisceration control differed between slaughterhouses e.g. setting of the evisceration equipment and removing carcasses or their parts with visible faecal contamination in Slaughterhouse A was hardly ever carried out, whereas in Slaughterhouse B it was frequently carried out (Fig. 2).”

In table 6 it is shown that abattoir B had much better post mortem inspectors and the removal of carcases or their parts with visible faeces led to a much lower level of bacterial contamination.

The Board’s representatives have exchanged views with the Commission, on 13/09/2018 they wrote:

“As already indicated in replies to written questions of Members of the European Parliament and as laid down in Regulation (EC) No 854/20041, meat is to be declared unfit for human consumption if it shows soiling, faecal contamination or other contamination. Trimming of (individual) carcases showing visible contamination instead of declaring the whole carcase unfit for human consumption, is not allowed”.

EWFC is surprised by this statement as everyone involved in poultry processing and official controls knows that rejecting every carcase with visible faecal contamination does not reflect the current practice in EU slaughterhouses, or the requirements of current legislation.

Unfortunately, poultry carcases with visible faecal contamination, frequently continue down the production line, are sprayed with water, then continue their journey to the consumer.

We have asked the Commission, in our public consultation comments that their, “dangerous proposal should be withdrawn”, as there is significant correlation between visible faeces on carcases and unseen Campylobacter that may harm public health.

We believe that removing post mortem inspection of every carcase will expose more consumers to the risk of eating Campylobacter and Salmonella contaminated meat.

We have not seen any scientific evidence that supports the Commission view that there is no link between visible faeces and higher bacterial contamination. We call on the Commission to produce evidence of such a “missing” link.

Microbiological sampling

The Board agree that the above is a good indicator of process hygiene but taking just a sample, either to visually inspect or microbiologically test, will not detect random carcases with heavy contamination. The study by Cibin, which we have criticised, at least shows there is a great deal of variation between the microbiological status of individual carcases in a given batch. The carcases with dangerously high levels of microbiological contamination, even if they are selected for testing, will, by the time the results arrive, be on their way to the consumer.

The “Utrecht study” indicated that this is probably due to incidents during evisceration that rupture some part of the intestinal tract. This is random and will only be detected by visible inspection of every carcase, instead of reducing official post mortem control of poultry the Commission should be tightening it up to the level of red meat controls.

Abuse of Process

We further consider the use of an Implementing act to be an abuse of process. It is our understanding that such acts are only used to put into force practical arrangements for decisions that have already been agreed. We do not believe, that when regulation 2017/625 was agreed, the EU Parliament ever imagined that poultry post mortem official controls would not continue to take place on every poultry carcase.

EWFC repeats its appeal to the Commission to withdraw this dangerous proposal.

15-10-2018 14:Oct:th