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Proposed meat inspection regulation

Proposed Meat Inspection changes – respond by January 31

The provincial government is proposing to impose provincial meat inspectors on all slaughter facilities (except federally inspected plants). This would mean that, except when an owner of an animal slaughters the animal if the carcass is for the sole use of the owner and not for sale, every animal would need to be inspected by a government inspector before and after it was slaughtered. This includes rabbits and poultry – every animal raised for food.

The inspector, who has about two weeks practical training and learns to recognize abnormal animals, will need to have an office, a desk and lockable cabinet and a washroom, and will need to be paid a minimum of four hours at whatever hourly rate the government sets.

Currently, outside of the designated areas – see the list at the end – local health inspectors have not felt any need to ask for designation. They inspect the plants, and have felt comfortable with their safety and health practices.

These proposed changes will greatly damage small farmers and rural areas. It will force us all towards industrial slaughtering and factory farming of animals. Small and specialty producers (including organic ones) will find if increasingly difficult and more expensive to get their animals slaughtered, locally or at all.

Large, industrial production and slaughtering facilities do not produce high quality, healthy product. They are driven to efficiency, maximum productivity and cost reduction. (I read a few years ago that most US poultry inspectors don’t eat poultry, and most beef inspectors don’t eat beef.)

Please inform yourself about this issue, and contact the government to express your support or dismay about this


Before January 31 contact:

Kersteen Johnston, executive director, health protection planning division kersteen.johnston@gems5.gov.bc.ca

Colin Hansen, minister of health colin.hansen@gems6.gov.bc.ca

John Van Dongen, minister of agriculture john.vandongen@gems4.gov.bc.ca

and your own MLA. You can find out who it is in the blue pages of your phone book.



Below is access to more information, an open letter from Lyle Young of Cowichan Bay Farm, and a copy of an email I sent on this topic.


The proposed Meat Inspection Regulation is available at www.healthplanning.gov.bc.ca/protectmeat_inspection.html


Standards for abattoir (slaughterhouse) plant construction, equipment and operation standards,
Abattoirs Code of Good Practice,
BC Designated Meat Inspection Areas, and
Meat Plant HAACP Guidelines
are available at
http://www.bccdc.org/content.php?item=144


Current “Designated Meat Inspection Areas” are:
Lower Mainland (Vancouver to Agassiz inclusive)
Municipalities of Squamish, Whistler and Pemberton
Southern Vancouver Island (School Districts 61, 62, 63)
South Peace River (School District 59)
City of Vernon
Sunshine Coast Regional District (Gibsons, Sechelt, Egmont, Pender Harbour, Roberts Creek)



An open letter to the public regarding
Meat inspection and you

The BC government, under the auspices of the Ministry of Health has proposed legislation that will make all areas of BC meat inspection areas. At first glance this may seem like a good thing, as I think everyone believes in improving food health and safety where possible.

In this instance, however, there are two parts of the draft, concerning facilities and inspectors, that could compromise food health in BC, as well as put our small scale specialty meat processors out of business causing many other negative ramifications. These ramifications include a hugely negative impact on agriculture, rural communities, our environment, tourism, animal welfare, food security, and your ability to purchase meat and poultry grown the way you believe is best.

This is the most serious issue I have seen facing agriculture in the past 16 years.

Historically, local government has always applied to the provincial government for inspection services when the community feels those services are desirable. This means a government inspector is on site performing ante and post mortem inspections of food animals. Under the new legislation the provincial government is imposing the regulations on local government. There are currently only five meat inspection areas in BC, the lower mainland, southern Vancouver Island (which has an exemption for poultry and rabbits), the municipalities of Squamish and Whistler, the city of Vernon, and the south Peace River. None of the other communities in BC to date, have felt the necessity of having government meat inspection services.

All other communities in BC are classed as "uninspected" which means the facility, the water and septic have all been inspected and passed as satisfactory by the local health authority but there is no government inspector on site during the processing of animals. For the record, a government inspector is not a trained veterinarian. A government inspector is any individual who has applied for training, and who has worked along side a certified government inspector for a period of about two weeks, and learned how to spot atypical animals or carcasses so they can be held for further inspection by a vet.

About 60% of all processing plants in BC are small "uninspected" family operations that have been serving the small scale, specialty and organic agriculture community for many years. It is not unusual for the operators to have between 10 and 30 years experience watching for "atypical" animals during processing. For decades these small operators have built relationships with their communities, and there has never been a recorded major food health issue with one of these plants. The same cannot be said for the likes of the large scale fully inspected plants, with our recent experiences of Aylmer et al.

The new legislation assumes that the local health authority approval of these small scale custom processing plants is suddenly inadequate. It also assumes that a small scale plant that processes a few lambs or cattle, to a few hundred poultry per day, should have the same level of facilities requirements as a plant that processes a few hundred large animals or tens of thousands of poultry per day. The new legislation also assumes that plant operators that have been processing animals for years have less ability to remove atypical animals from the food chain than a government inspector that has a certificate and two weeks of practical experience.

The capital and increased operating expenses that will be required to upgrade our small scale custom and specialty processing plants will put most of these businesses out of business. If this essential infrastructure is removed from our rural economies we can expect the following:

Widespread insolvency of organic, small scale and specialty farms that raise meat, estimated as 2,314 farms on Vancouver Island alone (60% of total farms on Vancouver Island, 1999 BC Assessment survey). BC wide expect a bigger impact.

Further collapse of businesses in communities as farm businesses close, so will veterinary clinics, feed mills, hardware stores, etc.

Enormous pressure on the Agricultural Land Commission to remove farmland from Agriculture Land Reserve, due to insolvency directly resulting from legislation.

Huge potential impact on the environment and rural landscape if land is allowed to removed wholesale from the ALR and developed (loss of green space, increased air pollution etc).

Loss of green space will negatively impact tourism, one of our most valuable renewable resources, and one of the fastest growing sectors of tourism. Agritourism or culinary tourism will end as specialty agriculture collapses.

As small processors shut down, the farms that are left will be forced to ship their animals longer distances for processing. The stress on animals being trucked long distances for slaughter has serious animal welfare and food health issues associated with it. The UK, through legislation and EU market forces went from 1,300 processors to just over 300 in a matter of just a few years. The increase in animal travel to slaughter was one of the primary factors in the devastating foot and mouth epidemic the UK experienced just three years ago. Animal and food health suffered in the UK directly as a result of small scale plants closing.

There are numerous indications that travel stress on animals decreases the animals' resistance to pathogens, and that longer periods of travel, coupled with the stress of a large scale processing environment can (and does) increase pathogens on meats. Irradiation of meat has been the big meat industry's answer in the US to increased levels of food borne pathogens (in order to preserve your food health). Check out Canadian Food Inspection Agency (CFIA) website for irradiation plans in BC.

Contrary to the intent of the meat inspection draft regulations as written, centralizing meat processing facilities may in fact decrease food health in our province and certainly decreases our food security.

In an era where humane farming practices are recognized as increasingly important values to consumers, endorsing choices that are counterproductive to humane farming practices need to be seriously examined.

People are increasingly making food choices based on how the food is grown and where it comes from. Our top Chefs make these choices too, sourcing the best local ingredients, raised in an animal friendly and organic fashion. Locally grown free range, pasture raised, organic meats and poultry grown on small family farms is the fastest growing sector in the food business, and it is no wonder Vancouver Island farmers and Chefs are receiving the international accolades for food grown and served right here.


If the BC government proposed meat inspection legislation goes through as written, you might as well forget about getting your free range turkey for next Christmas from the farm up the road. Serving Salt spring Island lamb when guests come, or enjoying Cowichan Bay Farm pasture raised chicken at your favorite dining establishment, could very well become a thing of the past.

Farmers and processors are not against increasing food health in BC, however the draft legislation, as written, is both counterproductive to increasing food safety and threatening to many sectors of our economy and ethics. We as farmers and producers are encouraging the government to consider standardization of food health laws across BC, but to recognize through a risk assessment processes that large scale processing plants can pose a greater risk to the public than small scale plants, due to travel times, animal stress etc.

We are lobbying the government to raise the bar on food health in BC by providing training and certification for small scale plant owner operators equivalent to BC government inspectors. This will supplement their years of experience and provide a solid foundation for a HACCAP based self inspection system similar to what is being used successfully in Denmark and in some places in the States. Qualified self inspection in small scale local plants will eliminate the financial burden of a having a government inspector on site and go a long way to achieving food health in BC.

We are also adamant about results based programs for plant cleanliness and hygiene. We simply cannot have our businesses and local economy be threatened because our local health authority approved existing processing facilities do not meet the same provincial standards of processing plants that typically process up to 50 times the volume of animals per day of our small plants. If our small scale plants can prove through testing, certified cleaning programs and reasonable periodic upgrades that they are consistently able to produce excellent results, we should be supporting their continued operation as valuable infrastructure in our communities.

Will you support us on these issues?

Please write to your MLA (look in the blue pages of your phone book under British Columbia) and cc Kersteen Johnston,
Executive Director
Health Protection Planning Division
4th Floor, 1515 Blanshard St
Victoria BC
V8W 3C8

This is a political issue, and the most effective way to address it is through political channels. As farmers only comprise 5% of the vote, agriculture does not have a very strong voice. This issue will affect British Columbians far beyond the agriculture sector. Please write! Every letter your MLA receives is immensely valuable in creating political will for positive change.

The deadline for comment has been indicated as January 30, 2004, although please do not hesitate to write if the deadline has already passed, - especially to your MLA.

Thank you!
Lyle Young
Cowichan Bay Farm
And thousands of other small scale producers and processors in BC who are brining you the very best BC has to offer!

The draft regulations are posted on the BC Ministry of Health Planning website
www.healthplanning.gov.bc.ca/protect/

The companion manual to the draft regulations is "Abattoirs, plant construction equipment and operation standards to qualify for licensing under the British Columbia Meat Inspection Program"
available at www.bccdc.org/dowloads/pdf/fps/reports/abbatoirs.pdf








To: kersteen.johnston@gems5.gov.bc.ca, colin.hansen@gems6.gov.bc.ca, john.vandongen@gems4.gov.bc.ca, judith.reid.mla@leg.bc.ca
From: pjohnst@mail.island.net (Peter Johnston)
Subject: proposed meat insection regulations

Dear Ms Johnston, Mr. Hansen, Mr VanDongen, and Ms Reid,

I write to you to ask you in the most strong and emphatic voice possible, to rethink and rescind the proposal to introduce one regulation for all meat processing and slaughtering plants in BC.

This proposal will cause untold damage to small and medium sized farms, and to small slaughter plants and butchers. It will do nothing to increase food safety, and will cause much loss of business and income and productivity on Vancouver Island and the Gulf Islands, as well as other parts of the province.

Both farmers and processors have demonstrated their readiness and willingness to address any food safety concerns with their local public health officers (who already inspect and approve them) and with the CFIA.

It is a fact that most food safety concerns arise from intensive industrial meat handling and processing operations, where productivity is the main concern. Local and small meat production has not been a great concern in the past, and there is no reason to consider it to be more risky now.

Locally produced and slaughtered meat is no less safe, and it is much higher quality than industrially produced meat. Chefs and cooks and homemakers seek it out, because of its superior taste, freshness and quality. They seek out and pay a premium for locally produced, non-industrial meat and animal products. They assist many small and medium farms to make a living, and also a fairly large number of local and regional slaughtering facilities and butchers. These people all contribute to the local economy, in more ways than just money, and are a large part of the reason that our rural economy is as healthy as it is. Your proposal will be greatly harmful to many, many people.

People who see out locally and naturally or organically raised and handled animal products will not switch to industrially slaughtered meat. This will mean that a great deal of meat will be processed "under the table", and with some increased health risk, as well as great economic and political/social damage.

I urge you to rethink and rescind this ill-advised plan. Thank you for your consideration. If you have anything you would like to ask, or anything you would like to tell me, please do.

Peter Johnston
Heron Bay Farm
Lasqueti Island
BC V0R 2J0
250-333-8785
pjohnst@island.net


I received the following response from Ms Johnston:

Mr. Johnston, thank you for your email note and comments. These along with others being received will be shared with government.

Are you a farmer/gardener? yes

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Re: Proposed meat inspection regulation

I sent a short message to the authorities expressing my concern. this is what I said - "Though I uphold the concepts and precepts of food safety near and dear, freedom of choice needs to be protected as well. There must be some way to recognize local health inspectors expertise so they may fill the food safety requirement gaps that this legislation is trying to address".

Re: Proposed meat inspection regulation

Greetings everyone. The Province is proposing a meat inspection regulation that would have very negative consequences for small meat producers and
processors. These consequences would undermine regional food systems, which is key to what the BC Food Systems Network is all about.

Although the deadline for comment was today, it would still be worthwhile visiting the following Web site:

www.bcfarmnet.org

and voicing your concern to the Ministers and your MLA.


Cheers

Kathleen

_____________________________

Kathleen Gibson, Principal
GBH CONSULTING GROUP LTD.

Tel: 250.598.4280
Fax: 250.598.4288
Email: gbhgroup@shaw.ca

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Re: Proposed meat inspection regulation

From : Capital Region Food and Agriculture Initiatives Roundtable (C R – F A I R)
Bringing about positive change in the food and agriculture system within the Capital Region

30 January 2004

To: Honourable John van Dongen
Minister of Agriculture, Food & Fisheries

Honourable Colin Hansen
Minister of Health Services

Dear Sirs,

RE: Proposed meat inspection regulation

CR-FAIR is one of a number of community-based food security organizations in British Columbia. For the past 10 years we have been working on positive change in the food and agriculture system in the Capital Region. In a few weeks we will be launching a Baseline Assessment of Food Security in BC’s Capital Region. It includes the following definition of food security:

Residents of a food secure community have universal access to food that is healthful, nutritious, safe, and culturally acceptable. Food is acquired through dignified means and from non-emergency sources. The community has created “a system of growing, manufacturing, processing, making available and selling food that is regionally based, grounded in the principles of justice, democracy and sustainability.”

We believe that, in principle, any region or community should look after its ability to feed itself, and that this mandate should be part of its regional and local government.

We also know that farm and food businesses provide significant numbers of jobs and dollars that circulate in local communities. One local farm job is estimated to multiply out to 10 related local food jobs in food distribution, stores and restaurants.

Our Baseline Assessment of Food Security shows that there is enormous potential for growth in our region’s farm and food businesses. Local foods have acquired cachet for residents and visitors alike. Colleagues from around the world tell us that the Islands could be an international tourism destination for their cuisine alone.

The major threats we have identified include the disappearing agricultural land base and crumbling infrastructure (processing and distribution systems). These are very serious barriers that local producers are working to overcome. We are very concerned that the proposed meat inspection regulation will deal a harsh blow to our Islands meat producers and greatly increase the obstacles to their success.

According to the businesses themselves, this regulation will put several of our Islands specialty meat processors out of business. This will lead to loss of small-scale and specialty meat farm operations with a domino effect on the local businesses that serve them. We have already seen that when the Lilydale chicken processing plant left Vancouver Island, the number of commercial chicken producers dropped from 37 to 12 in three years. The same pattern will be repeated for small specialty meat operations.

We fully support the concerns raised and the options proposed by the Island Farmers Alliance and others and collected at www.farmnet.org.

We are of course interested in top-quality local foods that are, by definition, nutritious and safe. We are simply concerned that the proposed regulation will do more harm than good. In addition, we are concerned that the consultation process to date could have been more thorough and that the Province has not been able to gauge the full implications of the proposed regulation.

Everything we have said about our region applies in other regions of BC as well.

Accordingly we encourage your Ministries to:

1. Convene dialogues on meat inspection with regional farm and food organizations around the province.
2. Consider alternative routes to the shared goal of increased food safety such as:
· Standardization of food health laws across the province
· Introduction of risk assessment criteria that include a wider range of factors involved in food production and that address different scales of production
· Introduction of results-based programs for plant hygiene that relate to the size of the plant
· Introduction of a HACCP-based training/certification program for small-scale plant owner-operators
· Feasibility study of government-inspected mobile abattoirs (there are examples in the US)

If this regulation goes ahead as proposed, the Province may also find it has compromised the very processing infrastructure that another of its initiatives has committed to support. In the same time frame (spring 2004), the Ministry of Agriculture, Food and Fisheries, working through Investment Agriculture Foundation with a team of government and agri-food representatives, is launching a five-year Agri-Food Initiative on the Islands. Its overall purpose is to strengthen the Islands agri-food sector and one of its four goals is “to support increased agri-food processing as a catalyst for rural community development.”

With some more consultation and some reworking, we can find ways to ensure safe, top-quality regional foods, support local farm and food businesses’ incredible economic potential, and encourage their supporters in the voluntary sector to help regional agri-food initiatives of all kinds to be truly successful.

We look forward to hearing from you.

Yours very truly,

FOR THE CR-FAIR STEERING COMMITTEE


Kathleen Gibson

Members of the CR-FAIR Steering Committee

Community Social Planning Council of Greater Victoria
GroundWorks Learning Centre
Growing Green Project
LifeCycles Project Society
Ministry of Agriculture, Food and Fisheries
Small Scale Food Processor Association
TLC The Land Conservancy
Vancouver Island Health Authority

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