Annex B Copy of consultation document
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27 March 2001
Dear Sir/Madam
FEEDING TO LIVESTOCK OF BY-PRODUCTS FROM THE FOOD INDUSTRY: BAN ON SWILL-FEEDING
1. The purpose of this letter is to seek your comments on the proposed Animal By-Products (Amendment) Order 2001 and, in
particular, on the Government's proposals to ban the feeding of swill and related products.
Present position
2. The Animal By-Products Order 1999 permits the feeding to nonruminants of swill, i.e. processed catering waste or non mammalian animal by-products, after suitable treatment - heating to 100°C for at least one hour. These conditions will eliminate Foot and Mouth Disease (FMD), Swine Fever and other pathogens, although not the theoretical risk of TSEs. Premises producing swill and/or feeding it must be licensed by MAFF. They are subject to regular inspection by the State Veterinary Service.
3. We estimate that, in the year 2000, around 82,000 pigs in GB, about 1.4% of the total, were fed swill. About 74 premises are approved for processing swill, and 93 are licensed for feeding it to pigs or poultry.
The reasons for banning swill feeding
4. The arguments in favour of banning the feeding of swill to any farmed animals, include the following:
(a) because of the FMD outbreak, the risks from swill feeding are very much greater than they were previously. Before the present outbreak, the risk of swill feeding accidentally promulgating PMD came from imported infected meat products. For some time to come, however, there will be a much greater risk of infectivity from domestic meat used in swill.
(b) The consequences of one mistake in swill feeding can be enormous. The potential risk of swill feeding introducing disease to the great majority of livestock farmers who do not feed swill, and to the wider community, is much greater than the benefits to therelatively small number of those who do so.
(c) Because swill fed to pigs may contain porcine material swill feeding represents one of the few remaining examples permitted of intra species recycling. In theory it would be possible to ban intra species recycling and allow some swill feeding to continue, e.g. by allowing processed beef and sheepmeat material to be included in swill fed to pigs. But this would be impossible to enforce. The United Kingdom already bans the feeding of mammalian meat and bonemeal to all farmed animals. A ban on swill feeding would extend to liquid feed the general principle which applies already to dry feeding.
(d) Although EU rules do not currently ban swill feeding, such a ban is being considered in Brussels in the context of negotiations on the draft Animal By-Products Regulation.
The reasons for not banning swill feeding
5. Arguments for not banning swill feeding to non-ruminant farmed animals include the following:
(a) if the statutory conditions for feeding swill are complied with, it will not present a risk of transmitting FMD, SVD and other pathogens;
(b) swill is a useful inexpensive material used, for example, for feeding cull sows prior to slaughter. Marketing cull sows is a low margin activity. More generally, farmers feeding swill would lose the benefit of their investment in the necessary equipment;
(c) banning swill feeding will not necessarily prevent the illegal feeding of swill and catering waste to pigs, particularly by owners of small numbers of pigs. Indeed the risk may increase if legal (and controlled) swill feeding is not permitted;
(d) banning swill feeding will increase the quantity and cost of catering waste to be disposed of in other ways. Landfill is the most likely alternative option. However, the landfill option is becoming more difficult and the national waste disposal strategy envisages a reduction in its use.
Scope of any proposals
6. If swill feeding were banned; a decision would be needed on whether or not to include within the 'ban the feeding of catering waste not containing (or in contact' with) animal products other than milk, eggs, rennet, gelatin or melted fat as an ingredient. Such waste does not, at the present, require licensing under the Animal By-Products Order 1999. Continuing to allow catering waste not containing, or in contact, with, animal products to be fed to farmed animals would make it more difficult for SVS and local authority inspectors to detect meat-containing-catering waste or swill on farm. There would also be more chance of farmers accidentally feeding meat-containing catering waste to their pigs
(not realising that it contained meat). If a ban were introduced one option' would therefore be to prohibit the direct feeding to farmed animals of all catering waste, regardless of whether or not it contains, or has been in contact with, products of animal origin,but to permit its use in compound feeds manufactured off-farm. This is explored in more detail in paragraph 10.
7. The 1999 Animal By-Products Order prohibits the feeding of pig slaughterhouse waste to non ruminants, but continues to allow poultry and fish by-products to be, fed to pigs. Although the risk may be small, it would be difficult to ensure that poultry or fish waste is not contaminated on farm with mammalian waste. On balance, therefore, if there were a ban on swill feeding it would seem sensible to include poultry slaughterhouse waste within its scope.
Timing issues
8. A rapid withdrawal of swill as feed for pigs would create animal welfare problems for animals that had grown used to such a diet, as well as problems for those who would need to find an alternative disposal route. Veterinary advice is that, if swill feeding were banned existing swill feeders should be allowed a transitionalperiod of at least 3-4 weeks to enable their animals to adapt to the new type of feed.
Summary
9. I would therefore be grateful for your views on the following questions:
(a) should swill feeding of catering waste containing animal products be banned?
(b) if yes, should
(i) fish and poultry animal by-products fed on-farm be included in the ban; and
(ii) non-meat containing catering waste be included in the ban? In this case, should there be a total ban on the feeding of any catering waste (including vegetable waste) or should the ban be restricted to catering waste? Another option might be to require licensing of the supplier of the waste, the farmer who uses it, or both, or prohibit feeding on farm but permit their use in compound feeds.
(c) Should a 3-4 week transitional period apply?
(d) any other comments, including on whether or not it would be practicable to place obligations on the producers of catering waste eg. restaurants to ensure that its not fed to animals and on the enclosed draft Order?
10. I should be grateful to receive any comments on this letter by 10 April 2001. I apologise for the short notice but, for animal health reasons, it would be important to introduce any new arrangements as soon as possible.
Please could replies and questions on this consultation be directed to Catherine Lamb (020 7904 6408) at the above address.
11. In order to help informal public debate on the issues raised by this consultation document, the Ministry intends to make publicly available, at the end of the consultation period, copies of the responses received. The main Departmental Library at 3 Whitehall Place, London, SW1 (020 7270 8419) will supply copies on request to personal callers or telephone enquirers. It will be assumed therefore that your response can be made publicly available in this way, unless you indicate that you wish all or part of your response to be excluded from this arrangement. If you have no objection to your response being made available for public examination in the way described would you please supply an additional copy of your response to this consultation document.
12. For those wishing to obtain copies of comments, an administrative charge to cover copying and postage will be made. To enable requests to be dealt with efficiently and to avoid undue delay for those calling at the Library in person, it would be appreciated if personal callers could give the Library at least 24hours notice of their requirements.
Yours sincerely
Sue Bolton
BSE Division
