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Home > Publications > Special Reports - Parliamentary > The introduction of the ban on swill feeding > Annex B - Copy of consultation document
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.
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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 the
relatively 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.
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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 transitional
period of at least 3-4 weeks to enable their animals to adapt to the new type of feed.
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Summary
9. I would therefore b e 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 topersonal 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 24
hours notice of their requirements.
Yours sincerely
Sue Bolton
BSE Division
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