Decision Document: Acceptance of Hide Washes Used in Canadian Beef Facilities When Making Product for the European Union
Dan Etzler, Mark KlassenAlan Schlachter
Effective date:6/20/17
Objective:
This document provides background and the rationale for the Canadian government’s approval of the use of hide washes in Canadian beef abattoir programs to harvest European Union (EU) -eligible animalsto produce beef and beef products eligible for export to the EU.
Background:
In May 2016 representatives of the Canadian Cattleman’s Association, the Canadian Meat Council, the Canadian Pork Council and an industry representativeparticipated in a trade mission to Europe. In the context of ongoing technical discussions on approval of antimicrobial processing aids on carcasses and meat, the question was asked in a meeting with DG Santé officials if the use of“Hide-on Carcass Washes (HOCW)” would be acceptable. The HOCW combines a caustic and water solution with physical agitation to remove debris from the hide of an animal that has been stunned and bled but before the hide has been opened for dressing. This step, in addition to employees following good hygiene practices during the harvest process, is part of a multi-hurdle approach to reduce the likelihood of pathogens getting onto the final dressed carcass.
In that meeting, DG Santé initially stated it would be acceptable but then stated they would have to discuss and decide on the process’ acceptability. Despite repeated requests for clarification by the Canadian industry and government during 2016-17, no response was received.
In European Regulation (EC) No 853/2004, ‘Carcase’ means the body of an animal after slaughter and dressing’1. Based on this definition, in 2016, it was discovered that Canadian industry and government representatives did not correctly explain the wash in a way that EU officials would easily understand since a dead animal prior to skinning and evisceration does not meet the European Regulation’s definition of a ‘carcase’.
During a subsequent trade mission to Europe in May 2017 by members of the same industry associations, this distinction was discussed with regulators in the United Kingdom and industry members of the European Livestock and Meat Trade Union (UECBV). In both discussions, the Canadian delegation clarified that the Hide Wash occurred after the animal was knocked and bled but prior to opening its hide for dressing. Both the UK regulators and members of the UECBV stated this was acceptable within the EU as it was equivalent to the desired outcomes articulated in existing Member regulations setting standards for cleanliness for cattle presented for slaughter to improve the hygiene of carcasses (e.g., UK Clean Livestock Policy). In consultation with the CFIA Veterinary Counsellor posted in Brussels, it was agreed that Hide Washes were not an issue meriting further exploration with EC officials.
Justification:
As stated in European Regulation (EC) No 853/2004, ‘‘Carcase’ means the body of an animal after slaughter and dressing’1. Using this definition, a dead animal is not considered a carcase when it passes through the Hide Wash and so, as is the case in the EU, it does not fall under European regulations on carcases.
Based on the definition of ‘Carcase’ in this regulation and subsequent discussions with both UK regulators and European meat industry representatives, CFIA has determined that Hide Washes are an acceptable element of Canadian beef abattoir programs to harvest EU-eligible cattle and allows their use on animals that qualify for production ofproducts eligible for export to the EU.
Reference Documents:
- Corrigendum to Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin. Official Journal of the European Union L 139 of 30 April 2004. Page L 226/32.
- Clean Livestock Policy of the United Kingdom. Accessed on May 24, 2017.
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