Informal resolution process for red meat carcases rejected at post mortem inspection

Process aim

This procedure has been developed by the Food Standards Agency (FSA) in conjunction with meat industry representatives to provide food business operators (FBOs) with access to an informal and voluntary resolution process when the decision has been made not to apply a health mark following ante mortem and post-mortem inspection (“inspection result decision”), and the FBO is in disagreement. 

For consideration

Where a review is requested, the final decision regarding the fitness of a carcass continues to rest with the Official Veterinarian (OV) attending on the day the animal was processed.

An FBO may request a review of the initial OV inspection result decision by an FSA veterinarian who is also a qualified OV (we will refer to this veterinarian as FSA Vet for the purposes of this document and to avoid confusion between the OV at the plant and the FSA OV).
Notwithstanding the request for a review, where the OV considers that it is reasonable to take action to eliminate or contain any risks to human or animal health, or to animal welfare, the OV retains the right to take such action. 

Where an FBO disagrees with the inspection result decision, an FBO is not required to request an informal review and may challenge the inspection result decision through the usual legal routes.

Considering that requesting an informal review will inevitably delay the OV in reaching a final decision, FBOs should ensure that fully functional and lockable facilities are available for the hygienic refrigerated storage of detained meat before requesting an informal review.

The process of requesting an informal review

1. Where an FBO does not agree with the OV’s inspection result decision, they must first discuss their concerns directly with the OV. Consideration must be given to allowing carcasses to set, perhaps allowing overnight refrigeration before initiating this procedure (e.g. oedema in older cattle). 
2. Following the discussion, if agreement cannot be reached, the FBO should notify the OV of their intention to request an informal review both verbally and in writing. The FBO, or a representative appointed by the FBO, should complete Part 1 of the form set out in Annex I and email it to the OV. This notification should take place within the agreed OV working hours of the day when the inspection result decision was made. The Head of Operational Delivery (HOD) should be copied into this email notification.
3. The OV should gather photographic and video evidence. Photographs and videos should have an accurate date and time stamp and preferably be taken within 24 hours of the slaughter of the animal. 
4. After the FBO contacts the regional HOD (see point 2), the HOD will appoint an FSA Vet, to provide a review at the earliest opportunity, in preparation for the receipt of the documentation for review. 
5. After the OV has gathered evidence, they should complete Part 2 of Annex I and submit it to the HOD no later than close of play on the next working day after the FBO has initiated this procedure. The FBO initiates this procedure when they complete step 2 of this process. 
6. The HOD will submit Annex I to the FSA Vet as soon as reasonably practicable but will use reasonable endeavours to do so on the same day it is received. The FSA Vet should provide their review, including details of their rational, as soon as reasonably practicable and return Annex I after completing Part 3 to the HOD and the OV.
7. The FSA Vet should discuss with the OV the content of Annex I if necessary and may visit the establishment to inspect the carcase and body parts if required to reach their opinion. 
8. As soon as reasonably practicable after receiving the completed Part 3 of Annex I, the OV will consider the views of the FSA Vet. The OV will then complete Part 4 of Annex I, setting out the final decision. They will communicate this final decision to the FBO in writing, by emailing all completed parts of Annex I to the FBO and the HOD as soon as reasonably possible. 
9. If the review outcome agrees with the OVs decision, that the carcase and body parts are unfit for human consumption, the carcase and associated material will be declared unfit and the FBO must disposed of all material as the appropriate category of ABP. 
10. If the review outcome identifies further evidence or issues which may point to a different conclusion, after considering all the factors and evidence, the final decision on the fitness of the carcase and body parts will rest with the OV.
11. All involved in the procedure are expected to act in good faith. 
12. Annex II includes a process flow diagram for further clarification.

Cost implications

There will not be any cost for the work of the FSA Vet during the trial period. Once this period is over, this position will be reviewed.