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JOINT COMMITTEE ON AGRICULTURE, FISHERIES AND FOOD debate -
Wednesday, 21 Jan 2009

Contamination of Meat Products: Discussion with safefood and Irish Grain and Feed Association.

On behalf of the joint committee, I welcome the representatives of safefood: Mr. John Dardis, chairman of the advisory board; Mr. Martin Higgins, chief executive; Mr. Raymond Dolan, director of planning and resources; and Dr. James McIntosh, chief specialist of chemistry and toxicology, who are here to make a presentation on their role in promoting food safety. I thank them for accepting our invitation. I personally welcome Mr. Dardis, a former Member of the House. He attended many of this committee’s meetings for a number of years.

Before I call the delegates to make their presentation, I draw attention to the fact that while members of the committee have absolute privilege, the same privilege does not apply to witnesses appearing before the committee. Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official either by name or in such a way as to make him or her identifiable. I understand Mr. Higgins will make the presentation but that Mr. Dardis wishes to say a few introductory words.

Mr. John Dardis

I thank the Chairman for the invitation. We are honoured to be here and hope we can be of assistance in the committee's deliberations on this important issue. It is nice to come back to the Houses of the Oireachtas. I hope Members enjoyed their 90th birthday party yesterday and did not stay up too late last night watching the US President being installed.

I will introduce my colleagues. Mr. Martin Higgins is the chief executive officer of the Food Safety Promotion Board, otherwise known as safefood. Mr. Ray Dolan is our director of planning and resources and Dr. James McIntosh, our chief specialist in chemistry and toxicology. As biographies have been circulated to members of the committee, there is no need for me to explain their qualifications and so on.

We are unique, being a North-South body established under the Good Friday Agreement. I was honoured to be asked by the Government to chair the advisory board. I emphasise that it is an advisory board, not an executive board. It was established under the British-Irish Agreement Act 1999. Part 2 of Annex 1 sets outs our functions. We are statutorily liberated in certain ways and statutorily constrained in others. It is important to emphasise that we are not an enforcement body. Our primary purpose is to communicate and tell people about matters related to food safety. We report to the Oireachtas and the Assembly. We are under the ultimate control of the North-South Ministerial Council and the respective Health Ministers on either side of the Border.

It is important to emphasise the all-island nature of the body which gives it a certain perspective. It may be helpful to take an all-Ireland approach. The committee does not need me to tell it that the whole island is involved when certain things happen. I refer to the outbreak of foot and mouth disease, for example, or the pork dioxin scare. It is worth emphasising that the reputation of the food and agriculture industries across the entire island needs to be safeguarded. We are giving more attention to these industries than we did when the Celtic tiger was roaring, rightly so, although we never forgot about this important area of economic activity.

It is good that the composition of the advisory board reflects all traditions on the island. The exchanges at board level are quite free. It is useful to hear the perspectives of people with whom we might not otherwise interact so closely. It is inevitable that we are inclined to focus on our own jurisdiction. Our mission statement makes it clear that we will strive to contribute to public health by promoting, fostering and maintaining confidence in the food supply on the island of Ireland, in partnership with others. I emphasise the words "promoting" and "partnership".

Under the Good Friday Agreement, there is an east-west dimension to our work. We interact with statutory and independent bodies in Great Britain. The chief executive of safefood, Mr. Higgins, will discuss these matters in greater detail.

Mr. Martin Higgins

As Mr. Dardis said, safefood is a North-South body which reports to the health Departments on either side of the Border on an operational basis. Its headquarters is located in Little Island, County Cork. It has a sub-office in Dublin. It does not have a physical presence in Northern Ireland. The board had a budget of €10.2 million, or £9 million, last year. The Department of Health and Children provides 70% of the organisation’s funding, with the remaining 30% coming from the Northern Ireland Department of Health, Social Services and Public Safety. The ratio of funding is dictated by the ratio of population on the island. That is how the figure comes about. The body has 30 permanent staff, 23 of whom are located in County Cork and seven in Dublin. The organisation’s governing legislation provides that the chief executive shall carry out all the functions of the body under the direction of the North-South Ministerial Council. The chief executive is assisted by a 12-member advisory board, of which Mr. Dardis is chairman, and an 18-member scientific advisory committee. There is 50-50 North-South representation on the board and the committee.

I wish to compare the roles of safefood and the Food Safety Authority of Ireland. The FSAI is the national body with responsibility for enforcing food law in Ireland. As Mr. Dardis said, safefood does not have an enforcement role but is tasked with the promotion of food safety and healthy eating and the development of collaboration in such areas. Another key difference is that the statutory role of the FSAI does not extend beyond this jurisdiction, whereas safefood operates in both jurisdictions. The relevant legislation provides for safefood, at the request of the North-South Ministerial Council, to review and advise on the adequacy of the food enforcement arrangements in place across the island. No such request has been made to date. The key function of safefood is to promote food safety as a responsibility shared by the entire food chain. The organisation is also charged with giving advice on healthy diets. In addition to broad awareness campaigns, it has also developed specific programmes for specific target groups in schools, work settings and communities. We promote, commission and fund research to try to acquire evidence that underpins our promotional and educational activities.

I will outline what happens when there are food alerts such as in the case of the recent withdrawal of pork products. Primary responsibility for the management of such alerts rests with the enforcement agencies in each jurisdiction — the FSAI in this jurisdiction and the Food Standards Agency Northern Ireland on the other side of the Border. safefood plays a key role in advancing scientific co-operation, particularly between laboratories. Food laboratories play a key role in identifying sources of pathogens when outbreaks of disease take place. We have established a number of networks to improve the responsiveness and capacity of laboratories. In partnership with laboratories and food safety agencies on either side of the Border, we have developed an enhanced information technology system that will greatly improve the speed with which information can be shared. If detailed testing of pathogens is required, all samples from both jurisdictions are sent to Great Britain for testing. As time is of the essence when outbreaks of disease take place, it would be preferable to have a testing service on the island of Ireland. However, we have to ensure such a service meets the highest international standards. This is something we are examining, at the request of the North-South Ministerial Council. We are consulting key stakeholders.

In addition to our collaborations on food borne disease, safefood is also engaged in partnerships in respect of nutritional surveillance. Members will be aware that obesity is one of the greatest public health challenges facing developed countries. If we are to tackle the problem of obesity in the coming years, it is vital that we have good evidence of how it is developing. Such evidence will help us to develop communications strategies and maximise the effectiveness of our messages. In 2005 safefood initiated a programme of two comprehensive screening exercises a year in the three-year period. Each review exercise profiled a specific food category; described the relevant food safety and nutritional issues pertaining to it at various stages along the food chain; and identified opportunities to communicate the human health benefits to and influence the behaviour of the various stakeholders. The primary focus of the review exercises was food safety and nutrition. Certain other consumer concerns not directly related to food safety such as labelling and quality assurance schemes were also commented on in the review exercises.

The pork sector was the subject of one of the review exercises mentioned. The full review was published on 24 November 2008, just before the withdrawal of pork products. Copies of the summary document have been made available to members of the committee. The review highlights that prior to the difficulties that arose before Christmas, consumers had few concerns about the safety of pork or the industry enforcement controls in place. It is clear from the review that consumers wish to increase their consumption of lean and fresh pork. Some 85% of people on the island of Ireland eat pork products. More than half of the pork we eat is processed — bacon, sausages and ham — which is almost always high in salt and has varying fat and meat content levels. The review has found that children of primary school age in the Republic of Ireland eat twice as much processed pork as lean pork. Just 22% of children between the ages of five and 12 eat unprocessed pork. Some 59% eat bacon, while 65% eat sausages. The review points out that consumers can decrease their total fat and saturated fat intake and thereby reduce their risk of cardiovascular disease by choosing leaner cuts more often.

The current dietary advice on the island of Ireland supports the recommendation of the World Cancer Research Fund that high levels of consumption of red meat and processed meat are linked to a number of cancers. In the light of the large levels of consumption of processed pork products on the island of Ireland, however, we suggest a more practical and achievable interim goal for many consumers would be to gradually reduce their intake of processed meats. We advise parents to balance the amount of pork their children eat by introducing more unprocessed pork into their children's diets or by using leaner cuts of fresh pork. On average, pork, an excellent source of iron, has a lower total and saturated fat content than other red meats such as lamb and beef. Fresh pork is also a source of essential nutrients such as phosphorus, zinc, potassium, magnesium and the B vitamins.

The safefood review found that consumers had confidence in the safety and integrity of the pork supply chain. The concerns of consumers centred on the health implications of processed products in terms of cholesterol and blood pressure. In response to health concerns regarding salt levels in foods and, more specifically, a negative focus on processed meat products, the pork industry is moving to reduce the levels of salt in pork by 2010.

The review also highlighted the need to harmonise the approach to the control of salmonella in pork in Northern Ireland and the South. The importance of an all-island approach to control schemes to minimise the incidence of salmonella species in pigs is underlined by the fact that almost 40% of pigs slaughtered in Northern Ireland originate in the South.

The document circulated to the committee is a summary of the full report which is available on our website, www.safefood.eu. I will provide copies of the full report, if required.

I welcome representatives of safefood, in particular, Mr. John Dardis, who had a distinguished career in the House.

The joint committee is charged with investigating the debacle of the pork recall and ascertaining how the State can learn from it. It is appropriate that a body such as safefood which has a North-South dimension is appearing before us because the recall had implications at all levels, including in Northern Ireland. For example, it impacted on primary processors in the bovine sector, as well as the pig sector, and also had consumer and retail implications.

Mr. Higgins has noted that safefood’s role is to act as an advisory rather than enforcement body. However, he has also pointed out that legislation provides that the body may review and advise on the adequacy of food enforcement arrangements. I note safefood has not been asked by the North-South Ministerial Council to do this. What lessons can the joint committee learn about the adequacy of current enforcement arrangements? Members are anxious to find out whether they were adequate. There are glaring gaps along the food chain and we want to determine how they can be closed. I ask our guests to comment.

The publication of safefood’s review of consumer attitudes to pork predated the recent controversy and is very welcome. It would be interesting to learn how it measured consumer confidence in pork, which was high prior to the outbreak in November. Perhaps a further study will be undertaken later this year to determine what have been the consequences of the recall of pork products.

Dr. Wall, the former head of the Food Safety Authority of Ireland who was also involved previously in the European Food Safety Authority, appeared before the joint committee last week and expressed concern that the legacy of the recent controversy would be one of long-term damage to Ireland as a food producing nation, including a long-term impact on markets. It is also important to identify the domestic legacy of the recall. Addressing this legacy will require identifying the extent of the damage caused. Does safefood intend to follow up on the review published in November? In the absence of an invitation from the North-South Ministerial Council, can it publish its deliberations on the enforcement regime at some point in 2009?

Mr. Martin Higgins

On the adequacy of the enforcement regime, the policy is clear. safefood does not have a right or responsibility to comment on or critique the enforcement regimes, unless a specific request is made to do so by the North-South Ministerial Council. That has been made clear to us by the sponsoring Departments and is also clear in the legislation. We are precluded, under the relevant legislation, from acting on our own initiative in that regard.

The background to this issue is that when the body was established, it was recognised that while European food law in its broadest sense applied to both jurisdictions, the manner in which it was enforced and the delivery mechanisms for inspection were different in the two jurisdictions. Perhaps this was one of the reasons we were not given this remit. Unless we are specifically asked to do so by the North-South Ministerial Council, we are prevented from conducting such a review.

On Deputy Creed's second point, safefood is examining the current level of consumer confidence. We use focus groups and omnibus surveys to gauge consumer concerns and responses to issues. We have not done this with regard to pork since the withdrawal of pork products because in the immediate aftermath of previous difficulties consumers continued to react to media reports. However, it would be useful to put this issue to field shortly. If, as we expect, we do so in the next week, we should have results around the middle of March.

To illustrate this point, members may be aware that a couple of years ago there was a concern about an industrial dye known as Sudan Red which had entered the food chain. While public health concerns did not arise at the time, the media were full of reports about the issue and consumers became concerned about it. Our helpline was jammed with calls from people concerned about the product. If asked, however, most consumers would no longer know what Sudan Red was. We must, therefore, allow some time to elapse before carrying out a survey. Given the confidence expressed in the pork food chain when our report was compiled, it is important to gauge at what level consumer confidence is at this point. We will move on this issue in the next week or thereabouts.

Mr. John Dardis

Members of the board were obviously concerned about these issues and fully briefed at our previous meeting. Dr. McIntosh is an expert on the science involved. What we, at board level, try to do is ensure everything is backed by science. One receives many opinions about food and food production but we must, as far as possible, try to ensure the opinions we express are based on science.

Dr. James McIntosh

To paraphrase the comments made by Mr. Higgins and Mr. Dardis, it is important that the science on this matter is accurate. Dioxin has a long history. The evaluations conducted needed to be done to ascertain precisely what we were dealing with. The bottom line is that whatever happens it must be underpinned by good science. This is also specified in our legislation.

I welcome the representatives of safefood, or the Food Safety Promotion Board. We all strive to ensure food safety and provide best quality food. The better the quality of our food, the more we can sell and promote it abroad. While I am aware the issue I raise does not fall within the remit of safefood, the joint committee is carrying out an investigation into the recall of pork in December. I note the recall was barely referred to in the presentation. As an agency promoting food safety, what does safefood believe will be the repercussions of the recall? Will we overcome the negative reaction to pork? We have made significant progress in this respect as a result of the Government’s response to the issue which has rebuilt confidence in the consumption of pork. What is the opinion of our guests?

As a North-South body, is there full co-operation between the North and South in promoting a joint food programme of healthy eating? Will we have better co-operation in the future? Can safefood play a part in promoting Irish food products, pork in particular, and having them returned to European and world markets in the wake of what has happened?

We are very fond of bacon in Ireland; rashers and sausages are our favourites. They comprise part of the famous Irish breakfast. How can we get young people and even people of our age to change to the more healthy option, pork, which is not salted and better for those with high blood pressure or a heart condition? How can pork be promoted over rashers, sausages and puddings?

Mr. John Dardis

I am a little less constrained by comparison with the chief executive. He might want to say what I would say but he might not be in a position to do so. I am expressing a personal opinion, not necessarily that of the board.

At European level, the board liaises with the bodies in Brussels and we hope to be able to contribute. Our role is obviously the promotion of safe food rather than Kerrygold or a specific producer. There are other bodies to do that job; let them do so. We can contribute to the effort.

Since my appointment as chairman, I have become far more aware of what is happening on the ground in the agriculture sector in Northern Ireland, although I would have had some knowledge from an agricultural journalism point of view. It would be useful for the committee to consider what happens in the North with regard to traceability in that there are lessons to be learned from how our Northern counterparts handle matters. We liaise with the Food Safety Authority of Ireland, the Food Standards Agency in the North and the agency's parent body in Great Britain. At least, we try to ensure joined-up thinking.

With regard to controls and the history of what has taken place, I read what the Secretary General of the Department of Agriculture, Fisheries and Food had to say to the committee and support what he said completely. Even still, I am not sure we are fully at the point where we accept the primacy of the consumer. There is much talk about this and lip-service is paid to it but I wonder to what extent people are really committed to ensuring all of the focus is on the consumer. It may appear that controls are very severe for producers and processors but when one considers what we export, we have no choice in the matter. Can one imagine what it would have been like had the Dutch or the Danes intervened rather than ourselves? It would have been catastrophic. Confidence can be restored. I am sure this issue arose during the recent visit to Japan. It takes time to restore confidence but it can be done. While BSE and other scares may not be forgotten, consumption is no longer affected.

Dr. Wall indicated very strongly to us that had the problem been detected by some country other than ours, it would have been serious for the trade.

Mr. John Dardis

It would have been catastrophic. That is my personal view, not necessarily that of the board which has considered the matter of traceability in some detail.

On the North-South dimension, the North-South Ministerial Council has been active in encouraging us to deal with obesity, particularly among children. The problem is serious and becoming more so all the time. We have initiated campaigns in this regard. One may have seen an advertisement on television over Christmas in which some little fellow says, "My body is a temple, too." We have been active in educating children. We have approached schools, North and South, and health officers to ensure these messages are getting through to the greatest extent possible.

Mr. Martin Higgins

On North-South co-operation, I will illustrate some of the measures being taken on an all-island basis. As Mr. Dardis stated, obesity is an issue. The National Taskforce on Obesity in the South has produced a report and there is a similar document, "Fit Futures", in Northern Ireland. Just before Christmas we set up an obesity action forum that will allow those interested in the area in the North and South to work together. We are working with the Food Standards Agency in Northern Ireland on ongoing nutritional surveillance. This is mirroring what is being done in the South as part of the SLÁN survey. It will result in all-island data that will allow us to compare North, South, east and west.

We are involved in co-operation in research. We have a research project, on which a report is due in March. Teagasc is the principal researcher but the University of Ulster and Queen's University are also involved. The study focuses on salmonella in pork. I have no doubt the report will contain some recommendations on the management of salmonella in pork on an island-wide basis.

On promotion at European level, our vision is to ensure confidence in food on the part of consumers on the island of Ireland. By extension, if Irish consumers have confidence in food, Europeans should also have confidence in it. The focus is on the Irish consumer.

The Irish breakfast is an issue, as a lot of processed food is being eaten. The point we make all the time is that there are no bad foods. It is not like smoking where every cigarette is doing one harm. There are no bad foods in that it is a question of having a balanced diet. That is why we have taken the approach of seeking a reduction in the amount of processed food consumed. However, we are realistic in that we realise processed food is a dominant part of our diet. We must emphasise that pork is a very good food, as we have done in the report. It tends to be lower in saturated fat than other meat products. It is high in iron and vitamins. We can promote in that way.

The obesity problem is such that one in four children starting school is overweight, a very serious statistic. Modelling in the United Kingdom shows that if circumstances do not change, up to 80% of the population will be overweight or obese in 20 years. We do not believe Ireland is any different. The implications of an increase in obesity are considerable. The task we face, therefore, is considerable and it faces all developed countries. The focus will be on shifting attitudes to food.

I thank the representatives of safefood. The purpose of the study was to give the public the information they needed to make informed choices about food they eat.

Mr. Dardis alluded, admittedly in a personal capacity, to the traceability regime in the North. Will the delegates elaborate on this? The fact that 40% of the pigs processed in the North come from the South begs the question as to whether the produce is branded as being from Ireland or the United Kingdom. What way do processors in the North market their product? The delegation claims it needs a request from the North-South Ministerial Council. If it is to take its advice to another level, it cannot say matters such as labelling and quality assurance are not related directly to food safety. This involves ingredients. If traceability and quality assurance are not included, how can one be sure that it does what it says on the pack? If safefood is to play a role in this, whatever way the request has to come, it should be asked to go to the next level. The other dimension is that North-South standards are harmonised. If 40% of the North’s product emanates from the South, this must have an impact on its processing industry.

Mr. Martin Higgins

When we refer to food safety concerns, we are referring to microbiological and toxicological issues. We distinguish between labelling and traceability in that regard.

Our research shows there is an increasing awareness among consumers, particularly in the South, of country of origin. This concern is heightened in the South, more so than in Northern Ireland. As we have seen in the review of the pork industry, there can be confusion. Much raw pork is imported into Ireland and the majority is processed and re-exported. The issue of substantial transformation and where the products come from is one we are examining. Our next consumer focus review will deal with this issue, food miles and so forth. We expect it to be completed in the next few months.

We need to differentiate between quality and safety. They can be different. Many of the quality assurance schemes in place relate to good animal husbandry and so forth which can have an effect on food safety. Very often it has to do with the quality of the product, not necessarily safety.

Mr. John Dardis

Deputy Doyle has raised an important issue about labelling, on which there was a detailed discussion recently at a board meeting. It was pointed out to us that while we had a detailed discussion, there was not much we could do about it. Even for the North-South Ministerial Council to intervene would be difficult. There are also other bodies which deal with these matters and we do not want to overcrowd the field. That is not to say the matter is not important. As stated by Mr. Higgins, if a product from South America is imported into Ireland and processed here, it becomes an Irish product. This is a serious issue. It is like the difference between Irish smoked salmon and smoked Irish salmon. Perhaps the committee could add this to its report or tackle the Minister on it. Country of origin is a serious issue.

Has safefood a role in drawing up food standards law? Does it test any products? What input did it have in dealing with the recent pork debacle? What is the agency’s defined role? Is it involved in food promotion within the country only?

Mr. John Dardis

Yes, it promotes food on the island only.

Mr. Martin Higgins

When the pork issue emerged, the chairman and I had discussions, as we were required to do. There is a requirement that the two jurisdictional enforcement bodies, the Food Standards Agency and the Food Safety Authority of Ireland, inform us when an issue emerges that will have implications in the other jurisdiction. Protocols are in place as to how the two bodies communicate with each other. We were briefed before the issue became public. We discussed it and considered there was little point in yet another body getting involved in communicating with the public. We offered assistance to the Food Safety Authority of Ireland in making our helpline available to take telephone calls from consumers. The Food Safety Authority of Ireland had issued a 1800 telephone number. It would have confused issues by having another one. We had callers to our helpline and gave the same information, on which we had been briefed by the Food Safety Authority of Ireland.

Not only is Dr. James McIntosh an expert in toxicology but he also has previous experience with the Department of Agriculture, Fisheries and Food. His expertise was made available to colleagues in other bodies.

Our main remit is, in the long term, to create confidence in the food we eat and promote a healthy diet and good food safety practice in the home and at retail level. The primary interface between the regulatory authorities and the industry tends to be at regulatory level. They are the enforcers of food law. We are prevented from becoming involved in this area by our establishing legislation. It would also make no sense for yet another body to be involved in the industry. We concentrate on promotion for the retail sector and consumers. We have an arrangement with the Food Safety Authority of Ireland that ensures it does not become involved in consumer promotion. Our main message on hygiene is cook, clean, chill and separate, as well as ensure healthy eating.

An Bord Snip Nua comes to mind.

Mr. John Dardis

That will be the members' decision, not ours.

I thank everybody for coming, for their very comprehensive presentation and answering questions. We wish the delegation well in its role and note that it is doing a very good job in promoting food safety, which is very important. As we know, obesity, especially in young people, is a serious problem. Perhaps the delegation might attend the committee again at a later date.

The sitting is suspended until 2.30 p.m. When we resume, we will have representatives of the Irish Grain and Feed Association before us.

Sitting suspended at 12.05 p.m. and resumed at 2.30 p.m.

We will resume the debate. This is our fourth day of hearings. We have had two sessions some days. I welcome Ms Deirdre Webb, director, Irish Grain and Feed Association; Dr. Pat Shiels, general manager, Lakelands; Mr. Seamus Greene, quality manager, Glanbia; and Mr. Michael Ennis, nutritionist, A.W. Ennis. I thank them for accepting our invitation. Prior to calling on the witnesses to make their presentation I want to draw to their attention the fact that members of the committee have absolute privilege but the same privilege does not apply to witnesses appearing before the committee. Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official by name or in such a way as to make him or her identifiable. I understand Dr. Shiels will begin the presentation and Mr. Ennis and Mr. Greene will also speak. They are all welcome and I wish to give a good Kells welcome to my friend from Kells, Mr. Ennis.

Dr. Pat Shiels

I thank the Chairman and members of the committee. Copies of our presentation document are available. I will give an introduction and Mr. Ennis will speak on the legislation as it pertains here at present and what we are doing in this regard. My other colleague, Mr. Greene, will speak about other assurance schemes which the industry also operates. I will then summarise at the end. I wish to bring members' attention to one technical matter which is that the reference on page 2 to Regulation 185/2005 should read Regulation 183/2005.

We thank the committee for the opportunity to outline the monitoring and safety systems under which our members operate. It is important to point out whom we represent and who are our members. The Irish Grain and Feed Association, IGFA, is the representative body for the Irish grain and feed industry. Among our members are 37 compound feed manufacturers producing more than 90% of the 3.5 million tonnes of animal feed manufactured in the country annually. We also have five importer members who import 3 million tonnes of feed ingredients which represents all feed ingredient imports, and ten grain members who handle 80% of the domestic grain crop grown here.

Our association is voluntary and while we represent most of the compound trade, all of the import trade and most of the grain trade, we accept that a number of feed operators are not members of our association and that up to 1 million tonnes of feed is home-mixed on farms with which we have no involvement and on which we cannot comment.

The Irish Grain and Feed Association, IGFA, attaches enormous priority to feed safety. Our members work diligently to ensure their businesses and those of our customers, be they in the processing industry or supermarkets, meet and exceed all requirements of the feed hygiene legislation to which we operate. Our safety control systems are underpinned by complete traceability of all ingredients and finished products. My colleagues may refer to audits and in these our members are asked to select a load of feed or raw materials and are requested to provide documentation from the place it originated, through the ship and lorry and onto all of the farms to which it went. This is a standard in our industry which is expected and delivered upon.

Turning to the issue of the day, the feed at the centre of the recent crisis came from a food recycler operating to a much lower level of regulatory control than our members. While we were shocked, disappointed and unhappy about this, we believe that any report on this crisis will fail the consumer and the industry in general if it does not look beyond this operator and his practices and include all components of and partners in the feed and food chain. We want to outline our views. I will now hand over to Mr. Michael Ennis who will go through the European legislation to which we operate and provide the committee with details on what is involved from the point of view of a feed operator.

Mr. Michael Ennis

I thank the Chairman and I will deal with the official approval and registration system under Regulation 183/2005. Under the regulations all feed business operators are required to register with the Department of Agriculture, Fisheries and Food. At present, only commercial feed manufacturers which manufacture 3.5 million tonnes output per annum and home mixers which use certain additives must undergo a full approval process. In addition, a company producing medicated feed must also hold a separate licence granted by the veterinary division of the Department of Agriculture, Fisheries and Food. This licence also necessitates a full target audit by veterinary personnel. Therefore, mills producing medicated feed have to cope with two separate full audits and inspection burdens.

The approval audit for the manufacture of feed covers such areas as procedure monitoring, traceability, quality control, HACCP plans, purchasing, sampling raw materials, formulating, distributing, labelling, weighing, grinding, mixing, storing, cubing or pelleting, heat treating, drying, medicating, dispensing, sampling of finished product, screening, loading, selling and advising, managing people, plant and products, recording, rejecting, temperature recording, weight recording, filtering of air, managing steam and flushings, bird and rodent controls and monitoring bacteria. All these activities fall under our licence remit and these are monitored by the Department of Agriculture, Fisheries and Food, DAFF, formally and informally on a regular basis.

Yearly visits and audits take place and on average a feed mill may have up to eight visits per year. One visit will be for a full audit which involves a full day audit of all the areas listed above and generally involves two DAFF personnel and two people from the company. In addition, we undergo a minimum of three unannounced inspections per year. The rest of the visits may be announced or unannounced and are primarily to collect samples and randomly check records and labels. The DAFF veterinary section audits the medication licence annually and also audits monogastric mills an average of five to seven times a year, focussing on salmonella control procedures.

At present, the majority of companies also have an annual audit by at least one independent quality assurance company. In the case of the plant where I work, we are audited by the egg quality feed assurance scheme and by the British egg quality assurance scheme, BEIC, and the Lion Code Egg Marketing Body in the UK. We are also audited by the Tesco feed assurance scheme to ensure compliance with its feed standards which include statements in our HACCP scheme on the grade and quality of oils and lubricants used in the process. These independent audits take at least one working day to complete and each scheme can cost approximately €5,000 to administer.

As a professional with more than 43 years experience in feed safety, I cannot accept that any waste food recycling business can be classified as a low-risk operation while the feed industry is classified as high risk.

Mr. Seamus Greene

I will speak about assurance schemes in the animal feed industry. These are add-ons to the legislation outlined by Mr. Ennis. The assurance schemes operated by members of IGFA are integrated food safety schemes and are voluntary and in addition to current food and feed safety legislation. The schemes are updated regularly to reflect market demands, regulatory changes and emerging risks and, in conjunction with official controls, provide for a robust and effective control mechanism. Safety and quality control systems operated by feed compounders who are members of IGFA are based on the following six critical platforms: good manufacturing practice; hazard analysis critical control point safety systems, HACCP; traceability; independent certification; EN 45011 accreditation; and training.

The universal feed assurance scheme UFAS which is called IFAS in Ireland, was adopted by members of IGFA in 2002 and is the scheme operated by Irish feed manufacturers and by importers of feed ingredients. The scheme is HACCP-based with a firm focus on traceability. The twin drivers are feed safety and regulatory compliance. Assured feed mills have to clearly demonstrate risk assessment procedures. A critical component is the requirement to purchase from suppliers that are approved to an equivalent integrated standard, such as FEMAS.

The core UFAS standards were written and are updated by people who are actively engaged in the industry. Audits are conducted by qualified people with a background and expertise in the industry and the scheme is run by a global certification and inspection company. Under the scheme, the feed supply chain is broken down into its key components — feed manufacturers, feed material producers, stores, shippers, importers, traders, transport and laboratories. Each component understands our safety requirements and is encouraged to develop equivalent schemes. This ensures effective communication from each component on safety and quality.

Some of the critical requirements of the scheme are as follows. All UFAS-registered mills can only source feed materials from an assured supplier registered by the Department of Agriculture, Fisheries and Food. The Irish grain assurance scheme, IGAS, is the recognised scheme for cereals in Ireland. It covers growing, handling, storage and transport of grain. All Irish grain entering a UFAS mill has an IGAS number. An importer, trader, broker or merchant selling a product must ensure that the product complies with EU and national legislation on feed safety. We ask that the committee, when considering its report, give priority to the issue of feed safety throughout the feed chain.

Hauliers are signed up to the TASCC code of practice for road haulage. This code is based on HACCP principles and provides haulage exclusion and sensitive lists. Loads carried and cleaning records are maintained and inspected. The scheme is certified to EN 45011, thereby providing customers with complete reassurance that the feed product is produced to a European recognised standard and is fit for the purpose for which it is intended.

Assurance schemes are increasingly becoming a necessary part of modern feed production. The schemes focus on areas that are likely food safety risks and ensure controls are put in place to deal with these risks. They assist in complying with EU and national feed regulations. We can never guarantee that we have removed all risk from the feed chain. However, we can demonstrate to our customers and the authorities that we have made every effort to manage these risks. Can all stakeholders in the food chain demonstrate this level of feed safety? These schemes are not there to replace legislation but should at the very least be a clear indicator of the willingness of stakeholders to comply with legislation.

Dr. Pat Shiels

It is clear that the industry and association members are well regulated and take their responsibilities seriously. We will continue to work with the authorities, both in Ireland and in Brussels, to ensure our industry continues to deliver on its commitments. By comparison, a plant simply blending feed without adding additives or a large home mixer or food recycler is required to go through a simple registration process as a feed manufacturer under the feed hygiene regulations. These plants can then operate under a much less robust control system, having at most one inspection per year in comparison with the ten to which Mr. Ennis referred.

We ask that the committee, when considering its report, gives priority to the issue of feed safety throughout the feed chain. To this end we recommend that the approval system for all feed manufacturers, home mixers and suppliers be risk based. The inspection and monitoring process should be rebalanced towards monitoring for emerging and real food safety risks across all the chain. HACCP systems need to be promoted across all sectors of the industry in accordance with the legislation, and the food processing industry must promote and encourage best practice within its purchasing policies.

I welcome the Irish Grain and Feed Association to the meeting. We are charged with reporting on this issue and determining how contamination can be avoided in the future by improving the current systems. Dr. Shiels said the approval system for all feed manufacturers, home mixers and suppliers should be risk based. There will be no difference of opinion on that point from committee members. However, at the heart of the matter is the question of what poses risk. The Department of Agriculture, Fisheries and Food considered the feed chain in general — not just the plant in Carlow — as low risk. I appreciate that there are differences in the inspection regime which IGFA members undergo but, in his professional capacity, can Dr. Shiels say the operation in Carlow and similar plants around the country are high-risk operations?

Mr. Ennis said the Tesco feed assurance scheme audit required a statement under the HACCP scheme relating to the grade and quality of oils and lubricants used in the process. The oils used in the Carlow plant to generate the heat to dry the feed were the source of the contamination. Under the HACCP obligations for Tesco, do IGFA members test their oils for dioxins? In Belgium, oils were added directly to the feed but oils used for heating were not considered to be a risk. Evidence of previous witnesses to this committee suggests fumes from the oil, which had been contaminated with PCBs, came into contact with the product. These producers are competitors of IGFA in the pig sector and the enterprise is low margin, but does Dr. Shiels believe it is appropriate to recycle feed which has passed its sell-by date? Is that a legitimate enterprise in the opinion of the delegates? Is it a high-risk approach and, under the HACCP requirements relating to Tesco, do the delegates test oils for dioxin contamination?

I will take two speakers at a time and now call on Deputy Eamon Scanlon.

I thank the Irish Grain and Feed Association representatives for the presentation. I was interested to read that the association receives up to eight inspection visits per year. A full day was spent with two Department officials and other inspections took place in the human food chain section. I see that the egg marketing bodies in England and Ireland were involved, along with Tesco. I fully agree with the statement made by Mr. Ennis. The people in this industry are using natural ingredients like grain yet they receive far more inspections than people involved in the human food waste recycling business, which may have only received one inspection — it received no inspections in 2008. One might compare this system to the other one relating to recycling. Human food waste may be seen as low risk but the processing of it is a high-risk activity and lessons should be learned from past experience. If the same inspection system applied to it that applies to the delegates' industry I do not think we would have had the problems that we have had in recent times.

I will call on Dr. Shiels and encourage him to allow any of his colleagues to contribute, if necessary.

Dr. Pat Shiels

The background to the comment that this should be risk-based is that at the moment businesses are approved depending on what they do. As I said, one is either registered or approved. A relatively simple feed business that does not include additives and minerals will go through a registration process. However, there will have been no risk assessment of the raw materials or process used in that business. My point is, at the moment one falls into either a registration or approval category, depending on one's type of business. It does not depend on the risks associated with one's type of business. We feel that the simple categorisation of feed safety is insufficient. The nature of the food recycling business means it requires registration, not full approval. There is little risk assessment carried out in such businesses.

Is Dr. Shiels implying that it is a high-risk business?

Dr. Pat Shiels

I am not saying that as we have our own views on what constitutes a high-risk business. We believe that food waste products in themselves may not pose a risk, though often they are high-moisture, perishable products that we believe may pose a risk in terms of storage and stability. We believe that the process must also be assessed for risk.

The members are asking whether it is a high-risk business but we are not in a position to answer that because we have not examined it in that way. We believe, however, that the simple classification system that dictates that some businesses must be merely registered while others must go through an approval process is incorrect. We believe that both types of business should be assessed for risk in terms of raw materials, their source and the processes involved. After that assessment is completed one could decide whether a simple registration process or approval is needed. This is the issue; we are not saying any specific business is high-risk. The categorisation system is too simple and risk assessment is not carried out. As feed manufacturers, we include minerals in all of our feed and automatically fall into a high-risk category that requires approval. Approval is a complex process that includes the issues Mr. Ennis has outlined. Registration is a simple process that may or may not include one audit per annum.

Home mixing at farm level is the very same business. Farmers who make their feed at home are classified as simple, low-risk businesses. We will not comment on whether this is the case; our point relates to the system of classification that makes them registered businesses, rather than approved businesses. We are not necessarily judging the risk involved; we are saying the process of risk assessment must be changed.

Regarding oils, under UFAS, the voluntary scheme that our members have joined, one is required to have food grade oils in one's plant, and in most milling processes grease or an oil-based product would be the main lubricant.

Is that added to the product?

Dr. Pat Shiels

No. One puts grease in a bearing. If one has a conveyor one must have a bearing and one must grease it. One must use feed grade grease in a bearing.

What about pelleting?

Dr. Pat Shiels

We add edible vegetable oils to increase the oil levels.

Will that grease have contact with the food?

Dr. Pat Shiels

No.

It is only grease for the machine.

Dr. Pat Shiels

Yes. The other issue relating to the whole industry is the grain drying process. As Mr. Greene said, all of our members operate to UFAS and buy their grain from IGAS-approved growers. IGAS has a code of practice with a list of requirements that covers the growing, harvesting, drying, storing and transport of grain. The code of practice ensures a dryer is compliant, that it operates to current standards and uses appropriate fuel.

The appropriate fuel issue is of great relevance to the Carlow plant. It is under investigation but I assume that plant was not testing the oils used to generate heat. As grain drying is important to members of the Irish Grain and Feed Association, is this an area of risk that needs to be reviewed, in terms of testing oils? The oil in question was blended and supplied illegally but, notwithstanding this, people buy oil in good faith. I buy oil for home heating and do not test it — I assume it is what it says on the tin. Is it too much to have expected the association or the plant in Carlow to have tested the oil that was bought in good faith? The business in question did not contaminate the product, recycled human food, and nor did the delegates' business of drying grain. Are the delegates conducting tests or is it the case that until now they did not test but will in future?

Dr. Pat Shiels

In risk assessment, as part of that process, one tests grain sporadically. Not every load of grain that comes out of the plant is tested. All of our grain dryers use diesel and are required to run efficiently under the code of practice; they must be checked and signed off on.

Is the product tested?

Dr. Pat Shiels

Grain samples at the other end are tested.

It emerged that even if the Department had tested the plant in Carlow repeatedly it would not have conducted the appropriate dioxin test. The problem was only discovered through a residue monitoring testing system on the carcass. Is the association testing for dioxin contamination?

Dr. Pat Shiels

Under UFAS we test for a number of undesirable things and tests for dioxins are carried out sporadically. The plant in Carlow should have done the same.

The fumes from the heating system in one's house do not go through every room. Deputy Scanlon spoke on this matter earlier and might put a question more clearly.

When the delegates dry grain, does the naked flame come in contact with it or are only dryers involved?

Mr. Michael Ennis

Hot air is used.

The hot air is generated outside in the big boiler, I am sure.

Mr. Michael Ennis

Yes.

What I cannot understand is how fumes from a boiler outside could come in contact with the recycling product or the bread that was used, as happened in Carlow. I have asked this question on a number of occasions. I do not care what anyone is burning. They could be burning turf in a boiler outside.

Mr. Michael Ennis

We only heard this morning exactly what process was carried out at the plant. There is a rotary kiln drier. This is a very large barrel, perhaps 5 ft. in diameter and 20 ft. long. At one end there is a burner, which burns fuel right through the barrel and heats up the barrel to a certain temperature. The moist feed comes in at the other end. The barrel has lifters in it, and the feed goes around and dries as it comes down the barrel towards the flame. Just before the flame itself there is an outlet, and the product drops onto a conveyor. Effectively, all the fumes from the flame go down the barrel to meet the approaching feed. That is the difference between feed compounding and the particular process involved here. There are no naked flames in feed compounding——

I know that.

Mr. Michael Ennis

——because the process is steam generated. In heat treatment and pelleting, steam is used to generate heat. It is only in a boiler that oil actually burns. It is steam that circulates through a mill. That is the difference between the two processes.

Were there more questions from Deputy Scanlon, or were they all included?

Dr. Pat Shiels

The other question was about the product versus the processing, and we have sorted that out.

I will be brief. I welcome the deputation and thank them for outlining what they do. I see this as an opportunity for them, which they have seized with both hands. Fair play to them. I congratulate them on that.

When the representatives of the Department of Agriculture, Fisheries and Food came before the committee I asked one specific question, because I have some insight into the HACCP programme. I felt there was a lot of buck-passing regarding the residual monitoring programme and so on. A Department official did state, after I asked him on several occasions, that he felt one inspection per annum in a low-risk facility — as Deputy Creed said — in Carlow was sufficient. Would the witnesses contradict that?

The official also stated that it was only a visual inspection and that one did not take place in 2008. I had to ask several times how we could incorporate the testing of oils as part of the HACCP programme. The officials admitted that before now the testing of oils for contaminants was not part of any HACCP programme. I asked the official, if he had two barrels of oil, whether he could tell the contaminated oil from the non-contaminated oil, and his answer was "No". How could the person running the processing plant in Carlow have identified the contamination without testing? It must be pointed out that there was no testing prior to this. In the food industry, the EHOs are very quick to point out the hazards and the critical control points, and they must be monitored on a daily basis, but the testing of oils was not part of any HACCP programme that I have seen. I do not think it was a prerequisite for the person running the establishment in Carlow to test oils.

I would go so far as to say "We are what we eat". For this reason, all processing and manufacturing plants such as the one under discussion are high risk. The Department stated that one inspection per annum was adequate but I totally disagree. The difference between registration and approval was mentioned. This is a grey area. We are talking about a licensing programme or format. I imagine registration costs a lot more than it does to acquire approval. The people represented by the witnesses are the big boys and they require registration.

Ms Deirdre Webb

No.

The witnesses can come back to me on this. That is my understanding of the situation, but perhaps they would clarify it for me. I appreciate that the big boys go through a much more stringent process in terms of monitoring and so on, and I agree with that, but the small operator who receives approval should go through the same monitoring procedures. I fervently believe this. It is a high-risk area because we are what we eat.

I thank the representatives of the Irish Grain and Feed Association for their presentation and for coming here to explain things to us. We expected they would be able to account for themselves and they are handling themselves very well.

The witnesses stated that there were 37 compound feed manufacturers in their industry. Do they have any idea how many compound feed manufacturers are in the country overall? It will be hard to get a handle on the industry and to regulate it properly if there are many such manufacturers. I believe there are many people involved in the pig industry, especially the bigger units that manufacture their own compound feed. I can see why this has to be the case. They are in an industry in which the profit margins are tight and, in many cases, they are working below profit. This is hard to sustain for any period of time. Therein lies part of the problem in trying to regulate the feed business. When one has so many players out there trying to do the best for themselves, they will try to produce feedstuffs at the lowest possible cost. That is understandable.

The witnesses have answered a question today which was baffling all of us up to now. Deputy Scanlon was the person who raised it on several occasions. It is now quite obvious where the problem arose in this instance. The system is completely different to that used for drying grain. It adds clarity to the situation. I find it hard to believe there would be any risk attached to the recycling of human food products. It is the methods used that constitute the risk. If something is good enough for us to eat, it is hard for me to believe, as a lay person — the witnesses are the experts in this area — that if it is recycled properly it is not good enough to go into animal feed. Feed production and manufacturing is an important part of the chain. We must have a level playing field for everybody because it is hard to control or regulate the sector when there are so many manufacturers, especially if they are not all under one umbrella or not working together in the same manner. As Deputy Sheahan said, there must be the same checks and balances for everybody involved. I might return to this matter later.

Dr. Pat Shiels

I will respond first to Deputy Sheahan who asked if we considered it was sufficient to make one inspection visit per annum. I reiterate that we do not know much about the plant in question; therefore, we cannot comment on it specifically. We believe the system under which there was one visit per annum to the plant, simply by reason of the way it operated, rather than a risk assessment, is wrong. A risk assessment would have placed the plant in a high risk category. That may be discovered as a result of this inquiry. We will see what will happen.

On the testing of the oils, it is important for us to clarify that in our business the only time a mineral oil is used directly is in the grain drying process. Diesel oil and gas are the two products used in all drying plants. They are totally acceptable for the job in hand. The Irish grain assurance scheme, IGAS, ensures a manufacturer uses them.

A second point is that the drier should work efficiently. That, in itself, is a policed programme. The IGAS is policed by a group called Cropsure which visits farmers and merchants to inspect the process used against the code of practice in place. That should take care of that side of the equation, provided the system is policed, which it is. Our view is that inspection ensures operators use the proper fuel oil. It will be cross-referenced at the other end by feed testing, as distinct from oil testing. That is the way we have always operated, by using the correct raw material and checking the finished product. It is interesting that the operator involved was producing a product that could have been used as an ingredient for the feed trade.

Prior to this, if checks were being made regularly at the plant, would the oil have been checked?

Dr. Pat Shiels

The feed would have been checked. If the operator is approved, there is also legislation on undesirable ingredients. Eventually the material would have come in for dioxin testing.

On that point, although tests were conducted, at no stage was the appropriate test done to identify dioxin contamination at the plant or among its customers. The dioxin contamination was identified in a carcass when a post mortem was done under the national residue monitoring programme. If we want to learn from this incident, the question is whether we should test for dioxins in the samples taken from the IGFA grain driers or the operators. That question also arises from delegates' direct experience.

Mr. Seamus Greene

To return to the issue of feed safety, the system must be risk assessed.

The source of oil is critical. One does not go to a fly by night operator for it. We use Exxon Mobil and have the material safety data sheets and everything else associated with the oil we use. We use natural gas in certain plants. First, one must make a risk assessment of all the products in the system, including oil, which should be sourced from an assured and reputable supplier. If a person has to fill the home heating oil tank, he or she does not ask a man who comes to the house to fill it with some unidentified oil. One goes to a reputable supplier. Second, Dr. Shiels has mentioned that the most important point about grain driers is that the burners should be checked and serviced regularly in order that the oil burns with 100% efficiency. That is essential. The burners are checked regularly during the harvesting period at which stage dates are also recorded. Third, with regard to final verification from a risk assessment and HACCP point of view, one checks the finished product, namely, the grain, for PCBs.

Waste oil should not be used in any burner.

Mr. Seamus Greene

The burners are made fit for purpose in grain drying. They are made for marked diesel oil or gas.

We understand waste oil was used. We do not know for sure but that is what is said.

Where is the grain tested for dioxins or PCBs? I imagine a sample would not be taken from every load.

Mr. Seamus Greene

Testing is done outside the country. We send a sample away. A composite is made during drying in the facility.

The IFSA has many suppliers and represents many individuals.

Mr. Seamus Greene

We have our own site — Glanbia — which supplies us directly.

How many tests are carried out during the year?

Mr. Seamus Greene

In general, we do approximately 25,000 tests on our feed systems. That figure includes tests for undesirable substances such as PCBs and micro-toxins and salmonella. Tests for pesticides are included. It is done on a risk basis.

I wondered about that——

The Deputy is coming in all the time.

I will finish. In previous presentations we were told about the cost of doing these tests. However, I find the figure of 25,000 tests striking, considering the high cost of testing for toxins and PCBs. Fair play to the IFGA if it does 25,000 tests.

Mr. Seamus Greene

Yes; we test feed for a variety of substances.

Dr. Pat Shiels

There is one other point. The man whose plant has been implicated was producing a product which we, as feed millers, possibly might have used. Under the universal feed assurance scheme, UFAS, we are required to buy from a food material assurance scheme, FEMAS, assured supplier. We could not have bought from this plant had we wished to do so because the individual in question had not gone through an approval process. All of our suppliers are FEMAS approved. That is the international standard in supplying raw materials under the universal feed assurance scheme. That is an aside but worth noting.

Do the delegates believe this product should be incinerated rather than used in the food chain?

Dr. Pat Shiels

I am not sure. We do not know because we do not use these products. We do not know which products are involved. We have heard about bread, bakery waste and a number of ingredients. We understand some are high moisture, perishable products. In that case the process used becomes more of an issue than the product because there is a risk of moulds, micro-toxins, etc, of which we are conscious. I do not believe we are in a position to make that call.

We must be careful. I was raised on a farm and for years we have been recyling human food. There is no problem with pigs eating this food. This incident involved the process used to dry the food in question. There is nothing wrong with recycling food.

Deputy O'Sullivan asked a relevant question.

What is the cost of being approved?

Dr. Pat Shiels

The initial cost is probably in the order of €1,500 to €2,000. There is the ongoing cost of an annual audit by the Department. The separate assurance schemes, as mentioned by Mr. Greene, cost approximately €5,000 per annum to operate.

Dr. Pat Shiels

Yes. Before the feed hygiene legislation and approval process was introduced, we operated under the 1967 licensing legislation. To be fair, that was probably out of date and it did not meet some of the requirements of our customers. We examined and followed the universal feed assurance scheme, UFAS, requirements because our customers, whether Tesco or whoever, required that of us. They needed to be able to say to that we had UFAS approval for the broiler process. We went down that road and agreed that the system in place was not good enough and that we must take action. That is where the change originally came from. It is voluntary at this stage.

Mr. Seamus Greene

Obviously, feed safety can never be compromised. Personnel on-site are involved and watching the process.

Mr. Michael Ennis

Since the company was new, it probably did not have sufficient experience to know exactly the consequences of its actions. Let us consider the feed industry in which we are involved. We have many years of experience and have known of four or five dioxin problems in the industry in the past 20 to 25 years. One of the most well known instances involved citrus pulp brought into the country which contained dioxins. We are all familiar with what occurred. It was from the exhaust of direct flame in the drying process of the citrus pulp in South America. The producers were faced with problems of margins at the time and recycled much of the exhaust through the system and contaminated the citrus pulp. That incident will stick in our minds and when using direct drying systems, what one should be aware of is exactly that. We would set up hazard analysis and critical control point, HACCP arrangements to deal with the type of oil and the capacity of the burner in question. It is not something which only happened here for the first time. It has happened in several places in the world.

Have all the questions been addressed?

My opening question concerned the number involved in the business. A figure of 37 was mentioned. Does the delegation have any idea how many are involved?

Dr. Pat Shiels

There are 57 feed manufacturers in the country. We have 37 members and represent approximately 90% of the tonnage. The other 20 operators are reasonably small in comparison. A member referred to home mixing. We estimate there are probably 300,000 tonnes of pig feed manufactured on a home-mix basis. All such manufacturers are approved and it is similar to the process involving a mill, because minerals are added. They have gone through that process, but there are a further 600,000 or 700,000 tonnes of remnant feed manufactured and used on remnant farms, which are registered.

In his presentation, Dr. Sheils stated that he believed any report on the crisis would fail the consumer and the industry if it did not look beyond the operator in question and his practices and include all components of the feed chain. Is that a reference to the other 20 operators?

Dr. Pat Shiels

No, not necessarily. They are licensed operators and are approved by the Department. As far as I am concerned, they are all approved. I was referring to due process in the way they are described, whether they are registered or approved, the associated risk assessment and what is taking place in the farm and at the processing stage. We believe this should be processor-pulled to a certain extent. We believe any response should involve the approval and monitoring of everyone in the industry against a standard, which is fair and appropriate for the process involved. We believe that process should take place from A to Z. At present, if one is operating in this way, one is categorised in a certain way and if one is operating in another way one is categorised differently, which we believe is incorrect. The on-farm aspect has not been properly examined and we must see what can be done at processor level to begin to pull this forward.

Let us consider the production of beef, poultry, pigs, eggs and dairy in the UK. Some 70% or 80% of product is produced under an insurance scheme which has at its core what happens with feed. The industry in the UK is an example of one which is at a stage some ten years further down the road. We have a national beef assurance scheme which has only a very minor reference to feed.

It is bad manners for the Chairman to speak when others are waiting to contribute, but does the delegation know if there are many other companies using the same practices as the company in County Carlow?

Dr. Pat Shiels

We do not know. We heard from the Department that there are only a small number of such companies. Nor do we know the range of products involved or what they were handling.

Earlier, it was suggested that we should visit the company in County Carlow. The clerk to the committee is in contact with the company and it is possible we will not be allowed to enter. However, if we were to go to County Carlow to examine the premises, would it be possible to visit a premises associated with the delegation in the locality?

There is one such premises in Kilkenny which is part of the association and there are only two relevant premises.

If we were going to——

Some people here used to be involved in the pig processing business.

Will that trip involve the committee?

Were the inspections carried out by the Department notified inspections?

I welcome the delegation. It is very obvious from the debate that there is a need for national standards and legislation. Nothing that is voluntary works very well. Regulation should incorporate all processes. Legislation is necessary, because there has been disarray since the BSE crisis, which was the first time any changes were made to legislation and standards in substitute feeding. The Department must move on this matter. I will put it to the Minister next week that there must be national standards and legislation to incorporate all levels of the industry. Such a move will give assurance to the consumer, producers and the industry.

The delegation referred to imports. A substantial percentage of imports involve protein substitutes, protein, carbohydrate feeds and so on. What tests are carried out on these products? Compound feed is imported from Northern Ireland. Is that subject to testing? What standards are in place?

I am not impressed by the reference to Tesco. There would be no pig, egg or poultry industry in Ireland if Tesco had its way, because it sources such products from the cheapest parts of the world, namely, the Far East and South America. That is the bottom line.

I refer to pelleting. What heating is used in the manufacturing process of cubes? Is oil used? What kind of bonding is used? Does the process involve molasses or what substitutes are used? I refer to oil burning. Many changes have come about in recent decades to reduce the cost of burning oil. There is a good deal of on-site grain storage and drying in farms. I understand new technology has been developed in the UK to dry grain, whereby the exhaust pipe is channelled back into the grain sending dioxins to the product. If the technology is known in that part of the world, then I have no doubt the good news has spread here also.

Dr. Shiels mentioned reputable oil distributors. Outsourcing is now common practice and we have numerous agencies distributing oil. A constituent recently complained to me about smuts and, possibly, dioxins in paraffin. I had the paraffin tested at a university and it was found to contain traces of diesel. It was discovered that there were traces of diesel in the pipe carrying the paraffin to the householder's storage tank and this was contaminating the paraffin. The supplier was not properly cleaning his pipe between deliveries. We must be careful that regulations are adhered to.

Diet wagons are now used to reduce costs at beef and dairy farm level. Beef and dairy farming are low profit margin businesses. Milk prices are expected to go under a euro this year and pig prices are falling. People are frightened.

Will the programme for Government not do something about that?

We will discuss that another day.

As a public representative, in other positions and in a private capacity, I have seen the pig industry throughout the world. The pig and beef industries throughout the world depend on substitute feed. Denmark, which has approximately 23 million pigs and is the model for the pig industry, depends on fish oil, fish offal, some dairy product, barley and soya. The pig industry in Holland uses almost 80% substitute feed. In Ireland, we have a very high cost pig feed base and pig producers have survived on low profit margins. If substitute feed is removed from farming diets we will soon have no pigs in the country. We must get the substitute feed part of the business right and put the necessary technology in place. I do not know what happened in the Kilkenny plant. However, in South America, I saw huge numbers of pigs being fed tomatoes, sugar cane and other mixes.

I do not want to mention what goes on in the poultry industry in the Far East, where much unpalatable substitute feed is used. I have a piece of paper in my briefcase on this subject. In Ireland, we have been very conscious of food safety because we export much of our product. For that reason we must keep our product right while also keeping our cost base right. We must recognise the need for substitute feeding.

In the northern part of the country, pig production is based in dairy farming areas of Cavan and Monaghan and pigs are fed on whey, butter oil and buttermilk. In the southern part, the biggest concentration of pig production is in dairy farming areas. West Cork once had the biggest concentration of pigs in the country. Pig farming in my area is built around dairy substitutes but dairy farming is moving on. There is need for change. It is clear from what has been said this afternoon that we must legislate and put standards in place to protect the industry and consumers. Voluntary codes of practice can work. However, the representatives of the Irish Grain and Feed Association have told us they do not represent all grain producers. Legislation would apply to everyone.

Recent events have been a huge cost to the pig industry. More important, they have affected the reputation of Ireland, which has probably replaced Belgium as the dioxin capital of the world.

Dr. Pat Shiels

Deputy O'Keeffe mentioned voluntary codes of practice. There is legislation dealing with registration or approval. There is a basic legal requirement for all operators in the business. It is Regulation 183 of 2005. We have issues about how the legislation describes people but, nonetheless, it is there and is being operated. The voluntary scheme is in addition to that.

Ms Deirdre Webb

The legislation, in Articles 21 and 22, lays out the codes of practice and says they should be promoted and supported on farm by the member state. Within Ireland, the only sector that does not have a code of practice is the home mixing sector.

Is Ms Webb referring to the EU directive?

Ms Deirdre Webb

Yes. We are only missing the home mixing code of practice. Copa-cogeca are considering working on this and I believe there is a code of practice in the United Kingdom. It is all in the legislation. I accept that people are anxious about what has happened. However, existing legislation would be sufficient if it were implemented correctly and evenly.

Farmers involved in home mixing say they are regulated and that inspectors frequently visit their farms and take samples.

Ms Deirdre Webb

Pig home mixers are approved. Other home mixers are registered. The legislation states that to help everyone understand HACCP and the complex issues connected with it, there should be a sensible code of practice. It states that member states should encourage and support the sectors in writing codes of practice. The Irish grain assurance scheme, IGAS, was written by the IFA and IGFA. The Department of Agriculture, Fisheries and Food helped it along but has since withdrawn its support. There is sufficient legislation to solve most of the problems. We need to start from basics. We need a correct risk assessment procedure, a correct approval procedure and robust codes of practice.

Chairman, I wish to ask a question on diet wagons. Keenans is the prominent diet wagon provider and I suggest that we invite them to address the committee. The use of diet wagons is being encouraged as a source of low cost feed. I recently saw a newspaper advertisement for a diet wagon which could be used as a blender. What is the law covering that?

Dr. Pat Shiels

I will put diet wagons on my list of questions to be answered. Another of Deputy O'Keeffe's questions referred to ingredients imported from the rest of the world. They are subject to the same legislation and testing requirements as grain produced in Ireland. There is a testing procedure which is operated by the Department at the point of entry and, sporadically under our codes of practice, at the mill, which is the point of use. He referred to Tesco's safety standards. It is the only company seeking these standards at present and that is why it is on our list. Dunnes Stores is not on our list at present. It may be in the future.

Dunnes Stores has a policy of buying Irish.

Dr. Pat Shiels

It is not asking us to apply certain standards.

We should not name companies or individuals. That is not why we are here.

Dr. Pat Shiels

Our business has a consumer requirement that we are compliant with a code of practice. Tesco sought the information and that is why it is mentioned.

I cannot comment on how oil burners are used to dry grain in the United Kingdom. I can only speak about the IGAS code of practice under which all our members are inspected by CropSure. In the pelleting of feed, it is heated by steam in all cases. There is no direct flame or hot oil.

I will not comment on how oil distributors operate their business. We will concentrate on our own responsibilities. The use of diet wagons and substitute feed is part of the industry and will continue to be so. It needs to be policed. Reference was made to what happens in South America. What has happened in terms of Brazilian beef is a clear example of how limitations in what they are doing can be identified. What we are doing at that level, in terms of beef assurance schemes, allows us to refuse entry. We accept substitute feeding takes place. The question was asked if this was the right thing to do with feed. We cannot comment on that matter except to say that while it will continue to be part of the process, it needs to be controlled equitably.

Dr. Shiels referred to multiples which import chicken, beef and pigmeat from the four corners of the earth, including Brazil, Thailand and Vietnam, which do not enforce standards. A lack of standards in respect of products imported from such parts of the world is forcing Irish farmers out of business. We must ensure products imported from Thailand, Brazil and so on are of a standard equal to that produced in Ireland. I agree wholeheartedly with Dr. Shiels's comments in regard to Brazilian imports. I have no problem with imports provided the playing pitch is level.

We agree totally.

I welcome the delegation from the Irish Grain and Feed Association. As a feeder of bovine and fattened cattle and sucklers, I am reassured by what I have heard today in respect of controls in regard to feed. I welcome that the association has taken samples of feed from the 5,000 manufacturers it represents. It represents a vote of confidence in the type of feed I am feeding my cattle.

This is our fifth meeting with stakeholders in the industry. Up to now we have heard of samples being taken from finished products. I made the point, as did several other people, that we should be examining feed because that is what will be inside the animal when slaughtered. As I understand it, samples are not being properly taken. It has been stated that in Carlow, where this controversy arose, only one inspection took place in 2007 and there was no inspection in 2008.

In all fairness, Deputy, it was stated by Mr. Moran and others that the millers are being tested. Also, meals at farm level are being tested.

The officials stated here that no inspection had been carried out and that even if one had been only the premises would have been inspected. It would not have taken any samples of the dry bread being produced. It is all very fine to inspect premises and to examine how products are being handled but samples were never taken of the product being sent to farms where the contamination occurred. Is our inspection regime good enough? Dr. Shiels made five particular points earlier, which are good. The point I am trying to make is that the same procedures should apply in respect of every person manufacturing food for consumption by animals.

We are told that transmitter oil was used on the premises concerned and that as a result PCBs and dioxins got into the feed. Even if IGFA members used the wrong oil, it would not, given they use a different system, end up in the feed. I am not suggesting IGFA members are using unsuitable oil. However, if they did use contaminated oil it would never get near the feed. It is important to point out that the methodology being used by IGFA members ensures oil does not mix with food.

I presume all of the grain and raw material used by the IGFA is not produced in Ireland and that it imports soya bean, minerals and mixtures etc. Are such imports tested for dioxins and PCBs? Are they tested in finished product form prior to being used as feed? For example, are samples taken of soya bean at import level to ensure the product is dioxin free? It is important that this is being done.

As a producer of cattle, I am reassured that the feed coming from the IGFA factory is of top quality. The five recommendations referred to earlier should be implemented across the board. Perhaps through the enforcement of more regulation we can ensure this type of debacle never happens again.

Can anything be done to bring down the cost of feed?

We are not discussing that matter today.

Perhaps Dr. Shiels will comment on whether it was the method rather than the material used that caused the problem.

Dr. Pat Shiels

We are not sure how many recyclers exist, the range or multitude of products they are handling or the nature of those products. We are in this instance speaking about recycled bread waste which, to some extent, we have to assume is relatively safe. We cannot, however, inherently state that. We must question whether a product is recycled because it is out of date or for another reason. We cannot comment on that matter. Risk assessment would assess each of the products and the process through which they found their way from the backdoor of the food processing company, to which they were surplus, to the animal's mouth. There are two aspects to this: assessment of the product to determine whether it is safe and examination of the process through which it gets from the back door of the bakery and so on to the feeding trough in front of the animal.

That is very reasonable. We are dealing in this instance with bread which was obviously out of date and returned to the supplier. Bread is returned by bakeries every day of the week. Is it reasonable to believe that it was the process rather than the material used that led to the problem in this case?

Dr. Pat Shiels

It is reasonable to assume that. Products coming back from bakeries include recycled dough, a high moisture product which is unstable, liable to perish and to grow moulds. As native grain producers we are asked to ensure there are no moulds or micro-toxins in our grain. Is that an issue?

That is what I am trying to establish.

Dr. Pat Shiels

Both aspects are important.

They use Mars bars and so on.

It is important that we visit the plant to establish what exactly was being used.

They do not use only dough and bread but Mars bars, chocolate and so on.

On a point of information, under what regulation were they inspected?

Ms Deirdre Webb

Regulation 183 of 2005.

Order, please. I call Deputy P.J. Sheehan.

I will be brief. Deputy Edward O'Keeffe, one of the biggest producers in Cork county, knows everything there is to know about pig producing.

As I understand it, the Irish Grain and Feed Association is made up of 37 compound feed manufacturers which produce 90% of the 3.5 million tonnes of our annual animal feed output, which provides reassurance it has this situation well in hand. It has been stated that the feed at the centre of the recent crisis came from a food recycler operating at a much lower level of regulatory control than members of the Irish Grain and Feed Association. The association believes any report on the crisis will fail the consumer and the industry if it does not look beyond this operator and his practices and include all components of the food chain. Dr. Shiels states it is clear that the industry is well regulated and takes its responsibilities seriously and the association will continue on that line to ensure it happens. However, he states by comparison that a plant that simply blends without adding additives or a large home mixer or food recycler is only required to go through a simple registration process as a feed manufacturer under the feed hygiene regulations. These plants can operate under a much less robust control system, having, at most, one inspection each year. I would not be happy with this for these plants as it is insufficient. Is it in the power of the Irish Grain and Feed Association to insist that there be more than one inspection each year and that they are not notified in advance in order that it would be a spot inspection?

Dr. Pat Shiels

That is not in our power. To return to my original point, the decision as to how these plants are inspected is made on the wrong lines. Our view is that risk assessment, if done properly, would change this. We are anxious to point out whom we represent — the Deputy mentioned the figures. We represent one link in the food chain, feed producers, of whom we represent a large proportion but not all.

I asked about sampling imports.

Dr. Pat Shiels

All raw materials are sampled at the point of entry by departmental officials. There are also checks at the point of entry to plants.

Are they random checks?

Dr. Pat Shiels

Yes, they are random checks on importers. These materials are all tested under the undesirable substances section of the Act. A large proportion are tested for spicules and particles on the basis of processed animal protein and previous issues. We have asked that there be a rebalancing of what materials are tested for. This is mentioned among our five end points.

This may be a minor point, but 50 years ago every farmer reared pigs on what used to be called slops, recycled food and waste from the farm. People and pigs were healthy in those days. The message now is that it is wrong to feed pigs recycled human food, but in this case it was the method used to recycle the food that was wrong, not the food itself.

Also, there were very few food imports in those days. Now imported products go into the mix.

People were healthy in the 1950s and 1960s. I remember when farmers used go to the fair in Waterford city to buy one or two pigs to rear each year on slops or waste from the table.

We are what we eat.

One is now breaking the law in doing so.

I understand, but it was done.

Were there any inspections?

The Deputy need not worry. I do not have two pigs in my backyard.

I am sure Deputy Aylward milked cows at home by hand too. I remember as a child drinking warm milk from the bucket while my mother was milking the next cow, and devil the harm it did.

I no longer have the stand; it is gone. Does anybody remember the stand?

Mr. Seamus Greene

On that note, our trucks pass Deputy Aylward's door every day. If they have not called in so far, they definitely will.

They had better come with a smaller truck.

I thank the delegates for coming before the committee and their comprehensive presentation and responses to questions. They have been here before and I am sure will visit again. We thank them for the invitation to attend their annual dinner, but I do not know how many of us will be able to attend. The committee has decided I should go. I am trying to get the clerk to the committee to come, but she may not be available that night. We will see what we can do. We would love to have a representative present if we can and are grateful for the invitation.

The joint committee adjourned at 4.05 p.m. until 10.30 a.m. on Thursday, 22 January 2009.
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