Chapter 3
The policy review process and implementation of the revised policy
Introduction
3.1
Consultation on the proposal to relax Australia's import requirements
for beef and beef product began on 28 July 2009 at a regular meeting of the Red
Meat Market Access Committee (RedMMAC).[1]
Further meetings with other beef industry organisations were held throughout
August, September and October 2009. A round table discussion with health and
medical bodies was held on 28 September 2009. On 29 August 2009, the Department
of Health and Ageing (DOHA) commissioned Professor John Mathews to review the
current scientific evidence on BSE particularly in relation to food and the
flow on implications to human blood, human blood products and other human
therapeutic goods.[2]
Professor Mathews submitted a draft of his report to DOHA on 15 September 2009.
The final report Review of Scientific Evidence to Inform Australian Policy
on Transmissible Spongiform Encephalopathies (TSEs) (the Review) was
released on 9 October 2009.
Scientific review – human health
3.2
Professor Mathews was charged with updating and re-examining the
scientific evidence used to inform Australia's BSE policy since the last review
in 2006.[3]
3.3
The Review made the following conclusions:
- over the last five years the evidence for more effective control
of the global BSE epidemic has strengthened. Passive and active surveillance,
carried out in accordance with World Organisation for Animal Health (OIE)
guidelines and European Community legislation, has shown that numbers of
BSE-affected cattle are falling year by year in all affected countries;
- the amount of BSE-infected material entering the human food chain
in 'controlled BSE risk' countries such as the United Kingdom (UK) is now very
small because of the decline in BSE, the removal of brain and other specified
risk material (SRMs) from carcasses, and the detection and destruction of
infected animals;
- the risk of future food-borne transmissions leading to human vCJD
is very small, if not negligible, even in the UK, where previously the risk was
greatest; and
- the risk to Australians from UK beef imports, if this were
allowed, is found to be a 0.002 per cent chance of a case of vCJD occurring in
the next 50 years.[4]
3.4
The review also noted a number of new understandings and questions
arising from laboratory science, including the possibility of 'carriers' and
advances in risk mitigation methods.
BSE and vCJD carriers
3.5
Experimental models for prion disease have identified circumstances
where BSE infectivity can be 'carried' in an animal for long periods, and
transmitted to others, without the 'carrier' animal ever developing the disease
within the normal life span of the species. The Review observes that such
findings have raised the possibility that there may be a large number of as yet
undetected 'carriers' of vCJD who might transmit the prion to others without
themselves becoming infected with the disease within the usual incubation
period. The Review suggests that as we have not yet seen a secondary peak in
vCJD beginning to emerge in the UK any theoretical risk of disease in
'carriers' could only emerge after a very much longer incubation period, if at
all.[5]
Risk mitigation methods
3.6
The Review refers to animal experiments that suggest it may be possible,
in some circumstances, to partly prevent or delay the onset of prion disease
through immunisation or administering anti-prion antibodies. The Review notes
that there is still some work to be done before trials of such approaches are
justified.[6]
The Review also notes recent scientific advances which allow for more effective
sterilisation of medical and surgical instruments and devices that need to be
re-used after the possibility of contamination with vCJD-infected material.[7]
Risk to Australia from other animal
transmissible spongiform encephalopathies (TSEs)
3.7
The committee received evidence with regard to a range of questions
arising from current scientific research. The following sources of potential
risk were among those drawn to the committee's attention:
- the possible risk to human health posed by other animal TSEs such
as scrapie and chronic wasting disease (CWD);
- the ability for BSE to be passed from cattle into other species;
- the apparent spread of BSE into the UK sheep flock;
- the long incubation period for BSE and the fact that the disease
usually presents after the common age at which cattle are slaughtered for human
consumption,
- that there is no effective live test for BSE, tests are only
accurate in the final stages of the disease or post-mortem, and that tests can
easily produce false negatives in both animals and humans and are rarely
performed; and
- the risk of prions adhering to abattoir or butchering equipment
and being spread accordingly.
3.8
The committee notes the Review concludes that the risk to Australians
from scrapie or for BSE to be transmitted to humans via other pathways is
remote. The Review also states that there is no evidence of CWD in Australian
deer herds and no evidence of transmission to humans in contact with
CWD-infected herds.[8]
Nevertheless, the committee notes the views of submitters that our
understanding of the infection pathways for other TSEs is limited and the risks
are therefore unknown.[9]
The committee notes Professor Mathews' statement that:
In terms of risk analysis—whether we are talking about
scrapie, BSE or variant CJD—coming from the epidemiological tradition, it is
the magnitude and the quantification of risk that is important. I understand
the philosophical principle that, if one can avoid risk entirely, one should.
But there is another philosophical question that says: well, is the risk in Australia totally zero at the moment? And I do not think we need to talk about that today.[10]
Level of risk of BSE entering
Australia
3.9
The committee notes that some of the evidence received in relation to
the level of risk of BSE entering Australia was somewhat contradictory. Both Mr
Stephen McCutcheon, the Chief Executive Officer of Food Standards Australia New
Zealand (FSANZ) and the Minister for Trade, the Hon Simon Crean MP were
prepared to state that Australian consumers could be 100 percent certain that
imported beef products would be BSE free.[11]
In answer to a written question posed by a journalist from The Australian
newspaper, Mr McCutcheon provided the following written response:
6. Will consumers be able to be 100 per cent certain that
imported beef products are BSE free?
Yes. Consumers can be confident that the new policy
arrangements will be underpinned by a rigorous scientific risk assessment
process and robust risk mitigation measures to prevent BSE from entering the
human food chain.[12]
3.10
The committee notes that others appearing before it were prepared to
concede that there is not a zero risk. Mr Greg Brown of the Cattle Council of
Australia told the committee:
Absolutely there is a risk, and we all accept that; that is
the business of trade. But there is an appropriate level of protection. It is
not a zero risk but we are moving towards OIE standards in terms of risk.[13]
3.11
Professor Mathews was also not prepared to claim a zero risk of BSE
entering Australia through imported beef. In his Review report, he stated that:
If Australia were to permit the importation of beef products
from BSE-affected countries such as the UK, there would be a theoretical but
negligible increase in risk of vCJD.[14]
3.12
Professor Mathews explained that 'negligible risk' does not imply zero
risk. He stated:
It simply implies that the risk in question is very small in
comparison with the other risks that people assume in everyday life. An
estimate of the absolute risk to Australia from UK beef imports is quantified
in Table 4 [of the Review report], and found to be 40 million times less than
the risk from road accidents.[15]
3.13
In assessing the potential risk to Australian consumers from beef
imports Professor Mathews based his assumptions and parameters on those used in
recent assessments of risk to the UK food supply. In particular, Professor
Mathews assumes that:
- the quality control on exports
would be at least as good as the beef products for home consumption;
- Australia would import not more
than 10% of its annual supply of beef products from a "controlled"
risk country such as UK;
-
per capita Australian consumption
of beef products could be up to twice as high as in the UK.[16]
3.14
The committee makes the following observations in relation to these
assumptions.
3.15
The committee considers that the question of BSE control measures in
the exporting country is key to the level of risk posed to the Australian
consumer. The mechanisms through which Australia will satisfy itself that
appropriate control procedures are in place prior to import approval being
granted is discussed at paragraph 3.68. The committee notes Professor Mathews'
discussion of the measures implemented in the UK which have led "UK
authorities to believe that BSE has been substantially excluded from the human
food chain in the UK and from meat products that the UK exports to other
countries."[17]
Professor Mathews also states that there is now sufficient evidence, according
to OIE criteria, that BSE is either absent or well-controlled in most developed
countries. Professor Mathews notes that there is insufficient evidence to
exclude the presence of BSE in a number of developing countries.[18]
The committee considers that notwithstanding any assessments to date by the
OIE, Australia must satisfy itself first hand of the systems and procedures in
place in any country seeking to export to Australia before it draws any
conclusions on the potential risk to Australian consumers flowing from the
importation of beef from that country.
3.16
The committee notes that in its submission, the Department of
Agriculture, Fisheries and Forestry (DAFF) discusses the quantities of beef
imported by Australia from Europe and Japan in 2001 when beef imports from 30
European countries and Japan were suspended. DAFF concludes that the quantity
of beef imported is expected to remain relatively small given Australia's
status as a very competitive and significant global beef exporter and the small
quantities of imported beef and beef products, both historically and currently.[19]
Committee comment
3.17
The committee notes the evidence presented by Professor Mathews that BSE
has been excluded from the human food chain in the UK and is either absent or
well-controlled in other developed countries. However, the committee is mindful
of the fact that our knowledge of the extent to which BSE can be claimed to
have been eliminated from the food chain in any given country is severely
limited by the fact that there is currently no effective live test for BSE and
no effective post-mortem test. The committee notes the evidence of Australia's
Chief Veterinary Officer, Dr Andrew Carroll, that:
It is correct that there is no live test for BSE. The test
with regard to dead animals has an extremely low level of accuracy until
animals are of more advanced years because of the way that BSE behaves—[20]
3.18
Therefore the committee considers that before it can accept the risk
projections of either Mr McCutcheon or Professor Mathews it would need to see a
more thorough risk analysis undertaken to consider in detail the quality
control systems in place in countries who may seek to export beef to Australia
as, in the absence of effective tests or the requirement to administer them,
such procedures and systems will be critical to the level of risk posed to Australian
consumers.
Timeline of scientific review
3.19
The committee noted that in the Review report Professor Mathews
acknowledged the limitations imposed by the timeline in the Review by saying:
The Executive Summary with Conclusions is supported by a short
Scientific Review, and by risk estimates and essential references dealing with
evidence that may have changed since the earlier reviews. It has been
impossible to access all potentially relevant references in the time available.[21]
3.20
The committee therefore sought clarification from Professor Mathews and DOHA
regarding the timeline for the review. Professor Mathews provided the committee
with the following timeline:
19 August – Telephone call from Health and Ageing (Mary
McDonald).
20 August – E-mail confirmation of a request.
29 August – Contract signed. The final terms of reference are
in the report.
15 September – Draft report submitted and circulated to NHMRC.[22]
17 September – Received secretariat comments from NHMRC
following the TSEAC discussion of the draft report; verbal comments were also
received from the Chair of TSEAC (Prof Colin Masters). [23]
20 September – Final report submitted to Health and Ageing
and to NHMRC *NHMRC Subsequently wrote to Health and Ageing about my report,
but I have no record of having received a copy of that letter.
8 October – Minor amendment – posted on government web-site.
3.21
Professor Mathews provided clarification of the extent to which he was
able to apprise himself of recent published and unpublished work that may have
been significant within the terms of the review. Professor Mathews advised the
committee that:
I am personally acquainted with some of the overseas experts
who have modelled and studied the epidemiology of BSE and variant CJD (eg Neil
Ferguson, Christl Donnelly and Azra Ghani and others), as well as with local
experts such as Colin Masters, Michael Alpers, John Kaldor, Albert Farrugia,
Steve Collins and Anthony Keller.
Accordingly in updating my knowledge of the science for the
review, I drew upon the published work, both in the scientific (refereed)
literature, and in the grey literature (eg government and other sources found
through Google). I also had access to records of the Transmissible Spongiform
Encephalopathies Advisory Committee of NHMRC, of which I was a member until
2006.
I also contacted Australian experts and persons overseas to
see if they were aware of any other recent unpublished work that might be of
major significance for my review.[24]
3.22
Professor Mathews provided the committee with a complete list of the
contacts he used both overseas and locally. Professor Mathews advised the
committee that he received no personal feedback, either locally or from
overseas, that provided information of substance that he was not otherwise
aware of. Professor Mathews told the committee that he found these 'negative'
contacts reassuring.[25]
3.23
The committee was provided with a copy of the comments provided by the
NHMRC, which reviewed a draft of Professor Mathews' Review report. The
committee notes that the NHMRC raised a number of issues including the need for
caution in discussing the extent to which the risks associated with BSE and
vCJD might have diminished. Professor Mathews advised the committee that he
addressed these concerns in the subsequent drafts of his report.[26]
Committee comment
3.24
The committee is concerned that Professor Mathews completed the
scientific review which underpinned this significant change in Australia's food
safety policy in two and a half weeks. The committee notes that Professor
Mathews is a highly respected epidemiological researcher with more that 40
years of experience.[27]
The committee also notes Professor Mathews assurance that:
... the inquiries that I was able to undertake and the
literature that I was able to read in that time was supported by, as I
mentioned before, many years of work in epidemiology and a very longstanding
interest in the transmissible encephalopathy question.[28]
3.25
However, the committee remains concerned that, given the significance of
Professor Mathews' scientific review in this policy development process, the
time allocated for the Review was unduly short and not appropriate for a
comprehensive scientific review. The committee makes particular note of the
NHRMC's observation that there is so much about this disease that is still
unknown.[29]
The committee does not accept that two and a half weeks offered sufficient time
to ensure that the government knew everything it could before the decision to
relax the import requirements for beef and beef product was taken.
Assessment of the risk to animal health
3.26
The committee was also concerned that the implications for animal health
were not thoroughly considered as part of the policy review. The committee was
advised that the risk assessment undertaken prior to the decision to change the
policy was an assessment of risk to human health. As risk to human health
requires a more conservative assessment than that required for the assessment
of risk to animal health, the assessment of risk to human health was considered
sufficient to address both categories of risk.[30]
3.27
The committee heard that the biggest risk to animal health from the
importation of beef and beef products would be the risk of importation of
specified risk materials (SRMs) and the subsequent feeding of such material to
cattle. In its submission to the inquiry, DAFF told the committee that:
There is no plausible route by which this non-contagious
disease could be transmitted to Australian cattle via safe, imported beef.
Australian governments have existing BSE-related regulatory controls that inter
alia prohibit feeding cattle and other ruminants with meat and bone meal
and which serve to protect Australia's internationally recognised 'negligible
BSE risk' status.[31]
3.28
Dr Andrew Carroll, Chief Veterinary Officer with DAFF explained that
there are a series of measures to help control the risk of importation of SRMs.
Dr Carroll said:
One is that, for countries that have BSE or risk factors, the
best they can hope for is category 2. SRMs are not allowed to be imported from
category 2 countries. In addition to that, we have measures within Australia as
well, such as the ruminant feed ban, which is there to address the risk of BSE.
So, completing the circuit so as to speak of the material getting to Australia,
it is not allowed in and, if it were here or arose from a spontaneous case or
in any other way, the ruminant feed bans are meant to address that. That is
part of the basis on which we maintain to other countries that we are of
negligible risk: we have an effective ruminant feed ban in place.[32]
3.29
The committee notes that a key part of Australia's defence against the
entry of BSE rests on its ability to be confident that countries exporting beef
to Australia also implement a ruminant feed ban and that meat meal is not used
at all in the lot feeding or the final preparation of animals for slaughter. Dr
Carroll explained to the committee that countries wanting to export beef to
Australia would need to go through a rigorous assessment process equivalent to
that which Australia has had to meet in exporting its beef. He said:
That would be based on the assessments that we have had to
undergo for overseas countries. I would surmise that that would be a key
element of FSANZ’s risk assessment because we [Australia] have to go through a
relatively rigorous process identifying how we make sure that ruminant material
is not fed to ruminants.[33]
3.30
Ms Narelle Clegg outlined the certification requirements in the new
policy:
The requirements in the new policy for certification are that
the beef and the beef food product is derived from animals that have been born,
raised and slaughtered in a category 1 or category 2 country; that they have
passed antemortem and post-mortem inspection under official veterinary
supervision; that they were not subjected to a stunning process prior to
slaughter with a device injecting compressed air or gas into the cranial
cavity, or to a pithing process; and that they were produced and handled in a
manner under official veterinary supervision which ensures that they do not
contain and are not contaminated with BSE risk materials. The policy gives you
a summary, on page 4, of what BSE risk materials are:
BSE risk materials are tonsils
and distal ileum from bovine animals of any age; brains, eyes, spinal cord,
skull and vertebral column of bovine animals over 30 months of age.
Also, it is a requirement that mechanically separated meat
from the skull and vertebral column from cattle over 30 months of age are not
included in the product. Official veterinary certification is required.[34]
The need for an import risk
analysis
3.31
The committee was concerned to note that no risk analysis appeared to
have been undertaken specifically in relation to the level of risk to animal
health as a result of the new policy.
3.32
The committee was told that risk assessments have been conducted in the
past for meat and meat products and they have also been conducted
internationally through the OIE.[35]
The committee was also told that the current situation does not meet the
requirements for having an Import Risk Analysis (IRA).[36]
3.33
The IRA Handbook (the Handbook) states that an IRA will be undertaken
when:
- relevant risk management measures have not been established; or
- relevant risk management measures for a similar good and
pest/disease combination do exist, but the likelihood and/or consequences of
entry, establishment or spread of pests and diseases could differ significantly
from those assessed. The Handbook states that a risk analysis which does not
meet these criteria will be undertaken as a non-regulated analysis of existing
policy.[37]
3.34
Dr Carroll explained to the committee that the discretion to choose the
regulated approach of a full import risk analysis approach was available to
Biosecurity Australia and would be considered in circumstances where an
application to import beef was received from a country for which Biosecurity Australia
(BA) did not already have an analysis for a country with a similar animal
health situation. Dr Carroll said:
It says an IRA would be conducted for a country with a
different disease situation. So, if we turned around and said, ‘We will now
import beef from Kenya,’ where they have foot-and-mouth disease, we would have
to do an IRA to see how we would safely import meat from a foot-and-mouth
disease infected area. That would be a new country situation. If we said we
were going to import beef from Fiji, which essentially has a similar health
situation to the United States—there are no great differences with regard to
foot-and-mouth disease between Fiji and the US—that would be an equivalent
country situation from an animal health perspective. It is different from the
FSANZ set-up.[38]
3.35
Dr Carroll explained that of the 32 countries that may seek to apply to
export beef to Australia, New Zealand, Vanuatu, Canada and the United States
were unlikely to undergo a full risk assessment as conditions for importing
beef from these countries are already in place. Dr Carroll explained that in
the case of Canada and the United States these pre-existing conditions had
become non-operational when the imports from these countries had stopped
following the detection of cases of BSE in each country.[39]
3.36
The committee notes the explanation of the decision not to proceed with
an IRA provided by Minister Crean to the Shadow Minister for Agriculture and
Food Security, the Hon John Cobb. Minister Crean explains that Australia has a
long history of importing beef and has assessed all of the diseases that can be
carried by beef and developed systems for ensuring these diseases do not enter.
The Minister's letter is at Appendix 4 to this report.
3.37
The Minister states that in relation to BSE:
We have knowledge about the disease, we know how it's
transmitted, we know how to managed (sic) the risks. Most importantly we know
how to prevent entry of the disease into the human and animal health
populations.
...
In these circumstances risk assessment and targeted science
are the best response to manage any animal quarantine risk – not an IRA that
tells us what we know.[40]
3.38
Minister Crean provided the following table to illustrate how the
decision not to proceed with an IRA had been reached:
IRA Criteria |
Relevant here? |
Relevant risk management measures have not been established |
No
-
We already have import
conditions for beef imports
-
Protocols address BSE
-
Risk assessments address other
disease risk (eg FMD, rinderpest) |
Needed to assess the likelihood of spread of diseases |
No
-
Minute risk
-
BSE is not a contagious disease.
It is spread only through cattle eating contaminated meat products and since
1997 Australia has banned feeding meat products to cattle |
Needed to assess the level of probability of entry |
No
-
Overall risk is profoundly low.
As quantified in the Mathews' report (0.002% over the next 50 years)
-
Human health – FSANZ has said
consumers can be 100% certain that all imported beef would be BSE free
-
Animal Health – finding no
viable pathway for transmission of BSE to Australian cattle (ie no live
imports and no bone meal feed). A review of existing policy will address any
animal quarantine risk[41] |
3.39
Minister Crean stated that countries wishing to export fresh beef to
Australia will not only need to pass a rigorous assessment with regard to BSE
risk, they will also need to "abide by stringent import conditions for
other animal health diseases".[42]
3.40
Minister Crean also stated that:
In addition to the protocols (developed by FSANZ to deal with
the food safety issue), we are also undertaking a quarantine risk assessment
for each country wanting to export beef to Australia. This assesses each
country on a case-by-case basis and will ensure our animal quarantine
requirements are met. This risk process includes a public consultation.[43]
3.41
The committee notes Biosecurity Australia Advice 2010/02 (the Advice),
published on 24 February 2010, which informs stakeholders of the standard
procedures that Biosecurity Australia will follow in processing market access
requests and the implementation of quarantine requirements for beef and beef
products for human consumption.
3.42
The Advice outlines the need for countries to apply to the BSE Food
Safety Assessment committee for individual country risk assessment to address
human health and food safety issues. The Advice then states:
Separately, Biosecurity Australia will, under its normal
procedures for market access requests for the importation of beef and beef
products for human consumption (except for retorted/shelf stable beef products
and casing – the retorting process addresses animal diseases of quarantine
concern), conduct an analysis in line with the Import Risk Analysis Handbook
2007 (update 2009) to address animal quarantine issues. This analysis will be
on a country-by country basis in response to specific market access requests.
It will be conducted outside the regulated IRA process as a non-regulated
analysis of existing policy.[44]
Committee comment
3.43
The committee fails to understand why a thorough analysis of the animal
health and economic implications of this policy decision have not been considered
during the risk analysis process. The arguments advanced in support of a
relaxation of the import requirements for beef, which have been in place for
nine years, suggest a strong belief that the likelihood and/or consequences of entry,
establishment or spread of BSE have changed. The extent of this change should
have been thoroughly explored. The committee was told that the pre-2001 import
requirements for beef and beef products pre-date the introduction of the IRA
framework. The committee considers that this suggests that the pre-existing
import policy also pre-dates the BSE epidemic. The committee notes that some
important risk management measures have been established in relation to beef
imports both in Australia and overseas in this time. However, the committee
considers that the effectiveness of these measures should have been considered
through a formal risk assessment process.
3.44
The committee is also mindful that an expanded IRA process provides for
the proper consideration of the likely economic consequences of a pest or
disease incursion. The committee notes that concerns were raised during this
inquiry regarding the implications of a case of BSE in Australia and the
implications of a change in import policy. The committee considers that these
concerns have been given limited consideration and analysis. For example, the
committee has heard various claims that the removal of beef and beef products
from domestic sale would have extensive and costly ramifications for the
Australian beef industry, yet no attempt has been made to quantify this impact
during this policy review and measures do not appear to have been developed to
specifically address this concern.
3.45
Similarly, the committee has heard conflicting views as to whether the
new policy will affect Australia's most favourable animal health status as a
'negligible BSE risk' country.[45]
3.46
The committee has already noted that Professor Mathews' finding of
'negligible risk' is based on an assumed 10 percent importation of beef from
any given country that has had a reported case of BSE and considers this to be
a flawed proposition.
3.47
The committee firmly believes that each of these implications should
have been given thorough consideration through a formal overarching risk
analysis process, modelled on the expanded IRA process provided for in the IRA
handbook, before the decision was taken to relax Australia's import
requirements. The committee is not persuaded that we know all we need to know
about BSE and its implications for Australian animal health and the Australian
beef industry.
Consultation
3.48
As noted in paragraph 3.1, consultation on the policy proposal commenced
in July 2009. The committee was advised that a wide range of health and
industry stakeholders were consulted. In answer to a question on notice, DFAT
advised that DAFF had coordinated consultations with meat industry bodies on
the proposed changes and DOHA had consulted with health bodies. DFAT told the
committee that no concerns were raised by those consulted.[46]
Consultation with meat industry
groups
3.49
DFAT provided the following list of meat industry groups who were
consulted and the dates on which they were consulted:
- Red Meat Market Access Committee (28 July 2009).
- Red Meat Advisory Council (31 August, 14 September and 16 and 19
October 2009).
- Meat and Livestock Australia (13 September and 16 October 2009).
- The Cattle Council of Australia (16 September and 19 October
2009).
- The Australian Meat Industry Council (31 August, 14 September, 16
and 19 October 2009).
- The Australian Lot Feeders' Association (19 October 2009).
- National Farmers Federation (31 August and 16 October 2009).
- Australian Dairy Farmers (18 October 2009).[47]
3.50
The committee was advised that these groups provide comprehensive
representation of the Australian beef industry.[48]
3.51
Organisations such as the Australian Meat Industry Council (AMIC) – who
were involved in the initial consultation – spoke positively about the process:
From our perspective it was more than adequate. All of our
members were engaged across the years. As far as other sectors are concerned, I
believe the Cattle Council, ALPA through RMAC were all engaged, and they are
the peak producer representative bodies. I can only suggest from my perspective
that the consultation process appeared adequate; in fact, more than adequate.[49]
3.52
Representatives of each of the member organisations that make up RMAC
told the committee that the need for a revision of the policy has been an
ongoing subject of discussion within the beef industry and between the beef
industry and government over a number of years. Mr John Dorian, Veterinary
Counsel with the Australian Meat Industry Council (AMIC) told the committee
that this was not a new policy position for AMIC. He said:
This is not a new position from AMIC’s point of view. This
has been a position held for a very long time and discussed with other
governments for a very long time.[50]
3.53
Similarly, Mr Palmer, the Managing Director of Meat and Livestock
Australia (MLA) confirmed that this was an issue of longstanding within the
industry. He told the committee that:
During a routine discussion with the secretary of the
department at a board meeting of the company [MLA], where all the matters
before the board are confidential anyway, a discussion was held around a whole
range of issues. This issue came into play. I do not think anyone around the
board table heard anything that they had not heard already. It has been a topic
of some discussion around industry and government—on both sides of the
House—since 2005, so there was nothing new or illuminating from our point of
view.[51]
3.54
During the inquiry the committee expressed concern that not all sections
of the beef industry were invited to be involved in the consultation process.
The committee notes the comments of Mr Brad Bellinger, Chairman of the Australian
Beef Association, who told the committee that while organisations such as RMAC
had been formally consulted and informed about the Minister's decision several
days prior to his announcement:
I received a phone call from the minister's office three
hours prior to the announcement being made to the media. That was the only
consultation the Australian Beef Association received on this matter.[52]
3.55
The committee was also concerned to note that those industry
organisations who were involved in the consultation process were asked to
maintain confidentiality. In evidence, industry representatives indicated that
whilst they were not required to sign anything, they "were asked to keep
it confidential whilst government communicated with everyone."[53]
Evidence provided during this inquiry indicates that these terms were
acceptable to the organisations concerned:
Senator BACK—With regard to the consultations that you
had with the government in this process leading up to the announcement, were
you asked to sign or were you asked to indicate that you were prepared to enter
into some form of confidentiality agreement that you would not discuss this
outside that process?
Mr Burridge—Yes, we were. We did not sign anything. We
were asked to keep it confidential whilst government communicated with
everyone.
Senator BACK—And you found that acceptable?
Mr Burridge—I found it acceptable given that
government undertook to communicate with various parties.
Senator BACK—Gentlemen in front of us, you found that
acceptable as well?
Mr Dorian—Certainly.[54]
3.56
RMAC members expressed confidence that FSANZ would develop a set of
import requirements that would reflect the industry's expectations. However,
the committee noted some disparity between the expectations of industry
representatives and the commitments provided by departmental officials. For
example, with regard to the question of livestock traceability, beef industry
representatives appearing before the committee expressed a clear expectation
that import protocols would require full livestock traceability. Mr Justin
Toohey, Secretary of the Red Meat Advisory Council, told the committee:
I will not say it again. I said it quite clearly. Whatever
beef comes into this country must be from cattle that can be proved to have
full traceability for a whole of life and to its cohorts. Full stop.[55]
3.57
Mr Toohey also expressed the view that if individual processors could
demonstrate adequate traceability this would be acceptable to the industry. Mr
Toohey said:
In the case of the US, where massive processing plants
operate, they put out, in quantity terms, an enormous amount relative to some
of our plants in this country. As an individual applicant, if they can secure a
very good, tight system that can be inspected by us and can guarantee, to the extent
possible, traceability forwards and backwards of all animals and their cohorts
and a thorough system of SRM removal et cetera—the requirements that are being
enunciated in this policy—then we would see that as the appropriate way
forward.[56]
3.58
The committee notes the following statements from Dr Carroll which
clarified the traceability requirements:
The requirement is not that the animal comes from a BSE-free
herd; the requirement is that the animal comes from a country of either
category 1 or category 2—[57]
...
It will depend on the circumstance. If it comes from a
negligible-risk country and the country has applied for the whole country to
come in then knowing that the animal came from Texas and was slaughtered in
Utah is not necessarily relevant.[58]
...
When we determine our traceability needs it will be based on,
as I said, two elements. One will be what we need to do to best insure our
market access for the countries we trade to, and some of the more stringent
ones are for Europe; Japan also has stringent ones. In instances where that
degree of precision is not required, then we will have fewer requirements, but
our traceability, from my perspective of my responsibility, is one of the main
things—to be able to trace where we have disease—[59].
Consultation with medical and
health groups
3.59
The committee notes that consultation with medical and health groups
centred on a round table discussion on 28 September 2009 at which Professor
Mathews presented the findings of the Review. DFAT provided the committee with
the following list of attendees at that meeting:
- Red Cross;
- College of Pathologists;
- Blood Transfusion Society;
- Haematology Society;
- Bone Marrow donor Registry;
- Cord Blood Bank Network; and
- The National Blood Authority.
3.60
However, the committee was concerned to learn that at least one
interested stakeholder was unable to participate in the round table. The CJD
Support Group advised that it had been invited to the meeting, but due to the
short notice provided was unable to arrange for a representative to attend.[60]
Committee comment
3.61
The committee is not persuaded that this policy proposal was the subject
of comprehensive consultation. The evidence presented to the committee suggests
that the policy was developed within a closed circle and was deliberately kept
secret from the wider beef industry and the Australian public.
3.62
The committee makes particular note of evidence from Mr David Palmer
from MLA that the need for the policy change had been discussed at an industry
level over a lengthy period of time.[61]
In this context the committee considers it extraordinary that an issue that has
been under consideration for a number of years and that apparently has such
widespread support with the Australian beef industry should be the subject of
such a clandestine consultation process.
3.63
The committee also notes that since it commenced its inquiry many
individual producers have written to the committee expressing dissatisfaction
with the level of consultation with the beef industry and also with the extent
to which their interests have been considered and represented as part of the
policy review process.[62]
3.64
The committee is also concerned that the protocols through which the
policy will be implemented were also developed without consultation. The
committee notes that after the committee's first hearing, industry
representatives sought urgent discussions with the relevant departments in
relation to the development of the import protocols and in particular, the
traceability requirements that would apply. The committee is surprised that
there could have been such a disparity of views between the industry and those
formulating the protocol after an apparently comprehensive consultation
process.
Implementation of the policy
3.65
The process and protocols through which this policy will be implemented were
published on the FSANZ website on 23 February 2010. The committee was told that
the development of the risk assessment process for determining the food safety assessments
in relation to beef imports from particular countries was largely progressed by
FSANZ.[63]
The assessment process
3.66
Under the new policy, countries will apply to the Australian BSE Food
Safety Assessment Committee (ABFSAC), for a country assessment.[64]
The application must be accompanied by a completed Australian Questionnaire
to Assess BSE Risk completed by the competent national government authority.
FSANZ will undertake a risk assessment of each country's BSE risk and assign
one of three categories:
- Category 1 – minimal risk that there could be BSE in their cattle.
- Category 2 – previous BSE outbreak or risk of an outbreak, but
verified risk mitigation.
- Category 3 – not an acceptable exporter to Australia.
3.67
In his letter to the Shadow Minister, Minister Crean advised that the
following criteria would be applied for the purposes of the risk category
assessment, following assessment of the completed questionnaire:
- if previous BSE outbreak, in-country assessment including on
traceability, identification, diagnostic capability, slaughter and processing;
- if previous BSE outbreak, ensure verifiable system to prevent
export of risk material (eg brain, spinal cord etc);
- if previous BSE outbreak, ensure verifiable system of no cross
contamination of risk material.[65]
3.68
In the event that any of the above criteria are not met that the country
would be assessed as Category 3.[66]
3.69
This risk assessment will be reviewed by the Australian BSE Food Safety
Assessment Committee (ABFSAC), and a draft report including the interim BSE
risk assessment category will be provided to the applicant country for a 60 day
comment period. If required, a visit by Australian government officials will be
undertaken to verify in-country control measures and the evidence obtained
during such a visit will be considered prior to completion of the assessment.
The final assessment report will be approved by the FSANZ CEO who will advise
the Deputy Secretary of the Biosecurity Services Group of DAFF of the final BSE
risk assessment category. The FSANZ CEO will also advise the applicant country
and relevant departments, federal ministers and the industry.[67]
3.70
Under a separate process countries will also apply to BA for assessment
of their animal quarantine risks. BA will conduct an analysis in line with the
Import Risk analysis Handbook 2007 to address animal quarantine issues. This
analysis will be on a country-by-country basis in response to specific market
access requests and will be conducted outside the regulated IRA process as a
non-regulated analysis of existing policy.[68]
Development of the import protocols
3.71
The governance and risk assessment processes were developed by FSANZ.
The committee sought clarification from FSANZ of the 'checks and balances' that
were applied in the development of the protocols to ensure that they meet the
needs and expectations of the Australian beef industry and the Australian
public. At the committee's hearing on 5 February 2010, Mr McCutcheon advised
the committee that the protocols:
will be developed by FSANZ in accord with the various other
scientific risk assessment documents that we have. Secondly, it will be based
on OIE methodologies. This is a publicly available document. It will be
reviewed by an expert from the OIE to ensure that Australia's risk assessment
methodology is scientifically sound and consistent with what is acceptable in
international terms.[69]
3.72
Mr McCutcheon confirmed that FSANZ is under no legislative requirement
to consult in the development of the protocols and there would be no
parliamentary oversight to determine if the protocols were appropriate. There
would also be no opportunity for the beef industry to determine if they
considered the protocols were appropriate.[70]
Mr McCutcheon told the committee that it is open to anyone to advise FSANZ of
any concerns regarding the protocols once they have been published. He said:
If there are particular issues on protocols that anyone in
the Australian community, or international community for that matter, wants to
comment on after they are published they are quite free and able to let us
know.[71]
3.73
Mr McCutcheon advised that the protocols are always subject to
refinement and that FSANZ would examine any information provided or concerns
raised and make any changes that FSANZ deemed necessary.[72]
Mr McCutcheon explained that:
If, for example, suddenly there are some new risk factors, or
new science emerges, then, clearly, FSANZ would be under an obligation to
review those protocols to ensure that they were designed in a way that would
address any new issues that came along.[73]
3.74
Mr McCutcheon went on to explain that:
There is no mechanism to require FSANZ to do that. But again,
operating under our legislation, we have an obligation in discharging our
legislative functions to ensure that the protocols we have in place are the
most appropriate.[74]
3.75
The committee was concerned that FSANZ appeared to be able to make
further changes to the protocols without input from industry and without
parliamentary oversight. The committee sought clarification from FSANZ that
this was correct:
CHAIR—I think this is quite important to know. If we
make the decision, as it has been taken, that this goes ahead on 1 March
without any parliamentary oversight whatsoever or any ability for input from
industry, down the track, once that commences, FSANZ has the ability to change
those protocols in any way they choose, without any accountability. Is that a
yes or a no?
Mr McCutcheon—Yes, that is true.[75]
Implementation of the import
protocols
3.76
The import protocols for the importation of beef and beef product to
Australia consist principally of the Australian Questionnaire to Assess BSE
Risk (the questionnaire).
3.77
The questionnaire seeks data and supporting evidence from the Competent
Authority of the country seeking to export to Australia over five areas;
- Risk assessment requirements regarding risk release and exposure;
- Other system requirements including:
- ongoing BSE awareness program;
- compulsory notification and investigation of BSE cases;
- diagnostic capability;
- animal traceability and identification systems; and
- animal slaughter and processing systems.
- BSE surveillance and monitoring system ;
- BSE history of the country;
- Ongoing review of country BSE status and additional data.[76]
3.78
The questionnaire states that these data requirements are consistent
with Chapter 11.6 – Bovine Spongiform Encephalopathy of the OIE Terrestrial
Animal Health Code, 2009. The questionnaire also states that verification
of in-country control measures may be undertaken by in-country inspection and
the results of any such inspections will be considered prior to completing the
country assessment.[77]
3.79
The committee notes that the level of data and supporting information
required of applicant countries appears to be comprehensive. However the
committee was concerned that the questionnaire gives no indication of the
criteria against which the responses provided will be assessed. The committee
explored this in the context of the questions relating to animal traceability
and identification systems. The committee was told that the intention was to
provide maximum flexibility to applicant countries to demonstrate their ability
to satisfy Australia that appropriate systems are in place.[78]
Dr Carroll explained to the committee that the questionnaire did not seek to
pre-empt or prejudge how a country might satisfy particular requirements.[79]
He said:
We have absolute 100 per cent ability to make sure that
nothing can be ruled out from us and nothing is ruled in for us, so we can be
absolutely convinced that the traceability system meets our requirements. They
will also be using lawyers to answer these documents, and the more you put in
them the more the lawyers can sit and argue about the clauses.[80]
3.80
The committee was particularly interested in whether countries would
need to be able to demonstrate that they have full country traceability systems
in place. The committee notes the following assurance that the assessment
process is conducted on a country basis and not by region:
Senator BACK—Sure. But you can give us the comfort
that nothing in this process is looking at dividing a country into regions or
areas? Because of the ease of movement of animals, you are giving us that
satisfaction that you would be looking at countries, not areas within
countries?
Mr McCutcheon—These are country assessments, yes.
Senator BACK—So we cannot have ‘western something or
other’ versus ‘eastern whatever’ because the disease is known to occur in one province
or region and therefore we only look at that region. It is a countrywide
assessment that is the whole basis.
Senator HEFFERNAN—It would follow, then, that it is
whole of country traceability?
Dr Carroll—We can only repeat our answer.[81]
3.81
In his letter to the Shadow Minister, Minister Crean stated that
Australia "will demand the same traceability standards of foreign beef
producers as we demand of Australian beef producers". The Minister stated
that Australia would require:
- animal traceability to origin/birth;
- forward animal traceability to destinations after production; and
- the ability to provide the above traceability within 48 hours.
3.82
The Minister stated that for each of these requirements no alternatives
would be accepted.[82]
3.83
In the case of electronic ear tags, the Minister stated that Australia
would accept an equivalent tag to that used in Australia or an alternative
method. The Minister indicated that plastic ear tags would be accepted or an
"equivalent output", but only where Australia has verified that the
alternative method ensures animals can be traced up and down the food chain
within the specified timeframe (ie 48 hrs)."[83]
3.84
With regard to national vendor declarations and livestock production
assurances, the Minister advised that equivalent alternative methods would be
accepted but only where Australia has verified that the alternative method
ensures the same outcome. In the case of national vendor declarations, the
Minister advised that proper records/attestations about on farm risk management
would be accepted, and in the case of livestock production assurances, evidence
would need to be provided that demonstrated on-farm risks are managed, "eg
chemical treatments, no use of bone meal, veterinary drug use etc".[84]
3.85
Recognising that the responsibility for final approval of the ABFSAC's
assessment of applications rests with the CEO of FSANZ and not with the
Minister for Trade, or indeed any other Minister, the committee sought
confirmation that the Minister's advice, at least with regard to traceability,
was consistent with the approach the ABFSAC would take in assessing
applications. Mr McCutcheon, the CEO of FSANZ, told the committee:
I can certainly say that the minister’s words are absolutely
correct. I have said several times that essentially what we will be looking for
is equivalency of outcomes. In other words, other countries will have to meet
the same performance criteria we might set here—that is, very clearly be able
to trace an animal right back through the food chain, from its slaughter right back
to where it came from, and be able to trace birth cohorts from the same
property and the same animal forward through the food chain to wherever it
might be, whether it is to its final destination or another property.[85]
3.86
Noting this answer, the committee sought further clarification of the
approach ABFSAC would take in respect of an application from Canada or from the
United States. In the case of Canada, the committee notes that the Canadian
Food Inspection Agency is progressively implementing its animal identification
system. As of 1 January 2010 all cattle must be tagged with a Canadian Cattle Identification
Agency (CCIA) approved radio-frequency identification (RFID) tag. However, the
CCIA is still working toward implementation of premises identification and
systems for reporting animal movement.[86]
In the case of the United States, the committee notes that animal disease
traceability will only be required for animals moving interstate. Animal
disease traceability will be administered by the States and Tribal Nations who
will have the flexibility to determine the specific approaches and solutions
they will use to achieve the minimum animal traceability.[87]
3.87
Mr McCutcheon told the committee that in both cases the expectation is
that countries must be able to convince the ABFSAC that they have the ability to
track animals up and down the meat supply chain.[88]
3.88
In the same vein, the committee expressed concern about the ability of
countries to track stock across country borders. The committee sought
clarification of how Australia could be satisfied that the origins of beef
exported to Australia were known in such circumstances. Mr Yeend told the
committee:
If that is happening, then all the information is requested
of the country that is seeking to import into Australia, and then there is
expert advice taken on whether or not the conditions are met.[89]
3.89
The committee was concerned that the assessment process does not clearly
place the same level of expectation on those countries who seek to export to
Australia as is required of Australian beef producers who seek to export into
these same countries.
In-country inspections
3.90
The committee was concerned that the assessment process described to it
appeared to be largely a desk top process. The committee therefore sought
clarification of the circumstances in which in-country inspections would be
undertaken. Mr McCutcheon explained that where FSANZ was not satisfied with the
information provided in the questionnaire a delegation of food safety and
animal health experts would undertake an in-country inspection.[90]
The committee asked why an in-country inspection would not be undertaken as a
matter of course for each assessment. Mr McCutcheon explained to the committee:
We do have long-established relationships with many of our
trading partners around the world.
...
There is an element of judgment here. We expect countries in
good faith to properly address the questions ... and come back to us with the
information.
...
I am sure we will be able to work out whether a country is
telling us the full story or not. Clearly, if we have any doubts at all about
the veracity of the information that has been provided in response to the
questionnaire then we will definitely be going over there to verify.[91]
3.91
Dr Carroll went on to explain that one of the reasons for conducting an
in-country inspection is to assess the competency of the veterinary services
within a country that underpin the import requirements. He said:
The in-country assessment is every bit as much about checking
the veterinary service and how it works as about looking at the animal health
situation in that country. We do not just say, ‘Whatever the competent
authority of country X says is correct’. We go across and determine whether or
not they are in a position to offer the certification that is required. That
same process happens frequently with Australia—other countries come across and
check our veterinary services to ensure that we are competent to provide the
certifications that we offer.[92]
3.92
The committee concurs with Dr Carroll that in-country assessment of the
competencies and systems is extremely important.
3.93
The committee notes that the Questionnaire advises that one or a number
of the following criteria may trigger an in-country inspection:
- Incomplete information and data provided in the country
submission;
- BSE cases reported from cattle born in the previous five years in
the applicant country;
- The general history of trade and knowledge of infrastructure and
food safety an veterinary services in the applicant country;
- Request by the applicant country for an in-country inspection to verify
the effectiveness of controls; and
- Timely capacity to identify, trace and report on any animals,
derived risk materials and cohorts with respect to positive BSE cases.
3.94
The committee notes that under the current policy and protocols a
significant element in the management of Australia's risk of importing BSE
rests on how FSANZ exercises its judgement with regard to these criteria.
The case for in-country inspections
– 2004 importation of beef from Brazil
3.95
The committee expressed concern that the Australian public and the beef
industry were being asked to rely on a set of protocols and systems that in
turn relied on overseas jurisdictions providing accurate information and
certifications and did not include mandatory in-country inspections. During the
inquiry, the committee referred specifically to circumstances surrounding the
importation of a consignment of beef from Brazil on 29 November 2004. The
committee considers that this incident illustrates how quickly and easily a
lack of stringent processes could compromise Australia's disease free status.
3.96
In this particular case an import permit was issued for the import of
approximately half a tonne of beef trimmings for quality testing in November
2004. This comprised 20 cartons of frozen beef, 13 of which were held at a cold
store in Melbourne. Five were distributed to individual companies manufacturing
small goods and two were sent to a processing plant in Wagga Wagga, New South
Wales, for testing. These two cartons were opened, tested and discarded and buried
at the local municipal tip under the conditions for industrial waste regulated
by the New South Wales government.[93]
3.97
Four weeks after the initial importation, Biosecurity Australia became
aware of a suspected but unconfirmed report of foot-and-mouth disease (FMD) on
a property in Brazil on the border with Paraguay and within the zone declared
as free of FMD by the World Organisation for Animal Health (OIE). The permits
that had been issued were immediately suspended and quarantine authorities
placed into quarantine the 18 cartons of imported beef that were still in cold
storage. The policy under which the import permits were issued was suspended
pending a review. Precautionary measures were also put into place at the Wagga
Wagga plant and at the municipal tip. On 7 January 2005, Biosecurity Australia
received advice from the Brazilian authorities that the FMD test result had
been confirmed as a false positive.[94]
3.98
The committee considers that this incident is significant for three
reasons. First, the import policy which underpinned the granting of permits for
the importation of beef from Brazil was developed without an IRA process. The
justification for this was that it was an amendment to an existing, long
standing policy.[95]
The committee was told at the time that the policy had been reviewed following
comprehensive consultation with the industry.[96]
However, the committee received copies of statements by the Cattle Council
expressing concern that the policy review had not included an assessment of the
impact the importation of beef meat from Brazil would have on Australia's
trading status.[97]
3.99
Second, country assessments under the policy were based on desk top
analysis undertaken by Australian bureaucrats drawing on OIE assessments of foot
and mouth disease (FMD) free zones.[98]
Neither of these processes included an in-country inspection. At the time, this
committee expressed concern that Australia had decided to import fresh meat
from a country without any understanding of the country's internal stock
identification scheme, its internal controls in relation to the movement of
stock prior to slaughter or its border. The Cattle Council also expressed
concern that there had been "no on-ground assessment/audit by Australian
authorities of the zoning systems in Brazil to ensure animals/product from
non-FMD-free zones are not shipped to Australia."[99]
An in-country inspection of these systems did not take place until some months
after the incident.[100]
3.100
Third, responsibility for the development and implementation of the
policy rested with middle ranking officers within DAFF and AQIS and was not
subject to ministerial or parliamentary oversight.[101]
3.101
During the 2005 Additional Estimates, the committee expressed grave
concern that Australia could consider importing fresh meat from a country known
to have such a highly contagious disease as FMD without an in-country
inspection to satisfy itself that that the country had systems in place that
were capable of preventing contaminated meat being imported into Australia.[102]
3.102
In an answer to a question on notice during the current inquiry DAFF
advised the committee that there were no quarantine risks to Australia involved
in this case as the suspected case of FMD was subsequently confirmed to be
false and the small quantity of uncooked product imported from Brazil was
traced and accounted for.[103]
The committee notes that this outcome owes more to luck and the cooperation of
the Australian importer than good management by the agencies concerned who
appear to have drawn few lasting lessons from the incident. The committee's
view at that time was that beef should not have been imported from a country
known to have had occurrences of such a significant disease without an IRA and
an in-country inspection to ensure that adequate systems were in place to
ensure that the disease could not be imported into Australia and that these
processes should have been overseen at Ministerial level. This view has not
changed.
Committee view
3.103
The committee considers that the protocol that has been implemented for
the importation of beef and beef product is clearly intended to elicit
comprehensive data from countries seeking to export to Australia. However, the
committee has two fundamental concerns regarding the process through which
completed questionnaires will be assessed. First it is unclear as to the extent
FSANZ will insist on current comprehensive information and data or the extent
to which such information and data will be verified through an in-country
inspection. Second, it is not clear what criteria FSANZ will have regard to in
the assessment of completed questionnaires.
3.104
Throughout this inquiry the committee has expressed concern that
responsibility for the development and implementation of the protocols does not
rest with a minister and is not open to scrutiny by the parliament. The
committee has noted the assurances provided by the Minister for Trade, however,
the committee also notes that neither FSANZ or Biosecurity Services Group report
to the Minister for Trade.
3.105
The committee is concerned that the Australian public and the Australian
beef industry are being expected to take a great deal on trust and that by the
time the results of the assessments of each country are made public, it will be
too late to raise concerns in relation to a particular country's claims or the
assessment of them.
Country of origin labelling
3.106
During the inquiry the committee was advised that there is no country of
origin labelling requirement for unpackaged fresh beef, however packaged fresh
beef is required to be labelled.[104]The
committee notes that country of origin labelling is required for fresh pork and
seafood and fresh fruit and vegetables.[105]
3.107
In its submission to the inquiry DAFF advised the committee that country
of origin labelling is a separate issue to the new policy for the importation
of beef and beef product. DAFF advised that country of origin labelling is not
a requirement to ensure the safety of imported beef for consumers, but that it
serves to inform consumer choice in making purchasing decisions. DAFF said that
the Council of Australian Governments (COAG) and the Australia New Zealand Food
Regulation Ministerial Council have agreed to undertake a comprehensive review
of food labelling law and policy.[106]
3.108
The committee notes a Panel led by Dr Neal Blewett AC will undertake the
review and report to the Australia New Zealand Food Regulation Ministerial
Council in December 2010 and to COAG in early 2011.[107]
The review panel will be required to:
1. Examine the policy drivers impacting on demands for food
labelling.
2. Consider what should be the role for government in the
regulation of food labelling. What principles should guide decisions about
government regulatory intervention?
3. Consider what policies and mechanisms are needed to ensure
that government plays its optimum role.
4. Consider principles and approaches to achieve compliance
with labelling requirements, and appropriate and consistent enforcement.
5. Evaluate current policies, standards and laws relevant to
food labelling and existing work on health claims and front of pack labelling
against terms of reference 1-4 above.
6. Make recommendations to improve food labelling law and
policy.[108]
3.109
The committee notes that this review will consider the question of
country of origin labelling and specifically what criteria should determine
which, if any, foods are required to have country of origin labelling.[109]
3.110
The committee considers that all imported beef and beef product should have
a country of origin label to provide consumers with a choice as to whether they
wish to eat beef from countries that have had a BSE outbreak.
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