44
www.food.gov.uk FOOD STANDARDS AGENCY CONSULTATION Title: REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK CONSULTATION SUMMARY PAGE Date consultation launched: Closing date for responses: 21 February 2014 16 May 2014 Who will this consultation be of most interest to? Enforcement bodies carrying out official controls (competent authorities) on behalf of the FSA and Food Business Operators (FBOs) in FSA approved meat establishments. What is the subject of this consultation? Key changes are being considered for official control audits in FSA approved meat establishments – i.e. Slaughterhouses, Cutting plants (Co located and Stand Alone) and Game Handling Establishments subject to veterinary controls across the UK. The proposals include changes to audit risk ratings, use of evidence, audit outcomes, audit frequencies. An initial impact assessment on the proposed changes is included in the consultation. What is the purpose of this consultation? To seek stakeholders' views on the key elements of the draft audit proposal and evidence towards our initial impact assessment (Annex B) of the proposals on UK stakeholders. The audit process is due fundamental review as it has been in place since 2006 and the proposals are intended to make the current official control audit system in the UK more proportionate to the risks posed by meat production, by taking into account additional controls and assurances within the meat supply chain. The proposals are in line with from the FSA’s strategic outcome that enforcement is effective, consistent, risk-based, proportionate and focused on improving public health and engagement with industry representatives and FSA has developed the proposals in line with the following objectives : Understandable, fair and effective audit system Assure confidence (both internal and external) in the accuracy and consistency of audit assessments; Leads to appropriate enforcement action and drives FBO compliance Provides the basis for understandable meat plant audit outcomes and for the application of earned recognition benefits for better performing plants with the extension of audit frequencies. If you would prefer to receive future FSA consultations by e-mail, or if you no longer wish to receive information on this subject please notify the named person in this consultation.

Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

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Page 1: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

wwwfoodgovuk

FOOD STANDARDS AGENCY CONSULTATION Title REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT

ESTABLISHMENTS WITHIN THE UK

CONSULTATION SUMMARY PAGE

Date consultation launched Closing date for responses 21 February 2014 16 May 2014

Who will this consultation be of most interest to Enforcement bodies carrying out official controls (competent authorities) on behalf of the FSA and Food Business Operators (FBOs) in FSA approved meat establishments

What is the subject of this consultation Key changes are being considered for official control audits in FSA approved meat establishments ndash ie Slaughterhouses Cutting plants (Co located and Stand Alone) and Game Handling Establishments subject to veterinary controls across the UK The proposals include changes to audit risk ratings use of evidence audit outcomes audit frequencies An initial impact assessment on the proposed changes is included in the consultation

What is the purpose of this consultation To seek stakeholders views on the key elements of the draft audit proposal and evidence towards our initial impact assessment (Annex B) of the proposals on UK stakeholders The audit process is due fundamental review as it has been in place since 2006 and the proposals are intended to make the current official control audit system in the UK more proportionate to the risks posed by meat production by taking into account additional controls and assurances within the meat supply chain The proposals are in line with from the FSArsquos strategic outcome that enforcement is effective consistent risk-based proportionate and focused on improving public health and engagement with industry representatives and FSA has developed the proposals in line with the following objectives

bull Understandable fair and effective audit system bull Assure confidence (both internal and external) in the accuracy and

consistency of audit assessments bull Leads to appropriate enforcement action and drives FBO compliance bull Provides the basis for understandable meat plant audit outcomes and for the

application of earned recognition benefits for better performing plants with the extension of audit frequencies

If you would prefer to receive future FSA consultations by e-mail or if you no longer wish to receive information on this subject please

notify the named person in this consultation

Following implementation of the new audit system in July 2014 pending consultation results It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

Responses to this consultation should be sent to Name Kenneth Thoresen DivisionBranch Operations Assurance Division FOOD STANDARDS AGENCY Tel 07789877601 Fax

Postal address Food Standards Agency Operations Change and Support Team Foss House Kings Pool 1-2 Peasholme Green York YO1 7PR EmailKennethThoresenfoodstandardsgsigovuk

Is an Impact Assessment included with this consultation

Yes No See Annex A for reason

2

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK

DETAIL OF CONSULTATION

Introduction

1 The current audit system for FSA approved meat establishments was introduced in January 2006 with the introduction of the EC Food Hygiene legislation While refinements have been made to the system over the years we believe that it is now appropriate to undertake a more fundamental review of effectiveness The FSA Board discussed audit arrangements in September 2013 as part of wider considerations on compliance in the meat industry [FSA 130906] and acknowledging concerns raised by industry representatives there was support for early improvements to strengthen audit arrangements

2 Flexibilities within the EU legislative framework have been considered to inform proposals with consideration of official control audit systems in other Member States and third countries including scoring frequency of audit and patterns of visits

3 A UK-wide review of audit arrangements has been carried out on basis (following the FSA Board meeting in September 2013) with consideration towards the differences within each of the four countries ndash including that meat official controls delivered by the Department of Agriculture and Rural Development (DARD) in Northern Ireland on the FSArsquos behalf and the establishment of the National Food Body in Scotland in April 2015 - potentially influencing how changes might be implemented in these countries

4 There are 1401 approved meat establishments in GB and 59 in Northern Ireland outlined as follows

Establishments England Scotland Wales Northern Ireland

Slaughterhouses 274 33 27 20 Game Handling Establishments

44 18 0 3

Cutting Plants (amp Market Stalls)

741 (55 Market Stalls)

93 57 36

5 The Food Standards Agency (FSA) system of audit in approved meat plants (slaughterhouses cutting plants and game handling establishments) has been in place since 2006 Some refinements have been made since then - most recently in October 2012 where a greater emphasis was placed on food safety in terms of scores awarded and audits for slaughterhouses with co-located cutting plants were combined ndash but audit arrangements have largely stayed the same

6 A strategic review of audit arrangements has been under way with the FSA working in collaboration with meat industry stakeholders to come up with proposals for change and consultation in relation to the following key underpinning audit requirements

bull Risk ratings bull Use of evidence

3

bull Audit outcomes bull Audit frequencies

Audit Proposals

7 Who carries out the audit function - Recital (9) of Regulation (EC) 85420040F

1

requires that Official Veterinarians must carry out the audit role in approved meat establishments given their specific expertise Drawing on industry feedback and also previous Board discussions it is clear that we need to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted Most industry stakeholders consider that the auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections and we developed the proposals on this basis

8 Risk Rating - Regulation (EC) 8542004 outlines the requirements for auditing of meat establishments as follows ldquothe nature and intensity of auditing tasks in respect of individual establishments shall depend upon the assessed risk To this end the competent authority shall regularly assess

(a) public and where appropriate animal health risks (b) in the case of slaughterhouses animal welfare aspects (c) the type and throughput of the processes carried out and (d) the food business operators past record as regards compliance with food lawrdquo

9 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on frequent audits because of their throughput or because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments during the actual audit process and not based on potential hazards This consultation asks for stakeholder views on that proposal

10Use of evidence ndash To strengthen how evidence may be drawn upon and used to assess overall food business operator performance the current descriptors of active broad weak or poor compliance are considered vague in terms of objectivity in scoring and they are not easy to understand A number of audit systems have been looked at to inform an alternative approach including

bull SAI Global (formally EFSIS) bull British Retail Consortium bull Red Tractor bull Canada bull Australia bull New Zealand

4

Definitions proposed

Score Description

Compliant Compliance with a food safety programme food regulatory requirements and animal health and welfare regulations (in the case of slaughterhouses) is achieved if the food business is operating in accordance with its food safety management systems food safety standards and has met the requirements of the regulations

Minor non A non-compliance that is not likely to compromise public health compliance (including food safety) animal health and welfare or lead to the

handling of unsafe or unsuitable food A minor non-compliance is an isolated low risk situation and does not compromise achieving control measures of the food safety program ie overall the food safety program is still effective in controlling the food safety hazards When viewed collectively a number of related minor non-compliances may represent a major nonshycompliance

Major non A major non-compliance is a non-compliance that is likely to compliance compromise public health (including food safety) animal health

and welfare or may lead to the production and handling of unsafe or unsuitable food if no remedial action is taken When viewed collectively a number of related major non-compliances may represent critical non-compliance

Critical non compliance

A critical non-compliance is non-compliance where the contravention poses an imminent and serious risk to public health (including food safety) animal health or welfare

11Audit outcomes ndash The current compliance descriptions of active broad weak and poor are used to provide outcomes of audits but to make audit outcomes more transparent alternative outcomes have been considered Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit (so the compliance scores for each question and overall section of the audit) and reflect the extent and effectiveness of compliance with four compliance ratings ndash good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system and audit outcomes are outlined in the table below and we have taken into account a comparison to the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises under Local Authority control

5

Audit Outcome proposal

Compliance rating Description Comparison to Food Comparison toHygiene Rating Food Hygiene

Scheme (England Information Wales and Northern Scheme

Ireland) (Scotland) Good No issues of significance

for public health animal health or animal welfare during the entire audit period

Generally Satisfactory

No issues of significance for public health animal health or animal welfare identified on the day of the audit Any nonshycompliances identified during the audit period corrected promptly

Improvement necessary

Major non-compliances identified at audit andor non-compliances during the audit period not always responded to and corrected promptly

Urgent Improvement necessary

Multiple major nonshycompliances or critical non-compliance identified during audit visit or interim audit period Official intervention required to ensure public health safeguards

12Audit Frequencies ndash Frequency of audit is not prescribed in EU regulations General obligations with regard to the organisation of official controls under Regulation (EC) 8822002 are provided in Article 3 and bring out that these controls should be carried out regularly on a risk basis and with appropriate frequency The official controls may be carried out without prior warning - except in cases such as audit where prior notification may be necessary

13Under the current system frequencies of audits vary between a minimum of once every two three five eight or twelve months ndash depending on overall audit scores Eight months is typically the ceiling level for slaughterhouses and cutting plants In working up audit options the following factors were considered relevant

bull The need to focus activities on problematic plants especially with follow-up visits ensuring an appropriate level of consideration and having objective evidence available in the event of a need to review approval

bull Employing effectively focused partial audits to address audit findings bull Reducing regulatory burdens for good performers

6

bull Providing an incentive for businesses to do things well widening the frequency for those that are performing well compared to those that are not

bull Balancing follow-up audit visits (partial audits) and unannounced inspections to maintain assurances on food business operator performance

14There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit Full audit frequency

Good 0 18 months Generally satisfactory 1 interim visit 12 months Improvement necessary Within 1 month 3 months Urgent Improvement necessary

Within 1 month 2 months

Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial Minimum number Full audit audit of unannounced frequency

inspections during interim audit period

Good 0 1 12 months Generally Satisfactory

1 interim visit 1

Improvement necessary

Within1 month 1 3 months

Urgent Improvement necessary

Within 1 month 1 2 months

7

Key proposal(s)

Preferred options for a new audit system in relation to

bull Risk ratings - It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are

bull Use of evidence - Current descriptions of compliance given to each audit question audit section - active broad weak and poor - are considered vague in terms of objectivity of scoring It is proposed that these are changed to minor major and critical non-compliances drawing on approaches used in alternative audit systems with these underpinned by objective requirements and evidence

bull Audit outcomes ndash four new compliance ratings are proposed on audit outcomes - good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit - It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Consultation Process

15There has been ongoing communication with stakeholders during development of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal These meetings have informed this consultation and the accompanying IA

16This consultation seeks your views on the key changes listed in the above box A number of key questions are set out in the box below We would also be interested in your comments about any other aspect of the proposal which you would like to bring to our attention

17This consultation has been issued by the FSA on a UK basis to all identified stakeholders including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered

8

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

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C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

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DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

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FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

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HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

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KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

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MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

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PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

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SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

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TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 2: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Following implementation of the new audit system in July 2014 pending consultation results It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

Responses to this consultation should be sent to Name Kenneth Thoresen DivisionBranch Operations Assurance Division FOOD STANDARDS AGENCY Tel 07789877601 Fax

Postal address Food Standards Agency Operations Change and Support Team Foss House Kings Pool 1-2 Peasholme Green York YO1 7PR EmailKennethThoresenfoodstandardsgsigovuk

Is an Impact Assessment included with this consultation

Yes No See Annex A for reason

2

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK

DETAIL OF CONSULTATION

Introduction

1 The current audit system for FSA approved meat establishments was introduced in January 2006 with the introduction of the EC Food Hygiene legislation While refinements have been made to the system over the years we believe that it is now appropriate to undertake a more fundamental review of effectiveness The FSA Board discussed audit arrangements in September 2013 as part of wider considerations on compliance in the meat industry [FSA 130906] and acknowledging concerns raised by industry representatives there was support for early improvements to strengthen audit arrangements

2 Flexibilities within the EU legislative framework have been considered to inform proposals with consideration of official control audit systems in other Member States and third countries including scoring frequency of audit and patterns of visits

3 A UK-wide review of audit arrangements has been carried out on basis (following the FSA Board meeting in September 2013) with consideration towards the differences within each of the four countries ndash including that meat official controls delivered by the Department of Agriculture and Rural Development (DARD) in Northern Ireland on the FSArsquos behalf and the establishment of the National Food Body in Scotland in April 2015 - potentially influencing how changes might be implemented in these countries

4 There are 1401 approved meat establishments in GB and 59 in Northern Ireland outlined as follows

Establishments England Scotland Wales Northern Ireland

Slaughterhouses 274 33 27 20 Game Handling Establishments

44 18 0 3

Cutting Plants (amp Market Stalls)

741 (55 Market Stalls)

93 57 36

5 The Food Standards Agency (FSA) system of audit in approved meat plants (slaughterhouses cutting plants and game handling establishments) has been in place since 2006 Some refinements have been made since then - most recently in October 2012 where a greater emphasis was placed on food safety in terms of scores awarded and audits for slaughterhouses with co-located cutting plants were combined ndash but audit arrangements have largely stayed the same

6 A strategic review of audit arrangements has been under way with the FSA working in collaboration with meat industry stakeholders to come up with proposals for change and consultation in relation to the following key underpinning audit requirements

bull Risk ratings bull Use of evidence

3

bull Audit outcomes bull Audit frequencies

Audit Proposals

7 Who carries out the audit function - Recital (9) of Regulation (EC) 85420040F

1

requires that Official Veterinarians must carry out the audit role in approved meat establishments given their specific expertise Drawing on industry feedback and also previous Board discussions it is clear that we need to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted Most industry stakeholders consider that the auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections and we developed the proposals on this basis

8 Risk Rating - Regulation (EC) 8542004 outlines the requirements for auditing of meat establishments as follows ldquothe nature and intensity of auditing tasks in respect of individual establishments shall depend upon the assessed risk To this end the competent authority shall regularly assess

(a) public and where appropriate animal health risks (b) in the case of slaughterhouses animal welfare aspects (c) the type and throughput of the processes carried out and (d) the food business operators past record as regards compliance with food lawrdquo

9 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on frequent audits because of their throughput or because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments during the actual audit process and not based on potential hazards This consultation asks for stakeholder views on that proposal

10Use of evidence ndash To strengthen how evidence may be drawn upon and used to assess overall food business operator performance the current descriptors of active broad weak or poor compliance are considered vague in terms of objectivity in scoring and they are not easy to understand A number of audit systems have been looked at to inform an alternative approach including

bull SAI Global (formally EFSIS) bull British Retail Consortium bull Red Tractor bull Canada bull Australia bull New Zealand

4

Definitions proposed

Score Description

Compliant Compliance with a food safety programme food regulatory requirements and animal health and welfare regulations (in the case of slaughterhouses) is achieved if the food business is operating in accordance with its food safety management systems food safety standards and has met the requirements of the regulations

Minor non A non-compliance that is not likely to compromise public health compliance (including food safety) animal health and welfare or lead to the

handling of unsafe or unsuitable food A minor non-compliance is an isolated low risk situation and does not compromise achieving control measures of the food safety program ie overall the food safety program is still effective in controlling the food safety hazards When viewed collectively a number of related minor non-compliances may represent a major nonshycompliance

Major non A major non-compliance is a non-compliance that is likely to compliance compromise public health (including food safety) animal health

and welfare or may lead to the production and handling of unsafe or unsuitable food if no remedial action is taken When viewed collectively a number of related major non-compliances may represent critical non-compliance

Critical non compliance

A critical non-compliance is non-compliance where the contravention poses an imminent and serious risk to public health (including food safety) animal health or welfare

11Audit outcomes ndash The current compliance descriptions of active broad weak and poor are used to provide outcomes of audits but to make audit outcomes more transparent alternative outcomes have been considered Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit (so the compliance scores for each question and overall section of the audit) and reflect the extent and effectiveness of compliance with four compliance ratings ndash good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system and audit outcomes are outlined in the table below and we have taken into account a comparison to the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises under Local Authority control

5

Audit Outcome proposal

Compliance rating Description Comparison to Food Comparison toHygiene Rating Food Hygiene

Scheme (England Information Wales and Northern Scheme

Ireland) (Scotland) Good No issues of significance

for public health animal health or animal welfare during the entire audit period

Generally Satisfactory

No issues of significance for public health animal health or animal welfare identified on the day of the audit Any nonshycompliances identified during the audit period corrected promptly

Improvement necessary

Major non-compliances identified at audit andor non-compliances during the audit period not always responded to and corrected promptly

Urgent Improvement necessary

Multiple major nonshycompliances or critical non-compliance identified during audit visit or interim audit period Official intervention required to ensure public health safeguards

12Audit Frequencies ndash Frequency of audit is not prescribed in EU regulations General obligations with regard to the organisation of official controls under Regulation (EC) 8822002 are provided in Article 3 and bring out that these controls should be carried out regularly on a risk basis and with appropriate frequency The official controls may be carried out without prior warning - except in cases such as audit where prior notification may be necessary

13Under the current system frequencies of audits vary between a minimum of once every two three five eight or twelve months ndash depending on overall audit scores Eight months is typically the ceiling level for slaughterhouses and cutting plants In working up audit options the following factors were considered relevant

bull The need to focus activities on problematic plants especially with follow-up visits ensuring an appropriate level of consideration and having objective evidence available in the event of a need to review approval

bull Employing effectively focused partial audits to address audit findings bull Reducing regulatory burdens for good performers

6

bull Providing an incentive for businesses to do things well widening the frequency for those that are performing well compared to those that are not

bull Balancing follow-up audit visits (partial audits) and unannounced inspections to maintain assurances on food business operator performance

14There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit Full audit frequency

Good 0 18 months Generally satisfactory 1 interim visit 12 months Improvement necessary Within 1 month 3 months Urgent Improvement necessary

Within 1 month 2 months

Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial Minimum number Full audit audit of unannounced frequency

inspections during interim audit period

Good 0 1 12 months Generally Satisfactory

1 interim visit 1

Improvement necessary

Within1 month 1 3 months

Urgent Improvement necessary

Within 1 month 1 2 months

7

Key proposal(s)

Preferred options for a new audit system in relation to

bull Risk ratings - It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are

bull Use of evidence - Current descriptions of compliance given to each audit question audit section - active broad weak and poor - are considered vague in terms of objectivity of scoring It is proposed that these are changed to minor major and critical non-compliances drawing on approaches used in alternative audit systems with these underpinned by objective requirements and evidence

bull Audit outcomes ndash four new compliance ratings are proposed on audit outcomes - good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit - It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Consultation Process

15There has been ongoing communication with stakeholders during development of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal These meetings have informed this consultation and the accompanying IA

16This consultation seeks your views on the key changes listed in the above box A number of key questions are set out in the box below We would also be interested in your comments about any other aspect of the proposal which you would like to bring to our attention

17This consultation has been issued by the FSA on a UK basis to all identified stakeholders including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered

8

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 3: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK

DETAIL OF CONSULTATION

Introduction

1 The current audit system for FSA approved meat establishments was introduced in January 2006 with the introduction of the EC Food Hygiene legislation While refinements have been made to the system over the years we believe that it is now appropriate to undertake a more fundamental review of effectiveness The FSA Board discussed audit arrangements in September 2013 as part of wider considerations on compliance in the meat industry [FSA 130906] and acknowledging concerns raised by industry representatives there was support for early improvements to strengthen audit arrangements

2 Flexibilities within the EU legislative framework have been considered to inform proposals with consideration of official control audit systems in other Member States and third countries including scoring frequency of audit and patterns of visits

3 A UK-wide review of audit arrangements has been carried out on basis (following the FSA Board meeting in September 2013) with consideration towards the differences within each of the four countries ndash including that meat official controls delivered by the Department of Agriculture and Rural Development (DARD) in Northern Ireland on the FSArsquos behalf and the establishment of the National Food Body in Scotland in April 2015 - potentially influencing how changes might be implemented in these countries

4 There are 1401 approved meat establishments in GB and 59 in Northern Ireland outlined as follows

Establishments England Scotland Wales Northern Ireland

Slaughterhouses 274 33 27 20 Game Handling Establishments

44 18 0 3

Cutting Plants (amp Market Stalls)

741 (55 Market Stalls)

93 57 36

5 The Food Standards Agency (FSA) system of audit in approved meat plants (slaughterhouses cutting plants and game handling establishments) has been in place since 2006 Some refinements have been made since then - most recently in October 2012 where a greater emphasis was placed on food safety in terms of scores awarded and audits for slaughterhouses with co-located cutting plants were combined ndash but audit arrangements have largely stayed the same

6 A strategic review of audit arrangements has been under way with the FSA working in collaboration with meat industry stakeholders to come up with proposals for change and consultation in relation to the following key underpinning audit requirements

bull Risk ratings bull Use of evidence

3

bull Audit outcomes bull Audit frequencies

Audit Proposals

7 Who carries out the audit function - Recital (9) of Regulation (EC) 85420040F

1

requires that Official Veterinarians must carry out the audit role in approved meat establishments given their specific expertise Drawing on industry feedback and also previous Board discussions it is clear that we need to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted Most industry stakeholders consider that the auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections and we developed the proposals on this basis

8 Risk Rating - Regulation (EC) 8542004 outlines the requirements for auditing of meat establishments as follows ldquothe nature and intensity of auditing tasks in respect of individual establishments shall depend upon the assessed risk To this end the competent authority shall regularly assess

(a) public and where appropriate animal health risks (b) in the case of slaughterhouses animal welfare aspects (c) the type and throughput of the processes carried out and (d) the food business operators past record as regards compliance with food lawrdquo

9 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on frequent audits because of their throughput or because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments during the actual audit process and not based on potential hazards This consultation asks for stakeholder views on that proposal

10Use of evidence ndash To strengthen how evidence may be drawn upon and used to assess overall food business operator performance the current descriptors of active broad weak or poor compliance are considered vague in terms of objectivity in scoring and they are not easy to understand A number of audit systems have been looked at to inform an alternative approach including

bull SAI Global (formally EFSIS) bull British Retail Consortium bull Red Tractor bull Canada bull Australia bull New Zealand

4

Definitions proposed

Score Description

Compliant Compliance with a food safety programme food regulatory requirements and animal health and welfare regulations (in the case of slaughterhouses) is achieved if the food business is operating in accordance with its food safety management systems food safety standards and has met the requirements of the regulations

Minor non A non-compliance that is not likely to compromise public health compliance (including food safety) animal health and welfare or lead to the

handling of unsafe or unsuitable food A minor non-compliance is an isolated low risk situation and does not compromise achieving control measures of the food safety program ie overall the food safety program is still effective in controlling the food safety hazards When viewed collectively a number of related minor non-compliances may represent a major nonshycompliance

Major non A major non-compliance is a non-compliance that is likely to compliance compromise public health (including food safety) animal health

and welfare or may lead to the production and handling of unsafe or unsuitable food if no remedial action is taken When viewed collectively a number of related major non-compliances may represent critical non-compliance

Critical non compliance

A critical non-compliance is non-compliance where the contravention poses an imminent and serious risk to public health (including food safety) animal health or welfare

11Audit outcomes ndash The current compliance descriptions of active broad weak and poor are used to provide outcomes of audits but to make audit outcomes more transparent alternative outcomes have been considered Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit (so the compliance scores for each question and overall section of the audit) and reflect the extent and effectiveness of compliance with four compliance ratings ndash good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system and audit outcomes are outlined in the table below and we have taken into account a comparison to the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises under Local Authority control

5

Audit Outcome proposal

Compliance rating Description Comparison to Food Comparison toHygiene Rating Food Hygiene

Scheme (England Information Wales and Northern Scheme

Ireland) (Scotland) Good No issues of significance

for public health animal health or animal welfare during the entire audit period

Generally Satisfactory

No issues of significance for public health animal health or animal welfare identified on the day of the audit Any nonshycompliances identified during the audit period corrected promptly

Improvement necessary

Major non-compliances identified at audit andor non-compliances during the audit period not always responded to and corrected promptly

Urgent Improvement necessary

Multiple major nonshycompliances or critical non-compliance identified during audit visit or interim audit period Official intervention required to ensure public health safeguards

12Audit Frequencies ndash Frequency of audit is not prescribed in EU regulations General obligations with regard to the organisation of official controls under Regulation (EC) 8822002 are provided in Article 3 and bring out that these controls should be carried out regularly on a risk basis and with appropriate frequency The official controls may be carried out without prior warning - except in cases such as audit where prior notification may be necessary

13Under the current system frequencies of audits vary between a minimum of once every two three five eight or twelve months ndash depending on overall audit scores Eight months is typically the ceiling level for slaughterhouses and cutting plants In working up audit options the following factors were considered relevant

bull The need to focus activities on problematic plants especially with follow-up visits ensuring an appropriate level of consideration and having objective evidence available in the event of a need to review approval

bull Employing effectively focused partial audits to address audit findings bull Reducing regulatory burdens for good performers

6

bull Providing an incentive for businesses to do things well widening the frequency for those that are performing well compared to those that are not

bull Balancing follow-up audit visits (partial audits) and unannounced inspections to maintain assurances on food business operator performance

14There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit Full audit frequency

Good 0 18 months Generally satisfactory 1 interim visit 12 months Improvement necessary Within 1 month 3 months Urgent Improvement necessary

Within 1 month 2 months

Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial Minimum number Full audit audit of unannounced frequency

inspections during interim audit period

Good 0 1 12 months Generally Satisfactory

1 interim visit 1

Improvement necessary

Within1 month 1 3 months

Urgent Improvement necessary

Within 1 month 1 2 months

7

Key proposal(s)

Preferred options for a new audit system in relation to

bull Risk ratings - It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are

bull Use of evidence - Current descriptions of compliance given to each audit question audit section - active broad weak and poor - are considered vague in terms of objectivity of scoring It is proposed that these are changed to minor major and critical non-compliances drawing on approaches used in alternative audit systems with these underpinned by objective requirements and evidence

bull Audit outcomes ndash four new compliance ratings are proposed on audit outcomes - good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit - It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Consultation Process

15There has been ongoing communication with stakeholders during development of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal These meetings have informed this consultation and the accompanying IA

16This consultation seeks your views on the key changes listed in the above box A number of key questions are set out in the box below We would also be interested in your comments about any other aspect of the proposal which you would like to bring to our attention

17This consultation has been issued by the FSA on a UK basis to all identified stakeholders including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered

8

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 4: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

bull Audit outcomes bull Audit frequencies

Audit Proposals

7 Who carries out the audit function - Recital (9) of Regulation (EC) 85420040F

1

requires that Official Veterinarians must carry out the audit role in approved meat establishments given their specific expertise Drawing on industry feedback and also previous Board discussions it is clear that we need to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted Most industry stakeholders consider that the auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections and we developed the proposals on this basis

8 Risk Rating - Regulation (EC) 8542004 outlines the requirements for auditing of meat establishments as follows ldquothe nature and intensity of auditing tasks in respect of individual establishments shall depend upon the assessed risk To this end the competent authority shall regularly assess

(a) public and where appropriate animal health risks (b) in the case of slaughterhouses animal welfare aspects (c) the type and throughput of the processes carried out and (d) the food business operators past record as regards compliance with food lawrdquo

9 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on frequent audits because of their throughput or because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments during the actual audit process and not based on potential hazards This consultation asks for stakeholder views on that proposal

10Use of evidence ndash To strengthen how evidence may be drawn upon and used to assess overall food business operator performance the current descriptors of active broad weak or poor compliance are considered vague in terms of objectivity in scoring and they are not easy to understand A number of audit systems have been looked at to inform an alternative approach including

bull SAI Global (formally EFSIS) bull British Retail Consortium bull Red Tractor bull Canada bull Australia bull New Zealand

4

Definitions proposed

Score Description

Compliant Compliance with a food safety programme food regulatory requirements and animal health and welfare regulations (in the case of slaughterhouses) is achieved if the food business is operating in accordance with its food safety management systems food safety standards and has met the requirements of the regulations

Minor non A non-compliance that is not likely to compromise public health compliance (including food safety) animal health and welfare or lead to the

handling of unsafe or unsuitable food A minor non-compliance is an isolated low risk situation and does not compromise achieving control measures of the food safety program ie overall the food safety program is still effective in controlling the food safety hazards When viewed collectively a number of related minor non-compliances may represent a major nonshycompliance

Major non A major non-compliance is a non-compliance that is likely to compliance compromise public health (including food safety) animal health

and welfare or may lead to the production and handling of unsafe or unsuitable food if no remedial action is taken When viewed collectively a number of related major non-compliances may represent critical non-compliance

Critical non compliance

A critical non-compliance is non-compliance where the contravention poses an imminent and serious risk to public health (including food safety) animal health or welfare

11Audit outcomes ndash The current compliance descriptions of active broad weak and poor are used to provide outcomes of audits but to make audit outcomes more transparent alternative outcomes have been considered Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit (so the compliance scores for each question and overall section of the audit) and reflect the extent and effectiveness of compliance with four compliance ratings ndash good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system and audit outcomes are outlined in the table below and we have taken into account a comparison to the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises under Local Authority control

5

Audit Outcome proposal

Compliance rating Description Comparison to Food Comparison toHygiene Rating Food Hygiene

Scheme (England Information Wales and Northern Scheme

Ireland) (Scotland) Good No issues of significance

for public health animal health or animal welfare during the entire audit period

Generally Satisfactory

No issues of significance for public health animal health or animal welfare identified on the day of the audit Any nonshycompliances identified during the audit period corrected promptly

Improvement necessary

Major non-compliances identified at audit andor non-compliances during the audit period not always responded to and corrected promptly

Urgent Improvement necessary

Multiple major nonshycompliances or critical non-compliance identified during audit visit or interim audit period Official intervention required to ensure public health safeguards

12Audit Frequencies ndash Frequency of audit is not prescribed in EU regulations General obligations with regard to the organisation of official controls under Regulation (EC) 8822002 are provided in Article 3 and bring out that these controls should be carried out regularly on a risk basis and with appropriate frequency The official controls may be carried out without prior warning - except in cases such as audit where prior notification may be necessary

13Under the current system frequencies of audits vary between a minimum of once every two three five eight or twelve months ndash depending on overall audit scores Eight months is typically the ceiling level for slaughterhouses and cutting plants In working up audit options the following factors were considered relevant

bull The need to focus activities on problematic plants especially with follow-up visits ensuring an appropriate level of consideration and having objective evidence available in the event of a need to review approval

bull Employing effectively focused partial audits to address audit findings bull Reducing regulatory burdens for good performers

6

bull Providing an incentive for businesses to do things well widening the frequency for those that are performing well compared to those that are not

bull Balancing follow-up audit visits (partial audits) and unannounced inspections to maintain assurances on food business operator performance

14There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit Full audit frequency

Good 0 18 months Generally satisfactory 1 interim visit 12 months Improvement necessary Within 1 month 3 months Urgent Improvement necessary

Within 1 month 2 months

Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial Minimum number Full audit audit of unannounced frequency

inspections during interim audit period

Good 0 1 12 months Generally Satisfactory

1 interim visit 1

Improvement necessary

Within1 month 1 3 months

Urgent Improvement necessary

Within 1 month 1 2 months

7

Key proposal(s)

Preferred options for a new audit system in relation to

bull Risk ratings - It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are

bull Use of evidence - Current descriptions of compliance given to each audit question audit section - active broad weak and poor - are considered vague in terms of objectivity of scoring It is proposed that these are changed to minor major and critical non-compliances drawing on approaches used in alternative audit systems with these underpinned by objective requirements and evidence

bull Audit outcomes ndash four new compliance ratings are proposed on audit outcomes - good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit - It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Consultation Process

15There has been ongoing communication with stakeholders during development of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal These meetings have informed this consultation and the accompanying IA

16This consultation seeks your views on the key changes listed in the above box A number of key questions are set out in the box below We would also be interested in your comments about any other aspect of the proposal which you would like to bring to our attention

17This consultation has been issued by the FSA on a UK basis to all identified stakeholders including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered

8

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 5: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Definitions proposed

Score Description

Compliant Compliance with a food safety programme food regulatory requirements and animal health and welfare regulations (in the case of slaughterhouses) is achieved if the food business is operating in accordance with its food safety management systems food safety standards and has met the requirements of the regulations

Minor non A non-compliance that is not likely to compromise public health compliance (including food safety) animal health and welfare or lead to the

handling of unsafe or unsuitable food A minor non-compliance is an isolated low risk situation and does not compromise achieving control measures of the food safety program ie overall the food safety program is still effective in controlling the food safety hazards When viewed collectively a number of related minor non-compliances may represent a major nonshycompliance

Major non A major non-compliance is a non-compliance that is likely to compliance compromise public health (including food safety) animal health

and welfare or may lead to the production and handling of unsafe or unsuitable food if no remedial action is taken When viewed collectively a number of related major non-compliances may represent critical non-compliance

Critical non compliance

A critical non-compliance is non-compliance where the contravention poses an imminent and serious risk to public health (including food safety) animal health or welfare

11Audit outcomes ndash The current compliance descriptions of active broad weak and poor are used to provide outcomes of audits but to make audit outcomes more transparent alternative outcomes have been considered Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit (so the compliance scores for each question and overall section of the audit) and reflect the extent and effectiveness of compliance with four compliance ratings ndash good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system and audit outcomes are outlined in the table below and we have taken into account a comparison to the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises under Local Authority control

5

Audit Outcome proposal

Compliance rating Description Comparison to Food Comparison toHygiene Rating Food Hygiene

Scheme (England Information Wales and Northern Scheme

Ireland) (Scotland) Good No issues of significance

for public health animal health or animal welfare during the entire audit period

Generally Satisfactory

No issues of significance for public health animal health or animal welfare identified on the day of the audit Any nonshycompliances identified during the audit period corrected promptly

Improvement necessary

Major non-compliances identified at audit andor non-compliances during the audit period not always responded to and corrected promptly

Urgent Improvement necessary

Multiple major nonshycompliances or critical non-compliance identified during audit visit or interim audit period Official intervention required to ensure public health safeguards

12Audit Frequencies ndash Frequency of audit is not prescribed in EU regulations General obligations with regard to the organisation of official controls under Regulation (EC) 8822002 are provided in Article 3 and bring out that these controls should be carried out regularly on a risk basis and with appropriate frequency The official controls may be carried out without prior warning - except in cases such as audit where prior notification may be necessary

13Under the current system frequencies of audits vary between a minimum of once every two three five eight or twelve months ndash depending on overall audit scores Eight months is typically the ceiling level for slaughterhouses and cutting plants In working up audit options the following factors were considered relevant

bull The need to focus activities on problematic plants especially with follow-up visits ensuring an appropriate level of consideration and having objective evidence available in the event of a need to review approval

bull Employing effectively focused partial audits to address audit findings bull Reducing regulatory burdens for good performers

6

bull Providing an incentive for businesses to do things well widening the frequency for those that are performing well compared to those that are not

bull Balancing follow-up audit visits (partial audits) and unannounced inspections to maintain assurances on food business operator performance

14There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit Full audit frequency

Good 0 18 months Generally satisfactory 1 interim visit 12 months Improvement necessary Within 1 month 3 months Urgent Improvement necessary

Within 1 month 2 months

Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial Minimum number Full audit audit of unannounced frequency

inspections during interim audit period

Good 0 1 12 months Generally Satisfactory

1 interim visit 1

Improvement necessary

Within1 month 1 3 months

Urgent Improvement necessary

Within 1 month 1 2 months

7

Key proposal(s)

Preferred options for a new audit system in relation to

bull Risk ratings - It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are

bull Use of evidence - Current descriptions of compliance given to each audit question audit section - active broad weak and poor - are considered vague in terms of objectivity of scoring It is proposed that these are changed to minor major and critical non-compliances drawing on approaches used in alternative audit systems with these underpinned by objective requirements and evidence

bull Audit outcomes ndash four new compliance ratings are proposed on audit outcomes - good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit - It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Consultation Process

15There has been ongoing communication with stakeholders during development of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal These meetings have informed this consultation and the accompanying IA

16This consultation seeks your views on the key changes listed in the above box A number of key questions are set out in the box below We would also be interested in your comments about any other aspect of the proposal which you would like to bring to our attention

17This consultation has been issued by the FSA on a UK basis to all identified stakeholders including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered

8

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 6: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Audit Outcome proposal

Compliance rating Description Comparison to Food Comparison toHygiene Rating Food Hygiene

Scheme (England Information Wales and Northern Scheme

Ireland) (Scotland) Good No issues of significance

for public health animal health or animal welfare during the entire audit period

Generally Satisfactory

No issues of significance for public health animal health or animal welfare identified on the day of the audit Any nonshycompliances identified during the audit period corrected promptly

Improvement necessary

Major non-compliances identified at audit andor non-compliances during the audit period not always responded to and corrected promptly

Urgent Improvement necessary

Multiple major nonshycompliances or critical non-compliance identified during audit visit or interim audit period Official intervention required to ensure public health safeguards

12Audit Frequencies ndash Frequency of audit is not prescribed in EU regulations General obligations with regard to the organisation of official controls under Regulation (EC) 8822002 are provided in Article 3 and bring out that these controls should be carried out regularly on a risk basis and with appropriate frequency The official controls may be carried out without prior warning - except in cases such as audit where prior notification may be necessary

13Under the current system frequencies of audits vary between a minimum of once every two three five eight or twelve months ndash depending on overall audit scores Eight months is typically the ceiling level for slaughterhouses and cutting plants In working up audit options the following factors were considered relevant

bull The need to focus activities on problematic plants especially with follow-up visits ensuring an appropriate level of consideration and having objective evidence available in the event of a need to review approval

bull Employing effectively focused partial audits to address audit findings bull Reducing regulatory burdens for good performers

6

bull Providing an incentive for businesses to do things well widening the frequency for those that are performing well compared to those that are not

bull Balancing follow-up audit visits (partial audits) and unannounced inspections to maintain assurances on food business operator performance

14There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit Full audit frequency

Good 0 18 months Generally satisfactory 1 interim visit 12 months Improvement necessary Within 1 month 3 months Urgent Improvement necessary

Within 1 month 2 months

Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial Minimum number Full audit audit of unannounced frequency

inspections during interim audit period

Good 0 1 12 months Generally Satisfactory

1 interim visit 1

Improvement necessary

Within1 month 1 3 months

Urgent Improvement necessary

Within 1 month 1 2 months

7

Key proposal(s)

Preferred options for a new audit system in relation to

bull Risk ratings - It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are

bull Use of evidence - Current descriptions of compliance given to each audit question audit section - active broad weak and poor - are considered vague in terms of objectivity of scoring It is proposed that these are changed to minor major and critical non-compliances drawing on approaches used in alternative audit systems with these underpinned by objective requirements and evidence

bull Audit outcomes ndash four new compliance ratings are proposed on audit outcomes - good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit - It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Consultation Process

15There has been ongoing communication with stakeholders during development of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal These meetings have informed this consultation and the accompanying IA

16This consultation seeks your views on the key changes listed in the above box A number of key questions are set out in the box below We would also be interested in your comments about any other aspect of the proposal which you would like to bring to our attention

17This consultation has been issued by the FSA on a UK basis to all identified stakeholders including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered

8

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

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C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

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DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

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FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

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HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

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KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

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MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

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PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

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SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

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TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 7: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

bull Providing an incentive for businesses to do things well widening the frequency for those that are performing well compared to those that are not

bull Balancing follow-up audit visits (partial audits) and unannounced inspections to maintain assurances on food business operator performance

14There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit Full audit frequency

Good 0 18 months Generally satisfactory 1 interim visit 12 months Improvement necessary Within 1 month 3 months Urgent Improvement necessary

Within 1 month 2 months

Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial Minimum number Full audit audit of unannounced frequency

inspections during interim audit period

Good 0 1 12 months Generally Satisfactory

1 interim visit 1

Improvement necessary

Within1 month 1 3 months

Urgent Improvement necessary

Within 1 month 1 2 months

7

Key proposal(s)

Preferred options for a new audit system in relation to

bull Risk ratings - It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are

bull Use of evidence - Current descriptions of compliance given to each audit question audit section - active broad weak and poor - are considered vague in terms of objectivity of scoring It is proposed that these are changed to minor major and critical non-compliances drawing on approaches used in alternative audit systems with these underpinned by objective requirements and evidence

bull Audit outcomes ndash four new compliance ratings are proposed on audit outcomes - good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit - It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Consultation Process

15There has been ongoing communication with stakeholders during development of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal These meetings have informed this consultation and the accompanying IA

16This consultation seeks your views on the key changes listed in the above box A number of key questions are set out in the box below We would also be interested in your comments about any other aspect of the proposal which you would like to bring to our attention

17This consultation has been issued by the FSA on a UK basis to all identified stakeholders including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered

8

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 8: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Key proposal(s)

Preferred options for a new audit system in relation to

bull Risk ratings - It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are

bull Use of evidence - Current descriptions of compliance given to each audit question audit section - active broad weak and poor - are considered vague in terms of objectivity of scoring It is proposed that these are changed to minor major and critical non-compliances drawing on approaches used in alternative audit systems with these underpinned by objective requirements and evidence

bull Audit outcomes ndash four new compliance ratings are proposed on audit outcomes - good generally satisfactory improvement necessary or urgent improvement necessary The proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit - It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

Consultation Process

15There has been ongoing communication with stakeholders during development of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal These meetings have informed this consultation and the accompanying IA

16This consultation seeks your views on the key changes listed in the above box A number of key questions are set out in the box below We would also be interested in your comments about any other aspect of the proposal which you would like to bring to our attention

17This consultation has been issued by the FSA on a UK basis to all identified stakeholders including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered

8

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 9: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Questions asked in this consultation

Q1 Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate If not please provide information to support your answer

Q2 Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence do you support the new descriptors If not please provide information to support your answer

Q3 Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments - so businesses will either be given a compliance rating of good generally satisfactory improvement necessary or urgent improvement necessary - depending on compliance and standards assessed through the audit

b) Are audit outcomes sufficiently clear and easy to understand If not please suggest alternative wording

Q4Audit Frequencies

a) Do you support the proposed new audit frequencies noting that less compliant businesses will be audited more frequently and also have further unannounced inspections and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months while this is extended to 18 months in premises with a routine presence and achieving good standards

18We welcome comments from all stakeholders Please send your response by email or post using the contact details given All responses received as part of this consultation will be given careful consideration they will be summarised and published on the FSArsquos website within three months of the close of the consultation

Responses

19Responses are required by close 16th May 2014 Please state in your response whether you are responding as a private individual or on behalf of an organisationcompany (including details of any stakeholders your organisation represents)

9

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 10: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Thank you on behalf of the Food Standards Agency for participating in this public consultation

Yours

Name - Kenneth Thoresen Branch - FSA Operations Group Division - Operations Assurance Division

Enclosed

Annex A Standard Consultation Information

Annex B Impact Assessment

Annex C List of interested parties

10

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 11: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Annex A

Queries

1 If you have any queries relating to this consultation please contact the person named on page 1 who will be able to respond to your questions

Publication of personal data and confidentiality of responses

2 In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140) The FSA will publish a summary of responses which may include your full name Disclosure of any other personal data would be made only upon request for the full consultation responses If you do not want this information to be released please complete and return the Publication of Personal Data form which is on the website at httpwwwfoodgovukmultimediaworddocsdataprotectiondoc Return of this form does not mean that we will treat your response to the consultation as confidential just your personal data

3 In accordance with the provisions of Freedom of Information Act 2000Environmental Information Regulations 2004 all information contained in your response may be subject to publication or disclosure If you consider that some of the information provided in your response should not be disclosed you should indicate the information concerned request that it is not disclosed and explain what harm you consider would result from disclosure The final decision on whether the information should be withheld rests with the FSA However we will take into account your views when making this decision

4 Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request with an explanation in the main text of your response

Further information

5 A list of interested parties to whom this letter is being sent appears in Annex C Please feel free to pass this document to any other interested parties or send us their full contact details and we will arrange for a copy to be sent to them direct

6 Please contact us for alternative versions of the consultation documents in Braille other languages or audiocassette

7 Please let us know if you need paper copies of the consultation documents or of anything specified under lsquoOther relevant documentsrsquo

8 This consultation has been prepared in accordance with HM Government consultation principles1F

2

9 An Impact Assessment will normally be published alongside a formal consultation Please see the Impact Assessment at Annex B

10For details about the consultation process (not about the content of this consultation) please contact Food Standards Agency Consultation Co-ordinator Room 2A Aviation House 125 Kingsway London WC2B 6NH Tel 020 7276 8140

2 httpwwwbisgovukpoliciesbreconsultation-guidance 11

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 12: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Comments on the consultation process itself

11We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process If you would like to help us improve the quality of future consultations please feel free to share your thoughts with us by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc

12If you would like to be included on future Food Standards Agency consultations on other topics please advise us of those subject areas that you might be specifically interested in by using the Consultation Feedback Questionnaire at httpwwwfoodgovukmultimediaworddocsconsultfeedbackdoc The questionnaire can also be used to update us about your existing contact details

12

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 13: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Title

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN THE UK IA No 0048

Lead department or agency

Food Standards Agency Other departments or agencies

Impact Assessment (IA)

Date 20022014

Stage Consultation

Source of intervention Domestic

Type of measure Other Contact for enquiries Kenneth Thoresen 07789877601 KennethThoresenfoodstandardsgsigovu k

Summary Intervention and Options RPC Opinion RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present Value

pound181

Business Net Present Value

pound081

Net cost to business per year (EANCB on 2009 prices)

-pound008

In scope of One-In Two-Out

Measure qualifies as

No OUT What is the problem under consideration Why is government intervention necessary

Food can pose a risk to human health if it is not produced manufactured and handled hygienically Meat Premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations The FSA is the central competent authority responsible for these audits The current system has been in place and remained unchanged since its introduction in 2006 A fundamental review of the audit system for approved meat plants has now been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives

What are the policy objectives and the intended effects

To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

What policy options have been considered including any alternatives to regulation Please justify preferred option (further details in Evidence Base)

Two options have been considered

Policy option 1 ndash Do Nothing ndash the current audit arrangements remain in place Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Option 2 is the preferred option as it is a risk-based approach in which the audit frequency awarded is a reflection of the FSArsquos confidence in the controls demonstrated by the FBOs to produce safe meat

Will the policy be reviewed It will be reviewed If applicable set review date 072014 Does implementation go beyond minimum EU requirements Yes No NA Are any of these organisations in scope If Micros not exempted set out reason in Evidence Base

Micro Yes

lt 20 Yes

Small Yes

Medium Yes

Large Yes

What is the CO2 equivalent change in greenhouse gas emissions (Million tonnes CO2 equivalent)

Traded Non-traded

I have read the Impact Assessment and I am satisfied that given the available evidence it represents a reasonable view of the likely costs benefits and impact of the leading options

20thSigned by the responsible FSA Director Date February 2014

1

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 14: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Summary Analysis amp Evidence Policy Option 1Description DO NOTHING

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate 0

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised costs by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional Optional Optional

High Optional Optional Optional

Best Estimate 0 0 0

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Other key non-monetised benefits by lsquomain affected groupsrsquo

There are no monetised incremental costs or benefits associated with this option This is the baseline against which the other option is assessed

Key assumptionssensitivitiesrisks Discount rate () 35 Continued use of the current audit system would retain a large FSA footprint across all UK meat plants rather than to focus resource on poor performers to improve their behaviour and drive up their compliance

BUSINESS ASSESSMENT (Option 1)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs 0 Benefits 0 Net 0 No Zero net cost

2

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

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ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

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C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

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DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

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FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

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HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

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KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

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MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

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PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 15: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Summary Analysis amp Evidence Policy Option 2Description IMPLEMENTATION OF PROPOSALS IN LINE WITH FINDINGS OF THE REVIEW OF AUDIT ARRANGEMENTS IN FSA-APPROVED MEAT PLANTS

FULL ECONOMIC ASSESSMENT

Price Base Year 2012

PV Base Year 2013

Time Period Years 10

Net Benefit (Present Value (PV)) (poundm)

Low Optional High Optional Best Estimate pound181

COSTS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Cost (Present Value)

Low Optional

1

Optional Optional

High Optional Optional Optional

Best Estimate pound006 pound0 pound006

Description and scale of key monetised costs by lsquomain affected groupsrsquo

Food Standards Agency one-off costs familiarisation of pound37799 (PV pound37799 over ten years) Industry one-off costs familiarisation cost of pound27090 (PV pound27090 over ten years)

Other key non-monetised costs by lsquomain affected groupsrsquo

None identified

BENEFITS (poundm) Total Transition (Constant Price) Years

Average Annual (excl Transition) (Constant Price)

Total Benefit (Present Value)

Low Optional

NA

Optional Optional

High Optional Optional Optional

Best Estimate NA pound022 pound188

Description and scale of key monetised benefits by lsquomain affected groupsrsquo

Food Standards Agency ongoing benefits Reduction of 258 audits per annum representing an annual saving of pound80828 (pound695738 in PV over 10 years) Reduction in discount payments of pound40425 per annum (PV pound347961 over ten years) Industry ongoing benefits Time saving from a reduction in number of audits per annum pound56667 (PV of pound487773 over ten years) Reduction of inspection (audit) charges to the UK meat industry of pound40415 (pound347876 in PV over 10 years)

Other key non-monetised benefits by lsquomain affected groupsrsquo

Greater incentive through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve Reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Recognise higher-performing FBOs by undertaking fewer audits and therefore reducing inspection charges Demonstrable evidence provided from which to focus operational resource on poor performing FBOs Provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

Key assumptionssensitivitiesrisks Discount rate () 35 The proposal will generate benefits to enforcement and industry from a reduction in the overall frequency of audits

BUSINESS ASSESSMENT (Option 2)

Direct impact on business (Equivalent Annual) poundm In scope of OITO Measure qualifies as

Costs pound0 Benefits pound01 Net pound01 No INOUTZero net cost

3

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 16: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Evidence Base

1 Problem under consideration and rationale for intervention

11 Food can pose a risk to human health if it is not produced manufactured and handled hygienically The Food Standards Agency (FSA) is the central competent authority for food safety from farm to fork in the UK and as such has responsibility for the delivery of official controls across the food chain

12 Meat premises are subject to official control audits carried out with prior warning to ensure compliance with hygiene regulations A fundamental review of the FSA system of official control audits for approved meat plants has been undertaken in consultation with industry to ensure the effectiveness of the system is maintained and that it reflects the FSArsquos revised strategic objectives A review was considered timely as the current audit system has largely remained unchanged since its introduction in 2006

2 Policy objectives and intended effects

21 To ensure that the FSA audit system for approved meat plants is proportionate risk-based and reflective of earned recognition principles and that the process is understandable transparent and effective The intended effect is a suitably robust audit system that provides assurance with regard to the accuracy and consistency of audit assessments whilst reflecting confidence in the controls demonstrated by Food Business Operators (FBOs) where evidence of consistent performance is available by recognising better-performing plants and enabling the FSA to target resources at premises most in need of further support to help drive up compliance

3 Policy Background

31 The Current Review

311 The FSA has recently carried out a review of audit arrangements for meat premises across the UK The review findings were reported to the FSA Board on January 21st 2014

312 The review was carried out on a UK-wide basis However it is appreciated that there are differences within the four countries ndash with meat controls delivered on the FSArsquos behalf by the Department of Agriculture and Rural Development (DARD) in Northern Ireland and the establishment of the National Food Body in Scotland in April 2015 potentially influencing how changes are implemented in these countries and the nature of those changes

313 Aspects included in the review were auditor training audit focus and approach risk of establishment reporting of outcomes addressing contraventions and auditing An analysis of other countriesrsquo auditing systems and Food and Veterinary Office audits as well as third party accreditation bodies found that organisations had similar audit requirements However a number of differences were found

Third Party audits have quality requirements within their standards

Other EU member states audit frequencies varied up to 2 years for meat establishments The Food and Veterinary Office focused on member states conducting audits as laid down in their individual National Control Plan and did not comment on the frequency established

4

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 17: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

314 The key recommendations were that

bull Risk ratings - the frequency of audits is based on risks that are fully and properly assessed during the audit process or on pre-set factors based on potential hazards

bull Use of evidence - current descriptions of compliance (rsquoActiversquo rsquoBroadrsquo lsquoWeakrsquo and rsquoPoorrsquo) are changed to lsquoCompliantrsquo rsquoMinorrsquo rsquoMajorrsquo and Criticalrsquo non-compliances which draws on approaches used in alternative audit systems

bull Audit outcomes ndash new compliance ratings should be established namely lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo The grading system descriptions should be comparable to those in the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises

bull Frequency of audit ndash Audit frequencies should recognise good business performance and further allow focused oversight of poorer performing premises It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by FSA officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved

32 The Existing Audit System

321 European food hygiene regulations (Regulations (EC) No 8522004 and 8532004) set out food hygiene requirements with which food businesses must comply Regulation (EC) No 8542004 sets out the requirements for official controls on products of animal origin Regulation (EC) No 8822004 on official feed and food controls requires that official controls are carried out without prior warning except in the cases such as audits where prior notification of the FBO is necessary The proposed audit system aims to maintain the announced (as required for audit) and unannounced inspection in line with the ad hoc basis of inspections and audit revisit element if official controls based on findings and risk from the audit process

322 The scoring of audit questions and overall section scores is favoured due to the underpinning objective requirements utilising minor major and critical definitions as objective evidence which relate directly to the effect on public health and animal health and welfare

323 The current frequency of audit reporting is determined on a risk basis assessed in part on the outcome of previous audits The scheme has five levels of audit frequency ranging from 2 to 12 monthly intervals Table 1 lists the minimum audit frequencies applicable to all types of food establishments 8 month audit category is effectively a ldquoCeiling Levelrdquo for slaughterhouses and cutting plants

5

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 18: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Table 1 Current Audit frequencies and ceiling level

Audit Category Points Range Minimum Audit Frequency

12 month 8 month 5 month 3 month 2 month

0-50 55-85 90-105

110-150 155+

At least once every 12 months At least once every 8 months At least once every 5 months At least once every 3 months At least once every 2 months

324 The current auditing system is in two parts with the first applying scores based on potential hazards (or pre-set factors) and the second based on effectiveness of systems in place Scores are combined to give an overall audit score which determines how frequently an establishment is audited Taking potential hazards into account many premises end up on more frequent audits because of their throughput because they are processing more than one species of animal or due to the processes carried out This is regardless of how well these risks are minimised or how effective control systems are The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments on the evidence of effectiveness during the actual audit process and not only based on potential hazards

33 Proposed Changes to the Existing Audit system

331 The recommendation arising from the findings of the review was that the frequency of meat plant audits for better performers across the UK should be reduced based on audit outcomes and that non-compliance should be effectively dealt with and continued compliance verified via unannounced inspections and partial focused follow up audit revisits triggered by findings of concern during the main audit To enable this to happen risk ratings and use of objective evidence to determine an understandable audit outcome have been realigned The aim is to continually drive compliance through effective audit and publishing information on audit outcomes that are understandable

332 The new frequencies proposed set out as follows utilise existing unannounced inspection rationale and follow up partial audits to provide further assurances

Table 2 Proposed audit frequencies for slaughterhouseco-located cutting plants and approved game handling establishments

Audit outcome Follow up partial audit

Full audit frequency

Good Generally Satisfactory Improvement necessary Urgent Improvement necessary

0 1 interim visit

Within 1 month Within 1 month

18 months 12 months 3 months 2 months

6

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 19: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Table 3 Proposed audit frequencies for standalone cutting plants

Audit outcome Follow up partial audit

Minimum number of

unannounced inspections

during interim audit period

Full audit frequency

Good 0 1 12 months Generally Satisfactory 1 interim visit 1 Improvement necessary Within1 month 1 3 months Urgent Improvement necessary

Within 1 month 1 3 months

333 For slaughterhouses with or without cutting plants and approved game handling establishments where there is routine attendance by officials there is the possibility of achieving an 18-month audit frequency where good standards are being achieved There is no routine official presence in standalone cutting plants and for this reason it is proposed that twelve months remains the maximum audit frequency

334 Meat plants with an audit outcome of lsquoImprovement Necessaryrsquo and lsquoUrgent Improvement Necessaryrsquo will have an audit frequency of 3 and 2 months respectively which emulates the current 3 and 2 months for lsquoWeakrsquo and lsquoPoorrsquo audit outcomes and allows a targeted approach to inspecting meat establishments which are not performing as expected

34 Supplementary Analysis of Other Audit Systems

341 To strengthen how evidence may be drawn upon and used to assess overall FBO performance the current descriptors of lsquoActiversquo lsquoBroadrsquo lsquoWeakrsquo or lsquoPoorrsquo compliance are considered vague as they are not easy to understand A number of audit systems have been researched to inform an alternative approach

342 The risk from meat plant processing can be realigned to findings during the audit process The proposals therefore seek to redress this and introduce a risk-based audit regime focused on audit outcomes taking assurance from objective information as evidence setting during audit

343 Further analysis was then carried out to assess the similarities and differences between the outcome of official control audits across member states and Australia Canada New Zealand and UK third party audit schemes in terms of the auditing arrangements and systems The aim of this project was to inform the feasibility and extent to which the auditing of meat establishments could be changed to decide the frequency of official controls whilst providing understandable audit outcomes which are published

344 Data on inspectionsaudits were drawn together from various sources including FVO audit reports of Member States and third party accreditation bodies and underwent a matching exercise The analysis involved matching individual audit requirements and comparing the outcome of the most recent visit from each audit scheme

7

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 20: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

345 The main conclusions of the analysis are that

There appears to be a general correlation between the risk assessments audit scoring and frequencies of the schemes across other countries and third party schemes

It is clear that we needed to ensure that audits are carried out objectively and by competent and suitably-qualified auditors to ensure a consistent approach and that audit findings are accepted and trusted

The auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections

Using objective evidence it is proposed that a grading system is introduced which will consider the number and type of non-compliances identified during an audit and reflect the extent and effectiveness of compliance with four compliance ratings ndash lsquoGoodrsquo lsquoGenerally Satisfactoryrsquo lsquoImprovement Necessaryrsquo or lsquoUrgent Improvement Necessaryrsquo

Audit frequencies should appropriately target those businesses presenting a higher risk and recognise those businesses achieving good standards

346 The FSA considers that the categorisation of meat establishments into four risk bands from audit outcomes with underpinning objective evidence during audit can be supported in terms of risk to public health Meat establishments should be subject to an inspection frequency based on all available evidence with unannounced inspections and partial audits in place to provide further assurances

35 Impact of the Change

Reduction in Audit Hours

351 The proposed new audit frequencies will result in an overall reduction in hours required for audits This impact is outlined in this section Table 4 gives an overview over the total number of audit hours under the current system and the associated costs As can be seen current auditing time accounts for about 4 of total Official Veterinarians hours recorded December 2012 ndash November 2013

Table 4 ndash Total audit hours and costs December 2012 ndash November 2013

Total Audit hours

recorded 2013 - 2014

Cost per hour for GB (Official Veterinarian) amp NI (Official

Veterinarian + Meat Inspector)

Total actual cost of FSA audits 2012 - 2013

GB 1757875 pound3680 pound646898 NI 3491085 pound3881 pound135473 Total 2106984 pound782371

352 Tables 5 to 10 show the impact of the proposal in terms of changes to audit frequency by establishment type The breakdown of audit frequencies under the current audit frequency arrangements and proposed audit frequency is calculated on the basis of audit outcomes for the period December 2012 ndash November 2013 1110 establishments were audited during this period

8

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 21: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Table 5 - Current audit frequencies January 2013 ndash December 2013

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 3 33 62 46 0 Slaughterhouse and

Collocated Cutting Plant 2 75 143 41 0

Stand Alone Cutting Plant 1 42 337 322 2 Total 6 150 542 409 2

Table 6 - Audit frequencies projected under the new audit frequency arrangements

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse 19 19 NA NA 101 5 Slaughterhouse and Collocated Cutting

Plant

41 34 NA NA 185 1

Stand Alone Cutting Plant

29 49 NA NA 579 47

Total 89 102 NA NA 865 53

Table 7 - Percentage of establishments by audit frequency under the old audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 m

on

ths

8 m

on

ths

12

mo

nth

s

Slaughterhouse 027 297 55 414 0 Slaughterhouse and Collocated Cutting

Plant 018 676 1289 369 0

Stand Alone Cutting Plant

009 378 3038 2903 018

9

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 22: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Table 8 - Percentage of establishments by audit frequency under the proposed audit system

Establishment type

2 m

on

ths

3 m

on

ths

5 M

on

ths

8 M

on

ths

12

mo

nth

s

18

mo

nth

s

Slaughterhouse Game Handling Establishment

171 171 NA NA 910 045

Slaughterhouse and Collocated Cutting

Plant 369 306 NA NA 1668 009

Stand Alone Cutting Plant

262 441 NA NA 5220 423

Table 9 ndash Average hours per establishment type for auditing

Establishment type Average audit time (hours)

Slaughterhouse Game Handling Establishment

761

Slaughterhouse and Collocated Cutting Plant

1054

Stand Alone CP 737

353 Shifting to proposed audit frequencies reduces the audit hours requirement The calculation is based on a 12 month period where all establishments are aligned to the new audit frequencies The calculation is worst case scenario as there is an expectation that establishments in the lower audit frequencies will improve and reach higher frequencies of audit Table 10 shows that the impact of the proposal is an overall reduction in hours required for audits from 17578 hours under the current system to 15382 hours under the new system ie a total reduction of 258 audits per annum The new system enables enforcement authorities to focus on poorer-performing establishments This means that some better-performing establishments will be subject to fewer audits and some poorer-performing establishments will be subject to more frequent audits The net impact of the proposal is however an overall reduction in audits which will benefit both the FSA and industry

10

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 23: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Table 10 ndash Total number of Audit Hours under the proposed audit frequencies

Establishment type

2

mo

nth

3 m

on

ths

12

mo

nth

s

18

mo

nth

s

Hours of audit (frequency)

Slaughterhouse 19 x 6 audits 761 hours

19 x 4 audits 761 hours

101 x 1 audit 761 hours

25 x 1 audit 761 hours

86754 (2) 57836 (3) 76861 (12) 1902 (18)

Slaughterhouse and Collocated Cutting Plant

41 x 6 audits 1054 hours

34 x 4 audits 1054 hours

185 x 1 audit 1054 hours

05 x 1 audit 1054 hours

259284 (2) 143344 (3) 19499 (12) 527 (18)

Stand Alone Cutting Plant

29 x 6 audits 737 hours

49 x 4 audits 737 hours

579 x 1 audits 737 hours

235 x 1 audits 737 hours

128238 (2) 144452 (3) 426723 (12) 17319 (18)

Total hours = 153823

Reduction in Audit Hours and the Discount Process

354 The proposed changes will also generate a reduction in the costs of audits both to the FSA and to food businesses FBOs pay for having the competent authority carrying out an audit of their establishments As outlined in the previous section we estimate that the proposal would generate a reduction in the number of audit inspection hours from 17579 to 15382 a total reduction of 2196 hours

355 FBOs dependent on throughput and official control time recorded at individual establishmentrsquos results in discounts being applied These discounts are variable dependent on individual meat establishmentsrsquo profile The average discount across UK meat sectors is 50

356 In practice FBOs only pay a percentage of the pound3680 per audit inspection hour The following 3 tables illustrate the actual percentage of discount applied to different types of establishment across the UK For example the first table shows that 7 game handling establishments received a discount of between 30 to 309 3 of which were in England and 4 in Scotland

11

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 24: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

12

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 25: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

4 Stakeholder Consultation

41 Further work within the audit review engaged the meat industry on their experience of the audit system and suggestions for change with feedback drawn from workshops and views of other government departments particularly agriculture departments given that audit arrangements in slaughterhouses also cover animal health and welfare

5 Description of options considered

51 Two options have been considered

Policy Option 1 ndash Do Nothing ndash the current audit arrangements remain in place

Policy Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

52 Option 2 is the FSArsquos preferred option as it is a consistent risk-based approach which provides an incentive for FBOs to do things well by widening the frequency for those that are performing well compared to those that are not The additional inspections provide assurances within the meat supply chain which in turn reduces the burden on business while maintaining consumer protection Under this option a consistent and proportionate audit outcome is planned to be introduced in the UK from July 2014 for official controls auditing in approved meat establishments This auditing system will make use of additional assurance controls for meat establishments which already exist by means of unannounced inspections and partial re- audits

53 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits become due under current requirements Meat establishments will shift to the new audit arrangements on the due audit date It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

54 Although there are no changes in EC regulations if Option 2 is chosen the guidance for auditors of approved establishments contained in Chapter 4 of the Manual for Official Controls will be revised to implement the changes

6 Sectors and Groups Affected

61 Industry

61 The proposal will have an impact on approved slaughterhouses co-located cutting plants standalone cutting plants and game handling establishments These establishments will incur familiarisation costs as they will need to be aware of the changes We also envisage that the proposal will generate benefits to these establishments in terms of a reduced time required for audits as well as a reduction in the total cost of audits

13

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 26: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Table 11 ndash Total number of approved meat establishments in the UK

Establishment type England Wales Scotland Northern Ireland

Totals

Slaughter House amp Game Handling Establishment

106 5 10 3 124

Collocated slaughter House and Cutting Plant

198 22 34 18 272

Stand Alone Cutting Plant

582 36 57 38 713

Totals 886 63 101 59 1109

62 Food Standards Agency

621 The proposal will impact on FSA enforcement officers This includes meat hygiene inspectors and Official Veterinarians as well as service delivery mangers and lead veterinarians (GB) and divisional veterinary officerssupervisory veterinary officers which are their equivalents in NI These officers will incur familiarisation costs as they will need to become familiar with and understand the changes through reading the Manual for Official Controls and associated guidance We also envisage that the proposal will result in a time saving to these officers from reduced time required for audits as well as a reduction in the costs of audits Table 12 below shows the number of officials affected in the UK whilst Table 13 shows their associated charge out rates

Table 12 ndash Number of enforcement officials affected in the UK

Officials England Wales

Scotland Northern Ireland

Meat Hygiene Inspectors 843 5 Official Veterinarians 309 6 Service Delivery Managers 34 -Lead Veterinarians 17 -Senior Meat Inspector - -

Divisional Veterinary Officer Supervisory Veterinary Officer -

4

Total 1203 15

14

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 27: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Table 13 ndash Charge out rate by occupational group

Officials England Wales

Scotland

Northern Ireland

Meat Hygiene Inspectors pound2850 pound2850 pound2720 Official veterinarians pound3680 pound3680 pound4423 Service Delivery Managers pound3160 pound3160 -Lead Veterinarians pound4325 pound4325 -Senior Meat Inspector - - pound3071 Divisional Veterinary Officer Supervisory Veterinary Officer - - pound4772

622 We envisage that there will be no cost to FSA for IT solutions as the existing audit database will be used and the higher frequency of audit will actually result in less administrative time inputting to the system We envisage that the proposal will generate benefits in terms of lower costs of audits as discounts may decrease

7 Cost and benefits of Options

71 Option 1 ndash Do nothing - the current inspection arrangements remain in place

Costs and Benefits

711 There are no costs or benefits associated with this option This is the baseline against which the policy option (Option 2) is appraised

72 Option 2 ndash Implement the proposals of the review recognising the additional controls and assurances within the meat supply chain by better performing FBOs when setting audit frequencies

Costs and Benefits

721 Costs to Industry

7211 Familiarisation Costs (One-Off Costs) There are 1109 approved meat establishments in the UK The new audit arrangements place no new obligations on FBOs However we expect that most managers will wish to familiarise themselves with the new audit procedures that officials are undertaking in their establishments Familiarisation costs can be quantified by multiplying the wage rate of the individual carrying out the familiarisation by the number of hours required for familiarisation It is our assumption that it will be the meat establishment manager (wage rate of pound2581) that will familiarise himselfherself and that familiarisation would take approximately 1 hour per meat premises This generates a total cost of familiarisation to meat establishments of pound27090

7212 In order for one-off costs to be compared to annual costs on an equivalent basis across the time span of the policy one-off costs are converted into

1 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

15

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 28: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Equivalent Annual Costs (EACs) by dividing the one-off cost by an annuity factor2

The total one-off familiarisation cost under this proposal is pound27090 which generates a total EAC of pound3147 Table 14 below shows both the total familiarisation cost to industry and the associated EAC with this proposal

Table 14 ndash FB0 Familiarisation Costs UK wide (pound) is

pound

FBO Familiarisation Cost pound27090 EAC pound3147

722 Costs to the Food Standards Agency

7221 Familiarisation cost (One-Off Cost) The new amendment will generate a familiarisation cost to enforcement officers who will need to familiarise themselves with the new changes Familiarisation costs can be monetised by multiplying the wage rate with the hours required for familiarisation We envisage that it will take an official about one hour to read and familiarise themselves with the changes Multiplying the number of officials in each occupational group (Table 15 below) by their respective Charge out rates (Table 13) and then again by the time required by official (1 hour) generates a total cost of familiarisation of pound37799 to the FSA Table 15 shows total familiarisation costs by country Table 16 shows the associated EACs

Table 15 - Familiarisation cost to the enforcement authority (pound)

Officials Total GB Total NI Totals

Meat Hygiene Inspectors pound2402550 pound13600 pound2416150 Official veterinarians pound1137120 pound26538 pound1163658 Service Delivery Managers pound107440 - pound107440 Lead Veterinarians pound73525 - pound73525 Senior Meat Inspector - - -Divisional Veterinary Officer - pound19088 pound19088 Supervisory Veterinary Officer Total pound3720635 pound59226 pound3779861

Table 16 - Total familiarisation amp equivalent annual cost to the enforcement authority (pound) is

pound

Familiarisation cost pound37799 EACs pound4391

2 The annuity factor is essentially the sum of the discount factors across the time period over which the policy is appraised For a policy with a life span of 10 years and a discount rate of 35 the annuity factor is approximately 86 The equivalent annual cost formula is as follows

1

00

1

1t

j

j

i i

rtr

a

16

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 29: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

723 Benefits to Industry

7231 Time Saving to Industry from Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction in the number of audits required per annum After the change businesses will be subject to 258 fewer audits per annum This is a benefit to businesses which can be monetised in terms of a time saving This benefit to industry arises from a reduction in the time that a FBO needs to allocate to prepare for inspection and deal with officials during the site visit and follow up To calculate this time saving we can multiply the reduction in the number of audits (258) by the average number of hours required per audit (85) and then again by the wage rate of the manager that would need to attend the audit inspection (2583) This generates a total per annum time saving to businesses in the sector of pound56667

Table 17 - Total per annum time saving to businesses due to reduced time required for audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound258 pound56667

7232 Reduced Cost to FBOs from Lower Audit Payments As outlined in paragraphs 7221 to 7321 FBO pay for having an audit carried out on their premises This payment consists of the wage cost of the official present at the audit minus the discount applied by the FSA Currently the average discount across all meat sectors is 50 Under the new proposal the number of audit inspections being carried out per year will be reduced in a phased approach (over an 8 month period) As outlined above we estimate there would be a reduction in the number of audit inspection hours from 17579 to 15382 giving a total per annum reduction of 2196 As shown in Table 18 below this generates a total cost saving to FBOs of pound40415 per annum

Table 18 ndash Cost Saving to FBOs from Lower Cost of Audits

Total Audit hours

(2012-13)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2012 - 2013

Total cost minus average plant

discount (estimated 50)

17579 pound3680 pound646907 pound323453 Total Audit hours

(2013-14)

Cost per hour for Official

Veterinarian

Total actual cost of FSA

audits 2013 - 2014

Total cost minus average plant

discount (estimated 50

Saving from 2012-2013 time

period 15382 pound3680 pound566058 pound283029 pound40415

724 Benefits to the Food Standards Agency

7241 Reduced Time Required for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum This represents a

3 Wage rate obtained from Annual Survey of Hours and Earnings 2012 httpwwwonsgovukonspublicationsre-reference-tableshtmledition=tcm3A77-280149 Median hourly wage rate of lsquoProduction managers and directorsrsquo was used pound1983 plus 30 overheads totalling pound258

17

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

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C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

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DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

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FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

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HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

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KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

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MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

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PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

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SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

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TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 30: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

benefit to enforcement officers which after the change can re-allocate their resources to other activities This benefit can be monetised in terms of a time saving which can be monetised by multiplying the reduction in hours (258) by the average time required for an audit inspection (85) and then again by the wage rate of the official carrying out the audit (pound3680) This generates a total per annum time saving to enforcement of pound80829

Table 19 ndash Time Saving to Industry from Reduced Number of Audits

Reduction in Average number Wage rate Saving from number of hours required per business 2012 ndash 2013

audits audit manager time period

258 85 pound368 pound80702

7242 Reduced Discount Payments for Audits As outlined in paragraph 353 the proposal results in a reduction of 258 fewer audits per annum Under the Audit system FBOs pay for the audits that the FSA carries out on their premises however a discount is applied As shown in Table 18 the total discount paid out to FBOs 2012-13 was pound323453 Under the new system the discount would be reduced to pound283029 which represents an annual reduction of pound40425

Do stakeholders agree with the Agencyrsquos data used to calculate the costs to FSA and FBOs as a result of this policy

725 Wider Benefits (Non-Monetised)

7251 We envisage that the proposal will result in greater incentives through 2 amp 3 monthly audit frequency to encourage underperforming FBOs to improve It will also result in a reduction in FBO escort requirements and preparation for audits and FSA back office audit processing Under the new proposal higher-performing FBOs will be recognised and be subject to fewer audits and therefore reduced inspection charges We envisage that under the new system audits will provide demonstrable evidence on which basis operational resource can be focused on poor performing FBOs It is envisaged that the new system will provide a basis from which to consider a scheme that recognises the input of those FBOs who consistently achieve high levels of compliance and high compliance ratings

726 Summary of Total Costs and Benefits under Option 2

7261 Option 2 generates a total cost to society of pound64889 (PV ten years) and a total cost to industry of pound27090 (PV ten years) These costs consist of familiarisation to industry and the enforcing body The proposal also generates a total benefit to society of pound1779096 (PV of pound1531390 ten years) which consists of time savings to industry and enforcement from fewer audit inspections a benefit to enforcement from a reduced discount payment and a benefit to industry from a lower cost of audit inspections The total benefit to industry is pound970821 (PV of 835652 ten years) The net impact is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years)

18

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 31: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

Table 20 Summary of Total Costs and Benefits under Option 2 (pound)

The Agency welcomes opinions preferably with an evidence backing regarding the assumptions and data used to calculate the costs and benefits

8 Risks and Assumptions

81 The main risk to any change in the delivery of official control audits is that the new system will not afford at least the same level of protection to consumers as that being replaced due to extended audit frequencies There are several manageable risks to the proposals which will be addressed during implementation These will ensure that public protection is maintained and that resources are effectively directed towards the worst-performing establishments by ensuring official controls are appropriate to the level of risk presented by individual establishment

82 Measures will need to be in place to ensure that there is good co-operation between the FSA and the meat industry FSA will lead on the development of these arrangements so that they are in place to support the proposed changes These measures will include

Continued links with industry and consumer groups thus ensuring that adverse audit results are reported fully and promptly with any necessary supplementary information

FSA will identify the level of non-conformance from audit outcomes that will prompt ad-hoc intervention in addition to routine inspection

FSA and industry representation to ensure proactive exchange of information on auditsinspections to improve awareness where standards do not match legislative requirements and resolve differences where there are matters relating to interpretation of those requirements

Refresher training for auditors and inspectors where necessary to ensure they are fully competent to undertake delivery of the new audit scheme

19

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 32: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

83 Other relevant controls are

Routine Unannounced Inspections including inspections to act on food complaint emergency visits following receipt of intelligence eg consumer protests etc will remain as an assurance in between formal systems audits

Monitoring and surveillance to assess compliance eg meat adulteration

Sampling duties for veterinary residues in meat programme

Do stakeholders agree that the actions proposed above will provide at least the same level of protection to consumers as the current policy If not please explain why you think protection will be reduced

9 Summary and preferred option with description of implementation plan

91 Option 2 the FSArsquos preferred option will result in a fall in the number of inspections in UK in terms of hours from 17579 hours to 15382 Average hours to audit all types of meat establishments is 85 hours using 2012 ndash 2013 audit figures therefore a reduction of 258 audits annually is predicted under the proposed audit system The net impact of the proposal is a net benefit to society of pound1466502 (NPV over ten years) and a net benefit to industry of pound460683 (NPV over ten years) (see paragraph 7261 above)

92 The audit system will focus resources on those establishments which have been identified through audit as higher risk and drive effective enforcement action against these establishments The proposals will underpin an enforcement regime which is focussed on driving up standards across the sector and is flexible enough to adapt to future priorities without compromising consumer safety

93 The recommended option aligns with wider Government initiatives including reducing the burden on business by reducing the impact of meat establishmentrsquos visits and streamlining and targeting enforcement activity on the basis of risk

94 The FSA undertook a period of informal consultation meeting with leading members of the meat industry and representatives including the Association Of Independent Meat Suppliers Scottish Association of Meat Wholesalers British Poultry Council and British Meat Processors Association

95 To ensure a smooth transition and the continued protection of public health the new auditing system will be phased in as meat plant audits are due under current requirements and meat establishments will shift to the new audit arrangements on the due audit date Following implementation of the new audit system in July 2014 and pending consultation results it is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

10 Competition Assessments

101 The preferred option may provide an advantage to well-performing meat establishment and will encourage higher-risk meat establishments to increase

20

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

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ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

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C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

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DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

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FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

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HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

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KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

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MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

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PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 33: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

compliance with hygiene regulations it will also make better use of enforcement resources

11 Small Firms Impact Test

111 Small firms are a feature of the meat establishment sector in the UK that will be subject to these proposals Small meat establishments are generally determined by levels of throughput at the establishment and charges for inspections are heavily discounted The preferred option will reduce the inspection burden on these businesses dependent on audit outcomes

12 Sustainable developments

121 Impacts under the three pillars of sustainable development (environmental economic and social) have been and continue to be considered in this Impact Assessment in the main evidence base Option 2 is the relatively more sustainable option because it reduces the costs of inspection on meat establishments that are low risk without compromising consumer safety

122 The number of official inspection journeys and therefore the overall mileage undertaken by those carrying out official control audits will be reduced with a consequent positive effect on the environment

13 One-In Two-Out

131 Because there are no changes in domestic legislation this measure is not within scope of the lsquoone-in two-outrsquo rule

21

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 34: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

List of Interested Parties - Annex C

FOOD STANDARDS AGENCY ndash UK WIDE ASSOCIATION OF INDEPENDENT MEAT

SUPPLIERS SCOTTISH ASSOCIATION OF MEAT

WHOLESALERS BRITISH POULTRY COUNCIL BRITISH MEAT PROCESSORS

ASSOCIATION SCOTTISH FEDERATION OF MEAT

WHOLESALERS ASSOCIATION QUALITY MEAT SCOTLAND NATIONAL CONSUMER ASSOCIATION NATIONAL GAME DEALERS ASSOCIATION HYBU CIG CYMRU (MEAT PROMOTIONS WALES) SMALL ABATTOIRS FEDERATION NATIONAL ASSOCIATION OF CATERING

BUTCHERS HALAL FOOD AUTHORITY MUSLIM COUNCIL OF BRITAIN ISLAMIC CULTURAL CENTRE INTERNATIONAL MEAT TRADE

ASSOCIATION NORTHERN IRELAND MEAT EXPORTERS

ASSOCIATION THE LIVESTOCK AND MEAT COMMISION

FOR NORTHERN IRELAND ASSOCIATION OF MEAT INSPECTORS NATIONAL FARMERS UNION DARDNI DEFRA MEAT TRADES JOURNAL FARMERS WEEKLY CITY OF LONDON CENTRAL MARKETS

AUTHORITY BIRMINGHAM WHOELSALE MART WHERESTHISFROMCOM (IPOD APP) ROYAL COLLEGE OF VETERINARY

SURGEONS EVILLE AND JONES HALLMARK OV SERVICES ndash ARRAN OV SERVICESndash ISLAY OV SERVICES ndash LEWIS OV SERVICES ndash SOUTHERN ISLES (BARRA) OV SERVICES ndash SOUTHERN ISLES (UIST) 1STOP HALAL LIMITED 2 SISTERS FOOD GROUP LTD A amp B CATERING BUTCHERS LTD A amp G BARBER LTD A amp R FOODS A AND R MEATS LTD

A B BUTCHERS LTD A BURNS LTD A C HOPKINS (TAUNTON) LTD A D HARVEY A E PEARS amp SON A E POXON AND SON LTD A E TAYLOR amp SON A H CONISBEE amp CO A H GRIFFITHS A J GREEN amp SONS A J LEESE TURKEYS LTD A JOHNSON amp SON LTD A K STODDART LTD A P BURLTON (FARMS) LTD A P JESS (PAISLEY) LTD A R HALAL MEATS LTD A S AUDHALI FARM GATE FRESH POULTRY

LIMITED A S PORTER A TRAVES amp SON LTD A WRIGHT amp SON AB amp S WHOLESALE MEATS ABDULS POULTRY LTD ABERCORN ESTATES ABERDEENSHIRE LARDER ABP ACKROYDS RESTAURANT MEATS ADAM HALAL FOODS LIMITED ADLINGTON LTD AHMED BROTHERS HALAL POULTRY

PRODUCTS AHMED JEEWA amp SONS AIRE VALLEY FROZEN FOOD LIMITED AJ WILD AL HAQ POULTRY AL MINARAH ALAN GARBETT BUTCHERS LTD ALEC JARRETT LTD ALI HALAL MEATS ALISHIA FOODS ALLENS OF MAYFAIR ALLISON BUTCHERS ALPINE FINE FOODS LIMITED ALTNAHARRA ESTATE LIMITED AL-UMMAH HALAL POULTRY LIMITED AMBER FOODS LIMITED ANA FOOD PACKAGING LIMITED ANA FOOD SERVICES LTD ANA PROCESSING LTD

22

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 35: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

ANDREW E SEED ANDREW HAWKINGS QUALITY MEATS LTD ANDREW JAMES BUTCHERY ANDREWS OF CAMBRIDGE ANGLO DUTCH MEATS (CHARING) LTD ANNAS HAPPY TROTTERS ARMSTRONG MEATS LTD ARTHUR HOWELL ARTHUR J GRANBY amp SONS (LIVERPOOL)

LTD ARUN MEAT amp LIVESTOCK COMPANY LTD ASHFOLD QUALITY MEATS LTD ASHIK CHICKEN KEBABS LTD ASHLYNS ORGANICS LTD ASHTON EXOTIC MEATS LIMITED ASIA HALAL MEAT SUPPLIER LTD ASK 4 MEAT PRODUCTS LTD AUBREY ALLEN LTD AVONDALE POULTRY LTD AVONVOGIE ENTERPRISES LTD AXE VALLEY FOOD SERVICES LIMITED B amp B WEBSTER B amp M SAUSAGES LTD B RILEY AND SONS B S MEATS BAILEYS TURKEYS BAKERS OF NAILSEA LIMITED BALLYMENA MEATS BANARAS HALAL MEATS LIMITED BANHAM POULTRY LTD BANNER FOODS (BROMSGROVE) LTD BANTUWAY LTD BARAN MEAT COMPANY LIMITED BARBICAN SUPPLIES LTD BARCLAY amp NEWTON LTD BARTLETT amp SONS LTD BATES WHOLESALE BUTCHERS BEESONS LIMITED BEEZ NEEZ LTD BELCHER FOOD PRODUCTS LTD BELLS FISHMONGERS LIMITED BEN CREESE COUNTRY BUTCHERS LTD BEN RIGBY GAME LTD BERKSHIRE MEATS BERNARD MATTHEWS FOODS LTD BEST MEAT (UK) LTD BICKERTON BROS LTD BILLFIELDS OF LONDON LIMITED BIRMINGHAM HALAL ABATTOIR LTD BIRMINGHAM HALAL POULTRY (UK) LTD

BIRMINGHAM WHOLESALE MEAT MARKET BIRTWISTLES CATERING BUTCHERS BISMILLAH HALAL PRODUCTS BLACK BROW ABATTOIR LTD BLACKHURST BUTCHERS BLACKLIDGE BROS BLACKMOOR GAME LIMITED BLAKEMORE FRESH FOODS BLAKES WHOLESALE amp CATERING BUTCHERS BLOCK AND CLEAVER LIMITED BLUE SKY POULTRY LTD BOARS OF BEAULY BOB THE BUTCHER WALES LTD BOLTON POULTRY PRODUCTS LTD BORDER MEATS BOSUEN MANOR MEATS BOUVERIE LODGE QUALITY FOODS LIMITED BOWERS BEEF BOWLAND FOODS LTD BOWLAND PORK BEEF AND LAMB BOWOOD YORKSHIRE LAMB BRADFORD HALAL MEAT LTD BRADMILL MEAT LTD BRADSHAW BROS LTD BRAEHEAD FOODS LTD BRAMBLE FARM BRAMFIELD MEATS BRAVEHEART BEEF (SCOTLAND) LTD BREDBURY CATERING LIMITED BRENDAN ANDERTON BUTCHERS LTD BRIAN ETHERINGTON MEAT COMPANY

LTD BRISTOL MEAT TRADER LTD BRITANNIA POULTRY PRODUCTS LTD BRITANNIC FOODS BRITISH MEATS BRITISH PREMIUM MEATS BRYMAY CATERERS LTD BURNSIDE FARM FOODS BURT FAMILY BUTCHERS LTD BURTONS CATERING BUTCHERS BUTCHER amp EDMONDS LTD BW amp DJ GLAVES amp SONS LIMITED C amp G WHOLESALE FOODS LTD C amp J MEATS C amp J FOOD PRODUCTS LTD C amp S MEATS LTD C A LEECH amp SONS C BRUMPTON BUTCHERS LTD

23

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 36: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

C E PARTRIDGE amp SON LTD C H amp E I BAMBRIDGE amp SONS C H MEATS LTD C H ROWLEY LTD C HUMPHREYS amp SONS C J BYFORD amp SON C MALLON C M B FOODS LTD C ROBINSON AND SONS (BUTCHERS) LTD C S MORPHET amp SONS LTD C S P FOOD SERVICES LTD C SNELL WHOLESALE C WASTENEY AND SONS CampP MEAT SALES LIMITED CALDECOTT TURKEY FARMS LTD CALEDONIAN BISON LTD CAM CATERING BUTCHERS LIMITED CAMPBELL BROTHERS LTD CAMPBELLS PRIME MEAT LTD CAPESTONE ORGANIC POULTRY LTD CARGILL MEATS EUROPE CARMICHAEL ESTATE FARM MEATS CARTMEL VALLEY GAME SUPPLIES LTD CASE amp SONS CAUSEWAY PRIME CCM QUALITY FOODS CELTIC FISH amp GAME CELTICA CENTRAL FOOD SERVICES CENTRAL FROZEN FOOD SUPPLIES LTD CENTRAL MEAT COMPANY LIMITED CHANCTONBURY GAME CHARNWOOD FAYRE (WHOLESALE) LTD CHELMARSH MEAT CHELTENHAM amp DISTRICT WHOLESALE

MEAT CO LTD CHERRY VALLEY FARMS LIMITED CHERRYFIELD (CROYDON) LTD CHESHIRE FOOD SERVICES LTD CHESHIRE HALAL UK LTD CHESTERFIELD POULTRY LTD CHESTNUT MEATS CHILTON DEER FARM CHOICE CUTS CHOICE MEATS CATERING LTD CHRIS ADAMSON WHOLESALE BUTCHERS CHRIS TROTT amp FAMILY LTD CHRISTIE MEATS LTD CIG CALON CYMRU CIG DYSYNNI LTD

CIG OEN CARON CLARK AND SON CLARKE MEATS LIMITED CLD MEATS CLEAVER MEATS LTD CLEEVE HOUSE FARM CLEVELAND MEAT CO LTD CLEVELEYS CLIFTON QUALITY MEATS LTD COLLICUTT MEATS LTD COMBE MARTIN MEATS COMPLETE MEATS CONCEPT FOODS LTD CONWY VALLEY MEATS LTD COOK amp JOHNSON (BUTCHERS) LTD COOPER AND PARISH COOPERS OF ANDOVER COOTEHILL POULTRY PRODUCTS LTD COPAS TRADITIONAL TURKEYS LTD CORNISH FARMHOUSE BACON COMPANY CORNVALE FOODS LTD CORRIES MEAT LTD COUNTRY HARVEST FARM FOODS COUNTRY VALLEY FOODS LTD COUNTY FOODS LIMITED CR HORNER CRAIGADAM COUNTRY LARDER CRANBERRY FOODS LIMITED CRANSTONS QUALITY BUTCHERS LTD CRANSWICK COUNTRY FOODS PLC CRAWSHAW BUTCHERS LTD CREEDY CARVER LIMITED CROESLLAN CATERING CROSSGAR FOODSERVICE LTD CROSSKEYS MEATS CROWN CHICKEN LTD CULQUOICH ESTATE STRATHDON

VENISON CUMBERLAND MEAT PACKERS LTD CURTIS OF LINCOLN D amp J THOMAS D amp J THOMAS D B FOODS LIMITED D B FOODS LTD D H GAME LTD D S (SLAUGHTERHOUSE) LTD D T INDEPENDENT FOODS D W GILLETTE CATERING BUTCHERS DADIPATEL POULTRY DALEHEAD FOODS (A DIVISION OF TULIP)

24

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 37: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

DAPHNES ORIGINAL WELSH LAMB DAVID ASHWORTH BUTCHERS LTD DAVID F SMITH DAVID KILLOH MEAT CO LTD DAWN CARDINGTON DAWN CARNABY DAWN DUERDEN DAWN MIDLANDS LIMITED DAWN PAC (WEST) DAWN WEST DEVON DECKERS RESTAURANTS LIMITED DEER N DEXTER DEERCARE DENHAM ESTATE DENIZ CATERING FAST FOOD LTD DEVENISH FOODS DEVON ROSE LTD DIAPER POULTRY LTD DIBS DISTRIBUTION LIMITED DICKEYS POULTRY DIRECT MEAT SUPPLIES LTD DIRECT MEATS (KNIGHTS FARM) LTD DIRECT POULTRY SUPPLY (INSKIP) LTD DONALD RUSSELL LTD DOHERTY amp GRAY LTD DONERFIELD DORIC GAME LTD DOVECOTE PARK DRUMGOLD QUALITY FOODS DUNBIA DUNNS BUTCHERS LTD E amp P CATERING BUTCHERS LIMITED E amp T JACKSON amp SONS E BUTLER LIMITED E H BOOTH amp CO LTD E ROBERTS AND SONS E T JONES SONS amp DAUGHTER E V SLACK amp SONS EKA ROBERTS AND SONS LTD EARDINGTON WHOLESALE MEATS LTD EAST HILL PRIDE EAST KILBRIDE EASTERN MEAT SUPPLIES EASTERTON FARM PARTNERSHIP ECKSTEINS EDEN VALLEY GROUP EDEN VALLEY VENISON EDGE AND SON EDMONTON MEAT CENTRE LTD EFES NAVSTAR

EGTON BUTCHERS ELITE FROZEN FOODS LTD ELITE POULTRY LIMITED ELMKIRK LIMITED ENFIELD MEAT LIMITED ESSEX POULTRY LTD ETHERSON MEATS LTD ETTINGSHALL POULTRY EURO FAST FOOD DISTRIBUTION LTD EURO QUALITY LAMBS LTD EUROSTOCK FOODS HINDLEY LTD EVANS amp SONS EVERLEIGH FARM SHOP LTD EVERSFIELD ORGANIC LTD EWE FARM GAME F A GILL LTD F BAILEY amp SON (FAMILY BUTCHERS) LTD F DRURY amp SONS LTD F L EDGE amp SON LTD F L EDGE amp SON LTD F M amp P LTD F REDFERN F SIMPSON AND SON F HOUGHTON amp FAMILY (WHOLESALE

BUTCHERS) LTD FACCENDA CHICKEN FACCENDA GROUP LIMITED FACCENDA GROUP LTD FAI FARMS LTD FAIRFAX MEADOW FAIRFAX MEADOW FARM LTD FAIRFAX MEADOW LTD FAIRFIELD MEAT COMPANY LIMITED FARADAY FINE FOODS LIMITED FARASI TRADING LTD FARMBOX MEATS LTD FARMERS BOY LIMITED FARMERS FRESH LTD FARMHOUSE MEATS LIMITED FAYRE GAME LTD FENNS OF PICCADILLY FERGUSON MEATS LTD FIELD FARM FRESH LTD FINE COUNTRY FOODS LTD FINNEBROGUE VENISON FIRST CHOICE MEAT CENTRE (BACKFOOT) FOOD CENTRE WALES FOODSERVICE FROM CREED FORGE FARM MEATS LTD FORRESTERS (SALES) LTD

25

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 38: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

FOWLER BROS (LATCHINGDON) LTD FOYLE FOOD GROUP FRANK BIRD (POULTRY) LTD FRANK GODFREY LTD FRED C ROBINSON LTD FREEMAN CATERING BUTCHERS FREEMANS OF NEWENT LTD FRESH DIRECT LOCAL (LONDON) LIMITED FRESH FIELDS FOODS LTD FRESHASIA FOODS LTD FURNESS FISH amp GAME LTD FURZELAND DEER PARK G A KIRK amp SON G amp A DENNEY G amp G B HEWITT LTD G COLLIER BUTCHER G R EVANS amp CO GA INTERNATIONAL FOOD SERVICES LTD GAFOOR PURE HALAL LTD GAGES FARM LTD GALGORM MEATS GALLOWAY FOODSERVICE GAMSTON WOOD OSTRICHES GARBETTS MEAT WHOLESALERS GARLANDHAYES FARM GB POULTRY LTD GEARADHMOR GEOFF BETTERIDGE MEATS GEORGE BOLAM (FOODS) LTD GILBERTS KOSHER FOODS LTD GILCHRIST POULTRY GILLAMS BUTCHERS GIPPING VALLEY MEATS LTD GLEADHALL amp THORPE GM MATTHEWS (BUTCHERS) GODDEN BUTCHERS GORDON MCWILLIAM (ABERDEEN) LTD GOURMET GAME LIMITED GRANTS OF SPEYSIDE GRASMERE FARM LTD GRESSINGHAM FOODS GRESSINGHAM FOODS LTD GROVE FOODS LTD GST LTD GUNNE BUTCHERS UK LTD H C AIREY amp SONS LTD H D V FOOD LTD H DAWSON amp SONS H F STILES amp SON LTD H G BEARD BUTCHERS

H G BLAKE (COSTESSEY) LTD H GOWERS H GREAVES amp SON (MEAT PRODUCTS) LTD H J HELLETT amp SONS H L HINSULL H P WESTWOOD LTD H R JASPER amp SON LTD HACKNEY MEAT TRADERS LTD HADFIELD CATERING BUTCHERS LTD HALAL POULTRY amp MEAT PRODUCTS LTD HALAL SERVICES COMPANY LTD HALAL WORLD HALDERS BUTCHERS LTD HALLS POULTRY HAMPSHIRE GAME LTD HANDCROSS VILLAGE BUTCHERS LIMITED HANNAN MEATS HARRINGAY MEAT TRADERS LTD HARRIS amp SON WHOLESALE MEATS LTD HARRY LEE amp SONS HARTSHEAD MEATS (2011) LTD HASHAMS HALAL POULTRY HASWELLS HOMER HILL FARM SHOP LTD HAZELS BUTCHERS HCF POULTRY LTD HEATHS TURKEYS HELLABY MEATS (UK) LTD HENSON FOODS LTD HERB FED LTD HEWITT MEATS HI SPEC MEATS HIGGINSHAW ABATTOIR LTD HIGHBURY POULTRY FARM PRODUCE LTD HIGHGATE TURKEYS LTD HIGHLAND MEATS (A DIVISION OF DAWN

MEATS (UK)) HIGHLAND CROWN LTD HIGHLAND GAME LTD HILTON MEAT PRODUCTS LTD HILTON MEATS RETAIL LTD HILTON MEATS (COOKSTOWN) LTD HK FOODS LTD HMD BUTCHERS HOGANS BUTCHERS LTD HOLDEN MEATS LTD HOLDSWORTH HOLME FARMED VENISON HOLMESTERNE FOODS HOME FARM - MAPLE HAYES HOMELAND MEATS LTD

26

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 39: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

HONEYWELL MEATS LTD HOWELLS BUTCHERS LTD HUBERTUS GAME LTD HUGH BLACK amp SONS LTD HUGHES MEATS COMPANY LTD HUNDRED RIVER FOODS LTD HUNTS FOODSERVICE LTD HUSSAIN MEATS LTD HV GRAVES I amp B JONES LTD IAN K MOORE POULTRY LTD IDEAL MEAT IHP LTD IMPERIAL FAST FOOD DISTRIBUTION LTD IMPERIAL MEAT WHOLESALERS LTD IMRAN HALAL POULTRY IMS OF SMITHFIELD LTD IQBAL BROTHERS POULTRY ISLAND FOODS LIMITED IVAN CLARKE CATERING BUTCHERS LTD J amp A GIBBINS J amp B FITTON LTD J amp B WILDE amp SONS J amp D PAPWORTH LTD J amp E MEDCALF LTD J amp L WOOD AND SON LTD J A JEWITT (MEAT) LTD J A MOUNFIELD amp SON LTD J AND J FARMERS ABATTOIR J BROOMHALL LTD J C ALTHAM amp SONS (MORECAMBE) J C MITCHELL POULTRY AND GAME DEALERS J COLEMAN WHOLESALE BUTCHERS LTD J E HAWKES J E HOWARD BUTCHERS AND HOWARDS

ABATTOIR J GILMOUR amp CO LIMITED J MALLINSON LTD J PRICE POULTRY LTD J R FARM MEATS LTD J S QUALITY MEATS LIMITED J SHARPE GAME J T HERITAGE J V RICHARDS (RIETFONTEIN) LTD J W HEATH J W METTRICK amp SON LTD J W SARGEANT J WESTCOTT J WILLIAMS amp CO J BROTHERS

J W YOUNG (BUTCHERS) LIMITED JW YOUNG (BUTCHERS) LTD JACK BRAND LTD JACKSON MEATS LIMITED JAK FOOD SERVICES LIMITED JAMEEL POULTRY JAMES BURROWS LTD JAMES CHAPMAN (BUTCHERS) LTD JAMES CONNOLLY WHOLESALE LTD JAMES LAW LTD JAMES WHANNEL (WHOLESALE) LTD JAMES WHITE BUTCHERS LIMTED JAMIE WARD JANAN MEAT LTD JASPERS (TREBURLEY) LTD JAYS FARM JC ROOK amp SONS FACTORY AND FOOD

SERVICES JCB FARMS LIMITED JENNINGS OF CAVERSHAM JLP MEATS JOHN COYSTEN MEATS JOHN HENDERSON (MEAT SPECIALISTS)

LTD JOHN M MUNRO LTD JOHN PENNY AND SONS JOHN ROBERTSON amp SONS HAMCURERS

LTD JOHN SCOTT MEAT (PAISLEY) LIMITED JOHN SHEPPARD BUTCHERS LTD JOHNSON amp SWARBRICK GOOSNARGH

LTD JON THORNERS LTD JONES BROTHERS JOSEPH MORRIS BUTCHERS LTD JTM MEATS K D CATERING BUTCHERS LTD K amp G MCATAMNEY WHOLESALE MEATS KARACA MEAT LIMITED KARRO FOOD GROUP LTD KARTAL MEATS LIMITED KASHMIR CATERING BUTCHERS KAZON LIMITED KEARNS POULTRY KEBABISH ORIGINAL EXPRESS LIMITED KEDASSIA POULTRY LTD KELLY TURKEY FARMS LTD KEN BALLARD LTD KEPAK U K LTD KERRY FOODS LTD KESBURY LTD

27

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 40: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

KETTYLE IRISH FOODS KEVIN MCADAM CATERING BUTCHERS KEZIE LTD KHAN AND SONS KHAWAJA POULTRY LIMITED KHT (UK) LTD KINDA FOOD LTD KINGSWOOD POULTRY KISMET HALAL MEAT amp DONER KITTOWS BUTCHERS KNIGHT MEATS LTD KNK HALAL POULTRY LTD KOREA FOOD COMPANY LTD BIRMINGHAM WAREHOUSE KOSHER DELI (UK) KOSHER POULTRY LTD KURPAS MEATS PLC L amp A DENT (GAME DEALERS) LIMITED L amp O MEATS LTD L amp S JONES AND SONS L BROWN amp SON WHOLESALE BUTCHERS

LTD L H amp C A PHILLIPS L WOOD amp SONS LAKE DISTRICT FARMERS LTD LAKES SPECIALITY FOODS LTD LAKEVIEW FARM MEATS LTD LAMBERTS THE ABATTOIR LANCASHIRE DIRECT HALAL MEATS LTD LANCASTER MEAT COMPANY LTD LANE FARM COUNTRY FOODS LANGTHORNES BUFFALO PRODUCE LAVERSTOKE PARK FARM LTD LDA MEATS LTD LEA VALLEY MEAT LTD LEICESTERSHIRE FARM FRESH TURKEYS LEONARD AMES (AMPTHILL) LTD LEWIS QUALITY FOODS LIMITED LINCOLNSHIRE CO-OPERATIVE SOCIETY LINCOLNSHIRE MEAT COMPANY LTD LINCS TURKEYS LTD LINDEN FOODS LTD LITTLE ANGUS LIVERPOOL MEAT AND FISH MARKET LLECHWEDD MEATS LOBO MEAT AND POULTRY LTD LOCHABER GAME SERVICES LTD LOCHMADDY SLAUGHTERHOUSE LOCKERBIE ABATTOIR LONDON CENTRAL MARKETS LONDON POULTRY

LONG COMPTON ABATTOIR LTD LOTHIAN CATERING BUTCHERS LSA MEATS LYNCH QUALITY MEATS M amp C MEATS M amp J MEATS LTD M amp T BUTCHERS PRESTON LTD M amp W WHOLESALE MEATS M C KELLY LIMITED M COBAN LIMITED M I B UNITED MEAT LIMITED M I DICKSON LTD M J BIRTWISTLE amp CO LIMITED M NAJIB amp SONS LTD M S FOODS LTD MADDOCK KEMBERY MEATS MAINLAND POULTRY LTD MAINSTREAM INTERNATIONAL FOODS LTD MAISEBROOKE FARM MALTON BACON FACTORY MAMORE BOUCHERIE MAN FOODS LTD MAN SHUN LTD MANOR FARM DEER MANOR FARMS TRADING LTD MARBEC MEATS MARCUS STEVENS MAREN MEATS MARKS MEATS LTD MARSH POULTRY LTD MARTINS MEATS MATHESON JESS MATTHEWS QUALITY MEATS MCELROY FISH amp GAME MCINTOSH DONALD (1106) MCINTYRE MEATS LTD MCKEErsquoS

MCLAYS LTD MCTURK CATERING SUPPLIES LTD MEDINA MEAT AND POULTRY GROUP MEDINA SUPERMARKET MEGA CHICKENS LTD MELFAR MEATS LTD MELTON MEAT LIMITED MERRIDALE POULTRY MERSEYSIDE WHOLESALE MEATS MERT BUTCHERS LIMITED MICHAEL MALONE OF EDINBURGH LTD MICHAELS MEAT MARKET LTD MCKEOWN FINE FOODS LTD

28

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 41: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

MID GLAMORGAN PROVISIONS LTD MIDDLESEX MEAT COMPANY LTD MIDLAND BACON COMPANY MIDLAND FOOD SERVICES LTD MIDLAND FOODS LTD MIKES POULTRY LIMITED MILFORD FARM LTD MILLERS OF SPEYSIDE MIPA MEATS LTD MOO MOO MOORLAND MEATS LTD MORGAN THOMAS BUTCHERS MOYALLON MOY PARK MR D T HAVARD MR MEATS MUCHELNEY ABATTOIR SERVICES MULL SLAUGHTERHOUSE LTD MUNIR BROTHERS MUSGRAVE RETAIL PARTNERS GB

LIMITED MUSLIM HALAL LIVE POULTRY MUTCHMEATS LTD N A HALAL POULTRY LTD N BRAMALL amp SON LTD N H WHITTLE MEATS LTD N TM AND EM BASKEYFIELD N V GAGEN amp SON N WESLEY amp SON NANTEAGUE ABATTOIR NASONS POULTRY SUPPLIERS NATIONAL HALAL NATURAL FARMS (OXON) LTD NATURAL FARMS LTD NAZAR HALAL MEAT LTD NEIL POWELL CATERING NELSONS (BUTCHERS) LTD NEWBY FOODS LTD NEWHOUSE GAME NIDDERDALE POULTRY PRODUCTS LTD NIGEL FREDERICKS LTD NOBLE FOODS LIMITED NOEL CHADWICK LTD NOOR HALAL FOODS LIMITED NORFOLK QUAIL LTD NORSTED MANOR FARM MEATS NORTH LONDON MEATS

NORTHWOOD WILD BOAR O G GRIFFITHS amp SON OBRIEN WHOLESALE BUTCHER OAKDALE MEATS (NI) LTD OLDHAM POULTRY PRODUCTS ORCHARD HILL FARM ORIGINAL DONER KEBAB ORKNEY MEAT PROCESSORS LTD OSBORNE POULTRY PRODUCTS OSGROW OSSETT ABATTOIR SERVICES LTD OTTER VALLEY POULTRY OWEN TAYLOR AND SONS LTD OX CLOSE TRADITIONAL FINE FOODS P amp R WHITWAM P J HAYMAN amp SONS P J KING amp SON P J ROOFE CATERING BUTCHERS P J STEVENS FAMILY BUTCHER P LINGHAM amp PARTNERS P R DUFF LTD PCTURNER - WHOLESALE BUTCHER PACKINGTON FREE RANGE PAK HALAL POULTRY PAK POULTRY PRODUCTS LTD PAKEEZAH MEAT SUPPLIES LTD PALFREY AND HALL PAPWORTH FARMS PARKER FINE FOODS PAULS CATERING BUTCHERS PAULS QUALITY BUTCHERS PELHAM amp TALBOT LTD PEMBROKESHIRE MEAT COMPANY (2008)

LIMITED PENNYS MEATS LTD PERA FOODS LIMITED PERDON ORGANICS LTD PETER BODDY LICENSED SLAUGHTERERS

AND GAME DEALERS PETER COATES (ALREWAS) LIMITED PETER GRADON MEAT amp POULTRY MARKETING LTD PETER OSULLIVAN MEATS LTD PETERBOROUGH GAME CO LTD PFD (CARLISLE) LTD PHILIP BARTON WHOLESALE MEATS LTD PHILIP DENNIS FOODSERVICE PHILIP WARREN amp SON LIMITED

NORTHERN CATERING BUTCHERS LIMITED PICKSTOCKS (ASHBY) LIMITED NORTHERN MEAT AND POULTRY LTD PINKERTONS LTD NORTH WEST PORK PRODUCTS LTD PINNACLE FOODS LIMITED

29

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 42: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

PJM MIDLAND MEAT LTD PLUMGARTHS FARM SHOP LTD PMJ FOODS UK LTD POCOCKS POULTRY POL MEAT PORTAVO GAME PREMIER CUTS (13) LTD PREMIER HALAL LTD PREMIER MEAT N POULTRY PREMIER MEATS PREMIUM HALAL MEAT POULTRY LIMITED PRESTON WHOLESALE MEATS LTD PRICE amp FRETWELL LTD PRIMA FOODS UK LTD PRIME HALAL POULTRY amp MEAT LTD PUGHS PIGLETS QUEENSLIE R NATRASS amp SONS R amp J YORKSHIRES FINEST R amp M MEATS LIMITED R amp P MEATS LIMITED R amp S PLATTS (POULTRY) R amp S WHOLESALE BUTCHERS LTD R B ELLIOTT amp SON LTD R D JOHNS LTD R G B WEBSTER amp SONS LTD R J MOULT POULTRY WHOLESALERS R J PHILLIPS WHOLESALE BUTCHER R J TREVARTHEN WHOLESALE BUTCHERS R MANNERS amp SONS LTD R OWTON (WHOLESALE BUTCHERS) LTD R P J MEAT WHOLESALE LTD R P MEATS WHOLESALE LTD R W CAMPLEJOHN amp SON R AND J WHOLESALE MEAT COMPANY

LIMITED RS ASHBY LTD RALPH PEARSON RAMSAY OF CARLUKE LTD RANDALL PARKER FOODS LTD RANDALL PARKER FOODS LTD RAPYAL MEAT amp POULTRY LTD RARE BUTCHERS OF DISTINCTION LTD RAVENDALE FOODS LTD RAYLEIGH COLD STORE LTD RED LION MEAT PACKERS LIMITED REEDIEHILL DEER FARM REEVES BUTCHERS LTD RHUG ORGANIC RICHARD OF HOWDEN LTD

RICK BESTWICK LTD RITTER FRESH RIVERFORD BUTCHERY ROBERT ASHCROFT GAME ROBERT G TUCKEY ROBERT HAWKER VENISON LTD ROBIN MAYCOCK BUTCHERS ROBINSONS BUTCHERS ROCKVALE POULTRY RODGERS MEATS ROGERS NATURAL FOODS LTD ROMFORD CATERING SUPPLIES LTD ROMFORD HALAL MEATS LTD ROMFORD WHOLESALE MEATS ROSES BOWER FARM ROTHER VALLEY MEATS LIMITED ROTHER VALLEY ORGANICS ROUND GREEN FARM VENISON LTD ROWLAND AGAR (SLAUGHTERING CONTRACTORS) LTD RR ALDEN OXFORD LTD RUSE amp SON LTD RUSKINGTON POULTRY RUSSELL HUME LTD S amp D MEAT amp POULTRY LTD S amp H CATERING LTD S amp W GILMOUR S BAGSHAW amp SONS S J NORMAN amp SONS S L G WHOLESALE MEATS LTD S R COOPER MEATS LTD S W DOUGHTY SAC COMMERCIAL LTD SALISBURY POULTRY (MIDLANDS) LTD SALVATORI SAM COLE FOOD GROUP LIMITED SANDRIDGE FARMHOUSE BACON LIMITED SANDYFORD ABATTOIR (PAISLEY) LTD SAVIN HILL SCORSE FOODS LTD SCOTBEEF LTD SCOTT BROTHERS BUTCHERS SCOTTISH BORDERS ABATTOIR LTD SEAFIELD PEDIGREES LTD SELECT POULTRY amp MEAT LTD SERIOUSLY GOOD BUTCHERY SERIOUSLY GOOD VENISON LTD SESSIONS MEAT SUPPLIES LTD SEVERN POULTRY LTD SHARPHAM PARK

30

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 43: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

SHERBAN HALAL POULTRY SHETLAND ABATTOIR SHOTTS ABATTOIR SIDOR MEAT LIMITED SIMON HOWIE BUTCHERS LTD SIMPLY HALAL (BANHAM) LTD SIMPSON GAME LTD SMITHFIELD MURRAY LTD SMYTHACOTT FARM GAME SOLENT BUTCHERS LTD SOUTH DOWNS VENISON AND GAME LTD SOUTH EAST POULTRY SOUTH WEST POULTRY LTD SOUTHERN TRADITIONAL MEATS LTD SPAR DISTRIBUTION CENTRE SPENBOROUGH ABATTOIR LTD SPICY BITES BIRMINGHAM LTD SPRINGFIELD POULTRY SR DAVIS LTD ST MERRYN FOODS STAFFORDSHIRE MEAT PACKERS LTD STANDARD PLUS LIMTED STANLEY JONES STILLMANS (SOMERSET) LTD STOCKLAND FARMED VENISON STOKE CHICKEN LTD STORNOWAY ABATTOIR STRAP ORCHARD ABATTOIR SUFFOLK MEAT TRADERS LTD SULTAN ET LTD SUMMERS POULTRY PRODUCTS LTD SUPERCHICK POULTRY LTD SUPREME FOOD PROCESSORS SUPREME HALAL POULTRY UK LTD SWANDEAN FRESH MEATS LTD SWANNINGTON FARM TO FORK SWEETLANDS LTD SYKES HOUSE FARM LTD T amp H LOBB LIMITED T G SARGEANT AND SONS T H MEAT LTD T H MOTSON amp SONS LTD T M ATKINSON amp SONS LTD T M EWBANK T S BLOOR amp SONS LTD T S HARTLEY AND SONS LTD T SOANES amp SON (POULTRY) LTD T ALLMAN BUTCHERS LIMITED TADMARTON PRODUCTS LTD TAJ amp CO

TARIQ HALAL MEATS TARRADALE GAME LTD TASTE TRADITION LTD TAYLORS CATERING FOODS LTD TCR FOOD SERVICES LTD TEDSMORE HALL LTD TELMARA FARM LTD TEMPLE MEATS LTD TENDERCUT MEATS LTD TENDEROAK MEATS LTD TERRY LINDSAY amp CO WHOLESALE MEATS THATCHAM BUTCHERS LTD THE ARDGAY GAME FACTORY LTD THE CATERING BUTCHERS THE DOUBLE DONER KEBAB COMPANY THE FOOD TECHNOLOGY CENTRE THE FRESH CHICKEN COMPANY LIMITED THE GLASGOW OFFAL COMPANY LTD THE LONDON HALAL MEAT COMPANY LTD THE LONDON MEAT CO LTD THE ORIGINAL CHICKEN CO LTD THE QUALITY MEAT COMPANY THE RARE BREED MEAT COMPANY LTD THE REAL SAUSAGE COMPANY THE UK GAME COMPANY THE WILD MEAT COMPANY LTD THEOS FOOD COMPANY LIMITED THOMPSON (WHOLESALE MEAT) LTD THOMPSONS FOOD SERVICE LTD THROWCOMBE PARK TIDEFORD ABATTOIR LTD TMC CATERING SUPPLIERS TOPPING MEATS TORHILL VENISON TOTTINGWORTH FARM LTD TOVAH MEATS TOWERS THOMPSON TOWNHILL FOOD SERVICES TOWNSEND POULTRY LTD TPB FOODS LTD TRADINGNAME TRADITIONAL NORFOLK POULTRY LTD TRANS OCEANIC MEAT COMPANY (NOTTINGHAM) LTD TRAYMOOR LTD TRAYNOR QUALITY MEATS TREGAGLES TRENDY FOODS LIMITED TTS MEATS TULIP COOKED MEATS

31

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties
Page 44: Review of audit arrangements in FSA approved meat ...€¦ · 2013, as part of wider considerations on compliance in the meat industry [FSA 13/09/06], and, acknowledging concerns

TULIP FRESH MEATS TULLOR LTD TURNER amp PRICE LTD TWO RIVERS PRODUCE LIMITED UDALE SPECIALITY FOODS LTD UK FOODSERVICE LTD UK POULTRY LTD UMUT MEAT LIMITED UNDERWOOD MEAT COMPANY LIMITED UNITED FOODS DIRECT LIMITED UNIVERSAL TRADERS GLOUCESTER LTD UNIVERSITY OF BRISTOL UNIVERSITY OF NOTTINGHAM UPCOTT DEER FARM USK VALE POULTRY LTD VATAN CATERING LTD VEALLS OF NEWQUAY LTD VICARS GAME LTD VIVERS SCOTLAMB LTD VIVIAN OLDS LTD W amp G YATES (YIELDFIELDS) LTD W A FOODS W A JAMES BUTCHERS W ALLEN MEATS W BARTON amp SONS LTD W D MEATS LTD W J GEORGE (BUTCHERS) LTD W J PEARCE AND SONS W JAMES W NIXON AND SONS LIMITED W S CLARKE amp SONS W W WALES LTD WALKERS GAME WALKERS MIDSHIRE FOODS WALTER ROSE amp SON WALTON MEATS LTD WARREN BUTTERWORTH CATERING

BUTCHERS LTD WASHERS FARM WE HAE MEAT LTD WEDDEL SWIFT DISTRIBUTION LTD WEEKS WHOLESALE MEAT COMPANY LTD WELLS FARM SUPPLIES LTD WELSH BROS FOODS LIMITED WELSH FARM ORGANICS WELSH MEAT ON LINE WELSH VENISON CENTRE WELSH VENISON CENTRE LTD WEST END MEATS LTD WEST LANCASHIRE POULTRY LTD

WEST SCOTTISH LAMB LTD WESTCOMBE DEER PARK WESTGATE FROZEN FOODS LTD WESTLAND POULTRY WG YOUNG WH amp TR NEWTON TA NEWTON

BROTHERS WICK FARM MEATS WICKS MANOR PORK WILD GAME DIRECT LIMITED WILLIAM GRANT amp CO LTD WILLIAM LLOYD WILLIAMS AND SON WILLIAM PERRY WILLIAM TAYLOR amp SON WILLIAM WHITE MEATS LIMITED WILLIAMS OF FLINT WILLO GAME WILSONS OF SLOANE STREET WILTSHIRE GAME LTD WINTERTON BROS LTD WISHAW ABATTOIR LIMITED WM BOSOMWORTH WOBURN COUNTRY FOODS WOODCHESTER MEAT COMPANY LTD WOODHEAD BROS WOOLLEY BROS LTD WORCESTER WHOLESALE MEAT CO LTD WRIGHTS (MIDDLETON) STORAGE amp

PACKAGING LTD YORKES OF DUNDEE YORKSHIRE DALES MEAT CO LTD YORKSHIRE GAME LTD YORKSHIRE POULTRY PRODUCTS LTD YORKSHIRE PREMIER MEAT ZABIHAH HALAL GROUP

32

  • Consultation summary
  • Annex A Standard Consultation Information
  • Annex B Impact Assessment
  • Annex C List of interested parties