SUMMARY OF COMMENTS – Amendments to the "Regulations regarding the classification and marking of meat intended for sale in the republic of South Africa"
Proposed change / Suggested by/rationale / What was done / Comments(1) Guideline document for
Service Providers
A draft guideline document for service providers was tabled for consideration and inclusion in the current regulations.
(See annexure A below this table) / Industry (via SAMIC)*
The meeting supported the draft proposal. / Included as Table 6 – List of requirements for service providers.
Reference made to Table 6 in definition for "Service Providers".
Moved definition for "Meat classification" from table to beginning of regulations. / Translated these requirements into Afrikaans – Tables are indicated in both languages.
Various issues were changed to make the guidelines relevant – i.e. Table 6 differs somewhat from original document submitted by SAMIC.
(2) Definitions
New definition for "independent service provider" / Industry (via SAMIC)*
Since the proposed guideline document (see above) for service providers will be included in the regulations, “independent service provider” will also have to be defined. / Included definition for "Service Providers".
Changed regulation 3(1)(b) to refer to "Service Provider". / See point (4) of this table.
(3) Inclusion of requirements for Lighting / Industry (via SAMIC)*
SAMIC’s proposal that minimum lighting of 540 lux be required at the point of classification. / Was included – regulation 4(4) for cattle, sheep and goats and regulation 10(4) for pigs. / The word "white" was added in these regulations as well – there is a concern that yellow light may negatively influence the classifier.
(4) Regulation 3(3)(c) / Industry (via SAMIC)*
SAMIC requested that “responsible person” be replaced with “designated independent service provider”. / Included definition for "Service Provider".
Changed regulation 3(1)(b) to refer to "Service Provider". / "Responsible person" refers to the abattoir owner.
"Service Provider" can not replace definition for "responsible person" – is not the same.
Clarify responsibilities – see regulations 3(1), 3(3)(c), 3(5)(b), 3(7) and 3(10).
SAMIC is appointed as assignee - give approval for Service Providers (same as for classifiers).
"independent" – included it in the definition and Table 5.
(5) Regulation 3(5) / Industry (via SAMIC)*
SAMIC requested that (i) the “48 hours” requirement be reduced to “24 hours”, and (ii) the wording “all roller-mark equipment” be amended to read “all classification equipment” (to also include an intrascope). / Regulation 3(5) amended as requested. / The Department also clarified the issue regarding roller-mark equipment versus classification equipment in the draft – classification equipment also includes the Hennessey Grading Probe, Intrascope, etc.
(6) Regulation 3(7) / Industry (via SAMIC)*
The DAFF pointed out that “responsible person” shall be replaced with “designated independent service provider”. / "Responsible person" replaced by "Service Provider" in regulation 3(7).
(7) Regulation 3(10) / Industry (via SAMIC)*
SAMIC requested that the “48 hours” requirement be reduced to “24 hours". / Regulation 3(1) amended to "24" hours.
(8) Regulation 15(3) and Table 4 – M/D stamp marks / Industry (via SAMIC)*
The meeting agreed that the regulation and Table 4 shall be amended to indicate that the M/D stamp mark shall, in the case of all carcasses, be applied on each side of the cracass in the vicinity of the loin.
RMAA additional point
DAFF later received a request to maybe look at including the M/D stamp in the roller-mark (RMAA)&
DAFF – Additional point
It was mentioned that regulations 15(3)(b) reads difficult. / Included as requested.
Not included at this stage.
Regulation 15(3)(b) split into 15(3)(b) and 15(3)(c). / This suggestion will result in that the abattoirs now must have additional rollers
This proposal is different than decided on at the meeting.
(9) Independence of teeth counter / The meeting #
Requested that the possible use of independent teeth counters in future also be investigated by the DAFF, but that it should not be included in this round of amendmends. / No changes to the regulations were made in this regard.
(10) Table 2 / The meeting #
The heading as well as column 1 of Table 2 shall be amended to read “bovine, calf and pig”/ “bees, kalf en vark” to bring it in line with “conformation”/
”bouvorm” in Table 4. / Heading and Table amended as requested.
(11) Use of the term “bovine” / The meeting #
The DAFF will investigate the use of other designations as the term bovine includes animals such as water buffalo as well. / Included definition to clarify "bovine" in the English.
Afrikaans version is correct by referring to "bees".
(12) Trade marks, protocols and new labelling regulations of the Department of Health / The meeting #
The Chairman pointed out that in terms of the new labelling regulations of the Department of Health which will come into operation on 1 March 2012, the use claims such as “grain fed”, “grassfed”, “Karoo lamb”, “natural lamb”, “country reared”, “free range”, etc will only be permitted on prepackaged labelling and in advertisements if they are linked to specific protocols which are registered with the DAFF or regulations in terms of the APS Act.
The current regulations do not require that an abattoir supply a protocol when registering a certain “trademark” with the DAFF. The regulations therefore have to be amended to include this requirement and a different term for “trademark” needs to be investigated (e.g. “tradename”/”handelsnaam”). / Removed definition for "trade mark" and replaced it with definition for "quality indication".
Replaced all reference to "trade mark" with "quality indication" in the regulations.
Included "quality indication" in regulation 2(2)(b).
Included "quality indication" in restricted particulars– regulation 23(2).
Quality indications can be stamp marks as well, not only roller-marks – see definition for "quality indication".
(13) Brine injection / DAFF - Additional point
Due to the brine injection issue in chicken that made news headlines recently DAFF suggests that the red meat industry consider looking at this practice for the red meat industry – these regulations can only regulate it for carcasses and fresh and frozen cuts from these carcasses. / Added regulation 21(7) to provide for the indication of the treatment.
Reference is made to the labeling of raw-processed meats as required by Dept of Health.
Definitions for "Brine Injected" and "Permitted" added.
Changed heading of regulation 21 to include brine injected.
See labeling regulations of DoH – definition for "raw-processed meats" and regulation 26(2). / Is it adequate to require only correct labelling of injected meat or should a maximum injection percentage also be stipulated? Articles consulted indicate that phosphate treatment (injection) of meat between 5 and 10% can enhance the moisture of the meat and contribute to flavour. Fresh injected meat is to a certain extent self limiting on the amount of brine injected that can be retained, however frozen cuts may be subject to abuse.
(14) Deviations in classification / DAFF – Additional point
All quality standards (regulations) published in terms of the Agricultural Product Standards Act, 1990 allow for deviations in quality since the nature of a biological product is such that deviations in quality do occur.
DAFF has a service agreement with SAMIC to allow for 6% deviation in classification. However, this should rather be captured in the regulations to make it official. / Table 5 was included.
Reference to Table 5 was included – regulation 4(5) for cattle, sheep and goats and regulation 10(5) for pigs.
(15) Untidy and smudged roller-marks and stamps / DAFF – Additional point
The regulations imply that roller-marks and stamps must be legible but nowhere is it specifically addressed in the regulations. / Inserted regulations 15(5) and 17(5).
(15) Service Provider must take responsibility for classification stamps / DAFF – Additional point
There is a possible problem of fraud if the classification stamps are available to anyone. It was suggested that the Service Provider take full responsibility for the safekeeping of the classification stamps (not the rollers) / Added this requirement to regulation 3(3)(c).
(16) Meat of other species and sub-species / DAFF – Additional point
It was brought to the attention of the Department that meat, such as buffalo meat, is sold as beef. / Added a new requirement - regulation 23(3) to specifically address this issue.
Notes:
* SAMIC collated various requests from industry into one proposal that was forwarded to DAFF for consideration and discussion at a Standards Committee Meeting that took place on 16 February 2011.
# Additional points highlighted at the Standards Committee Meeting that took place on 16 February 2011.
& Issues that came to light after the Standards Committee Meeting.
ANNEXURE A
GUIDELINES FOR SERVICE PROVIDERS
Guidelines applicable to all species unless otherwise indicated.
- Definitions
For the purpose of these requirements the following definitions apply:
1.1Classification
- Evaluation of the carcass, by way of age determination, fat content, conformation, damage and muscularity;
- To see to it that:
Regulatory requirements pertaining to age, fat content, conformation, damage and muscularity is maintained according to the set regulations;
- To monitor and report to the relevant Service Providers any aspect of non-compliance to these regulations.
1.2Service Providers
The designated organisation that provides the service as prescribed by Regulations of the Agriculture Standards Act (Act 119 of 1990).
- Scope of Independent Meat Classification Service
2.1Meat Classification Services
2.2Auditing
2.3Training and Reporting
- Administrative Requirements
3.1The Service Providers must be legally identifiable.
3.2The Service Providers must have QMS which describes its functions and the technical scope of activity for which it is competent. The prescribed scope of Classification will be determined by the NDA and Assignee.
3.3The Service Providers must have a contractual agreement with the Assignee.
- Independence, Impartiality and Integrity
4.1General
The personnel of the Service Providers must be free from any commercial, financial and other pressures, which might affect their judgment. Procedures must be implemented to ensure that persons of organisations external to the Service Providers cannot influence the results of Classification carried out.
4.2Independence
The Service Providers must be independent and provide a service that will meet the following criteria:
4.2.1The Service Providers must be independent of the parties involved.
The Service Providers and its staff responsible for carrying out the Classification may not be the purchaser, owner, user or agent of the meat or animal products which they classify, nor the authorised representative of any such person.
4.2.2The Service Providers and its staff may not engage in any activities that may conflict with their independence of judgment and integrity in relation to their Classification activities. In particular they may not become directly involved in the supply, installation of animals being slaughtered or the purchaser or agent of any meat or animal product.
4.2.3All authorised parties may have access to the relevant records pertaining to the services of the Service Providers. The procedures under which the Service Providers operates must be administered in a non-discriminatory line function manner.
- Confidentiality
The Service Providers must ensure confidentiality of information obtained in the course of its Classification activities. Proprietary rights shall be protected.
- Organisation and Management
6.1The Service Providers must have an organisational structure that enables it to maintain the capability to perform its functions.
6.2The Service Providers must define and document the responsibilities and reporting structure of the organisation.
6.3The Service Providers must have a manager, however named, and experienced in the operation of the Service Providers and who has overall responsibility that the Classification activities are carried out in accordance with the Agricultural Standards Act and Regulations there under. He must be a permanent employee.
6.4The Service Providers must have designated persons who will deputize in the absence of any manager, however named, responsible for the rendering of the service.
6.5Each operation within the service shall be described. These job descriptions shall include the requirements for education, training, technical knowledge and experience.
6.6The Service Providers must maintain a system for control of all documentation relating to its activities. It must ensure that:
- the current issues of the appropriate documentation are available at all relevant locations and to all relevant staff;
- all changes of documents or amendments to documents are covered by the correct authorization and processed in a manner which will ensure timely availability at the appropriate location;
- superseded documents are removed from use through the organisation, but one copy is filed for a determined period;
- other authorised parties, as necessary, are notified of changes.
6.7The Service Providers must carry out internal audits to verify compliance with the criteria of the Act and Regulations. The personnel performing the audits must be suitably qualified.
6.8The Service Providers must have documented procedures for dealing with feedback and corrective action whenever discrepancies are detected in the performance of services.
6.9The management of the Service Providers must review the service at appropriate intervals to ensure its continuing suitability and effectiveness. The results of such reviews shall be recorded.
- Personnel
7.1The Service Providers must have a sufficient number and designated permanent personnel with the range of expertise to carry out its normal functions – this includes the availability of relief personnel.
7.2The staff responsible for the service must have appropriate qualifications, training, experience and a satisfactory knowledge of the requirements of the service to be carried out. They must have the ability to make professional judgments as to conformity with regulatory requirements and to report thereon. They must also have relevant knowledge of the technology used in the slaughter process, and of the defects which may occur during these processes.
7.3The Service Providers must establish a document training system to ensure that the training of its personnel, in the technical and administrative aspects of the work in which they will be involved, is kept up-to-date in accordance with its QMS.
- an induction period;
- a supervised working period with experienced personnel;
- continuation training, throughout employment, to keep pace with developing technology.
7.4Records of academic or other qualifications, training and experience of each member of its personnel must be maintained by the Service Providers.
7.5The Service Providers must provide guidance for the conduct of its staff, and a written code of conduct must be available.
7.6The Service Providers must ensure that persons engaged in Classification does not receive any compensation from sources other than the Service Providers.
7.7All personnel must be clearly identifiable as being a meat classifier in service of the Service Providers and must have proof of designation available at all times.
7.8The Assignee must provide the Service Providers with a national database of competent personnel, on which the Assignee will issue each Meat Classifier with an individual number, used for the purpose of designation to perform services for specific species.
7.9A classifier found guilty of fraud in a Court of Law in accordance with classification regulations. The designation of such a classifier will be withdrawn permanently.
- Facilities and equipment
8.1The Service Providers must have access to adequate suitable facilities and equipment required for rendering the service.
8.2The Service Providers shall ensure that all such equipment is properly maintained, in accordance with documented procedures and instructions.
8.3The Service Providers must ensure that, where appropriate, equipment is calibrated before being put into service and thereafter according to an established programme (e.g. Hennessey, Grading probe and Intrascope etc).
8.4The overall programme of calibration of equipment must be designed and operated so as to provide satisfactory evidence of correlation or accuracy of Classification results.
8.5If the Service Providers uses computers or automated equipment in connection with records, it shall ensure that:
- computer software is tested in order to confirm that it is adequate for use;
- procedures are established and implemented for protecting the integrity of data;
- Computer and automated equipment is maintained in order to ensure proper functioning; and
- Procedures are established and implemented for maintenance of security of data.
8.6The Service Providers shall have documented procedures for dealing with defective equipment. Defective equipment shall be removed from service. The Service Providers shall examine the effect of defects on previous Classifications.
8.7Relevant information on the equipment shall be recorded. This will normally include identification, calibration and maintenance.
9Classification methods and procedures
9.1The Service Providers must use the methods and procedures for Classification, which are defined in the Regulatory requirements, against which conformity is to be determined.
9.2The Service Providers must have and use adequate documented instructions on Classification planning and on standard assessment and Classification techniques. Where applicable, this requires sufficient knowledge of statistical techniques to ensure statistically sound assessing procedures and the correct processing and interpretation of results.
9.3When the Service Providers has to use Classification methods or procedures which are non-standard (dispensation), such methods and procedures must be appropriate and fully documented in a protocol, and approved by the NDA.
9.4All instructions, standards or written procedures, worksheets, checklist and reference data relevant to the work of the Service Providers must be maintained up-to-date and be readily available to the relevant authority.
9.5Observations and/or data obtained in the course of Classification shall be recorded in a timely manner to prevent loss of relevant information.
9.6All calculations and data transfers shall be subject to appropriate checks.
10Handling Classification traceability
10.1The Service Providers must ensure that carcasses and heads thereof be evaluated and identified to avoid confusion regarding the identity of such items at any time (traceability).
10.2The Service Providers must have documented procedures and appropriate facilities to avoid deterioration or damage to heads and carcasses which under its responsibility.
11Records
11.1The Service Providers must maintain a record system to suit its particular circumstances and to comply with applicable regulations.
11.2The records must include sufficient information to permit satisfactory evaluation of the service.
11.3All records must be safely stored for a specified period, held secure and in confidence to the client, unless otherwise required by law.