By Tony Goodger, head of marketing and communications, Association of Independent Meat Suppliers (AIMS)
Earlier this year AIMS was approached by one of its members who specialises in the catching, transportation and slaughter of end-of-life hens.
At present the business is having to throw away around four million eggs per annum as category three waste. These eggs have been harvested post-mortem from fully intact and feathered birds prior to evisceration.
What you are about to read demonstrates a degree of confused thinking on the part of the FSA at a time when the country needs to stop food waste and reduce imports of egg and egg products from countries with Salmonella and / or whose production standards are below the UKs.
The Food Standard’s Agency Manual for Official Controls says in Chapter 2.12, ‘Edible co-products’. Section 3.7.4.1 ‘Collection at different steps in the slaughterhouse’ that:
“Slaughterhouses do not satisfy the relevant definitions of ‘producer’, ‘registered production site’, ‘collection centre’ or ‘a packing centre’ and therefore FBOs cannot sell shell eggs. As such, those eggs will not comply with the definition of fresh eggs.”
Furthermore, slaughterhouses are not permitted to give eggs away to their staff for free though the site owner is allowed to consume the fully formed eggs.
The rules continue:
“Eggs that have not been laid prior to the animal’s death, cannot be eggs by definition, but would fall under the definition of offal – fresh meat, other than that of the carcase, including viscera and blood.”
As offal, the egg could be harvested as an edible co-product, ID marked and sold for human consumption.
However, the rules about eggs that have been removed from the hen at its time of death do, AIMS believe, need to be revisited in order that slaughterhouses may be permitted to recover some value from them.
Where an egg is harvested post-mortem in the presence of the site’s Official Veterinarian (OV) who then has passed the bird as being suitable for human consumption and, provided that egg’s shell and membrane are undamaged then it should, in our opinion, be permitted to enter the food chain.
Why? Well, the Manual of Official Controls, 3.7.2 says:
“Eggs are defined as eggs in shell — other than broken, incubated or cooked eggs — that are produced by farmed birds and are fit for direct human consumption or for the preparation of egg products.”
Which brings me back to whether a slaughterhouse could also be registered by its local authority as a packing centre in addition to its FSA license for the processing of birds.
Let’s face it, a hen just prior to being collected for slaughter can lay an egg that will enter the food chain as fit for human consumption but, should that hen not lay the egg at the production site but instead have it nipped out a few hours later at the slaughterhouse it will only be considered to be fit for human consumption by the owner of the slaughterhouse and nobody else, despite a vet being present at the time!
We have food banks desperate for protein to balance out the tonnes of donated carbohydrates but who are not allowed collect and distribute these eggs to the hungry.
There are liquid egg producers who would pasteurise these eggs to produce an entirely safe product but who are not allowed to do so.
And, in the case of one of our hen slaughterhouse members we have a business that is no more than 50 meters from a quiche factory. Imagine the reduction in emissions where that food manufacturers be permitted to source eggs from almost next door.
Clearly the time has come for the FSA, APHA, Defra’s egg and poultry team along with the egg industry and hen slaughterhouses to get together and correct this anomaly in the supply chain.
Otherwise, the old idiom of ‘as sure as eggs is eggs’ will need to be updated for some scenarios to something along the lines of ‘as sure as eggs is eggs offal!’