The Permanent Secretary explained that Ministers had been aware of the burdens which would be placed on the industry by the introduction of conveyancing solicitors brisbane veterinary supervision. It had been the intention that local authorities should use a high degree of flexibility to operate a meat inspection service appropriate to the needs of individual plants; Circular FSH 1/92 had given guidance to that effect. However, during the autumn of 1992 it had become clear that local authorities were planning to put in place widely varying levels of supervision, and many were intending to impose full-time supervision regardless of the size and hygiene standards of the plant.
Ministers had agreed that full-time supervision would place a disproportionately heavy financial burden on smaller plants. In order to ease that burden and ensure a greater consistency across different local authorities, Ministers had decided to issue further more specific guidance in the form of Circular FSH 4/92. The Permanent Secretary said that Ministers had been aware that the levels of supervision recommended by Circular FSH 4/92 were not those required by the 1991 Directive.
However, although under the Circular only 139 out of the 605 abattoirs in England and Wales would receive full-time veterinary supervision, those plants processed 75% of the total throughput.
In any event, it would have been impossible to achieve full-time supervision in all abattoirs. Having regard to the history of veterinary supervision in the United Kingdom, the costs to industry and the resources available to local authorities, the decision to target veterinary resources in that way had been a reasonable one. The implementation of European requirements for veterinary supervision was a difficult and complex policy area.
Decisions had to be taken which struck the right balance between the protection of public health, costs to industry, and consistency with the law. In implementing the 1991 Directive the then Government has aimed to make a balanced judgment on the levels of supervision required to protect the consumer and avoid overburdening an industry which was operating on extremely small profit margins and investing heavily in structural improvements to upgrade to European standards. The fact that the European Commission had subsequently found that the United Kingdom’s arrangements were not in conformity with the law did not change MAFFs conclusion that a considered decision had had to be made.