Summary
Scientific findings on the public health hazards of relying on end of process chlorine washing highlight the difficult choices which lie ahead for the UK government in regard to the future basis for post-Brexit food safety standards. These choices will carry important implications for UK-US trade negotiations and the level of controls the EU will apply to agro-food imports form the UK. This issue of regulatory divergence heightens the danger of a ‘hard’ Brexit in the agro-food sector. This suggest a need for ACP exporters serving triangular supply chains to start work now on identifying what administrative measures can be put in place to minimise disruption of current supply chains.
A study by a team of microbiologists from Southampton University has found ‘bacilli such as listeria and salmonella remain completely active after chlorine washing’, with the process ‘giving the false impression that the chlorine washing has been effective’, while it merely masks the presence of these bacteria (1).
This confirms the findings of earlier previous studies, all of which have been ‘dismissed by the US poultry industry as producing “laboratory-only” results with no relevance to the real world’. US National Chicken Council representatives described the most recent findings as ‘silly’, maintaining this wasn’t ‘an issue of science, rather one of politics and protectionism’ (1).
Press analysis notes ‘while chicken farmers in the EU manage contamination through higher welfare standards, smaller flock densities and inoculation, chlorine washing is routinely used in the US right at the end of the process, after slaughter, to clean carcasses’.
Professor William Keevil, who led the Southampton University team, noted how the issue was less to do with the chicken itself since contamination can be managed by thorough cooking. However the danger exists that while ‘giving the impression of being safe’ chlorine-washed chicken ‘can then cross-contaminate the kitchen’. (1).
The public health implications are seen as potentially serious. Analysis from the UK food and farming pressure group Sustain noted how according to the US Centre for Disease Control and Prevention ‘about 380 people die each year in America from foodborne salmonella poisoning’. In contrast figures from Public Health England show that between 2005 and 2015 ‘not a single death from salmonella poisoning in England and Wales’ was recorded (1).
The Chief Executive of Sustain stressed how ‘proper food safety relies on clean production methods with high animal welfare, resilience to disease, and full traceability and labelling – not just end-of-pipe chemical washes (1). According to the British Poultry Council chlorine washing simply masks shortcomings in US production processes.
The UK Food Standards Agency meanwhile highlighted how ‘only water safe for human consumption can be used to remove surface contamination from poultry carcasses in EU countries’ and stressed how ‘the current rules will remain in place after the UK leaves the EU (1).
These kinds of issues linked to the differences in US and EU approaches to food safety and public health could well become a major complicating factor in UK/EU27 post-Brexit agro-food sector trade negotiations. Analysis by the UK Soil Association cites no less than 10 major issues where US and EU standards differ (see box) in a context where the US Commerce Secretary is insisting ‘the UK would have to accept American food standards if it was to secure a trade deal’ (3)
| 10 food safety risks under a free-trade deal with US
A report by the Soil Association highlights 10 concerns about food safety in a post-Brexit era. These foods are currently banned in the UK: 1. Chlorine-washed chicken (banned in the EU). 2. Hormone-treated beef (banned in the EU). 3. Ractopamine in pork (banned in the EU). 4. Chicken litter as animal feed (banned in the EU). Includes the birds’ faeces. 5. Atrazine-treated crops (banned in the EU). Atrazine is a herbicide used on 6. Genetically modified foods (banned in the EU). 7. Brominated vegetable oil (banned in the EU). BVO is used in citrus drinks; Coca- 8. Potassium bromate (banned in the EU). A dough conditioner also banned in 9. Azodicarbonamide. A bleaching agent for flour, it has been linked to an increase 10. Food colourants (banned in the UK, regulated in the EU). Can lead to Observer, ‘10 food safety risks under a free-trade deal with US’, 26 May 2018 |
| Comment and Analysis The debate around chlorine washing highlights the difficult choices which lie ahead for the UK government. The choices made around food safety standards are likely to be central to both any future UK-US trade negotiations and the level of standard 3rd country controls applied to UK-EU27 agro-food sector trade. While the UK Food Standards Agency has stressed how current rules will remain in place after the UK leaves the EU and the UK Secretary of State for the Environment, Food and Rural Affairs has reiterated the UK’s commitment to high food safety standards, the pressure to address US criticism of the trade protectionist nature of EU non-tariff measures within any future UK-US trade agreement through substantive policy changes will be intense. To the extent the UK gives way to US pressure on food safety measures and UK and EU27 food safety standards diverge, the EU is likely to respond with stricter inspection and documentation requirements on imports from the UK, slowing down current trade flows. The issue of chlorine washing is just one of many issues arising in future UK-EU27 agro-food sector trade which are making the prospect of a ‘hard’ Brexit in the agro-food sector increasingly likely. UK Government complacency in this regard was most recently highlighted in the findings of the The House of Lords European Union Committee report on “Brexit: Food prices and availability” published on 10th May 2018 (4), which highlighted a distinct difference in the level of concern being displayed by private sector bodies involved in the UK food trade over the dangers of severe trade disruption and government Ministers. UK government Ministers take the view a comprehensive customs arrangements whether consisting of the ‘customs partnership’ option, the ‘maximum facilitation’ option or some hybrid arrangement will largely take care of all the concerns being expressed over the trade disruptive effects of non-tariff barriers in the post-Brexit period (beyond 1st January 2021) (see companion epamonitoring.net article, ‘Treatment of Agriculture under a EU27/UK FTA’, 28 May 2018). It is against this background that the time is rapidly approaching when ACP agro-food exporters along triangular supply chains will need to identify precisely the nature of the administrative arrangements which will need to be set in place to between ACP/EU27 and UK authorities to ensure the continued smooth onward flow of products along existing triangular supply chains. This may need to take the form of sector or product specific protocols dealing not only with tariff issues, but also more importantly non-tariff issues, such as the continued recognition by the UK authorities of existing SPS and food safety standards compliance documentation. Similar recognition issues will arise for goods transiting the UK to a EU27 member states (i.e. through the UK to Ireland). These protocols would need to apply for an extended period of time after the UK has formally left the EU and not just the transition period in EU27/UK relations. Given the extensive demands arising within the purely EU27/UK trade negotiation process, in order to kick start the process, affected ACP exporters may need to initiate dialogues with their EU27 and UK trade partners on what concrete administrative arrangements will be required. It is these types of dialogues which a “Be Prepared Facility” could usefully support in the coming 30 months. |
Sources
(1) Observer, ‘Chicken Safety fear as chlorine washing fails bacteria tests’, 26 May 2018
https://www.theguardian.com/world/2018/may/26/chicken-health-fear-chlorine-washing-fails-bacteria-tests-brexit-salmonella-listeria
(2) mbio.asm.org, ‘Viable-but-Nonculturable Listeria monocytogenes and Salmonella enterica Serovar Thompson Induced by Chlorine Stress Remain Infectious’,
http://mbio.asm.org/content/9/2/e00540-18.full
(3) Guardian, ‘Trump adviser Ross says UK-US trade deal will mean scrapping EU rules’, 6 November 2017
https://www.theguardian.com/business/2017/nov/06/trump-ross-says-uk-us-trade-deal-eu-brexit-chlorinated-chicken
(4) The House of Lords European Union Committee, ‘Brexit: Food prices and availability’, 10th May 2018
https://publications.parliament.uk/pa/ld201719/ldselect/ldeucom/129/129.pdf