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FOD Work Plan 2016-17: Abattoir Inspections - Bovine Tuberculosis (bTB)

Summary

This outlines the 2016/17 FOD proactive sample inspection programme to abattoirs which are slaughtering cattle in England and Wales.  The inspection aim is to ensure that enhanced controls, identified as part of an HSE investigation as necessary to adequately control abattoir workers exposure to the bacterium responsible for bTB, have been implemented.

Introduction

Bovine tuberculosis (bTB) is a chronic disease of cattle and other animals.  It is caused by the bacterium Mycobacterium bovis (M. bovis), which is classified in the Approved List of Biological Agents as a Hazard Group 3 agent capable of causing severe human disease.

Humans can become infected with M. bovis through contact with infected animals via a number of routes, but the risk is at its highest through inhalation of aerosols containing M. bovis bacteria.  Symptoms of human infection include weight loss, fever, night sweats and a persistent cough.  In extreme circumstances, infection may result in death.  In 2013, a male worker in a reactor abattoir (see below*) in the West Midlands, died as a result of becoming infected with M. bovis.  The deceased was a previous farm worker who also had a suppressed immunity due to treatment for a non work-related condition.  Nevertheless, HSE’s investigation into the death (and the Coroner) considered that the deceased’s TB was most likely acquired at the abattoir and therefore was work-related.

Historically the risk of ill health from exposure to M. bovis has been perceived as low. A combination of basic hygiene measures, pasteurisation of milk and school-age BCG vaccination have been adequate to control the risk to the general population, including workers in abattoirs.  In the UK, cases of TB in humans caused by M. bovis have historically largely been attributed to ingestion of raw milk, or travel to countries where the disease is more prevalent.  However, increased numbers of infected cattle (in particular in England and Wales) are being slaughtered as a result of measures now taken to control bTB in cattle and prevent M. bovis entering the food chain.  The level of protection afforded by the previous controls has also changed with the withdrawal of the school-age BCG vaccination and increases in the migrant workforce with varied exposure and vaccination history.  Therefore, the risk and potential for harm, for workers (in particular in England and Wales), has risen and in all likelihood will continue to rise in the coming years.

Scotland has the lowest prevalence of infected cattle in the UK.  Indeed Scotland achieved and has maintained Officially Tuberculosis Free Status (OTF) since 2009.   This does not mean it is bTB free – just that it has a low and stable incidence rate.

In England and Wales, 8 abattoirs (referred to as *reactor abattoirs) are specifically approved by DEFRA to slaughter cattle that have tested positive to a TB test (known as reactor cattle), carried out on farms by vets.  Whilst data from DEFRA indicates that only about 50% of slaughtered reactor cattle will have the disease, this currently amounts to approximately 19,000 animals per annum.  Such numbers present significant potential for exposure to abattoir workers to M. bovis; also to meat inspectors and vets from the Food Standards Agency (FSA) who are also present in all abattoirs in England and Wales.  In bTB hotspot areas, where the disease is more prevalent in cattle (eg Wales, West and South West England) the percentage of confirmed TB positive cattle could be higher.

As well as the 8 reactor abattoirs across England and Wales, there are approximately 170 other abattoirs, termed as non-reactor abattoirs.  Non-reactor abattoirs do not usually carry out planned slaughter of reactor cattle but can do on occasion as recent changes in cattle movement rules now allow non-reactor abattoirs to carry out planned reactor slaughter, should a farmer choose to take his reactor herd to that abattoir.  However, even without any planned slaughter of reactor cattle, a non-reactor abattoir may also identify, during slaughter, a bovine with suspected TB (ie lesions (mainly associated with the lungs and lymph nodes) are found that have developed since the last TB test).  These are known as ‘slaughter line cases’ and the frequency at which these are encountered varies depending upon the prevalence of bTB in herds in the area where the abattoir is located.  

The potential risk of exposure to M. bovis is greater in reactor abattoirs due to the large numbers of reactor cattle and the frequency at which they are being slaughtered.

The HSE investigation, into the above death, concluded that a higher level of control is now required during both reactor and non-reactor slaughter.  A working group of the Advisory Committee on Dangerous Pathogens (ACDP) was set up, in part, in response to this death.  Its report supported the conclusion of HSE’s investigation. 

In 2015, HSE wrote separate letters to all reactor (Trim: 2016/0310702) and non-reactor abattoirs (Trim: 2016/0310732) in England and Wales, and the FSA (Trim: 2016/0310737).  Via such, all were informed of the expected controls (against M. bovis) related to animal slaughter.  This was reinforced at a meeting between HSE and the British Meat Processors Association and FSA in January 2016.

Due to the higher bTB prevalence rates (and therefore more significant risk to workers), this sample inspection programme is being concentrated in England and Wales.  All 8 reactor abattoirs are targeted for inspection as are a statistically significant number (50) of non-reactor abattoirs.  Specifically, it is aimed at regulating two dutyholders who work in co-existence at abattoirs in England and Wales ie the abattoir operator and the FSA.  Both sets of workers are exposed to a similar level of risk from bTB.  The programme will specifically ensure that the enhanced controls, in relation to control of exposure to M. bovis and communicated to English and Welsh abattoirs and the FSA, are being implemented.

Action

DIOs

Should identify and select premises using targeting information in the Organisation section of this OG. 

For each abattoir, a COIN inspection case should be set up for both the abattoir operator and the Food Standards Agency (FSA).  These should be linked.  The FSA inspection case should be allocated to the customer no ID – 4019463 at the HQ site ID 4019464 with the name of the abattoir operator included in the (problem information) summary field.

When setting up the COIN inspection cases, include the keyword #BovineTB16/17 in the notes summary line.

Plan for the majority of visits to be carried out in the appropriate quarter of the work year (see Timing).

FOD Inspectors

It is not expected that the witnessing of animal slaughter will be necessary to carry out these visits.  A combination of office-based questioning and inspection at the location of slaughter (when slaughter and subsequent cleaning / disinfecting has been completed) should be sufficient to determine compliance.  Therefore, to ensure these facilities / working conditions, inspectors should visit by appointment.  

If an inspector chooses to witness animal slaughter, then this should be for non-reactor slaughter only.  Under no circumstances, due to the risk of exposure to M. bovis, should an inspector be present during reactor slaughter. Appendix 1 details health and safety information for visiting staff.

The SIC code recorded for the premises must be checked and, if necessary, amended to ensure the visit and findings are correctly analysed for sector insight and future targeting.  Depending on the major activity, it should be either:

Please send to Manufacturing Sector information on good or poor practices found.

If inspectors prioritise action in relation to Matters of Evident Concern (MEC) or Matters of Potential Major Concern (see OC18/12), further visits should be made to complete the actions below, as necessary.

Note:  Inspection instructions under OG “Musculoskeletal Disorders in food manufacturing” (Trim: 2016/124739) will also apply to abattoir inspections.

Inspectors should assess compliance by abattoir operators and the FSA, against the control measures which are summarised below.

For Reactor Slaughter:

During reactor slaughter, it is foreseeable that workers will be regularly exposed to M. bovis, in aerosols, during high risk activities** eg

In relation to workers exposed to these high risk activities, inspectors should ensure that adequate control measures, to protect workers from exposure to M. bovis, are in place and being used.  These are:

Appendix 2 gives further detail on these controls.

For Non-Reactor Slaughter:

During non-reactor slaughter, it is foreseeable that workers will be occasionally exposed to M. bovis during the above high risk activities** and the following control measures should be in place:

Appendix 2 gives further detail on these controls.

Note:  Prior to the HSE investigation into the above death, industry control at reactor and non-reactor abattoirs was at the level of PPE provision (not RPE) and cleaning and decontamination procedures (including welfare facilities for basic employee hygiene).

Food Standards Agency

It is expected that FSA workers will be present at abattoirs throughout the working day.

Prior to the visit, for an understanding of how the FSA operates, Inspectors are recommended to read the FSA Inspector Guide (Trim: 2016/408936).  This document was primarily written for an investigation involving FSA workers. 

For the purpose of a visit during this inspection campaign, Inspectors do not have to make prior contact the FSA Health, Safety and Wellbeing Manager, nor the HSE lead inspector for the FSA, as per the section entitled “HSE investigations involving the FSA”. 

If at a site visit the FSA is determined to be in material breach, HSE will look to resolve non-compliance by taking a central and collective approach to enforcement action (i.e. on behalf of all Inspectors).  Lyn Spooner (Inspector, Crewe) has been nominated for this role.  Therefore, Inspectors should refrain from writing notification of contravention letters, etc. to the FSA.  If appropriate on site, Inspectors should verbally express their opinion (with the FSA representative) that the FSA is in contravention of the law, and what the remedial measures are.  Further, Inspectors should explain that a central resource in HSE will communicate a considered enforcement position.

Please refer below for recording and reporting instructions for the FSA#. 

Background

The Control of Substances Hazardous to Health 2002 (COSHH) is the primary legislation used to assess and secure compliance.

EMM application to health risks

Guidance is available on the application of the EMM to health risks including where there is exposure to a biological agent, to determine the risk gap and Initial Enforcement Expectation (IEE).

In relation to the health risk associated with exposure to M. bovis in abattoirs (ie for a single and low casualty):

Further details on the application of the EMM and indicative Initial Enforcement Expectations (IEE) are contained in appendix 3.

Inspectors should give priority to minimising the risk (i.e. control) over arrangements for managing the symptoms (i.e. health surveillance) and focus particularly on those common tasks where inadequate controls can result in an extreme or substantial risk gap under the EMM.

Organisation

Targeting

Target inspection numbers will be provided by FOD HQ via the overall FOD Workplan.

The sample of inspection visits across England and Wales will maximise the impact of FODs inspection resource, by targeting abattoirs in areas where the risk of bTB is at its most significant.  Hence there will be a 58 visit programme (50 non-reactor, and 8 reactor abattoirs) with the split being:

Timing

M. bovis abattoir inspections must be carried out in Q3. 

Resources

Inspect sites nationally in-line with targeting.

Specialist Support

Inspectors should seek specialist inspector support from Microbiology and Biotechnology Unit (MBU), if uncertain about the level of control required.

If support is required in relation to health surveillance and vaccination, inspectors should refer to a medical adviser within the Corporate Medical Unit.

Recording & Reporting

Visits should be recorded in line with current work recording instructions (COIN and DO IT).  See below for specific FSA instruction.

Please include in the notes discussion on each of the following questions:

  1. Processes carried out involving exposure to M. bovis.
  2. Specific control failings.
  3. Any management failings such as training, instruction etc.
  4. Health surveillance in place.
  5. SG involvement.
  6. Enforcement action taken against the abattoir operator.  Enforcement action proposed in the case of the FSA.

Food Standards Agency#

To facilitate a collective and central enforcement approach with the FSA, Inspectors should record what they found on site in the COIN case notes, in accordance with the above six questions. 

Again, if appropriate (i.e. if a material breach is determined), Inspectors should refrain from writing notification of contravention letters, etc. to the FSA.  Where a material breach is determined, Inspectors should record their time as FODND, complete an appropriate invoice line and submit their timesheet as normal.  Inspectors should send a blank email to Lyn Spooner and Warren Pennington, stating #BovineTB2016/17 and the relevant COIN Case number in the subject line.  This will assist continual central monitoring of FSA performance during Q3 and ultimately the taking forward of collective and central enforcement action.  

Health & Safety

To ensure avoidance of personal exposure to M. bovis, inspectors should carefully consider and adhere to the specific health and safety information in appendix 1.

HSE health and safety information for visits to food and drink manufacturing premises is available.

Inspectors should also be aware of the company’s procedures when visiting.

Diversity

Be aware that agency and migrant workers form a significant proportion of the workforce in the food and drink manufacture industry and their first language may not be English.

HSE inspectors can access translation services for field visits and investigations.

Further References

Relevant information and guidance:

Contacts

Appendix 1:  Specific health and safety information for visiting staff

HSE inspectors should familiarise themselves with the contents of FOD Inspector Briefing Note 2: Note for staff visiting abattoirs (TRIM: 2016/50207). 

Also important is familiarisation with HSE’s safety supplement Microbiological hazards when visiting sites. 

In general:

  1. Inspections should be announced and planned in advance to ensure the following points can be adhered to.
  2. Do not enter any location where reactor cattle are being slaughtered.
  3. Do not enter any area of any abattoir, including the lairage, whilst hygiene measures are being undertaken following slaughter of any cattle (ie wash-down and de-contamination).
  4. If an inspector choses to be present during non-reactor slaughter, he/she should be ready to immediately remove him/herself from the area, should a bovine with suspected TB be identified.  Arrangements for this should be agreed with the dutyholder prior to entering the location of slaughter.
  5. Observe precautions laid out in the COSHH assessment and any local rules and arrangements for minimising the risk of occupationally acquired infections.
  6. Irrespective of local rules, be prepared to take sensible general precautions:
    • Adopt good standards of hygiene e.g. thorough hand washing, keeping hands away from mouth.
    • Avoid direct contact with potentially contaminated material or surfaces, especially faecal matter or objects/surfaces contaminated with faecal matter.
    • Wear suitable protective clothing eg wellington boots, coveralls (preferably disposable), safety glasses etc.
    • Where facilities allow, clean contaminated PPE before leaving site.  Alternatively, remove and where possible dispose of any contaminated PPE on site.
    • Cover wounds, with a waterproof dressing.
    • Clean any cuts or abrasions received during a visit as soon as possible and cover them with a sterile dressing.
  7. If advice is required, contact MBU or Corporate Medical Unit.

Health screening / BCG vaccination is not considered necessary for HSE visiting staff.  This position follows assessment that the risk to staff, from short term exposure, that avoids high risk activities, is very low.  However if staff are vulnerable to acquiring infections due to an underlying medical condition or treatment, then they should discuss this with their line manager.  In these circumstances, occupational health advice should be obtained to consider a member of staff’s medical fitness to visit an abattoir, where cattle are slaughtered or equivalent.

Appendix 2: Cattle Slaughter – bTB Related Control Measures

Provision of adequate Respiratory Protective Equipment (RPE):

For reactor slaughter, RPE should be provided and worn by all those exposed to or who may be exposed to M. bovis during higher risk activities**.   

For non-reactor slaughter, RPE should be provided and worn by those similarly exposed:

RPE (FFP3 protection factor) should be designed for protection against aerosols, maintained and appropriately stored.  In practical terms, disposable RPE is likely to be most suitable to remove the risk from contamination of RPE.

Face-fitting should ensure that selected RPE is suitable for each individual.  If necessary, visit the web guidance.

Controlling the Environment: 

For reactor slaughter, the environment where there is potential for exposure to M. bovis (ie the areas where higher risk activities** are taking place or the areas where aerosols may migrate to from these activities), should be controlled to prevent access by workers who are not wearing suitable RPE.  This could be achieved by placing signs on all entry doors warning of reactor slaughter and the presence of a biological agent, and the need for use of RPE in the specified areas.  If it is not reasonably practicable to physically segregate high risk** activities for workers not engaged in these tasks but who are potentially exposed to aerosols arising from them then RPE will need to be worn by these workers as well.

For non-reactor slaughter, control of the environment (as above) is applicable:

Decontamination and Cleaning Procedures:

Following reactor slaughter, contamination of the environment, equipment, individuals etc, should be adequately cleaned / disinfected to ensure the M. bovis organism is destroyed.  Procedures should at least include the following:

For non-reactor slaughter, this control measure should also be taken:

Health Surveillance and BCG Vaccination: 

These control measures apply to workers in reactor and non-reactor abattoirs, who are potentially exposed to M. bovis during higher risk activities**.

There is no specific health surveillance standard for TB.  This is because the onset of TB is influenced by various individual/personal risk factors, including exposure to and susceptibility to it.  Therefore the basis of any suitable health surveillance programme should be to check on susceptibility, likely exposure and these other personal risk factors. 

Suitable health surveillance should contain, as a minimum, the following:

1. Pre-placement screening of those working in reactor abattoirs:

1.1. A pre-placement health check should be undertaken to consider a worker’s fitness for work in an environment where M. bovis is likely to be present. 

1.2. Existing employees, who have not undergone this fitness for work health check,  should also have this undertaken.

1.3. Health checks for new employees or those new to a health surveillance programme should include:

2. Provision of BCG vaccination:

BCG vaccination should be offered and made available to all workers who are:

The distinction between those who are under or over 35 years of age in respect of BCG vaccination, is made in the current Department of Health document Immunisation against infectious disease, based on knowledge of vaccine effectiveness.  There is not currently sufficient evidence to support its effectiveness in people over 35 years old.

Employers cannot force workers to have the vaccination.  If a worker (under 35 years old) refuses, that person’s work/tasks should be managed to ensure that are not put at risk of exposure to M. bovis.

Vaccine Availability:

Inspectors should be aware that this vaccination action is not likely to be presently achievable due to a global shortage of this BCG vaccine.  Initial enforcement expectations in appendix 3 are therefore based on the vaccine being unavailable.  Dutyholders may refer to this shortage as a reason for an absence of vaccination.  Inspectors should seek evidence of failed attempts to source the BCG vaccination.  If evidence is provided, it is recommended that an advice letter confirms the importance of implementing this control measure as a matter of priority.  If no attempt has been made to source BCG vaccination, a NoC letter is recommended to provide this same message.

If inspectors find that a vaccine supply has been sourced, this information should be sent back to Manufacturing Sector.

3. Ongoing Occupational Health

This should include a minimum of the following:

4. Management Arrangements

To ensure an adequate health surveillance programme, management arrangements should contain and have considered at least the following:

A system of monitoring the delivery of the health surveillance programme.

Appendix 3

Updated 2017-01-29