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)*
Included as Table 6 – List of
requirements for service
providers.
Translated these requirements
into Afrikaans – Tables are
indicated in both languages.
Reference made to Table 6 in
definition for "Service
Providers".
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"
(3) Inclusion of requirements
for Lighting
The meeting supported the
draft proposal.
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.
Industry (via SAMIC)*
SAMIC’s proposal that
minimum lighting of 540 lux be
required at the point of
classification.
Moved definition for "Meat
classification" from table to
beginning of regulations.
Included definition for "Service
Providers".
See point (4) of this table.
Changed regulation 3(1)(b) to
refer to "Service Provider".
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).
(5) Regulation 3(5)
Industry (via SAMIC)*
(6) Regulation 3(7)
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).
Industry (via SAMIC)*
The DAFF pointed out that
“responsible person” shall be
replaced with “designated
independent service provider”.
Regulation 3(5) amended as
requested.
"Responsible person" replaced
by "Service Provider" in
regulation 3(7).
"independent" – included it in
the definition and Table 5.
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.
(7) Regulation 3(10)
(8) Regulation 15(3) and
Table 4 – M/D stamp marks
Industry (via SAMIC)*
SAMIC requested that the “48
hours” requirement be reduced
to “24 hours".
Industry (via SAMIC)*
Regulation 3(1) amended to
"24" hours.
Included as requested.
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)&
Not included at this stage.
This suggestion will result in
that the abattoirs now must
have additional rollers
This proposal is different than
decided on at the meeting.
DAFF – Additional point&
It was mentioned that
regulations 15(3)(b) reads
difficult.
Regulation 15(3)(b) split into
15(3)(b) and 15(3)(c).
(9) Independence of teeth
counter
The meeting #
No changes to the regulations
were made in this regard.
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.
(10) Table 2
(11) Use of the term
“bovine”
(12) Trade marks, protocols
and new labelling regulations
of the Department of Health
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.
The meeting #
Heading and Table amended
as requested.
Included definition to clarify
"bovine" in the English.
The DAFF will investigate the Afrikaans version is correct by
use of other designations as the referring to "bees".
term bovine includes animals
such as water buffalo as well.
The meeting #
Removed definition for "trade
mark" and replaced it with
The Chairman pointed out that definition for "quality
in terms of the new labelling indication".
regulations of the Department
of Health which will come into Replaced all reference to "trade
operation on 1 March 2012, the mark" with "quality indication"
use claims such as “grain fed”, in the regulations.
“grassfed”,
“Karoo
lamb”,
“natural lamb”, “country reared”, Included "quality indication" in
“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.
(13) Brine injection
regulation 2(2)(b).
Included "quality indication" in
restricted particulars –
regulation 23(2).
Quality indications can be
stamp marks as well, not only
The current regulations do not roller-marks – see definition for
require that an abattoir supply a "quality indication".
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”).
DAFF - Additional point&
Added regulation 21(7) to
provide for the indication of the
Due to the brine injection issue treatment.
in chicken that made news
Reference is made to the
headlines recently DAFF
labeling of raw-processed
suggests that the red meat
meats as required by Dept of
industry consider looking at this Health.
practice for the red meat
industry – these regulations can Definitions for "Brine Injected"
only regulate it for carcasses
and "Permitted" added.
and fresh and frozen cuts from
these carcasses.
Changed heading of regulation
21 to include brine injected.
See labeling regulations of
DoH – definition for "raw-
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
(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.
(15) Untidy and smudged
roller-marks and stamps
(15) Service Provider must
take responsibility for
classification stamps
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.
DAFF – Additional point&
The regulations imply that
roller-marks and stamps must
be legible but nowhere is it
specifically addressed in the
regulations.
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
processed meats" and
regulation 26(2).
Table 5 was included.
Reference to Table 5 was
included – regulation 4(5) for
cattle, sheep and goats and
regulation 10(5) for pigs.
Inserted regulations 15(5) and
17(5).
Added this requirement to
regulation 3(3)(c).
abuse.
(16) Meat of other species
and sub-species
for the safekeeping of the
classification stamps (not the
rollers)
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.
1.
Definitions
For the purpose of these requirements the following definitions apply:
1.1 Classification
a. Evaluation of the carcass, by way of age determination, fat content, conformation, damage and muscularity;
b. To see to it that:
Regulatory requirements pertaining to age, fat content, conformation, damage and muscularity is maintained according to
the set regulations;
c. To monitor and report to the relevant Service Providers any aspect of non-compliance to these regulations.
1.2 Service Providers
The designated organisation that provides the service as prescribed by Regulations of the Agriculture Standards Act (Act
119 of 1990).
2.
Scope of Independent Meat Classification Service
2.1 Meat Classification Services
2.2 Auditing
2.3 Training and Reporting
3. Administrative Requirements
3.1 The Service Providers must be legally identifiable.
3.2 The 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.
3.3 The Service Providers must have a contractual agreement with the Assignee.
4. Independence, Impartiality and Integrity
4.1 General
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.
4.2 Independence
The Service Providers must be independent and provide a service that will meet the following criteria:
4.2.1 The 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.
4.2.2 The 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.
4.2.3 All 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.
5.
Confidentiality
The Service Providers must ensure confidentiality of information obtained in the course of its Classification activities. Proprietary
rights shall be protected.
6.
Organisation and Management
6.1 The Service Providers must have an organisational structure that enables it to maintain the capability to perform its
functions.
6.2 The Service Providers must define and document the responsibilities and reporting structure of the organisation.
6.3 The 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.
6.4 The Service Providers must have designated persons who will deputize in the absence of any manager, however named,
responsible for the rendering of the service.
6.5 Each operation within the service shall be described. These job descriptions shall include the requirements for education,
training, technical knowledge and experience.
6.6 The Service Providers must maintain a system for control of all documentation relating to its activities. It must ensure that:
a.
b.
c.
d.
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.
6.7 The 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.
6.8 The Service Providers must have documented procedures for dealing with feedback and corrective action whenever
discrepancies are detected in the performance of services.
6.9 The 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.
7.
Personnel
7.1 The 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.
7.2 The 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.
7.3 The 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.
a.
b.
c.
an induction period;
a supervised working period with experienced personnel;
continuation training, throughout employment, to keep pace with developing technology.
7.4 Records of academic or other qualifications, training and experience of each member of its personnel must be maintained
by the Service Providers.
7.5 The Service Providers must provide guidance for the conduct of its staff, and a written code of conduct must be available.
7.6 The Service Providers must ensure that persons engaged in Classification does not receive any compensation from
sources other than the Service Providers.
7.7 All 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.
7.8 The 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.
7.9 A 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.
8.
Facilities and equipment
8.1 The Service Providers must have access to adequate suitable facilities and equipment required for rendering the service.
8.2 The Service Providers shall ensure that all such equipment is properly maintained, in accordance with documented
procedures and instructions.
8.3 The 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).
8.4 The overall programme of calibration of equipment must be designed and operated so as to provide satisfactory evidence of
correlation or accuracy of Classification results.
8.5 If the Service Providers uses computers or automated equipment in connection with records, it shall ensure that:
a.
b.
c.
d.
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.
8.6 The 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.
8.7 Relevant information on the equipment shall be recorded.
maintenance.
9
Classification methods and procedures
This will normally include identification, calibration and
9.1 The Service Providers must use the methods and procedures for Classification, which are defined in the Regulatory
requirements, against which conformity is to be determined.
9.2 The 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.
9.3 When 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.
9.4 All 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.
9.5 Observations and/or data obtained in the course of Classification shall be recorded in a timely manner to prevent loss of
relevant information.
9.6 All calculations and data transfers shall be subject to appropriate checks.
10 Handling Classification traceability
10.1 The 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).
10.2 The Service Providers must have documented procedures and appropriate facilities to avoid deterioration or damage to
heads and carcasses which under its responsibility.
11 Records
11.1 The Service Providers must maintain a record system to suit its particular circumstances and to comply with applicable
regulations.
11.2 The records must include sufficient information to permit satisfactory evaluation of the service.
11.3 All records must be safely stored for a specified period, held secure and in confidence to the client, unless otherwise
required by law.