Bonina Foods was a small cottage industry run in the West of Ireland, by the proprietor, her business partner and two part time employees.
The company had to cease production in the summer of 2002, because of draconian hygiene directives introduced by the EU, which were
completely inappropriate for small food producing cottage industries.
The following is a correspondence between the proprietors of Bonina Foods and the Director of the Food Safety Authority of Ireland (FSAI)
leading up to the closure of the production facilities.
BONINA FOODS
Kildimo
Miltown Malbay
Co Clare.
29th Jan 2002
Dr. P. Wall
Director,
Food Safety Authority of Ireland
Re. FSAI Guidance Note N o. 4
Dear Sir,
This company is a cottage industry, run by my wife and her business partner.
They produce about 20,000 worth of black pudding per annum for a strictly local, West Clare
market. The business has been running for about 10 years.
About 15 months ago we felt the need to expand the business somewhat in order to finance
an improved hygiene/food safety regime. At the time we were advised that new severe hygiene
restrictions were about to be issued by your office and we felt that it would be best to have sight
of these before committing ourselves to any large investment. Even now we are still not in position
to make the required improvements, due, inter alia, to the manner in which the new guidelines have
been introduced. There are three main problems as follows:
Our product is made with fresh blood (an essential part of the recipe ) which is sourced
from a local abattoir, approved by the appropriate health authorities. We are, however, informed that
we may not be permitted to use this local source, because it is not approved for export, even though
we do not ,of course, export our product. This to me is quite inexplicable. I do not understand what
public health issue is involved ?? We are told that a final decision on this matter will issue shortly.
When it does and assuming that we can accommodate that decision, what time period will we be allowed
thereafter to comply with the other aspects of the new regulations ???
We have been advised that we should not make any long term investment in our present premises
because that premises is in the vicinity of a farmyard. The guidelines require the site to be "removed
from farmyards" etc. this of course is a very general statement where specific directions are required.
How far from a farmyard must the food premises be ? Does "farmyard " include an area where
machinery is stored ? given that all milk and meat products originate on farmyards does the FSAI
consider farmyards to be a health risk per se ? If it should be that your answer to the above, is
that it depends on the individual circumstances, what appeals procedure is there against an
FSAI decision on the matter ?? Do you consider say, cheese production on a farmyard to be
objectional??
The same position applies to proximity to a domestic dwelling. Our food premises is attached to
our private house. We are prepared to rearrange the layout so that there is no internal connection
between the two but we are still advised, informally, that this will not be acceptable in the long run.
I am not aware of any specific reference to dwelling houses in the guidelines but it seems that it may
be implied under a general heading. Are we to believe that proximity to a private dwelling constitutes
a food safety risk ? If this is the case and if it applies to all food products then it rings the death
knell for all food based cottage industries. Could you please let us have a definitive statement on
this ? explaining the perceived health risks (if any) and what distances are necessary to obviate
them. Is it considered objectionable, for instance, for security staff to reside on a food premises.?
We require answers to the above points urgently to enable us to proceed with our expenditure
programme for food safety. There are, however, a number of other questions, as follows, to which
we would appreciate a response.
As a registered food premises of long standing, the only direct contact we have had from the
FSAI was an invitation to a meeting in Limerick to discuss the guidelines, which, at the time
were "forthcoming". My wife attended that meeting and heard an assurance that there would be a
derogation for small businesses such as ours. When the guidelines were issued the derogation never
materialised. Why ?? In fact the guidelines completely ignored the existence of small scale food
producers. It is clearly impossible that a single set of guidelines could cover situations as diverse
as a cottage industry and a multinational food factory. For instance, under the heading of "Rooms
Required", item J, page 13, states "An adequately equipped secure room/facility for the exclusive
use of the competent authority must be provided". are we to take it that a cottage industry which
cannot comply with this item will be closed ??
The guidelines tell us that butchers who produce products such as black pudding for direct sale
To@the public are excluded from the scope of these guidelines, regardless of the quantity they produce.
A large supermarket might produce ten times as much black pudding as we do. Perhaps you could
explain to us why public health/food safety requires that we should comply with a far stricter set
of guidelines than someone who produces significantly more than us for sale to the same public.?
Even the most casual perusal of the guidelines will make it obvious to anyone that the very
Small@business was not catered for when they were being drafted. Large premises with multiple
Different@rooms, numerous staff for allocation to different tasks and substantial capital for
investment in@equipment are all taken for granted, even though these attributes are rarely available
to cottage@industries. For instance, in our situation a minimum investment of some 20,000E will be
required just@for additional refrigeration equipment, which when it is installed will be running at
a fraction of its@capacity, based on our present production throughput. This will, of course, put us
at a serious@economic disadvantage in the market place. Other cottage industries will obviously
face a similar@situation. Given that our current operation does not@present any serious threat
to public health,@we would like to hear your comments on this aspect of the guidelines.
One might have expected that when the FSAI was established in 1999, they would at an early
Stage@have contacted all registered food producers with a statement of your policies and proposals
for the@industry. It would be normal to seek submissions from interested parties and perhaps give
assurance@to producers that as long as public health was not compromised you would give reasonable
assistance@for them to meet such new standards as were deemed essential. The FSAI might have made
advisers@available to small businesses, who would obviously not be in a position to engage
professional@consultants. Why was this not done ?? Were any trade associations etc. consulted before
formalizing@the guidelines ??
As a farmer, I am well aware that when the government introduces environmental schemes, such
As@the Control of Farmyard Pollution Scheme then invariably there is also a grant scheme to assist
Those@who are forced into additional expenditure. Why was there not some such scheme recommended to
the government in conjunction with the new guidelines.
In common with many other people I believe that the best possible assurance of high quality,
Safe@food is the personal supervision of the entire production process by a proprietor who is well
Trained@in all aspects of hygiene and who is identifiable by the final consumer. This is the situation
That@prevails in most cottage industries and it should be encouraged rather than ignored. Obviously
Such@a situation is impossible in a large industry and a HACCP system may be a suitable second best,
But@only second best! HACCP was not devised, nor is it appropriate for a business situation such as
Ours@(albeit there is much to be learned from studying such systems). The excessive and spurious
paperwork required by HACCP may indeed "form the basis of a due diligence type defence should
this prove necessary", but in practise is more likely to distract proprietorial attention from
production processes, to the detriment of hygiene etc..
All the questions raised above seem to beg the further question --- is it the policy of the
FSAI to eliminate small scale businesses such as ours??
I look forward to your response.
Yours sincerely,
Donal de Barra
Bonina Foods
cc An tUas. Eamon O`Cuiv
Minister for Rural Developement
Mr. John Molloy A.C.B.I.
Mr. Padraig F lynn,
Clare Co. Council.
*******************************************
RESPONSE TO THE ABOVE:
FOOD SAFETY AUTHORITY OF IRELAND
26TH February 2002
Dear Mr. De Barra,
I acknowledge receipt of your letter of 29th January addressed to Dr. P Wall, Chief
Executive.@I am grateful to you for the letter as you raise a number of very significant
issues for@which clarity is required by the trade.
Firstly, to clarify the role of the Food Safety Authority of Ireland. The Authority was
Established@in 1999 as an independent agency whose role is to protect consumers` health
by ensuring that food@produced, consumed, distributed or marketed in the state meets the
highest standards of food safety@and hygiene. In July of 1999, Part IV of the FSAI Act
was @commenced. This had the effect of@transferring responsibility for enforcement of
all food safety legislation to the Authority.@The Authority discharges this function via
service contracts which it has negotiated with two@government departments, ten regional
health boards, thirty three local authorities and a number@of other agencies.
Meat manufacturing premises, such as your own, are regulated by three EU directives and
their corresponding@Irish Statutory Instruments. No new legislation has been introduced for
that sector since the establishment@of the FSAI. Since the Authority is responsible for a
seamless inspection service and for ensuring a@glevel playing pitchh in the enforcement of
legislation across the country and across sectors, it was@recognised that such meat premises
had not been regulated under the appropriate regulations prior to the@establishment of the
Authority. The Authority set out on a process of informing the trade on the requirements
of the legislation and ensuring its enforcement via the Local Authority veterinary Inspection
Service. The supervision of this part of the trade has been subject to an audit mission by the
Food and Veterinary Office of the European Union and the report of this mission has confirmed
that the approach adopted by the Authority is the correct one.
You specifically ask if the Authority has a policy to close small meat manufacturing businesses.
I can confirm categorically that the answer to this question is no. In fact, the Authority is
Operating pro-actively to support such businesses. Much effort has been expended in training of
the Local Authority Veterinary Inspectors to enable them to assist the proprietors of such
premises. Whilst as an agency we have no brief relating to the provision of grant aid for any
business, we have in fact raised the issue of the small food manufacturers at the highest levels
both here in Ireland and at the European Union and we continue to advocate for support for
this sector.
As part of the consultation process for the change in the regulatory regime applied to such
premises, the Authority held a series of six regional meetings to which the proprietors of
all such premises and the veterinary Inspectors of the regions were invited. We have since
conducted a series of training days for the Local Authority Veterinary Inspectors and provide
two experienced staff members who are available to visit with the Local Authority Veterinary
Inspectors to any premises at their request. Guidance Note No. 4 referred to in your letter,
was prepared to assist the trade and the inspectors in understanding the provisions of the
regulations. I acknowledge the point made in your letter regarding the lack of any detailed
exposition of derogations in the guidelines. If it is deemed necessary, we will of course
produce a guidance on this matter. Presently, the Local Authority Veterinary Inspectors are
fully aware of the provisions of the guidelines including any derogations available and should
be in a position to advise proprietors appropriately. In the case of your own premises I would
hope that you would find this level of advice helpful and a member of staff of the Authority
would be pleased to visit to advise you should you deem this appropriate. An example of
a derogation is the issue of accommodation facilities for the visiting inspector. The
derogations provide that rather than a room, an appropriate locker is acceptable.
Regarding the issue of consultation with the trade, as stated already we have had a series of six
regional meetings. A notice was placed in the national newspapers and we also wrote to the
proprietors of all relevant businesses. Subsequently we have had a range of meetings with ACBI,
which represents a number of proprietors, and we have ongoing consultation on an ad hoc basis with
various groups. Industry are also represented in a formal way on our consultative council. We are
always happy to meet with individual proprietors or with industry groupings to clarify any
issues as required.
Regarding the issue of production of product at the rear of retail butcher shops, there is a very
specificand real issue here which is still unresolved. The EU directives provide exemptions for
products produced at the rear of retail butcher shops which are prepared for sale to the
gfinal consumerh. This term gfinal consumerh has been defined in Irish Statutory Instruments as
including sale directly over the counter and sale into the catering trade. Sale to other retail
or wholesale outlets is excluded. This definition is not entirely satisfactory from a consumer
protection point of view, as potentially large volumes of product could be supplied to the catering
trade from such premises. The FVO mission, referred to earlier, has referred this matter to the
legal services of the Commission to obtain a ruling. We await that ruling and will take appropriate
action when it comes to hand. In the meanwhile, Hygiene requirements at such premises at the rear
of retail butchers are being monitored.
On the issue of timescales, we have gone through a process, as I have outlined above, which has
Involved consultation, training, a mission report from the FVO, publication of the Guidance Notes
and ongoing inspections of the various premises by the Local Authority Veterinary Inspectors.
During this process a number of additional matters have been clarified further. Specifically the
health mark issue has been clarified. With regard to premises such as your own, two health marks
are possible. One health mark is a full oval EU approval health mark which indicates that the
premises is in full compliance with the directive and may place product into intra-community
trade. The second health mark is a modified oval health mark which will allow product to be traded
on the domestic market. Such premises can avail of the derogation outlined earlier. If your
application relates to the modified oval mark for domestic trade you may then source your raw
material from approved or permanently derogated abattoirs i. e. you may continue to take your
supply of blood from the local abattoir. Following approval of the premises, you will be allocated
a modified oval health mark which will allow the product to trade on the domestic market.
Regarding the issue of premises located within farmyards, you raise a very valid point. The obvious
Issue is the proximity of the food premises, be it meat or cheese, to livestock, manure storage, and
animal feed stores. In fact, a good example is the farmhouse cheese sector where a production
facility is located within the farmyard but appropriate separation ensures that there is no risk
to the finished product. The same principles apply in respect of meat premises. With regard to a
private dwelling, some very small premises have some obvious issues relating to direct contact
between the private dwelling and the food processing area and other issues such as lack of separate
toilet and washing facilities. Once these issues are resolved, there is no difficulty with a
premises which is physically adjacent to, but physically separated from, a residence being approved.
Again, can I confirm that the focus of the Authority is on safe food production and consumer
protection. There is no agenda to close any category of premises.
Please feel free to contact me again, when you have had time to review this letter, should you
require any further information.
Yours sincerely
Pat O`Mahony
Director of Consumer Protection
*******************************************************
BONINA FOODS.
KILDIMO,
MILTOWN MALBAY
CO. CLARE
PHONE 065/7084156
E. MAIL : BONINA@EIRCOM.NET
18 MAR. 02.
Pat O`Mahony,Esq.,
Director of Consumer Protection,
Food Safety Authority of Ireland,
Abbey Court,
Lower Abbey Street,
Dublin 1
Dear Mr O`Mahony,
Thank you very much for your letter of 26th Feb 02 and for the indepth response to my
queries.
Notwithstanding the detailed nature of your reply, I am afraid there are still some areas
which I do not fully understand and so I take up your invitation to enquire further.
Regarding the manner in which the FSAI apply regulations to the meat industry, it is my
understanding that the Statutory Instruments, upon which the Guidance Note no. 4 are based,
make specific provision by which smallscale businesses, such as ours, may be exempted from
the scope of those instruments, in exactly the same way as retail butchers are exempted
from them. If I am correct in assuming that the Statutory Instruments make provision for
such exemption (derogation ?), does it not follow that the Minister who signed the S. I.,
as well as Dail Eireann, anticipated that small business should/could not be visited with
the same regulations as those appropriate to a large meat processing plant. If this is
the situation, why does not the Guidance note, follow the S. I in granting a specific
derogation.
But then in paragraph 4 of your letter you comment on gthe lack of any detailed exposition
of derogations in the guidelinesg. This seems to imply that a derogation already exists by
which Guidance Note 4 does not apply to us at all. If this is so then I can only express
total dismay, that the FSAI could send us a set of guidelines and a formal edict to comply
with them, or else ............. when a derogation exists by which the guidance does not
apply to us at all or applies to us only in part. Again you say in your letter gIf it is
deemed necessary, we will of course produce a guidance on this matterh Could there possibly
be any situation in which a small business would not deem it absolutely necessary to know
that the very costly regulations which they had been instructed to implement forthwith,
did not in fact apply to them. ? If a derogation exists, have details of it ever been ]
published ? If the foregoing appears to indicate confusion on my part, then the indication
is accurate.
Can I now return to paragraph 5 of your letter. In my first letter to you I expressed my feeling
that the FSAI were intent on closing small business` such as ours and you categorically deny
that this is so. I accept your assurance. I feel, however that I should relate, that my wife
and her business partner visited the Teagasc Food Research Centre in Limerick, in the interim
since my first letter. The message that they got there, and it was very strongly expressed,
was that we were wasting our time and money trying to meet the new regulations, that the FSAI
were hvery serioush about closing down people like us. We were told that closure of our
production facility in the short term was inevitable and that if we wanted to stay in business
we should pass our production over to a large factory and concentrate on marketing the result.
So if I am confused I am not the only one !!
You state that the local authority Veterinary Inspectors operate as your agents, under service
contracts and that gmuch effort has been expended in training" them to enable them to assist
gsmall producers". Can I take it from this that the Local Authority Veterinary Inspectors are
contractually obligated to provide an advisory service to us ?. This, if it is so, is indeed
news to us. We have always received the greatest of help and advice from our LAVI and we have
to thank him that we are still in business today, but we were under the impression that, for
the most part, the advice he gave us was offered on an gex officioh basis. It would be most
helpful to know the full extent and limitations of this service ?.
On the question of meat products produced by the retail butcher trade, you say hThe FVO
mission ..... has referred this matter to the legal services of the Commission to obtain a rulingh
and that you will abide by that ruling. While I appreciate that you are bound by the law of the
land, I would have thought that your real concern would be more with public health than with
legalistic Interpretations by people of unknown qualifications in the matter of public health.
It seems obvious, to me, that both retail butchers and small producers operate in the same
environment (public healthwise !) and that they could be grouped together and endowed with an
entirely different set of guidelines, appropriate to the risks inherent in their kind of
business (indeed other small scale food producers might well be included in this group also).
The comments in my last letter on HACCP systems might be deemed appropriate to any such new
guidelines. If, as you say, you are active at the highest levels in the European Union in support
of the small business sector, maybe now is the time for urgent action to ensure that some legal
eagle in the E. U. does not condemn every butcher in the E.U. to close, by inflicting
Guidance note no. 4 on them all, if only by default.
Regarding the separation of food production from farmyards and domestic dwellings the
Crystallization of your response would appear to be that gappropriate separation ensures
that there is no risk to safety, gbut, of course, given that birds and insects can fly and
rodents have an uncanny ability to infiltrate man`s best defences, there is no such thing
as gno riskh, only gacceptable riskh and while it may be neither possible nor desirable to give
a general definition of gacceptable riskh it would be most helpful to know the criteria by
which we will be judged.?
I am sorry if this letter has ggone ong a bit and hope that you will be able to find time to
Deal with the points raised.
Kind regards,
Yours sincerely,
Donal De Barra,
Bonina Foods.
CC Eamon O`Cuiv,
Minister for Rural Development.
Padraig Flynn,
Veterinary Officer, Clare Co. Council.
John Molloy,
A.C.B.I..
******************************************
RESPONSE TO THE ABOVE
FOOD SAFETY AYTHORITY OF IRELAND
3rd April 2002
Dear Mr. De Barra,
I acknowledge receipt of your letter dated 18th March 2002 and previous correspondence.
As you say, there still seems to be some confusion regarding the terms gderogationh
and gexemptionh. With regard to the various meat Directives and Irish Statutory Instruments,
certain premises are exempt from the provisions of these regulations. Exemption means that
the regulations do not apply to such premises. The example as previously outlined is the
preparation of meat products at the rear of a retail outlet where the produce is used to
supply the consumer directly. All other premises are not exempt and the provisions of the
regulations apply. In this context, the term derogation then applies to the application of
the regulations to specific premises. The premises must be operated in compliance with the
regulations. The possibility the exists for premises operating on the local market to avail
of some specific gderogationsh from certain aspects of the regulations. This in effect
means that certain specified requirements of the regulations do not have to be fully
complied with in a plant that avails of the derogations. In essence such derogations
relate to the design of taps (hand operated), to the accommodation for the inspecting officer
(locker as opposed to room), and to a reduced frequency of sampling for microbiological
criteria.
I note your comments re advice received from Teagasc. In our ongoing contact with various
consultant and advisory personnel, the Authority will continue to reiterate our support
for small enterprise and ensure, in so far as we can, that these consultants are not
giving advice which is contrary to ours.
I am pleased to note your comments regarding the help and advice made available to you by your
Local Veterinary Inspector. These staff have a wealth of knowledge of the regulations and of
the operation of food businesses. Regarding the gextent and limitationsh of advice offered
by these inspectors, it must be recognised that the primary role is that of regulator, i.e. to
ensure that consumer protection legislation is adequately respected. They are not in the role
of gprivate consultants to the food businessh and the proprietors of some food businesses
may feel the need to obtain additional independent advice from private consultants.
And finally, regarding the separation of food production premises from farm yards and domestic
dwellings, I have done my best to deal with this in my previous letter. The issue of insect
and rodent control would be dealt with in the management system of any such food business and
you are of course right that nothing in life is totally risk free.
Yours sincerely
Pat O`Mahony,
Director of Consumer Protection
c.c. Eamon O`Cuiv, Minister for Rural Development
Padraig Flynn, Veterinary Officer,
Clare County Council
John Molloy, ACBI
*******************************************
BONINA FOODS.
KILDIMO,
MILTOWN MALBAY
CO. CLARE.
Phone; 065/7084156
E. Mail; bonina@eircom.net
30 April 02.
Dear Customer,
I regret to have to tell you that this week sees the last delivery of Bonina Blackpudding.
We have been producing and selling Bonina, in the Clare area for some 13 years past and
have been greatly encouraged over the years, by the complimentary remarks of our customers,
many of whom we have come to know personally. We were also honoured to receive the
Bridgestone gBest in Irelandh award ,for the last 3 years.
We believe that the success of our product was directly attributable to our unique recipe
and in particular the fact that we always used fresh animal blood, as opposed to the dried substitute
used by most, if not all our major competitors. The blood we used was sourced from a local abattoir,
which is approved by the Health Authorities. We are now instructed that we may no longer use this
source of blood, because of the manner in which the blood is harvested, and that only a huge investment
in new equipment by the abattoir would permit of the blood being used by us. As the financial return to
the abattoir is negligible, this course is out of the question, further, we know of no one in the West of
Ireland who can supply fresh blood harvested to the standards of the Food Safety Authority of Ireland, in
fact we have not even been able to find out what exactly those standards are. The only alternative open
to us, it seems was to resort to the use of dried blood, but, rather than compromise the quality of our
product, we have chosen to cease production altogether.
We confidently predict that when the F.S.A.I. gets into its stride, many other small scale local food
producers will suffer the same fate as us.
We should point out that both our premises and our product have been tested on a regular basis over
the years by the Health Authorities and we have always achieved the best possible laboratory reports. We
have always had the greatest possible commitment to hygiene in our production and distribution.
We would like to thank you for all your support over the years and we ask you to convey our thanks
to your customers, who were, of course the final judges of the quality of our product. It is our hope they
enjoyed the finished product as much as we enjoyed bringing it to you.
Finally we are, at present, considering alternative products in the area of high quality, local food and
hope to be in touch with you again before long.
Best wishes,
Treasa De Barra.
***********************************
BONINA FOODS.
KILDIMO,
MILTOWN MALBAY,
CO. CLARE.
Phone 065/ 7084156
E.Mail; bonina@eircom.net
Pat O`Mahony
Director of Consumer Protection,
Food Safety Authority of Ireland,
Abbey Court,
Lower Abbey St.
Dublin 1
26th May 2002.
Dear Mr. O Mahony,
Re; Use of Fresh Blood in Blackpudding Production.
As you may be aware this company has been forced to cease production of blackpudding
because we were instructed that the manner in which the blood, which we used, was
harvested was not acceptable to the FSAI.
Could you please let me know, as a matter of great urgency, what exactly the FSAI
standards are, regarding the use of fresh blood in the manufacture of blackpudding ?
It might help to reduce further correspondence if you could you could give a layman`s
explanation of your standards and deal with the point that our blackpudding is baked
for two and a half hours at a temperature of 250 degrees C, which must have a
considerable pasteurising effect.
I look forward to a reply at your very earliest convienience.
Yours sincerely,
Donal De Barra
BONINA FOODS
***********************************
FOOD SAFETY AUTHORITY OF IRELAND
ABBEY COURT,
LOWER ABBEY STREET,
DUBLIN 1
5th June 2002
Mr. Donal De Barra,
etc.
Dear Mr. De Barra,
I acknowledge receipt of your letter dated May 26th 2002.
As I am not aware of the source of blood used in your premises, I will
make some enquiries with the Local Inspectorate and revert to you
in due course.
Yours sincerely,
Pat O`Mahony,
Director of Consumer Protection.
***********************************
BONINA FOODS.
KILDIMO,
MILTOWN MALBAY,
CO. CLARE.
Phone 065/ 7084156
E.Mail; bonina@eircom.net
Pat O`Mahony
Director of Consumer Protection,
Food Safety Authority of Ireland,
Abbey Court,
Lower Abbey St.
Dublin 1
7 June 2002
Dear Mr. O`Mahony,
Re; Blackpudding Production
Thank you for your letter of 5th June.
The Information I require is the detail of the general standards
and hygiene requirements for harvesting of animal blood for use
in black pudding manufacture.
I do not require any comment regarding the particular
circumstances pertaining to our operation.
Looking forward to a speedy reply.
Yours sincerely,
Donal De Barra
Bonina Foods.
*****************************************
BONINA FOODS.
KILDIMO, MILTOWN MALBAY,
CO. CLARE.
Phone 065/ 7084156
E.Mail; bonina@eircom.net
12th July, 2002.
Pat O`Mahony,
Director of Consumer Protection,
Food safety Authority of Ireland,
Lower Abbey Street,
Dublin 1
Dear Mr. O`Mahony
Re; Blackpudding Production
I refer to my letter of 7th June, to which I have received no reply, and our previous correspondence.
The concern you expressed for the welfare of small businesses in your letter of 26th February,
last, rings hollow indeed, when, some 10 weeks after we were effectively closed down by the FSAI we
are unable to obtain a reply as to what standards we are required to meet, nor even a prompt reply
to our correspondence
Your early attention to this matter is now requested.
Yours Sincerely
Donal De Barra
Bonina Foods.
CC Eamon O`Cuiv Aire Gaeltachta agus Forbartha Tuaithe.
***********************************************
BONINA FOODS.
KILDIMO, MILTOWN MALBAY,
CO. CLARE.
Phone 065/ 7084156
E.Mail; bonina@eircom.net
Dr. Patrick Wall,
Chief Executive,
F.S.A.I/
Lower Abbey St.,
Dublin 1.
14, September, 2002.
Re; Blackpudding manufacture.
Dear Mr. Wall,
Since our business was closed down through the agency of the FSAI, I have written , three
times to your colleague Mr. O`Mahony, (26, May, 7, June, and 12 July ) requesting details of the
standardsrelating to the use of fresh blood in the manufacture of blackpudding. None of my
letters has received the courtesy of a constructive reply.
To deprive people of their livelihood because they are violating conditions, which you are not
willing to disclose to them, must surely be the greatest possible abuse of the arbitrary powers
which appear@to have been conferred on the FSAI.
I request you to deal immediately with this matter.
Yours,
Donal De Barra
BONINA FOODS
c.c. An tUas. Eamonn O`Cuiv,
An Roinn Gnothai Pobail, Tuaithe agus Gaeltachta
N.B. This correspondence will be posted on the Internet.
***********************************************
FOOD SAFETY AUTHORITY OF IRELAND
16th September 2002
Mr. Donal de Barra
Bonina foods
Kildimo
Miltown Malbay
Co. Clare
Dear Mr. de Barra,
Thank you for your letter of 12th July 2002 and we apologise for the late response. The
Food Safety Authority@was awaiting certain additional information on your query.
Please find hereunder the standards required for the collection of blood as an ingredient
in the manufacture of black puddings
The blood must be derived from animals which have received and passed both an ante-mortem
and post-mortem inspection.
The blood must only be collected in a licensed abattoir by trained staff.
The skin of the animal must be cut using one knife and the blood vessels opened using a separate
knife. Both knives must be sterilised using water in excess of 82 Degrees C
The blood must not come in contact with the hide or fleece of the animal during collection.
The blood must be collected in a hygienic manner i.e. the blood must flow directly from the stick
wound into the collection container. Special bleeding knives are available for this purpose.
The containers used to collect and store the blood must be food grade and maintained in a
satisfactory state of cleanliness.
The blood must not be stirred by hand. A food grade utensil must be used.
There must be clear separation between blood unsuitable for human use and blood collected for human
use.
The blood must be refrigerated as soon as possible after collection.
The blood must be dispatched to the end user by means of refrigerated transport.
Documented proof of dispatch must be maintained by the abattoir where the blood was collected.
Documented use of delivery must be maintained by the end user.
We hope this information will be of assistance to you. Please feel free to contact me again should you
require any further information..
Yours sincerely
David Nolan
Senior Specialist Veterinary Public Health
Food Safety Authority of Ireland
Abbey Court,
Lower Abbey Street,
Dublin i
Cdards SAbhjilteachta Bia na hLreann
Cdirt na Mainistreach,
SrAid na Mainistreach iocht.,
Baile Atha Cliath i
TELEPHONE: +353 1817 1300
FACSIMILE: +353 1 817 1301
EMAIL: infoCa)fsai.ic
WEBSITE: www.fsai.ie
***********************************************
FOOD SAFETY AUTHORITY OF IRELAND
19th September 2002
Mr. Donal de Barra
Bonina foods
Kildimo
Miltown Malbay
Co. Clare
Dear Mr. DeBarra,
We are in receipt of your letter dated 14th September addressed to Dr. Patrick Wall. It
appears that we have crossed letters in the post and hopefully you will have received our
reply, dated 14th September 2002, and that your queries have been clarified and
answered. If we can be of any further assistance please do not hesitate to contact me.
Yours sincerely,
David Nolan
Senior Specialist Veterinary Public Health
Abbey Court,
Lower Abbey Street,
Dublin 1
TELEPHONE: +353 1 817 1300,
FACSIMILE: +353 1817 1301
EMAIL: info@fsai.ie
*************************************
BONINA FOODS.
KILDIMO,
MILTOWN MALBAY,
CO. CLARE.
Phone 065/ 7084156
E.Mail; bonina@eircom.net
Mr. David Nolan,
Senior Specialist Veterinary Public Health,
F.S.A.I.
Abbey Court,
Dublin 1
22nd September, 2002.
Dear Mr Nolan
Re; Black pudding production.
Thank you for your letters of 16th and 19th of September, the former
did, indeed cross mine in the post. Perhaps you would be good enough
to explain to me why standards applied to collection of blood for use in
the production of black pudding are so much more stringent than the
standards applied to the collection of milk for human consumption. As
I have already pointed out, our blackpudding was baked for two and a half
hours at 250 degrees during manufacture, and is then cooked again by the
consumer prior to being eaten. I am not aware that milk gets any comparable
sterilisation. In particular :
Do cows get ante and post milking inspection.? You do not specify by whom
this must be carried out in the case of blood.
Are dairies licensed and dairy operatives compelled to attend hygiene courses ?
Can cows be milked without the milk coming into contact with the skin of the cow ?
Is there compulsory sterilization of milking equipment after every cow milked ?
Is all equipment used to transport milk between farm and creamery refrigerated ?
I would also like to know what checks the F.S.A.I. carry out on dried blood to
ensure that it complies with the standards set out in your letter.
I look forward to hearing from you.
Yours sincerely,
Donal De Barra,
BONINA FOODS
CC An tUas. Eamonn O`Cuiv,
Aire Gnothai Pobail, Tuaithe agus Gaeltachta.
******************************************
BONINA FOODS. KILDIMO, MILTOWN MALBAY, CO. CLARE. Phone 065/ 7084156 E.Mail; bonina@eircom.net Eamon O`Cuiv T.D. Aire Gnothai Pobail, Tuaithe & Gaeltachta. Baile Atha Cliath 20th December 2002. Eamon a chara, Ta me thar a bheith buioch as na hiarrachtai ar fad ata caite agat in ar dtaobh leis an FSAI. Is e deire an sceil on ar dtaobh, na nach bfeadfhadh muid an cineal airgid (breis is ?50,000) a ineistiu san gno seo againne mar gur gcottage industryh e ---- se sin gno beag sa bhaile a bhi i gceist againn o thus. Nil aon speis againn i gcursai monarchain. Comh maith leis sin creideann muid go bhfuil se i gceist ag an FSAI, d`ainneon a deireann siad, gnonna beaga dar leitheid ar fad a dhunadh suas , agus ca mbeadh ar chuid airgead ansan. Ma ta an FSAI chun an dearca ceanna a thaispeaint do gnonna beaga eile ( abair a leitheid de cais baile ) is a thaispeain siad duinne caithfhidh siad iad a dhunadh. Creidimse gur sin ata i gceist acu. Ta an dli, mar a sheasann se mi-cothram dar leitheidi.Ta se seo luiate go minic agam leo sa comhfreagras (feach alt 6 go miontuairisci D. Nolan 20-11-02). Ach in ait an dli a chur i gceart, d`usaid siad an seans chun muide a dhunadh. Nuair a bhi D Nolan anseo ag caint liom, luaig se, sa chomhra an tabhacht a bhi (dar leis) len ar gEC mastersh a shasamh (feach freisin, litir P O`Mahony 26th Feb 02, alt 4) Ni thuigimse an fath go bhfuil an oiread san oirmheas ag na instituidi stait anseo ar iniuchoiri on EEC (dream ,deirtear liom, gan moran cumhacht, in ndeire na sceala) Agus gan meas madra ar a mhuintir fein. Cuimhnigh nar cuir einne riamh in ar gcoinne go raibh aon deacreacht slaintiula len ar bputoga dubha. Dunadh ar gno ar maithe le paipearachas. Mar bhuile scoir, sa diospoireacht seo ba mhaith liom aird a dhiriu ar John Byrne ar n-ionadai san EEC. O tharla curam bia a bheith air, bfeidir go bhfeadfhadh seisean cursai dli a dhiriu sar a ghailleann muid an cumhacht deireannach ata againn san Eoraip. Ta roint mi-cruinneas sna miontuairisci a chuir D Nolan chughat ach ni fiu dom dul isteach ann, o tharla nach raibh de bheas aige coip a chur chugham. Aris gabhaim buiochas o chroi leat, agus guidhim beannachtai na feile ort fein agus do churam. Le mor mheas Donal De Barra CC D Nolan FSAI Padraic Flynn Clare County Council.