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Minimum Conservation Size Fish and the Animal By-Product Regulations Ian Murdoch Scottish Government Animal Health & Welfare Division
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Legislation Domestic –The Animal By-Products (Enforcement) (Scotland) Regulations 2013The Animal By-Products (Enforcement) (Scotland) Regulations 2013 EU –Regulation (EC) No 1069/2009Regulation (EC) No 1069/2009 –Commission Regulation (EU) No 142/2011Commission Regulation (EU) No 142/2011
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What are animal by-products? Animal by-products (ABPs) are entire animal bodies, parts of animals, products of animal origin or other products obtained from animals that are not fit or intended for human consumption. ABPs must be dealt with in accordance with strict regulations designed to prevent harm to people, animals and the environment.
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Where do ABPs come from? Fish mortalities Fishmonger and slaughterhouse waste (including blood) Food waste Catering waste International catering waste Fish skin and scales Fishing trophies Used cooking oil
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Categories of ABPs Category 1 ABP (few fish fall into this category) –Aquatic animals containing certain prohibited substances above specified levels or unacceptable levels of environmental contaminants Category 2 ABP –Also high risk material and includes mortalities Category 3 ABP (most below MCRS fish) –Low risk material
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What do we do with ABPs?
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Incinerate it
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Process it via pressure sterilisation (rendering)
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Use it as a fuel for combustion
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Turn it into feed for farmed animals
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Turn it into petfood
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Turn it into an organic fertiliser or soil improvers
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Spread it directly to land
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Compost it or turn it into biogas
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Turn it into biodiesel
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Or make products out it
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Enforcement Local authorities act as the enforcers The Food Standards Scotland are the enforcers in food hygiene establishments Animal and Plant Health Agency (APHA) staff are authorised persons and act as the inspectors in all other premises
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Handling MCRS fish You must continue to follow food hygiene rules and apply them to MCRS fish on board your vessel When it is decided that MCRS fish will go to non- human consumption uses, ABP rules will apply i.e. it becomes an ABP You need to make sure that ABP fish is put in storage and transport that is ABP approved
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ABP fish and human consumption fish You must keep sufficient separation between ABP fish and fish for human consumption during handling, storage and transportation examples, methods of sufficient separation could include: –clear space between ABP fish and food fish –some form of leak proof divide when ABP fish and food fish are in the same area
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Leak proof divides Leak proof divides could be made by: –having a separate compartment, container or an entire fridge only used for ABP fish in refrigerated spaces –shrink wrapping ABP fish or the containers the fish is held in –Do not put ABP fish boxes immediately above or beside boxes containing human consumption fish. This is because fish boxes do not have leak proof lids
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Labelling Fish boxes or other storage containing ABP fish must be clearly labelled as ‘CATEGORY 3: not for human consumption’.
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Registration/Approval process in Scotland Whether you need approval or registration depends on what your site does and the ABPs you handle there Vehicles transporting ABP fish need to be ABP registered, or work as a transporter to an ABP approved site There are no fees associated with ABP approval/registration
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ABP Storage and handling sites Site owners or ‘operators’ are responsible for: –getting ABP approval –the operation and upkeep of the facility –keeping relevant records
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Keeping records for ABPs When ABP fish is transported it must be accompanied by a commercial document that includes: –date of transport –description of contents including ABP category and quantity –origin and destination addresses with contact names at both –ABP approval or ABP registration numbers for the factory or vehicle –signature of whoever is responsible for the contents
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If no ABP storage facility is available Place ABP fish directly and immediately onto ABP registered transport You can transport human consumption fish and ABP fish on the same vehicle as long as: –they have been handled and stored in identical conditions –there is sufficient separation
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Landing ABP fish for pot bait exchange No need for ABP approval if you land MCRS fish and sell it directly as pot bait to other vessels operating out of the same port Owners who store and handle MCRS fish in any way before selling it as pot bait must have an ABP approval
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Key contacts First point of contact on any ABP issues should be your local APHA office: –Inverness (Highlands & Islands) –Inverurie (Aberdeenshire, Orkney & Shetland) –Perth (Central, Argyll & Bute) –Ayr (Ayrshire & South West Scotland) –Galashiels (Lothian & Borders) Contact APHA
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