The system of official controls in Ireland’s pet food processing plants overseen by the Department of Agriculture, Food and the Marine (DAFM) was “not fit for purpose”, according to a European Commission audit.

The audit, which took place from June 10-19 this year, sought to assess whether the oversight system on animal by-products (ABP) and derived products destined for the manufacture of pet food comply with European Union requirements.

The report concluded that all of the elements needed for an effective official control system on the ABP production chain are in place.

However, the auditors found that in practice “this is far from the case with widespread and systematic failure in both the system of inspections and the oversight thereof”.

The EU has laid down strict requirements on ABP and derived products to prevent and
minimise risks arising from those products, and to protect the safety of the food and feed
chain.

Pet food

The auditors found that inspections records were “unreliable” and that numerous non-compliances found by the audit team had not been detected in spite of the oversight arrangements put in place by DAFM.

“Overall, the system of official controls in this sector in Ireland is not fit for purpose and weakens assurances those controls provide on the compliance of pet food of animal origin with EU requirements,” the report stated.

The auditors highlighted deficiencies in “practically every area”, including the categorisation of ABP, documentation accompanying consignments of ABP and operators’ sampling for bacteria such as salmonella.

It also found issues with the maintenance of equipment in the processing plants and the cleanliness and hygienic production conditions in those plants.

Some of the non-compliances had been identified in the previous commission audit in 2018, such as inappropriate categorisation of ABP.

The auditors said this indicated that the measures taken by the department were “ineffective in addressing this issue”.

Audit

In one plant, approved by DAFM, the auditors noted ABP from slaughterhouses arriving as category 3, contained category 2 material such as digestive tracts with their contents, animals’ heads with attached plastic eartags, animal tissues mixed with plastic and paper and by-products in a state of decomposition.

DAFM did not provide any explanations to the auditors why the numerous non-compliances at the plant had not been identified in the course of their official controls.

The audit team analysed information on all inspections carried out in 2022 and 2023.

They found that non-compliances were rarely documented in the inspection reports and, when they were, they were classified as minor with a non-legally binding request to the operator to implement corrective actions.

Although there were no deadlines for corrective actions to be taken, the records indicated that the operators had addressed the issues and that implementation had been followed up by DAFM.

The report also noted that the targets for inspections of the processing plants planned for 2022 and 2023 “were usually met in less than 50% of cases”.

In 2022, 21 inspections were conducted out of 44 planned, while during the following year 12 out of 37 planned inspections were carried out.

The auditors noted that six out of the 11 inspections planned by the time of the audit report for 2024 had been conducted.

DAFM stated that the number of planned inspections was not met due to it having to divert staff resources to post-Brexit health certification duties.

DAFM

In response to the commission report, DAFM said that a high-level oversight group had been established which will be chaired by the department’s chief veterinary officer.

It said this group will monitor and ensure implementation of, and reporting on, the agreed action plan in response to the audit report and to ensure enhanced levels of communication within the control system.

The department also said it is in the process of developing a new system of verification inspections which will be subject to review after the second quarter (Q2) of 2025.

It said that all pet food and category 3 rendering plants will receive a verification inspection before the end of 2024, and at least one further verification inspection in the first half of 2025.

These inspections have been assigned to specific officers with “relevant experience and expertise” and reports from these officers will be reviewed by the oversight group.

Further targeted training of relevant control staff will take place in before the end of the year.

The department said that all pet food and rendering plants will be subject to quarterly official controls “to ensure confidence that all plants are operating in compliance with applicable legal requirements”.