No C 124/4 Official Journal of the European Communities 21. 5. 90 
3.4. Article 3 (5) 
3.4.1. The first line should begin: 'the transfer of 
samples to an approved public or private laboratory, 
not necessarily located in that Member State, ...'. 
3.5. Article 5 
3.5.1. The Commission text should read as follows: 
'The measure provided for in this Decision shall 
qualify for adequate financial aid from the Com­
munity'. 
Done at Brussels, 28 March 1990. 
1. General comments 
1.1. The Committee welcomes the proposed har­
monization of the rules for the disposal of cadavers, 
slaughter by-products and other animal waste. The aim 
is to prevent the spread of pathogens in the environment 
and the animal production chain, and to make it poss­
ible for low-risk animal waste to circulate freely in the 
Community. 
(!) OJ No C 327, 30. 12. 1989, p. 76. 3.5.2. The report on the results of this survey should 
be communicated to the Council, the European Parlia­
ment and the Economic and Social Committee. 
3.6. Article 12 
3.6.1. In the first paragraph replace 'eradiction plan 
is being applied' with 'survey is being conducted'. 
3.7. Article 13 
3.7.1. To ensure that the eradication programmes 
are successful, and to encourage farmers to report the 
disease, financial compensation should be available for 
farmers obliged to destroy stocks. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE 
1.2. The Committee's premise is that the proposed 
criteria are of a high standard. They will thus ensure 
adequate consumer protection. 
1.3. The Committee thinks that the scope of the 
proposed rules must be sufficiently comprehensive. 
Because of this, a review of their legal basis is proposed. Opinion on the proposal for a Council Regulation (EEC) laying down the veterinary rules 
for the disposal and processing of animal waste, for its placing on the market and for the 
prevention of pathogens in feedstuffs(1) 
(90/C 124/03) 
On 14 November 1989 the Council decided to consult the Economic and Social Committee, 
under Article 198 of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Section for Agriculture and Fisheries, which was responsible for preparing the Commit­
tee's work on the subject, adopted its Opinion on 9 March 1990. The Rapporteur was 
Mr Wick. 
As its 275th plenary session (meeting of 28 March 1990) the Economic and Social Committee 
adopted the following Opinion unanimously. 
21. 5. 90 Official Journal of the European Communities No C 124/5 
1.4. The Committee considers that the safety pro­
visions for plant workers must also be harmonized. 
This is in the interest of both the workers and the 
undertakings. 
2. Specific comments 
2.1. Chapter I, Article 2 (1) 
2.1.1. Animal waste 
2.1.1.1. The Committee thinks that animal excreta 
in discarded intestinal tracts should be included in the 
scope of the Regulation. In practice discarded intestinal 
tracts, including the content of stomachs and intestines, 
are bound to reach the knackery. 
2.1.2. Processing plant 
2.1.2.1. The proposal limits application of the Regu­
lation to processing plants which use sterilization. 
Establishments such as animal feed factories will be 
excluded if they use other processes. Examples of these 
include: 
— pasteurizing equipment, 
— equipment using a combination of heat treatment 
(at beneath sterilization temperature) and chemical 
treatment, 
— baking and extrusion equipment, 
— equipment for processing and storing material 
intended for animal feed factories. 
2.1.2.2. The Committee proposes that all processing 
plants be included in the Regulation regardless of the 
processes they use and that Annex II be changed accord­
ingly. 
2.1.2.3. It should be made absolutely clear that pro­
cessing plants do not include plants for the manufacture 
of petfood in accordance with Annex III. 
2.1.3. Petfood 
2.1.3.1. The Committee would point out that pet­
food is also made from other parts of the carcass (e.g. 
blood or poultry heads) to which meat and the by­
products of slaughter are added. This should continue 
to be permissible. 
2.1.3.2. In addition, the proposal should be consist­
ent in its use of language. The German text uses both 
'Haustierfutter' and 'Heimtierfutter' with the same 2.2. Chapter 11, Article 3 (1) and (2) 
2.2.0. The Committee is opposed to the burning or 
burial of high-risk materials being allowed on a par with 
low-risk disposal in a knackery. The risk of epizootic 
diseases spreading seems to be too great. There could 
also be other adverse side-effects. For example, ground 
water contamination is a distinct possibility. Exemp­
tions should therefore be granted only in a emergency 
(e.g. in the event of foot-and-mouth disease of swine 
fever). However, checks must be carried out in such 
cases in order to rule out any abuses. 
2.2.1. Article 3 (1) (e) 
2.2.1.1. The Committee notes the Commission's 
explanation that the products excluded from the rules 
also include the lower limbs of bovine animals. 
2.2.2. Article 3 (1) (f) 
2.2.2.1. It should be made absolutely clear that 'spo­
iled' means that the meat, poultry meat, fish, fish prod­
ucts, game and meat products are not suitable for 
human consumption. 
2.2.3. Article 7 (1) 
2.2.3.1. It should be made absolutely clear that only 
low-risk materials will be used. 
2.2.4. Article 7 (1) (ii) 
2.2.4.1. Working dogs, including those used for 
hunting, should also be exempted. 
2.2.5. Article 9, fourth indent 
2.2.5.1. The Committee would point out that it is 
not possible in a continuous production process to trace 
back the exact period of production of a dispatched 
batch. However, each dispatched batch can, for exam­
ple, be given a consecutive number. 
2.2.6. Article 10 (1) 
2.2.6.1. The Committee assumes that the details of 
the inspections and random checks are to be laid down. 
2.2.7. Article 13 
meaning. 2.2.7.1. The Committee notes that the Council Regu-
No C 124/6 Official Journal of the European Communities 21. 5. 90 
lation referred to was adopted in December 1989 and 
that its number will be indicated in the proposal. 
2.3. Chapter 111 
2.3.0. The Committee would point out that special 
Directives with regard to the production and marketing 
of feedstuffs are in force or pending. There is therefore 
no point in including feedstuffs components of veg­
etable origin in the Regulation. Consequently the Com­
mittee proposes that Articles 14 and 15 be changed 
accordingly. 
2.3.1. Article 14 
2.3.1.1. The Committee would point out that the 
planned controls must ensure that the end product is 
microbiologically pure. 
2.3.2. Article 15 (2) 
2.3.2.1. The Committee suggests that Community-
wide rules of conduct for the trade lay down details of 
the controls, so as to encure that similar controls are 
carried out in all Member States. 
2.3.3. Article 15 (2), third indent 
2.3.3.1. The Committee points out that, in the event 
of infestation, the cause of the contamination in particu­
lar should be determined, so that remedial action can 
be taken as quickly as possible. 
2.3.4. Article 16 
2.3.4.1. The Committee calls for the industry's 
involvement in the framing of the 'Recommendation 
with guidelines for the hygienic manufacturing of feed­
stuffs'. 
Done at Brussels, 28 March 1990. 2.4. Annex 1 
2.4.1. Paragraph 1 
2.4.1.1. The Committee trusts that the term 
'adequately covered' means that the containers and 
vehicles are completely impervious to liquids, i.e. no 
liquid can escape and no rainwater can penetrate them. 
2.4.2. Paragraph 3 
2.4.2.1. The Committee thinks that it would be 
advisable to preserve the records for a sufficient period 
of time. 
2.5. Annex 11 
2.5.1. Chapter II, paragraph 6 b) 
2.5.1.1. The Committe thinks that processes and 
microbiological standards should be under the control 
of the relevant authority. The key process parameters 
should be continously recorded by suitable means. The­
se should not be confined to the heating process. In 
accordance with the procedure laid down in Article 21 
specific times and temperatures could quite easily be 
laid down for the heating. Care must be taken to ensure 
that even extremely heat-resistant animal pathogens are 
killed by the heating process. However, other equally 
efficient methods should also be permitted. 
2.5.2. Chapter III, paragraph 1 
2.5.2.1. The Committe thinks that the planned pro­
cedure is extremely costly. In view of the exceedingly 
high cost, a check should be made to see whether such 
a procedure is genuinely necessary. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE