Clandestine slaughter, it goes without saying, cannot guarantee either food safety or animal welfare. Yet it is legitimized in fact, under the pretext of use 'private household'which is also extended to cattle, among the folds of the infamous legislative decree 27/21. (1) With a generalized green light for the slaughter of livestock for private use, by anyone and in any place.
The government led by Mario Draghi - after having foiled the attempt of sblight, aimed at decriminalizing food safety offenses (2) - must now reform the outlawed rule, before it causes serious public health risks in the name of Folklore uncontrolled. And eradicate the weed of Coldiretti's magic circle from the ganglia of the MiPAAF and every other public administration. #Clean shovels.
Clandestine slaughter, 'private domestic use'
Theprovisions in the field of slaughter for private domestic use'- introduced by Legislative Decree 27/2021 to article 16 - provide that slaughter can take place indiscriminately outside authorized slaughterhouses. Pointing out that the freedom of killing affects all animals on George Orwell's farm. Not only poultry, small game and lagomorphs (hares and rabbits) but also sheep, goats, pigs and even bovine species.
The only burden it is up to the 'do-it-yourself butcher' to notify the local health authority, communicating the place and time of the slaughter for self-consumption (legislative decree 27/2021, art. 16.3). Burden, inter alia, without sanction. On the unrealistic assumption that official public veterinarians can rush to the thousands of domestic sacrifices that are concentrated on holidays - civil or religious - to check compliance with the very general criteria that follow.
Legislative Decree 27/2021, the 'very general' criteria
The national legislator delegate has handed over to the Regions and Autonomous Provinces the detailed rules on slaughtering for 'self-consumption', limited to aspects related to animal welfare. Defining some general, indeed very general, criteria:
1) prohibition of marketing meat and products obtained from slaughter for 'private use',
2) respect for animal welfare, with a ban on ritual slaughter without stunning, (3)
3) definition of regional regulations to prevent zoonoses, (4)
4) preparation of control programs that allow sample checks on animal health and welfare, hygiene, correct disposal of by-products. (5)
Legislative Decree 27/2021 - 'in order to allow the maintenance at national level of traditional methods and consumption'- on the other hand, it abrogated the provisions consolidated in a century of honorable service by means of Royal Decree no. 20.12.1928 (Legislative Decree 3298/27, articles 21, 16.1.a). Precisely that Regulation for the supervision of meat that has guaranteed veterinary surveillance in Italy for 18.1 years, without prejudice to any agricultural tradition but rather saving millions of people from the risk of death and serious illnesses from foodborne infections. Thanks to a strict discipline of slaughtering for private use, according to which:
- the slaughter of cattle, buffaloes, pigs, sheep, goats and horses for food use could only take place in public municipal slaughterhouses (RD3298 / 1928, art.1.1),
- home slaughter was subject to the issue of an authorization and following the best practices of the municipal authority and prior notice (at least 24 hours before) to the municipal veterinarian. So that he could organize the necessary visit and attend the slaughter, followed by 'complete and accurate inspection of the meat '.
Royal Decree 3298/1928, the lost guarantees
In the past century before the entry into force of Legislative Decree 27/2021, the Regions and Autonomous Provinces had regulated home slaughter for private use, delimiting the number of animals / year for each family unit and the periods in which this activity could be carried out . In addition to defining:
- procedures and times for the authorizations of the competent health authority for the area,
- provisions for inspections of veterinary staff doors e postmortem, on meat and certain viscera (in particular the trichinoscopic examination, to detect the presence of dangerous parasites in the muscle tissue),
- rules for the disposal of by-products and sewage.
Measures adopted at the regional level, always allowing slaughtering for private use in approved slaughterhouses without species limits, aimed, among other things, at avoiding confusion with meat intended for marketing (with the 'family use' stamp and the slaughterhouse at predetermined times, or the obligation of transport documents to ensure the destination only to the authorized person and to receive the meat at their residence).
Public health hazard
The 'short story' legislative presents some very serious criticalities which are relevant above all from the point of view of food safety and public health. For a few simple reasons:
- killing, skinning and eviscerating animals requires infrastructures, equipment and sanitation skills which are essential to prevent and mitigate the risks of equally dangerous microbiological contamination. Some strains of E.Coli (Eg. STEC, VTEC) are fatal or can cause permanent damage to vital organs, Salmonella e Campylobacter are increasingly resistant to antibiotics,
- the green light for the killing, skinning and evisceration of sheep, goats, suidae, cattle and buffaloes outside the authorized slaughterhouses - with a public veterinary control only if possible and 'randomly' - removes outbreaks of even lethal diseases from public surveillance . With a de facto legalization of clandestine slaughter and the uncontrolled circulation of huge quantities of food at risk.
Protection of animals in the killing phase, EU rules
The reg. CE 1099/09 among other things, it has introduced minimum rules for the protection of animals in the killing phase. (6) First of all, the obligation to stun the animals before killing them (apart from only cases of ritual slaughter, to be carried out in any case in authorized slaughterhouses) and the qualification of workers in the killing operations, as well as specific measures for the construction of slaughterhouses, etc.
Such rules apply to the slaughter of animals reared for the production of food, wool, hides and furs, as well as killing for depopulation and related operations. With the exception of hunting and recreational fishing, as well as the debated areas of scientific experimentation, 'cultural' or sporting events (eg bullfights, palios).
Slaughter for self-consumption, EU rules
The European Food Safety Authority (EFSA) - in its opinion 'Welfare of cattle at slaughter'(2020) - exposed 40 critical issues on the application of reg. CE 1099/09. (7) Theminimum measures'are insufficient to protect animals and yet the Commission has postponed towards greater things the strategy on animal welfare. (8) As regards the killing of animals for self-consumption, reg. THERE IS. 1099/09 does not apply to the killing of poultry, rabbits and hares.
The killing of other animal species for self-consumption (cattle, horses, sheep, goats and pigs) falls within the scope of the European regulation and is subject to the cardinal rule, 'animals are spared avoidable pain, anxiety or suffering during killing and related operations'. The duties of:
- preventive stunning of animals, according to the methods and rules set out in Annex I to the regulation,
- guarantee of maintenance of the loss of consciousness and sensitivity until the death of the animal,
- adequate competence of the persons who provide for the killing (EC regulation 1099/09, article 10).
The ritual slaughter - understood as'a series of acts related to the slaughter of animals prescribed by a certain religion'- can be excluded from the obligation of preventive stunning, according to the European regulation, on the sole condition that it is carried out in specifically authorized slaughterhouses (reg. 1099/2009, art. 2.g, 4.4).
The EU Court of Justice among other things, recognized the legitimacy of stricter national regulations, in the direction of 'reversible stunning'as a compromise between rituals and animal welfare. (3) Italic liberalization, on the other hand, lends itself to the spread of the slaughter 'at home', especially close to holidays such as Id al-adha, the Islamic celebration also known as'festival of the slaughtering'The'mutton festival'.
Legislative decree 27/2021 is based on the 2018 European delegation law. (9) Which is by its nature 'aimed exclusively at the implementation of European directives and framework decisions to be transposed into national law, excluding any other provision of legislative delegation not directly attributable to the transposition of European legislative acts'. (10)
Parliamentary acts which preceded the adoption of the delegation law refer precisely to the updating of the system of official public controls with respect to the provisions introduced by reg. (EU) 2017/625, without referring to any deregulation. (11) Article 16 of Legislative Decree 27/21 is therefore unconstitutional. Indeed, it is unsuitable for ensuring compliance with the same regulation on official public controls, as well as with the requirements set out in CE 1099/09.
La LOBBY which commands agricultural policies in Italy, has obtained the green light for the most dismal festivals and clandestine slaughtering. In spite of the Constitution of the Italian Republic, the applicable European regulations and the same Treaty which, in article 13, recognizes animals as sentient beings.
It is indispensable and urgent abrogate the outlawed rule, for non-postponable public health needs. And it is equally necessary to open an investigation - to the MiPAAF and the Ministry of Health - to identify and punish those responsible for office abuses, in hairy connivance with the usual suspects.
(1) Dario Dongo. Legislative Decree 27/21 and repeal of law 283/1962, question of constitutional legitimacy. GIFTS (Great Italian Food Trade). 17.3.21/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/sicurezza/d-lgs-27-21-e-abrogazione-della-legge-283-1962-questione-di-legittimità-costituzionale
(2) Dario Dongo. Food crimes, the Draghi government saves law 283/1962. #Clean shovels. GIFTS (Great Italian Food Trade). 20.3.21/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/sicurezza/reati-alimentari-il-governo-draghi-salva-la-legge-283-1962-vanghepulite
(3) Dario Dongo. Ritual slaughter, green light by the EU Court of Justice for the obligation of reversible stunning. GIFTS (Great Italian Food Trade). 27.12.20/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/mercati/macellazione-rituale-via-libera-della-corte-di-giustizia-ue-all-obbligo-di-stordimento-reversibile
(4) Dario Dongo. One Health. Animal, human and planetary health and wellbeing. What can we do? GIFTS (Great Italian Food Trade). 2.6.21/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/consum-attori/one-health-salute-e-benessere-animale-umano-planetario-cosa-possiamo-fare
(5) Dario Dongo, Marina De Nobili. Animal health, 7 new regulations complete the EU reform. GIFTS (Great Italian Food Trade). 1.7.20/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/sicurezza/sanità-animale-7-nuovi-regolamenti-completano-la-riforma-ue
(6) EC Reg. 1099/09, concerning the protection of animals at the time of killing. Consolidated text as of 14.12.19 on https://eur-lex.europa.eu/legal-content/IT/TXT/?qid=1622823760136&uri=CELEX%3A32009R1099
(7) Dario Dongo. Animal welfare, EFSA opinion on cattle for slaughter. Status quo and prospects. GIFTS (Great Italian Food Trade). 4.11.20/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/sicurezza/benessere-animale-parere-efsa-sui-bovini-al-macello-status-quo-e-prospettive
(8) Dario Dongo, Marina De Nobili. Animal welfare, ad majora. The role of the ConsumActors. GIFTS (Great Italian Food Trade). 10.7.20/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/consum-attori/benessere-animale-ad-maiora-il-ruolo-dei-consumattori
(9) Law 4.10.2019 n. 117. Delegation to the Government for the transposition of European directives and the implementation of other European Union acts - European delegation law 2018. See article 11. https://www.gazzettaufficiale.it/eli/id/2019/10/18/19G00123/sg
(10) Law 234/12. General rules on Italy's participation in the training and implementation of European Union legislation and policies. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2012-12-24;234
(11) Chamber of Deputies. European delegation law 2018. Dossier 8.10.18. See page 67. https://documenti.camera.it/Leg18/Dossier/Pdf/ID0004.Pdf