The Food Standards Agency (FSA) has determined that placenta is considered ‘food’ for the purposes of food hygiene practice – but failed to publish any accompanying guidance for inspecting officers.
The news was warmly welcomed by the placenta processing community as it gives them a legal basis to operate. However, food hygiene experts were concerned at the brevity of the statement and the lack of practical guidance for local authority officers dealing with placenta FBOs, which the FSA had suggested it would produce.
The FSA’s decision has five points: placenta is not considered to be a ‘product of animal origin’; it is also not considered a ‘novel food’; placenta processing businesses are food business operators (FBOs) and should be considered for registration; placenta FBOs should apply a food safety management system based on HACCP principles; and they should be included in the Food Hygiene Rating Scheme unless the local authority decides they are exempt.
An FSA spokesperson said: “If they need further guidance, local authority EHPs should continue to use the usual channels for seeking further advice on food safety and hygiene issues. We will support as far as possible to find a way forward where food forums are unable to reach resolution.”
However, Ian Andrews, chair of the National Food Hygiene Focus Group and head of service at a London borough, said: “We had been led to believe that the FSA would publish guidance in March 2020. But what we were given in December 2020 is a single letter, not even a guidance document, […] that does give some legal clarity but it doesn’t answer all the questions that colleagues will have.
“Where it unhelpfully falls down is with respect to a food safety management system. All they’ve essentially said is that FBOs have got to comply with their legal requirement on HACCP principles. If we don’t know that we shouldn’t be even picking up the phone to talk to the business. But what is our reference point to determine that? Trying to get your head round it as a newly qualified officer could be difficult.”
He added that there was little in the December letter the FSA about levels of risk and viral contamination. He said: “There’s nothing that we would be dealing with as LAs on a regular basis where you’ve got a risk of hepatitis or HIV occurring in the raw ingredient. Basic food hygiene courses, regardless of provider or delivery, are not going to adequately equip someone to deal with human-derived ingredients and risks associated with that.”
Liz DeVere, commercial team manager at North Hertfordshire District Council, said members of the Herts and Beds Food Liaison Group, which she chairs, were disappointed by the FSA statement. “This document does answer some of the questions posed by EHPs but it leaves individual local authorities to decide if critical control points for these products are adequate. We had hoped that, bearing in mind the complex nature of the hazards identified in human placenta, the FSA would have provided some guidance on the suitable and appropriate controls that would be expected in a food safety management system. The majority of local authorities don’t have the expertise to assess the inherent risks posed by placenta.”
Kate Thompson, CIEH’s director for Wales and food safety spokesperson, said: “Local authorities have been waiting several years for a steer from the FSA on whether placenta is considered food so this determination is welcomed. It’s a pity, however, that more detailed guidance isn’t available, which would ensure a consistent approach.”
The FSA countered that it considers the advice ‘proportionate for this current situation’. It also confirmed that neither the FSA or Public Health England have any record of reported illness, infections or poisoning linked to the consumption of placenta.
The spokesperson said: “The FSA accepts that it is an individual mother’s decision to personally consume their own placenta following childbirth. Our position is based on the available evidence on risk and current information regarding practices being employed by small businesses providing services directly to mothers who wish to consume their own placenta or products made from it.
“If there are significant changes including wider application or commercialisation we will review and reconsider our determination.”