Introduction

Is beef skin edible and is there a difference in SA legislation between beef and pork skin?

I looked at:

1. Meat Safety Act (Act No. 40 of 2000):
   
2. Regulations Regarding the Classification, Packing, and Marking of Raw Processed Meat Products (R2410 of 2022):
   
3. Agricultural Product Standards Act (Act No. 119 of 1990):
   
4. Foodstuffs, Cosmetics, and Disinfectants Act (Act No. 54 of 1972):
   

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AGRICULTURAL PRODUCT STANDARDS ACT, 1990 (ACT No. 119 OF 1990)

According to this act:

-> “carcass” means the remaining part of a bovine, sheep, goat or pig after the blood thereof has been
drained and the hide, skin, hair, entrails, pluck (heart, liver and lungs), head, tail, hooves and
trotters, according to the customs in respect of a particular kind of animal, as well as the
diaphragm, sex organs and udder have been removed, and also —
(a) such a carcass that has been divided length-wise in two parts along the spinal column
thereof; and
(b) a part referred to in paragraph (a), that has been divided into two approximately equal
portions;

-> “fat thickness” with regard to a pig carcass, means the thickness of the back fat including the skin, as
determined in the manner contemplated in regulation 12;

-> “percentage meat” with regard to a pig carcass, means the meat content of a carcass after removal of the head, jowls, trotters, skin, subcutaneous fat, kidneys and kidney fat, tail and tailbone, expressed
as a percentage of the carcass without the head, jowls, trotters, kidneys and kidney fat and tail.

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Meat Safety Act (Act No. 40 of 2000)

Detailed Requirements for Beef Hides to Be Considered Edible for Human Consumption

The Meat Safety Act, 2000 provides comprehensive guidelines to ensure that any part of an animal carcass intended for human consumption meets strict hygiene and safety standards. For beef hides to be classified as edible and safe for human consumption, several detailed steps must be followed, which include hygiene protocols, inspection requirements, and regulatory approval. Here’s a detailed breakdown:

1. Hygiene and Safety Standards

The most critical aspect of ensuring that beef hides are edible for human consumption revolves around hygiene and safety requirements.

• Facility Hygiene: Processing must take place in approved and inspected facilities where hygiene is rigorously controlled. These facilities are required to maintain cleanliness, proper waste disposal, and ensure that all equipment used in processing is sterile. The environment must be such that the hides are free from contamination by bacteria, chemicals, or any foreign substances.
• Handling and Storage: The hides must be handled using clean and sanitized equipment and protective gear to avoid contamination. Cross-contamination with non-edible parts must be strictly avoided. Hides for human consumption must be stored at appropriate temperatures to prevent spoilage, following cold chain management practices if necessary.
• Washing and Sterilization: The beef hides need to be washed and may require chemical treatments to remove contaminants. This could involve steam cleaning, scalding, or the use of safe chemical disinfectants. The goal is to ensure that no harmful bacteria such as Salmonella or E. coli remain on the hides.

2. Processing and Treatment

After being cleaned, beef hides intended for human consumption need further processing to make them safe and palatable:

• Enzymatic or Chemical Processing: This may involve using enzymes to break down tough fibres or chemicals that aid in the preparation of the hides for human consumption. These treatments ensure that the hide is soft, free of pathogens, and edible.
• Thermal Processing: Hides might need to undergo heat treatment to denature any remaining pathogens. The hides may be boiled or steamed at regulated temperatures to eliminate harmful microorganisms and make them fit for human consumption. According to the Meat Safety Act, all processed animal products must meet the required temperature thresholds to ensure food safety.

The Meat Safety Act itself does not specifically list temperature thresholds for thermal processing, but general food safety guidelines for animal products such as hides will apply.

3. Inspection Requirements

• Inspection by Veterinary Authorities: The Meat Safety Act mandates that all animal products, including beef hides, must be inspected by certified veterinary authorities. These inspectors assess the hides to ensure that they have been processed according to legal safety standards and are free from diseases, contamination, or spoilage.
• Veterinary Health Mark: Once inspected, a veterinary health mark must be applied to the product. This mark certifies that the hides are safe for human consumption and comply with all relevant regulations. If the product does not receive this certification, it cannot be sold for human consumption.

4. Approval by the Department of Agriculture

• Approval of the Facility and Process: Before any beef hides can be considered edible, the Department of Agriculture, Land Reform, and Rural Development must approve both the facility where the hides are processed and the specific procedures used. This approval is given after the facility passes inspections related to hygiene, safety protocols, and adherence to food safety standards outlined in the Meat Safety Act.
• Periodic Audits and Approvals: To maintain this approval, facilities must undergo regular audits to ensure continued compliance with hygiene standards and safety regulations. Any changes in processing methods or facility structure need further approval to ensure ongoing safety.

5. Edibility Standards

• Edible Classification: Beef hides can be classified as edible only if they meet the standards set forth for food-grade animal products. The act stipulates that edible animal products must be free from harmful pathogens, contain no harmful chemicals, and be processed in a way that makes them safe and palatable for human consumption.
• Labelling Requirements: The Meat Safety Act also outlines labelling standards for edible animal products. Hides intended for human consumption must be clearly labelled, including processing methods, storage instructions, and the veterinary health mark.

6. Beef vs Pork Hides

In the context of the Meat Safety Act, 2000 and related regulations, there is no specific distinction made between pork and beef hides when it comes to their categorization as non-edible by-products or their processing for human consumption. The regulations apply broadly to all animal hides, requiring that they undergo similar hygiene and safety procedures if they are to be deemed fit for human consumption.

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NO. R. 2410 AGRICULTURAL PRODUCT STANDARDS ACT, 1990 (ACT No. 119 OF 1990)

Based on the Agricultural Product Standards Act, 1990, the regulations do not specifically address whether beef or pork hides (skins) are considered edible. However, the following provides insight:

1. Definition of Meat: According to the act, “meat” refers to the skeletal musculature and fatty tissue of domesticated animals, birds, or wild game used as food, along with connective tissues, residual blood, bone, fat, and cartilage that naturally occur in the skeletal musculature of the dressed carcass and head. The musculature of the lips, snout, scalp, and ears is excluded from this definition.
2. Offal and Animal Products: The act distinguishes between edible and inedible offal. Edible offal in the context of domesticated animals (such as bovines and pigs) includes specific parts like blood, brain, kidneys, cleaned tripe, and cow heels. However, inedible offal includes parts that are not classified as edible, but there is no direct mention of hides or skins being classified under either category.
3. Marking and Treatment of Carcasses: The act specifies the marking and treatment of imported and domestic meat products. Treated meat must include details of chemical treatments on the packaging, but again, no direct reference is made to the treatment of hides or skins for human consumption.

So, the act does not explicitly categorize beef or pork hides as edible or non-edible.

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Foodstuffs, Cosmetics, and Disinfectants Act (Act No. 54 of 1972)

The Agricultural Product Standards Act of 1990 does not make a clear distinction between beef and pork skins in terms of their edibility or specific regulations that treat them differently.

The key provisions that address skins and their potential edibility under the Act:

1. Definition of Meat:
   The Act defines “meat” as the clean, sound, and wholesome skeletal musculature and fatty tissue of any domesticated animal, bird, or wild game species, used as a foodstuff. The definition excludes the musculature of the lips, snout, scalp, and ears.
2. Animal Products:
   In the case of domesticated animals, “edible offal” is specified to include various internal organs like the liver, kidneys, tongue, tripe, etc.

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Conclusion

Skins are edible if it’s cleaned in the right way and processed in an approved facility (Meat Safety Act (Act No. 40 of 2000)). How does one explain the fact that pork skin seems to fall under the act also and that the formal approval process does not apply?

At the abattoir, dehairing of pigs involves immersing the carcass in a scalding tank to loosen the hair for easier removal. The scalding tank is maintained at a temperature between 58°C to 62°C, and the carcass typically spends 4 to 6 minutes in the tank, depending on the temperature. Lower temperatures may require a slightly longer immersion time, while higher temperatures can shorten the process. After scalding, the carcass is transferred to a dehairing machine, where mechanical scrapers and rubber beaters efficiently remove the loosened hair. This is followed by a singeing step to burn off any remaining fine hairs, and a final polishing to ensure the skin is smooth and clean. This process happens at the abattoir which is under veterinarian supervision through the appointed agents who are also responsible for the carcass classification. This means that the process, which has been approved by the department and the oversight takes place in terms of the Meat Safety Act (Act No. 40 of 2000). The agent of the department is present for the process to inspect the entire slaughtering process including the removal of the hair and the ultimate grading of the carcass.

The real issue with beef, is then that it is not convention for hair to be removed from the skin at the abattoir (as is the case with pork). This means that any processing of beef skin for human consumption within South Africa must now involve a processing step that is approved by the department and an appointed agent of the department must be present to certify the process and the skins (as is the case with pork).

Further processes such as the creation of gelatine have been approved and anybody operating such plants within South Africa, in my opinion, only needs to now deal with the matter of inspecting the process. In my estimation it can be accommodated initially through a batch processing structure, for example, the appointed agent of the department is present at a certain time and date when the skins for the week or month are cooked and dehaired and later, when volumes necessitate an agent to be present permanently, such an agent is arranged full time as is the case with abattoirs. These inspection services are available throughout South Africa by approved companies who make inspectors available to every abattoir in SA responsible for the grading of carcasses and the inspection of the meat at rates that have been negotiated with the industry.