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Food safety,EU rules

Ankara, 13 May 2009BSP

©2009 Dario Dongo CIAA, Food Safety Management Task Force, v.chairman

Global Food Safety Initiative Tech. Committee, CIAA representative

Federalimentare, Regulative Policies, responsible

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EU Rules, the A-B-C

Food & feed traded in the Single market

shall comply with the

EU requirements of food law, or

conditions recognized by the EC as equivalent

A) SAFETYC) CONTROLS

(public/private)

B) HYGIENE

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A) SAFETY

• RESPONSABILITY. All operators mustmonitor the safety of products andprocesses under their responsibility

Self-checks -> Safety assessment

• TRACEABILITY

• INCIDENT MANAGEMENT

(EC) Reg. No. 178/02, General Food Law

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RESPONSIBILITIES

“FROM

FARM

TO

FORK”

Primary production

Transport

Manufacturing

Distribution

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Safe food

• Food cannot be placed on the EU market if:

1) harmful (in the short-mid-long term /cumulative effects / sensitivities of specific categories of consumers)

2) unfit to human consumption (ie.

physical contamination, deterioration, putrefaction, deacay)

ie. aflatoxins in pistachio nuts

i.e. heavy metals in fish

i.e. undeclared allergens

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Safe food - allergens

Food labels must indicate

the presence - even if just in traces - of

� allergenic substances, and/or

� materials derived thereof(except those mentioned in Dir. 2007/68/EC)

Clear impact on the management of the whole process

Self checks against X-contamination

D A N G E R

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Safe feed

• Feed cannot be placed on the EU market nor fed to any food-producing animal, if they

1) have an adverse effect to animal health, or

2) make the food derived from food-producing animals unsafe for human consumption

i.e. (carry over) dioxins

i.e. melamine

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Safety assessment

• Safety is evaluated regarding the

normal intended use of the product, and the

information given on its label

• The entire batch/consignment

of a risky product is

presumed by law to be unsafe

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Traceability

All operators must

be able to identify their suppliers – who supplied what (food & feed, food contact materials)

be able to identify the business operators to whom they have delivered their products - whohas received which product

inform the competent authorities on what above, whenever requested

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TRACEABILITY

…

GOING

FURTHER!

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Incident management

Operators duties (1)

• In case of a food/feed safety risk:

immediate withdrawal of the product, so as to stop the distribution and to prevent its

placement on the shelves

inform the competent authorities. Immediately, specifying the adopted measures, when there is a danger for the human health

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Incident management

Operators duties (2)

where the product may have reached consumers, give

effective and detailed information to

consumers, explaining its reasons (ie. physical contamination with …, food non suitable for consumption, yes/no health danger)

“when other measures aren’t enough to achieve an

high health level”, public recall of products from the market

cooperate with competent authorities and theother operators involved

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Incident management (3)

Information to consumer, example

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B) HYGIENE

General obligations

• All business operators have to be registeredor approved (foods of animal origin) by the competent authorities

• It is due to implement measures and conditions

aimed to control hazards and ensure safety of the product

-> HACCP-based procedures

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Hazard Analysis and Critical Control Points

1. HAZARD ANALYSIS (multidisciplinary team; product description, its intended use; flow diagram; hazard & control measures list )

2. IDENTIFICATION OF CRITICAL CONTROL POINTS (decision tree)

3. CRITICAL LIMITS AT CRITICAL CONTROL POINTS (ie. temp., pH, sensory parameters � target levels)

4. MONITORING PROCEDURES AT CRITICAL CONTROL POINTS(continuously or on a set frequency)

5. CORRECTIVE ACTIONS

6. VERIFICATION PROCEDURES (ie. random analysis, tests)

7. DOCUMENTATION AND RECORD KEEPING

(Ref. FAO/WHO Codex Alimentarius document CAC/RCP 1-1996, rev. 4-2003)

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H

A

C

C

P

A

GLOBAL

ISSUE

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Hygiene

Detailed requirements

For certain products:microbiological criteria

EC Reg. 2073/05

Primary production:

EC Reg. 852/04

Art. 4.1, Annex I

After primary production:

EC Reg. 852/04

Art. 4.2, Annex II

Where applicable:

Contaminants & residues, food contact materials, GMOs,

irradiation, …

Food of Animal Origin:

EC Reg. 853/04

Feed:

EC Reg. 183/05

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Guides to Good Practice

do

• advise on plants, equipments, training (ie. cleaning and

disinfection procedures)

• define how to reach the safety targets

• adapt HACCP principles to the sector

• define what is necessary, appropriate, adequate, sufficient

-> From CIAA, see GMP’s (PAS 220), Acrylamide toolbox

To be developed by Industry associations (National and European)

and

implemented on a voluntary basis

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Export to the EU

Foods of animal origin

• Consignments must be presented at EU Border Inspection Posts - accompanied by all certificatesrequired in EU veterinary legislation - for import control

• Prior notice of the arrival in the BIP must be given(in accordance with National rules of the Member State in which the border inspection post is situated)

• Products must derive from approved countries, regions and establishments (as appropriate)

-> for certifications and certificates, see TR@CE (TRade Control & Expert System, EC), www.traces-cbt.net

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Export to the EU

Foods of non-animal origin

• In general, these foods

can enter the EU without certification by the competent authorities of the third country of

dispatch, and

are not subjected to a pre-notification procedure on arrival

• High risk foods of non-animal origin:designation of points of entry, prior notification of the arrival (EC Reg. 669/09)

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C) CONTROLS, public

The EU-Member States network implies

Information flow (RASFF, Border Inspection Posts)

Contact points (European Commission-DG Sanco, Ministries of Health)

Methods (sampling & analysis)

Scientific cooperation (European Food Safety Authority, EFSA)

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Rapid Alert System on Food& Feed

Annual report 2007: 2976 notifications

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RASFF – weekly overview

Abstract from Week 18, 2009:

Product (to be) re-dispatched

Border rejection

aflatoxins (B1 = 12.3; Tot. = 14.1 µg/kg - ppb) in roasted pistachio nuts from Turkey

2009.AVQ

Germany27/04/2009

Product (to be) re-dispatched

Border rejection

aflatoxins (B1 = 3.20; Tot. = 7.45 µg/kg - ppb) in roasted diced hazelnut from Turkey

2009.AVH

Germany27/04/2009

border control -

consignment

released

official control on the market

Notification basis:

information on distribution

not (yet) available

too high count of Escherichia coli (700 MPN/100g) in clams

(Donax trunculus) from Turkey

2009.0556

Italy29/04/2009

product (to be) withdrawn from the market

oxamyl (0.31 mg/kg - ppm) in

green peppers from Turkey

2009.0526

Germany27/04/2009

Status:Reason for notifying:Ref:Notified by:

Date

http://ec.europa.eu/food/food/rapidalert/index_en.htm

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RASFF – weekly overview

Abstract from Week 18, 2009:

product under customs seals

Border rejection

aflatoxins (B1 = 3.5; Tot. = 10.7 µg/kg - ppb) in natural dry figs from Turkey

2009.AVG

France28/04/2009

product under customs seals

Border rejection

aflatoxins (B1 = 2.6; Tot. = 7.9 µg/kg - ppb) in dried figsLerida from Turkey

2009.AVG

France28/04/2009

Product (to be) re-dispatched

Border rejection

aflatoxins (B1 = 3.74; Tot. = 12.9 µg/kg - ppb) in diced hazelnuts from Turkey

2009.AVR

Germany28/04/2009

Border rejection

Notification basis:

product under customs seals

aflatoxins (B1=20.9; Tot=28.9; B1=0.9; Tot=9.6

µg/kg - ppb) in dried figsfrom Turkey

2009.AVX

France28/04/2009

Status:Reason for notifying:Ref:Notified by:

Date