2. 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
C) CONTROLS
A) SAFETY
(public/private)
B) HYGIENE
2
3. A) SAFETY
• RESPONSABILITY. All operators must
monitor the safety of products and
processes under their responsibility
Self-checks -> Safety assessment
• TRACEABILITY
• INCIDENT MANAGEMENT
(EC) Reg. No. 178/02, General Food Law 3
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5. Safe food
i.e. heavy metals in fish
• Food cannot be placed on the EU market
if: ie. aflatoxins in pistachio nuts
1) harmful short-mid-long term
(in the /
cumulative effects / sensitivities of
specific categories of consumers)
i.e. undeclared allergens
2) unfit to human consumption (ie.
physical contamination, deterioration,
putrefaction, deacay) 5
6. 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)
ER
D ANG
Clear impact on the management of the
whole process
Self checks against X-contamination 6
7. 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
i.e. melamine
2) make the food derived from food-
producing animals unsafe for human
consumption
i.e. (carry over) dioxins
7
8. Safety assessment
• Safety is evaluated regarding the
normal intended use of the product, and
the
information given on its label
• The entire batch/consignment
risky product is
of a
presumed by law to be unsafe 8
9. 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 - who
has received which product
inform the competent authorities on what
above, whenever requested 9
11. 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
11
12. 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 the
other operators involved
12
14. B) HYGIENE
General obligations
• All business operators have to be registered
or 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
14
15. 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) 15
17. Hygiene
Detailed requirements
Primary production: After primary production:
EC Reg. 852/04 EC Reg. 852/04
Art. 4.1, Annex I Art. 4.2, Annex II
Food of Animal Origin: Feed:
EC Reg. 183/05
EC Reg. 853/04
For certain products:
Where applicable: microbiological criteria
Contaminants & residues, food EC Reg. 2073/05
contact materials, GMOs,
irradiation, … 17
18. Guides to Good Practice
To be
developed by Industry associations (National and European)
and
implemented on a voluntary basis
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
18
19. Export to the EU
Foods of animal origin
• Consignments must be presented at EU Border
Inspection Posts - accompanied by all certificates
required 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
19
20. 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)
20
21. 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)
21
22. Rapid Alert System on Food & Feed
Annual report 2007: 2976 notifications
22
23. RASFF – weekly overview
Abstract from Week 18, 2009:
Date Notified Ref: Reason for notifying: Notification Status:
by: basis:
27/04/ Germany 2009. official product (to be)
2009 0526
oxamyl (0.31 mg/kg - ppm) in
green peppers from Turkey control on withdrawn from
the market the market
29/04/ Italy 2009. border information on
too high count of Escherichia
2009 0556 control - distribution
coli (700 MPN/100g) in clams
consignment not (yet) available
(Donax trunculus) from Turkey
released
27/04/ Germany 2009. Border Product (to be)
2009 AVH
aflatoxins (B1 = 3.20; Tot. =
rejection re-dispatched
7.45 µg/kg - ppb) in roasted
diced hazelnut from Turkey
27/04/ Germany 2009. Border Product (to be)
2009 AVQ
aflatoxins (B1 = 12.3; Tot. =
rejection re-dispatched
14.1 µg/kg - ppb) in roasted
pistachio nuts from Turkey
http://ec.europa.eu/food/food/rapidalert/index_en.htm 23
24. RASFF – weekly overview
Abstract from Week 18, 2009:
Date Notified Ref: Reason for notifying: Notification Status:
by: basis:
28/04/ Germany 2009. Border Product (to be)
2009 AVR
aflatoxins (B1 = 3.74; Tot. =
rejection re-dispatched
12.9 µg/kg - ppb) in diced
hazelnuts from Turkey
28/04/ France 2009. Border product under
2009 AVX
aflatoxins (B1=20.9;
Tot=28.9; B1=0.9; Tot=9.6 rejection customs seals
µg/kg - ppb) in dried figs
from Turkey
28/04/ France 2009. aflatoxins (B1 = 2.6; Tot. = Border product under
2009 AVG rejection
7.9 µg/kg - ppb) in dried figs customs seals
Lerida from Turkey
28/04/ France 2009. Border product under
2009 AVG
aflatoxins (B1 = 3.5; Tot. =
rejection customs seals
10.7 µg/kg - ppb) in natural
dry figs from Turkey
24