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| Official
controls on products of animal origin for human consumption |
CFG
09/03 rev. 2
Summary of the proposal
In July 2002, the European Commission proposed new rules for the controls
of foods of animal origin. The proposal is one of five making up the
so-called "hygiene package" of measures foreshadowed in
the action plan of the Commission's White Paper on Food Safety. This
proposal provides for revised rules for official controls on fresh
meat, live bivalve molluscs, and milk and milk products.
The hygiene proposals are subject to the co-decision procedure. Once
adopted by the European Parliament and the Council, the Regulations
will replace the Directive on the hygiene of foodstuffs (93/43) and
sixteen product specific Council Directives.
As regards meat, the proposal is:
Science based
It integrates the latest opinions of the Scientific Committee on Veterinary
Measures related to public health. The requirements concerning
inspection procedures can be adapted in a flexible way in order to
take into account scientific opinions as soon as they are released.
Relevant hazards
The proposed system contains procedures for controls on all relevant
microbiological, chemical and food safety hazards. The proposal contains
standards for a number of these hazards.
Official veterinarians
The official veterinarian plays a central role in the system. Besides
auditing and inspection tasks, he or she has to ensure that information
resulting from inspections flows back to the farmers. The proposal
contains clear requirements in respect to specific training needed
by the veterinarian. It also specifies the training requirements for
the official auxiliaries, who can assist the official veterinarian.
Audits of the systems put in place by the operator
The operator has to ensure, through the application of good hygiene
practices (GHP) and procedures based on the HACCP, that the meat is
produced is in line with the EU standards.
Inspection activities
Besides carrying out audits of the system put in place by the operator,
the official veterinarian can carry out inspection activities, covering
the following issues: relevant records form the holding of provenance
of the animal, ante-mortem inspection, animal welfare, post-mortem
inspection, specified risk materials, laboratory testing, health marking.
Stable to table approach
Animals are not accepted for slaughter if they are not accompanied
by relevant food safety information from the farm. The proposal establishes
a continuous flow of information between primary production and slaughterhouses.
Animal health and welfare
Ante-mortem inspection is carried out by the official veterinarian.
S/he checks among other things whether any animal disease is present
and whether the relevant animal welfare rules are being respected.
Animals showing clinical signs of systemic disease or emaciation,
shall not be slaughtered for human consumption and shall comply with
the new rules on animal feed.
Frequency and intensity of official controls is risk-based
The frequency and intensity of official controls is based on an assessment
of the health risks, represented by the type of animals and the type
of process. At least one official veterinarian shall be present throughout
ante-and post-mortem inspection. However some flexibility exists for
small enterprises and for the poultry sector.
Involvement of staff of the establishment
The proposal creates a clear division of responsibilities between
the slaughterhouse operator and the competent authorities. Operators
who have a good record in meeting the legal requirement, and are motivated
to do so, can be allowed, under strict conditions, to have their staff
carrying out activities of auxiliaries.
Bivalve molluscs
As regards live bivalve molluscs, the proposal identifies what needs
to be done by the competent authority in order to ensure the safety
of these products. This includes the setting up of a monitoring programme
of harvesting areas to check the microbiological quality of live bivalve
molluscs, the presence of toxin-producing plankton and the presence
of chemical contamination.
Coverage
As regards milk and milk products, the proposal aims to ensure that
where raw milk fails to meet the required health standards, corrective
action is taken at farm level, and that milk that might constitute
a hazard to human health cannot be delivered for human consumption.
The measures applying to poultry are not changed.
Comments
Since the proposed regulation was part of the ‘hygiene package’
of measures proposed by the Commission’s White Paper on food
safety of January 2000. Foodaware is pleased that it is finally being
acted upon. There must be a clear commitment to implement a tighter
system of control and surveillance over food hygiene procedures in
the industry.
'The Commission’s proposal to use a regulation rather than a
directive as the legal instrument has the advantage that it will more
easily ensure uniform application of the legislation throughout the
EU. This will be particularly important with the imminent enlargement
with 10 new states, many of which have far less developed food hygiene
enforcement systems than the current members. On the other hand there
is a danger that the legislation will prove to be too inflexible and
not permit the member states to make local adjustments. Safeguards
should be introduced into the text to prevent this from arising. The
possibility of permitting national supplementary measures relating
to enforcement (as in other areas of food legislation) should not
be ruled out, as this is entirely in accordance with the principle
of subsidiarity as contained in Article 5 EC.'
Official veterinarians
Foodaware advocates uniform standards of enforcement across the EU,
at the highest possible level. However, this does not mean uniformity
in techniques, rather effective audit procedures to ensure broad equivalence
in terms of outcome.
Whilst Foodaware accepts the need for veterinary supervision, it does
not consider that trained vets are needed to carry out all the inspection
activities. It notes that the possibility of staff carrying out the
function of ‘auxiliaries’ is restricted to certain types
of animal and a proscribed period of good behaviour. The potential
role of ‘official auxiliaries’ and the scope of their
activities need to be more closely considered and clearly defined.
Foodaware is also concerned that, where ‘in-house’ staff
are authorised to carry out inspection tasks, in-house inspectors
should have adequate and uniform training. It would support the introduction
of an EU-recognised qualification to this effect.
Without compromising safety standards, the viability of smaller, more
local abattoirs does need to be taken into account.
HACCP
The principles of HACCCP should be applied right through production,
processing and placing on the market. Foodaware would recommend generic
guidelines in the official controls, for audit, good hygiene practices
(GHP) and HACCP programmes in all sectors.
Inspection
Foodaware would emphasise the importance of traceability and an information
chain. It supports the EU Economic and Social Committee in calling
for a documented information management system in each member state,
obviously important in any emergency. Foodaware would like to be assured
that national animal health problems are reported promptly so that
action can be taken if necessary on trade. Foodaware supports the
farm to table approach, to cover all sectors.
Bivalve molluscs
Foodaware supports extra monitoring which it has called for on the
Commission’s strategy for aquaculture (CFG 23/02 Rev. 2), based
on best practice testing. Toxic shellfish can cause serious illness
with symptoms ranging from vomiting to falling into a coma. Further
research is needed into more effective testing methods.
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