hygiene safety of fishery products cese 14 february 2014
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Hygiene & safety of fishery products CESE 14 February 2014 Paolo Caricato Deputy Head of Unit European Commission Health & Consumers Directorate General Directorate G Veterinary and International affairs Unit G4 Food, Alert


  1. Hygiene & safety of fishery products CESE 14 February 2014 Paolo Caricato Deputy Head of Unit European Commission Health & Consumers Directorate General Directorate G – Veterinary and International affairs Unit G4 – Food, Alert System and Training BTSF

  2. EU Food safety legislation • GOALS – Prevent contamination by hazards – and thus minimize risks for human consumption • Consequences: – FBO to work towards compliance – Competent Authority to control FBOs and to proceed to specific official controls/analyses on products throughout the production chain to ensure compliance or equivalence with food safety legislation are achieved and then certify 2

  3. EU LEGISLATION : PRINCIPLES • SAFE FOOD = FOOD COMPLIANT AND CONTROLLED WITH REGARD TO THE RELEVANT COMMUNITY LEGISLATION REQUIREMENTS • FOOD SAFETY BASED ON THE CONTROL OF THE FOOD PRODUCTION CHAIN versus CONTROL ON END-PRODUCTS • « FARM TO FORK APPROACH » = « SANITARY TRACEABILITY » (i.e. FOR IMPORTED FP: FROM SEA TO EXPORTED CONSIGNMENT) • IMPORTED FOOD: SAME LEVEL OF CONSUMER PROTECTION EITHER FOR FOOD PRODUCED IMPORTED OR PRODUCED IN THE EU (based on SPS principle), i.e. for FISHERY PRODUCTS: COMPLIANCE OR EQUIVALENCE • NO DISCRIMINATION BETWEEN THIRD COUNTRIES 3 EXPORTING TO THE EU (based on SPS principle)

  4. EC LEGISLATION • BASED ON CODEX ALIMENTARIUS RECOMMENDATIONS – PRE-REQUISITES (structure, organisation, equipment, material) – GOOD HYGIENE PRACTICES – HACCP PRINCIPLES/SYSTEM • OFFICIAL CONTROL & CERTIFICATION – OIE/CODEX RECOMMENDATIONS/GUIDELINES – ISO STANDARDS: • COMPETENT AUTHORITY CONTROL ACTIVITIES 4 • FVO METHODS FOR AUDITS/INSPECTIONS

  5. Former hygiene rules Meat Poultry Fishery Milk Processing meat products 5 Health and Consumers

  6. The “White paper” on food safety • -Published in January 2000 • -Plans for a proactive new food policy: • modernising legislation, • reinforcing controls, • increasing the capability of the scientific advice system, • guaranteeing a high level of human health and consumer protection. • -Strategic Priorities of the White Paper are: • to create a European Food Safety Authority • to consistently implement a farm to table approach in food legislation • to establish the principle that feed and food operators have primary responsibility for food safety; that Member States need to ensure surveillance and control of these operators; that the Commission shall test the performance of Member States' control capacities and capabilities through audits and inspections 6 Health and Consumers

  7. Regulation (EC) No 178/2002 Food law Competent authorities Food business operators Regulation (EC) Regulation (EC) No 882/2004 No 852/2004 General rules General rules for official controls on hygiene Regulation (EC) Regulation (EC) No 853/2004 No 854/2004 Specific hygiene rules Specific rules for official controls for products of animal origin on products of animal origin Regulation (EC) Regulation (EC) Regulation (EC) No 2075/2005 No 2074/2005 No 2073/2005 Trichinella Other implementing rules Microbiological criteria

  8. Legal framework: • - Regulation (EC) No 178/2002 - General food law • - General principles • Risk analysis and scientific basis • Precautionary principle • Protection of consumers’ interests • Principle of transparency • - General requirements • Food safety requirements • Presentation of products • Responsibilities • Traceability • Procedures • - European Food Safety Authority 8 Health and Consumers

  9. Hygiene legislation: The main branches -Regulation (EC) No 852/2004 - Hygiene of foodstuffs -Regulation (EC) No 853/2004 – Specific hygiene rules for food of animal origin -Regulation (EC) No 882/2004 - Official Feed & Food Controls -Regulation (EC) No 854/2004 - Official controls on products of animal origin intended for HC 9 Health and Consumers

  10. Import from Third Countries Regulation 178/2002/EC(Food Law ) Art. 11 Food and feed imported to the Community… shall comply with the relevant requirements of food law or conditions recognised by the Community to be at least equivalent… with requirements contained therein.

  11. Exporting Fish, Fishery products and live bivalve molluscs into the EU (2) • Specificically regulated by – Regulation (EC) 882/2004 (art. 46) • General – Commission experts may carry out inspection in third countries in order to verify compliance or equivalence – Regulation (EC) 882/2004 (art. 47) • General – Import conditions – Regulation (EC) 882/2004 (art 48) • Specific – Import Conditions.

  12. Exporting Fish, Fishery products and live bivalve molluscs into the EU (2) • A Regulation (EC) 882/2004 (art 48) • Specific – Import Conditions. Apply to fish, fishery Products and LBM • List of countries from which certain products may be imported (+ Reg. 854 art. 11 and art. 12) • Establishment of Model Certificates (+ Reg. 854 art. 14 and Annex VI) • Special import conditions for single products or group of products and from single countries or group of countries

  13. Harmonised procedures 1 Physical check 3 BIP by random sampling Documentary check 2 Organoleptic Visual Veterinary certificate Identity check Microbiological Origin Correspondence between Chemical products and the authorised veterinary certificate third country Environmental contaminants agreed establishment Additional checks * Products details recorded on the Checks on importation of products Original document certificate • number of establishment One sheet of paper * health mark check • officially approved Written in one of the official languages of MS of introduction * third country list From N.Brooks FVO

  14. MAIN HAZARDS IN FP AND LBM • Biological – Bacteria e.g. vibrio, salmonella, E. Coli, Listeria m., – Parasites • Chemical – Histamine (sensitive species) – Toxics – Heavy metals – Other environment contaminants (pesticides, dioxines,…) – Veterinary drug redisues in aquaculture products (nitrofuranes, chloramphenicol, malachite green…) – Marine biotoxins

  15. FVO MISSION OBJECTIVES • OBJECTIVES: TO VERIFY THAT THE CA IS CAPABLE – FOR MS: TO ENSURE COMPLIANCE WITH SPECIFIC REQUIREMENTS OF EC REG. 852/853/854/882/2004 – FOR TC: • TO CONTROL AND CERTIFY EXPORTED FP TO THE EU REGARDING REG (EC) 1250/2008 AH/PH combined REQUIREMENTS, amending REG. 2074/2005) • TO DEMONSTRATE ITS RELIABILITY IN ORDER TO MAINTAIN THE PRE-LISTING PROCEDURE 15

  16. MAIN FINDINGS RELATING TO FISHERY PRODUCTS PRODUCED IN OR EXPORTED TO THE EU – KNOWLEDGE/IMPLEMENTATION/CONTROL/ENFORCE MENT OF COMMUNITY REQUIREMENTS – CA EFFICIENCY, i.e. inspection frequency, scope, depth, follow-up, enforcement – BUDGET for CONTROLS/ANALYSES – LAB CAPACITIES/QUALITY OF ANALYSES – RESIDUE MONITORING PLAN FOR EXPORTED AQUACULTURE PRODUCTS

  17. MAIN FINDINGS RELATING TO FISHERY PRODUCTS PRODUCED IN OR EXPORTED TO THE EU (cont.) • RUNNING/POTABLE/CLEAN WATER (ICE) – FRESHNESS OF FISH LANDED – HYGIENE OF OPERATIONS – COLD CHAIN – HYPER-CHLORINATED WATER USE – FP TRACEABILITY: • FROM VESSELS TO PLANTS • WITHIN PLANTS • RAW MATERIAL IMPORTED OR COMING FROM NON « EU APPROVED » VESSELS OR ESTABLISHMENTS – HACCP Plan inappropriate, inadequate/insufficient documentation – NUMBER OF OWN-CHECK ANALYSES AND OFFICIAL ANALYSES 17 – ADDITIVES (crustaceans) 17 17 17 17 17 17 17 – HEALTH STATUS OF STAFF

  18. HOW TO IMPROVE THE SITUATION ? – Pressure on MS: • request for action plans • tight follow-up (on-desk exercise and FVO missions) – CA official training: SANCO programme « Better Training for Safer Food » for better harmonisation regarding control and enforcement – Feedback on Community legislation implementation for possible revision 18 18 18 18 18 18

  19. HOW TO IMPROVE THE SITUATION? – Pressure on TC: pre-listing on hold, appropriate and proportionate protective measures, action plans and follow-up (on-desk exercise and FVO missions) – CA official training: SANCO programmes, « Better Training for Safer Food » (including STM) – technical assistance provided by Commission services (DEVCO,TRADE, ELARG/TAIEX) following TC requests 19 19 19 19 19 19

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