EU DG Health and Food Safety audit in Sweden – Unexpected flaws in microbial safety of food of non-animal origin

Here below the summary of a recent audit of the EU Commission services on the Swedish official control system for food of non animal origin (in particular frozen food and sprouts/seeds for sprouting). Beside the detected shortcomings, is quite unusual to notice that from internal audits from 2014 and from EU Commission audit in 2015, nothing or little improvements have been made.

“This report describes the outcome of a DG Health and Food Safety audit in Sweden which took place from 18 September to 27 September 2018 under the provisions of Regulation (EC) No 882/2004 of the European Parliament and the Council of 29 April 2004.

The objectives of the audit were to assess:

 the system of official controls in the area of food hygiene to prevent microbiological contamination in the production of food of non-animal origin, notably as frozen products and sprouts and seeds intended for sprouting;

 the extent to which the corrective actions submitted to the Commission services in response to the recommendations of the previous Directorate-General for Health and Food Safety audit report of 2015 have been implemented and their effectiveness in addressing the identified shortcomings.

Overall, a risk-based control system for official controls on food of non-animal origin is in place. There is a system for registering primary producers and for the approval of sprout-producing establishments. This facilitates the implementation of a risk-based approach to official controls including microbial risks associated with food of non-animal origin.

Regarding official samples, the appropriate laboratory capability and capacity is available.

Significant shortcomings were identified in relation to the registration of food business operators and approval of sprout-producing establishments. The approval system does not ensure that noncompliances have been rectified before that approval is granted. In addition, the official control system presents a number of gaps, notably related to provision of specific instructions, technical support and staff training. As a result, official controls cannot be implemented correctly and effectively, resulting in poor controls. This impacts on the enforcement, where non-compliances are hardly detected and when detected are rarely followed-up.

A number of these shortcomings were equally reflected in the outcome of an internal audit performed by the Central Competent Authority
in June 2018, and which found little corrective action since the previous internal audit, in 2014.

Thus, non-compliant products might be undetected and the correct application of the relevant legislation might not be enforced, resulting in placing on the market of non-compliant products which may present a health risk.

In respect of the follow-up to the previous audit, certain actions have not been effective in addressing the identified shortcomings. Overall, the audit had to conclude that there has been limited improvement compared to what was found previously.”

(Source: DG Sante website)

Top ten 2018 articles and Foodlawlatest.com achievements

Dear readers,

At the end of 2018, foodlawlatest.com ranked 2nd in the category Niche and Specialty niche_and_specialty_-_2nd_place_badgeLaw Blog in the blog contest launched by the Expert Institute.

Thank you for all your support and for your votes.

After 5 years of activity is time to give you some numbers.

This year we proudly served more than 100 clients, on 3 continents (EU, North America, Asia) and we gathered readers from more than 160 countries.

Our LinkedIn group, with much more info and updates, is now including more than 4.000 food professionals and we launched with success our first massive online webinar (on FDA labeling).

Just as we speak we are gathering subscriptions for the next webinar’s wave and soon there will be much more: guest speakers from around the world will introduce you to food law in the major markets (a hint: the 1st one will be on the upcoming new Chinese labeling legislation…). From fall 2018 I am as well guest instructor for online courses of the Michigan State University Institute for Food Laws and Regulations.

Now we are a team of 5 here in Torino’s office and we cover more than 60 markets through local partners and contractors. In 2019 we would like to scale up, refresh the website and publish more frequently, launch a YouTube channel and bring to the surface the huge network and the different skills that we might put on the plate when it comes to offer you a strategic advice in marketing food. Two major publications on food labeling (in English) are as well in the pipeline.

Between our major partners, I’d like already to quote (and thank for the great support and exchange of knowledge):

  • MoniQa: MoniQA is an international and interdisciplinary network of professionals from institutions working in food research, regulatory bodies and trade, providing solutions to promote a safer and secure food supply worldwide. The main focus of the association is on food allergen management and food fraud prevention and I sit in the Scientific Advisory Committee;
  • Arcadia International: Arcadia is a multi-disciplinary consultancy dedicated to the food and feed value chain and is also recognized as expert by several European Commission Directorate-Generals for agriculture and food related activities. In particular a mention goes to my great friend Francesco Montanari, food lawyer in Lisbon/Paris;
  • ShantallaJohn G. Keogh: Shantalla provides retainer-based advisory services and project-based research for clients in the public and private sectors globally, on topics like:
    • Strategy & Policy Advisory
    • Supply Chain Integrity incl. Traceability and Brand Protection
    • Product and Consumer Safety incl. Recall
    • Supply Chain Transparency & Consumer Trust
    • Sustainability, Compliance & Governance
    • Industry Standards (GS1)
    • Technology Advisory incl. IoT & Blockchain Use Cases

Coming back to our blog, the most read articles in 2018 – in case you missed them – were the following:

  1. EFSA – Consumer perceptions of emerging risks in the food chain
  2. Food fraud update at EU level and Interpol/Europol Opson VII operation preliminary findings
  3. Vietnam – New Criminal Code provides stricter sanctions for food safety violations
  4. QeA EU Parliament – EU Commission to EU Parliament on Meat Sounding
  5. QeA EU Commission to EU Parliament – Allergens declaration on non pre-packed food
  6. EU Audit in Belgium on organic production and labeling – Are we still surprised of “organic frauds”?
  7. EU Study on Food Waste and Date Marking published
  8. FDA finalizes the extension of the compliance dates for new Nutrition Facts
  9. Food Law in Asia and Food Law in US Conference (Rome 16-17th April 2018)
  10. Hard times for industrial trans fats: EU upcoming legal limit and FDA moves

Please let us know what we can do more or better and thank you for your continuous support!

Cesare