This report describes the outcome of an audit carried out by the Food and Veterinary Office (FVO) in Myanmar from 24 February to 06 March 2014.
The objectives of the audit were to evaluate the official controls related to production and processing of seeds for human consumption (in particular, seeds for sprouting eg. mung beans and other seeds for sprouting) intended for export to the European Union (EU) in the framework of Regulation (EC) No 178/2002 and Regulation (EC) No 852/2004 and to evaluate procedures in place for the certification for imports into the EU of seeds for the production of sprouts as required by Regulation (EU) No 211/2013. The objectives of the audit were met.
Myanmar was selected to be audited as part of the 2014 FVO audit programme due to a number of outbreaks in the EU connected with the consumption of sprouted seeds and the volume of imports from Myanmar.
Official food safety controls on primary production, collection and processing of seeds for human consumption (in particular, seeds for sprouting) do not take place. This was acknowledged by the Myanmar Competent Authorities.
The CAs of Myanmar are aware of the requirements of EU legislation on sprouts and seeds for sprouting. There are currently no official controls carried out to attest the implementation of general hygiene requirements as laid down in Annex I to Regulation 852/2004. However, in the regions visited the above-mentioned requirements were implemented by primary producers. The hygiene practices in the processing facilities and collectors visited by the FVO audit team were generally in line with the relevant EU requirements.
The system of official food safety controls currently in place cannot ensure that the seeds for human consumption (in particular, seeds for sprouting) were produced under conditions which meet the general hygiene provisions for primary production and associated operations as set out in Part A of Annex I to Regulation (EC) No 852/2004 and therefore the CA is not able to certify conformity with these requirements as required by Article 3 of Regulation (EU) 211/2013.
The audit was carried out from 14th to 18th October 2013 to evaluate the official controls related to production and processing of seeds for sprouting intended for export to the European Union, becaus of the recent oubreaks of Shigatoxin producing E. coli (STEC) in EU and the large Chinese production.
The main Regulations applicable in EU for these products are:
– Reg. CE n. 178/2002 “General Food Law”;
– Reg. CE n. 852/2004 on hygiene requirements for food of non-animal origin;
– Reg. EU 211/2013 on the approval of establishments producing sprouts and the certification for imports into the EU of seeds for the production of sprout.
The objectives of the audit were only partially met, as the audit team was unable to visit primary producers of seeds for sprouting.
The Chinese Competent Authorities (CAs) have started to implement some of the requirements of the EU legislation on sprouts and seeds for sprouting, however there was no evidence provided regarding the hygienic conditions of seed production at farm level and there are no official controls for primary production of seeds for sprouting. The processing facilities visited by the audit team followed Good Hygiene Practices except in regard to the storage facilities. The effectiveness of the official control system is undermined by limited official sampling for microbiological contamination and the lack of representativeness of the official samples. The laboratories visited were accredited and suitable for the purpose of official microbiological analysis with the exception of Shigatoxin producing E. coli (STEC).
The system of official food safety controls currently in place cannot assure that the seeds for sprouting were produced under conditions which comply with the general hygiene provisions for primary production and associated operations set out in Part A of Annex I to Regulation (EC) No 852/2004 as required by Article 3 of Regulation (EU) 211/2013. This applies also for the 2013
The Chinese CAs acknowledged the fact that official food safety controls on farms do not take place and proposed a future follow-up audit by the FVO to observe implementation of the general food hygiene requirements at farm level.