Recent FVO report on bivalve molluscs and fishery products

Recently the Food Veterinary Office (FVO) spotted some problems regarding live bivalve molluscs in Greece and fishery products from Bangladesh.

GREECE – Live bivalve molluscs

The first report describes the outcome of a Food and Veterinary Office audit in Greece carried out from 14 to 24 October 2014, as part of its programme of audits for 2014.

The primary objectives of the audit were to assess whether the official controls of bivalve molluscs, echinoderms, tunicates and marine gastropods are organised and carried out in accordance with the relevant provisions of Regulation (EC) No 882/2004 of the European Parliament and of the Council of 29 April 2004 on official controls performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules and whether the control system in place for the production and placing on the market of bivalve molluscs, echinoderms, tunicates and marine gastropods is in compliance with European Union requirements.

The audit also verified the implementation of the recommendations of the previous 2011 Food and Veterinary Office audit visit covering the same subject.

The current report concludes that considerable improvements have been made since the previous audit, however, the official control system in place covering live bivalve molluscs cannot yet be considered as fully in compliance with all European Union requirements. Important shortcomings are still present, notably related to the definition of sampling points for the collection of water for phytoplankton testing and live bivalve molluscs for biotoxins testing, the frequency of monitoring/testing of live bivalve molluscs for one group of toxins (Paralytic Shellfish Poison) and the absence of demonstration of the efficiency of the purification systems.

Of the twenty recommendations of the 2011 audit, ten can be considered as addressed, three partially addressed, six not addressed (monitoring of biotoxins (for Paralytic Shellfish Poison); decisions taken after monitoring; additional monitoring requirements; purification centres; analytical and legal validity of samples; coordination between Competent Authorities) and one is no longer applicable.

BANGLADESH – Fishery products

This report describes the outcome of a Food and Veterinary Office audit in Bangladesh carried out from20 to 30 April 2015, as part of its programme of audits in third countries.

The objectives of the audit were to evaluate whether the official controls put in place by the competent authority can guarantee that conditions of production of fishery products in Bangladesh destined for export to the EU are in line with the requirements laid down in EU legislation and in particular with health attestations contained in the certificate and to verify the extent to which the guarantees and corrective actions submitted to the Commission services in response to the recommendations of the previous Food and Veterinary Office fishery products report of 2010 have been implemented and enforced by the competent authority.

The report concludes that improvements have been made since the last audit and in principle, the current organisation of the competent authority and its documented operational procedures provide for an acceptable official control system for fishery products which is implemented in a satisfactory way.

However, certain deficiencies in their implementation (i.e. temperature controls, structural standards of freezer vessels; lack of histamine, dioxin/PCBs and additives testing; maximum limits for cadmium) do not offer the necessary guarantees that fishery products intended for EU export fully respect the requirements defined in the health certificate for imports of fishery products intended for human consumption as set out in the model defined in Regulation (EC) No 2074/2005.

EU Commission report on official controls 2013

Here’s an abstract of the content of the report, published here, where I enlight the most critical points found by the Commission. There are data also related to other sectors/problems, but since the level of compliance was satisfactory, I’ve decided to not talk about them in the post.

LEGAL BASIS

Article 44 (4) and (6) of Regulation (EC) No. 882/20041 requires the Commission to submit to the European Parliament and Council, an annual report on the overall operation of controls in the Member States in the light of:
(a) the annual reports submitted by the national authorities on their control activities;
(b) Commission controls carried out in the Member States;
(c) any other relevant information.

Other relevant information related to controls includes:
• reports from Member States to the Commission on controls in specific sectors;
• the results of EU rapid alert systems (RASFF System, art. 50 Reg. CE 178/2002);
• Commission enforcement actions (including infringement cases) related to observed non-compliances in the Member States;
• reports from international standard setting bodies.

CONTROL TRENDS

The Commission noticed a continuing trend towards more risk-based control systems.

NON COMPLIANCE TRENDS

The main areas of non-compliance identified across sectors include: operational hygiene requirements; HACCP; structural or equipment based hygiene requirements; labelling of food and feed; additives in feed; record keeping; and microbiological contamination. The identification of underlying causes of non-compliance is generally limited. As was the case last year, HACCP/hygiene deficiencies were often attributed to high staff  turnover, a lack of training at food business operators (FBOs) and minimal or no consequences for non compliances.

COMMISSION’S CONTROL ACTIVITIES IN THE MEMBER STATES

Food safety

Official controls on milk and meat production

A trend already previously observed has been confirmed in relation to enforcement: whilst control authorities largely identify deficiencies correctly, sustained enforcement action is not always taken in a timely manner and as a result, non-compliances may persist.

Traceability of beef and beef products

A series of audits on traceability of beef and beef products was completed in 2011. The latest review indicates that controls of traceability of
beef and beef products and compulsory labelling have improved significantly in the Member States visited. In relation to the traceability of live animals, deficiencies in implementing current legislation and carrying out official controls were seen in places where animals are gathered, such as dealers’ premises, markets and assembly centres. Some shortcomings were also noted related to the management of databases used for the registration of animals.

Game – wild and farmed

A number of issues of interest have arisen from this sector: incomplete testing for Trichinella spiralis in small quantities of susceptible game species directly supplied to the consumer; a liberal interpretation of the “small quantities” which can be excluded from official hygiene controls; the regular use of wild game collection centres, which were not always registered and therefore not subject to official controls; unclear demarcation between farmed and wild game with risks of misleading consumer information on the true origin of game meat; and intra-Union trade of the bodies of unskinned wild game animals, contrary to EU legislation.

Fishery products and live bivalve molluscs

While the overall systems were well designed and managed, some important weaknesses were identified in relation to controls on:
• Primary production sites, such as fishing vessels and fish farms;
• Live bivalve molluscs, in relation to: classification of production areas; the frequency of testing in monitoring for biotoxins; and end product testing.

Poultry

The entire poultry production chain was covered, although in some cases the number of controls at farm level was limited, and some recent audits identified inadequate post-mortem inspection. The main areas identified for improvement continue to be in relation to: the application of specific hygiene requirements, such as the sampling frequency of carcasses and the implementation of HACCP plans in
establishments; and non-notification to the Commission of national legislation allowing flexibility for small capacity slaughterhouses.

As was the case for controls on milk and meat product establishments, a trend was identified in relation to enforcement, where although control authorities largely identify deficiencies correctly, enforcement action was not always taken in a timely manner.

Food of non animal origin import

Onward transportation, as defined under Regulation (EC) No 669/2009, and transfer of goods, under Regulation (EC) No 1152/2009, (which may allow certain checks to take place at a consignment’s final point of destination, after onward transportation from its point of arrival in the EU) did not always guarantee full traceability, in particular when several Member States were involved, and the prior notification requirement was often not followed. In half the Member States, customs release did not always correctly follow the procedures established by EU regulations. These deficiencies may lead to the situation where goods are released without the finalised checks. While the overall systems for laboratory analyses have improved, deficiencies in the implementation of specific analytical requirements of EU legislation were often detected.

Food of animal origin import

The Commission noted deficiencies in some Member States in the communication between central and devolved authorities, undermining in some cases the overall effectiveness of controls. While pre-notification of transhipped consignments is improving in some Member States, enforcement by competent authorities is still poor in relation to this requirement in some major ports.
Since last year’s report, the level of implementation of TRACES, the common computerised system for imports, has improved. Some of the Member States previously not using TRACES have now joined the system.

Residues of veterinary medicines and contaminants

Member States continue to face challenges similar to those identified in last year’s annual report in implementing their national residue monitoring plans, including: variations between Member States in the number of methods included in the scope of laboratory accreditation for residues analysis; and variations in the interpretation of requirements relating to Food Chain Information at slaughter.  With regard to the ongoing current round of dioxin audits which are evaluating the ability of Member States to ensure that fish caught in the Baltic Sea and placed on the market for human or animal consumption comply with EU limits for dioxins, the evidence gathered to date indicates that there is a lack of consistency in the approach taken by Member States to minimise consumer exposure to non-compliant fish.

OUTCOME OF OFFICIAL MONITORING

Salmonella and Campylobacter are the two main causes of food borne illness in the EU.

Sustained attention to and co-ordination of enforcement action remains a priority in all areas.

Member States ensure a good level of implementation of official controls across the food chain, and respect for food safety, plant and animal health, and animal welfare issues. While there is still scope for improvement, there has been progress in the efficient use of control instruments and resources, and in planning, implementation, and co-ordination of controls across all sectors.

Official controls, and legislative instruments to optimise their effectiveness, are key features of the EU food chain. They allow competent authorities to perform controls on a risk basis, and to identify shortcomings and address them in a timely manner. They also provide competent authorities with a meaningful overview of the food safety and health situations.

In the report, you’ll find also brief explanations about the animal health and welfare situation, animal feed and plant health.