FVO Report – Italy deficiencies of official controls on milk and milk products

The following FVO report stress several and persistent profiles of non compliance of the Italian official controls system on milk and milk products: the recommendations made in 2010, 2012 and 2013 were not properly addressed.

The audit took place in Italy from 9 to 20 March 2015 in order to evaluate the official controls related to production and storage of milk and milk products, and the follow-up action taken by the competent authorities (CAs) in response to the relevant recommendations made in the previous audit reports.

Three Regions (Abruzzo, Puglia and Piemonte) were visited. Official controls are carried out frequently according to control plans, are risk based and well documented. However, the establishment reports contain very little relevant information and many deficiencies are overlooked. In addition, there is very little effective follow-up. Communication within local CA units remains poor. In the eight establishments visited, among the deficiencies found by the Food and Veterinary Office audit team, only a few had been identified and documented by the CA.

Audits (Article 4.6 of Regulation (EC) No 882/2004) are carried out by central and Regional levels. The reports of these audits contain findings on non-compliances and systemic problems. Of the seven establishments visited (milk collection centre not included) in three Regions (six provinces) from the point of view of structure, maintenance, equipment, cleanliness and hygiene of operations, – four were satisfactory (with different levels of remarks and deficiencies) and three were unsatisfactory. There was no immediate public health risk. Serious deficiencies in official controls were observed on dairy holdings visited.

Raw milk quality standards (Section IX Annex III to Regulation (EC) No 853/2004): National derogations notified to the Commission for 2008 -2013 for all milk are still in place for sheep and goat milk. Food business operators (FBOs) take samples but these are not always analysed and laboratory performance is not always reliable. The CAs are not always notified of non-compliant results and there is no system in place to ensure notification – CA does take action when informed. There is no national system for official monitoring of FBO own checks related to raw milk parameters.

Residues: There were procedures in place for inhibitor controls in all establishments visited. However, out-of-date kits were in use in three establishments. The requirement to maintain records of treatment with veterinary medicines on milk production holdings is not enforced.

A number of recommendations have been made to the CA with a view of addressing the deficiencies identified during this audit. At least five of these or very similar recommendations have already been made in the Audit Report DG(SANCO)2010-8502, 2012-6333 and 2013-6875 but have not been properly addressed or implemented.

FVO report – India – Contaminants and residues

This report describes the outcome of a Food and Veterinary Office (FVO) audit in India, carried out from 3 to 14 March 2014, as part of the published programme of FVO audits.

The objective of the audit was to evaluate the performance of competent authorities and other officially authorised entities in their implementation of official controls concerning residues and contaminants in live animals and animal products, in order to assess whether these controls offer adequate assurance that the products and animals concerned, eligible for export to the European Union (EU) do not contain residues of veterinary medicinal products, pesticides and contaminants at concentrations in excess of EU maximum limits. Since the authorisation, distribution and use of veterinary medicinal products and feed additives have an impact on the monitoring of residues, the national rules governing the control systems in these areas were also part of the audit. In addition, attention was paid to examining the implementation of corrective actions promised in response to recommendations made in the report of the previous FVO residues audit in India (DG(SANCO)/2011/8861 MR-Final) in May 2011.

Overall, it is concluded that guarantees provided by the residue control system for aquaculture products in India are, with some exceptions, broadly equivalent to those foreseen by EU legislation. The residue monitoring plan is implemented in accordance with planned arrangements and in line with EU rules and meets minimum requirements laid down in EU legislation (for testing of aquaculture shrimp but not finfish). However a relatively narrow range of substances is tested for and no account is taken of the range of substances actually used in fish and shrimp production in the country. As such, guarantees on the residues status of aquaculture products rely to a large extent on the additional pre-harvest and pre-export testing programmes in place and these mitigate to a certain extent the long-standing deficiencies in official controls on farms, and in particular, an almost total absence of official controls on the use of veterinary medicinal products. Nevertheless, the relatively narrow range of substances tested for in those additional programmes also weakens the reliability of those guarantees. With regard to the follow-up of non-compliant results, some improvements have been noted relative to 2011 (for example progress made on the registration of farms), nevertheless, it remains the case that follow-up at primary producer level to identify the root cause of the non compliance is ‘delegated’ almost fully to export establishments which is not in line with EU requirements.

Concerning laboratories, improvements in performance have been noted relative to 2011, though certain deficiencies in quality control and ensuring the analytical integrity of samples have the potential to undermine the effectiveness of the residue monitoring plan.

With regard to veterinary medicinal products, the system for authorisation of, and controls on veterinary medicinal products is deficient in many respects compared to the EU system. Improvements have been made relative to 2011 (introduction of labelling legislation) however, the many non-compliances identified by the audit team in this respect and overall poor awareness and enforcement of the legislation collectively weaken the effectiveness of the residue control system.