Title: Overview new Regulations and preparation of the implementation of the hyg' packageimpact and forseen
1Overview new Regulations and preparation of the
implementation of the hyg. package-impact and
forseen actions-experiences in the Netherlands
- Ate Jelsma
- Food and Consumer Product Safety Authority
- Directorate of Inspection
- The Netherlands
2Subjects presentation
- Overview of hygiene and feed to food regulations
- Impact hygiene package general and detail
- Approval/registration
- Forseen actions
3Food safety legislation
- General Food law Regulation 178/2002
- H 1 - hygiene of foodstuffs Regulation 852/2004
- H 2 - hygiene rules for food of animal origin
Regulation 853/2004 - H 3 - official controls (meat inspection)
Regulation 854/2004 - H 4 2002/99/EC (animal health)
- H 5 - repealing 17 directives
- Official Feed Food Controls Regulation
882/2004
4General Food Law
- Regulation 178/2002
- general principles (definitions)
- risk analysis
- responsibility
- traceability
- EFSA
5Characteristics of Hygiene 1
- ? all food (replaces 93/43/EEC)
- ? stable to table (integrated approach GFP)
- all stages of production, processing,
distribution, exports - primary responsibility food business operator
6Characteristics of Hygiene 2
- ? food of animal origin red and white meat,
farmed and wild game, MSM, meat products, live
bivalve molluscs, fishery products, raw milk
dairy products, eggs ( products), frogs legs,
snails, rendered animal fat greaves, treated
stomachs, bladders intestines, gelatine,
collagen - ? not for direct sale to consumer (retail)
7Characteristics of Hygiene 3
- food chain information
- quantitative assessment of risks determining the
ante-mortem and p.m. examination - food business operator is responsible
- verification by competent authority
8Tasks for the CA veterinarian
- primary production information
- ante-mortem inspection (can be on the farm)
- animal welfare aspects
- post-mortem inspection
- canalization of destruction material
- interpretation of lab results
- feedback of inspection results
- audits and inspections
9Official feed and food controls Regulation (EC)
No 882/2004 and scope
- Controls verification of compliance with
- feed law
- food law
- rules on animal health, animal welfare and
certain aspects of plant health
10Official controls
- On a regular basis and with a frequency based on
risk - Without prior warning (as a general rule)
- At any stage of production, processing and
distribution - Including imports/exports
11Operational criteria
- Official controls must be effective
- Adequate laboratory capacity
- Adequate facilities and equipment continuous
training of sraff - Legal powers
- Verification procedures
- Documented procedures and transparancy
- Internal audits
- Reports
- Delegation of control tasks
12Feed and food controls
- fees (flexibility)
- community controls (FVO)
- in MS
- in third countries
- multi-annual national control plans
- annual reports
13Implementing measures
- Trichinella testing reference method
- ? not any longer trichinoscopic method (except)
- ? derogations
- slaughter pigs kept under specified conditions
- EFSA report end 2005
- registration of Trichinella free holdings
- but testing of horses, wild boar, breeding pigs,
organic pigs - Antimicrobial treatment and HACCP
- Transitional arrangements
14Implementing measures FCI
- contact details (farm, vet.)? identification
details ? management data ? animal health
status ? treatments ? additional information
(disease free farm, slaughter findings, disease
monitoring, etc.) - Transitional arrangements 24 hours one more
species other than poultry
15Current microbiological criteria
- 10-15 years old
- Laid down at different times and in different
Directives and Decisions - Cover only food of animal origin
- Inconsistencies between types of foods
- Not based on risk assessment
- Not based on internationally approved principles
- Need for review in the context of the recast of
food hygiene legislation
16Draft Commission Regulation on microbiological
crieria for foodstuffs
- SANCO document 4198/2001, revision 15
- Ongoing discussions
- salmonella criteria for minced meat
17Two types of MC
- Food safety criteria
- Defines the acceptability of the product/batch
- Applicable to products placed on the market
- Action withdrawl
- Process hygiene criteria
- Indicates the acceptable functioning of the
production process - Applicable during the process, not to products
placed on the market - Action improvement of production hygiene,
selection of raw materials
18Impact hygiene package (general)
- Regulation (EC) No 852/2004 (hygiene of
foodstuffs) and - Regulation (EC) no 853/2004 (specific hygiene
rules for food of animal origin) - Responsibility of the industry
- Regulation (EC) no 854/2004 (specific rules for
the organisation of official controls on products
of animal origin intended for human consumption) - Responsibility of the government
19Impact hygiene package (general)
- Comparison old and new regulations start 2004
- What is the impact on the organisation/number of
staff/veterinary field? - What is the impact on the connection between
government and industry - What is the impact on the tasks in the future of
the veterinarians and their education level - Comparison is made also on detail level (articles
and chapters) - Conclusion
- important impact in separation of
responsibilities between government and industry - important impact in tasks and forseen education
level of veterinarians (auditing)
20Impact Regulation (EC) no. 852/2004 (H1)
- Introduction HACCP in all stages with for all
same principles, except primary production - Introduction system of national guides to good
practice on level of primary production - Live animals and also on level of products of
non-animal origin - Government shall stimulate the development and
use of guides with the HACCP principles for all
type of products (meat, fish, dairy, retail etc.) - Important task government and industry
21Forseen action for Regulation (EC) no. 852/2004
(H1)
- Discussion government and industry
- Central organised industry will make up-date of
existing hygiene codes with 7 HACCP principles - Central organised industry will make national
guides on level of primary production - Government gives official permission for using
hygiene codes and national guides, based on
advice of VWA - Some industry not organised or not common with
hygiene codes and national guides government
gives information (meetings, internet/seminar end
of 2005) but industry is responsible - Use of hygiene codes and national guides is not
obligatory, but not without engagement
22Impact Regulation (EC) no. 852/2004 (H1)
- Regulation (EC) no. 852/2004 (H1)
- For all establishments (registration and
approval) same general hygiene requirements and
conditions for infrastructure. - Norms are more open.
- Can give more discussion in veterinary field
between establishment and veterinarian
23Impact Regulation (EC) no. 853/2004 (H2)
- Regulation (EC) no. 853/2004 (H2)
- Approved establishments conditions are mentioned
for number of rooms - Depends on the process of the company
- Cool- and freezing storage house approval or
registration was discussion - Establishments for composite products approval
or registration was discussion - Slaughterhouses/cutting plants how far it is
necessary to give detailed approval (species
discussion) - Impact different knowledge necessary for
inspector for products of animal and non animal
origin
24Registration or approval
- Reg. no. 853/2004 article 4 Establishments
handling, preparing or producing products of
animal origin must be approved by the competent
authority. - The list of approved establishments are laid down
in Annex III of Regulation no. 853/2004.
25List of Annex III of regulation 853/2004
26Forseen actions for Regulation (EC) no. 852/2004
(H1) and Regulation (EC) no. 853/2004 (H2)
- Checklists used in veterinary field will be up
dated - Same checklist for slaughterhouse, fish or meat
products etc. and also retail - Difference will be in number of rooms in
veterinary field - Slaughterhouses
- Cutting plants
- Cool- and storage houses
- Meat products
- Meat preparations minced meat MSM
- Format is made for type of approval up to
industry to make up their decision - Ready on 1-7-2005
27Impact Regulation (EC) no. 852/2004 (H1) and
Regulation (EC) no 853/2004 (H2) and forseen
actions.
- Approval small capacity not exists anymore after
1-1-2006 - Approval under conditions possible (Regulation
882/2004) - Also primary production will be registrated
- Forseen action
- Separated department of registration and
approvals on central level - If possible connection with existing
registration system in field of primary
production
28Impact Regulation (EC) no. 852/2004 (H1) and
Regulation (EC) no 853/2004 (H2) and forseen
actions
- Approval under conditions two times period of
three months possible useful in the case of
HACCP - Re-approval
- Will be given in 2006 by regular check
- Small capacity plants on request new approval
for internal market till that time products stay
on national market
29Impact Regulation (EC) no. 853/2004 (H2)
- Decontamination of poultry meat
- Depends on document of implementing measures and
EFSA interesting but reservations - interests and reservations different from
political side and side of industry - Food chain information
- Still discussion between member states
- Netherlands government wants to introduce it in
other industry than poultry (H2) - Has connection with national guides to good
practice on level of primary production (H1) - Important change in task of veterinarian in meat
sector (H3)
30Relation between reg. no. 852/2004 (H1) and
853/2004 (H2)
- General Food Law (178/2002) definitions large
scale from primary production till consumer
traceability - H1 primary production and national guides to
good practice - H2 Food Chain information to slaughterhouses
- Part of HACCP
- H3 Audit by official veterinarian
31Impact Regulation (EC) no. 854/2004 (H3)
- Task description of official veterinarian
- Task of official veterinarian changing from
control to auditing - Education conditions for official veterinarians
and official assistants are mentioned - Important role for veterinarian in a.m. and p.m.
inspection in slaughterhouses - Based on risk analyse more flexibility in the
frequency of control level in cutting plants is
possible - Possibility for inspectors of the company for
p.m. inspection in poultry slaughterhouses - Pig industry possibility of visual p.m.
inspection - Projects on a risk based meat inspection is
possible -
32Forseen action on Regulation (EC) no. 854/2004
(H3)
- Task description of official veterinarian task
changing from control to auditing - Important for official veterinarians is to read
it - Education conditions for official veterinarians
- Changing of the education norms on university
level - Changing of the education for the new incoming
official veterinarians in the inspection unit
(VWA)
33Forseen action on Regulation (EC) no. 854/2004
(H3)
- More flexibility in the frequency of control
level in cutting plants is possible - Project to find out what is possible probably
conclusion implemented HACCP system can be basic
for a lower frequency of inspection in connection
with the performance of auditing - Possibility for inspectors of the company for
p.m. inspection in poultry slaughterhouses - Exists in the Netherlands
- Discussion on small establishments
- Project to find out what can be criteria for a
lower frequency of the official veterinarian
during the p.m. inspection in slaughterhouses,
while p.m inspection is done by official
assistant (1 month frequency) - A.m. inspection opinion in Netherlands always a
veterinarian (FCI, animal health, animal welfare)
34Forseen action on Regulation (EC) no. 854/2004
(H3)
- Emergency slaughterhouses
- Project to find out if separated slaughterhouses
for emergency slaughterhouse will stay probably
not also industry has to make up their mind. - Cool- and freeze storage houses
- More flexibility in the frequency of control in
cool- and freeze storage houses is possible
project in connection with cutting plants
35Impact
- General Food Law (Regulation 178/2002)
- Hygiene package (Regulations 852/2004 853/2004
and 854/2004) - Microbiological criteria for all products are
developed can be used for verification in HACCP
system - Connection between the different regulations
- Less differences between the different products
- More connection in the chain
36Forseen action for industry
- Explanation in different stages is done by the
government - Primary production level
- Different product level (meat, dairy, retail
etc.) - Industry can do suggestions now for example
format FCI - Industry has to inform the members or
establishments by their own channels!
37Forseen action in veterinary field by the
government
- Education for this moment for veterinarians
- Explanation of the hygiene package
- Explanation of their responsibility
- Training in auditing (end of 2005)
- Project to find out what will be the performance
of auditing in slaughterhouses/cutting
plants/cool- and freeze storage houses - Information with guidelines are set up.
- Information for industry on internet www.vwa.nl