Overview new Regulations and preparation of the implementation of the hyg' packageimpact and forseen

1
Overview 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

2
Subjects presentation

• Overview of hygiene and feed to food regulations
• Impact hygiene package general and detail
• Approval/registration
• Forseen actions

3
Food 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

4
General Food Law

• Regulation 178/2002
• general principles (definitions)
• risk analysis
• responsibility
• traceability
• EFSA

5
Characteristics 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

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Characteristics 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)

7
Characteristics 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

8
Tasks 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

9
Official 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

10
Official 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

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Operational 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

12
Feed and food controls

• fees (flexibility)
• community controls (FVO)
• in MS
• in third countries
• multi-annual national control plans
• annual reports

13
Implementing 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

14
Implementing 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

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Current 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

16
Draft Commission Regulation on microbiological
crieria for foodstuffs

• SANCO document 4198/2001, revision 15
• Ongoing discussions
• salmonella criteria for minced meat

17
Two 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

18
Impact 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

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Impact 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)

20
Impact 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

21
Forseen 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

22
Impact 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

23
Impact 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

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Registration 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.

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List of Annex III of regulation 853/2004
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Forseen 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

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Impact 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

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Impact 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

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Impact 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)

30
Relation 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

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Impact 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

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Forseen 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)

33
Forseen 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)
  

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Forseen 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

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Impact

• 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

36
Forseen 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!

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Forseen 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