Two audits by the European Commission’s Health and Safety Authority have examined the microbial safety of food of non-animal origin (FNAO) in Estonia and the Netherlands.
The first remote audit by DG Sante in April 2021 in Estonia found that the official control system was effective but lacked flexibility and had problems tracking Listeria positives.
She covered before, during and after harvest of FNAO, including seeds and sprouts intended for germination. It was the first time that DG Sante dealt with controls of FNAO in Estonia. There are not many sprout producing companies in the country.
The Agriculture and Food Office, founded in January 2021, is responsible for the official controls along the supply chain in the audited companies. Certification according to private food safety systems is not common among entrepreneurs in Estonia.
The auditors said the process for assigning the risk level to operators was not flexible.
The minimum risk rating is given when production is less than 25 tons per year; from 26 to 300 tons is considered medium risk and over 300 tons high risk. However, there is no connection between quantities and product type. For example, a large sprout producer would rarely fall into the high risk category for production volumes, while arable farms such as cereals or potatoes, even with a relatively small number of hectares, would tend to be classified as the highest risk.
Some items can only be evaluated after the inspection, such as: B. the number of non-conformities and the assessment of the operator’s own checks by the inspector. However, the risk can and will be recalculated after an official inspection. Good Agricultural Practices and Good Manufacturing Practices applied by operators are not taken into account in the risk assessment to determine the frequency of official controls.
The audit team noted that despite the deficiencies identified at one sprout producer in 2020, the recalculated risk assessment concluded that it fell into the medium risk category based on production volume.
Processors have a monitoring plan in place to identify Listeria contamination. The system was effective in detecting contamination at the facility. However, corrective action after finding Listeria is not enough to ensure operators follow up on the contamination to ensure it does not recur.
After two processing plants were positive for Listeria, the monitoring plans were changed and the number of environmental samples for Listeria monocytogenes detection was increased from once a year to quarterly or twice a year. However, the Estonian guidelines state that if the result is positive, the frequency of analysis should be higher, e.g. B. once a week.
The 2021 plan included for the first time norovirus and hepatitis A virus in berries analyzed in an accredited laboratory in another country. Auditors said a lack of verification of the temperature of incoming official samples prevents labs from identifying flaws in temperature management that could affect the reliability of the results.
Dutch examination findings
The second remote audit in March 2021 in the Netherlands commended the training and knowledge of the employees but found problems with the primary production and the controls of the sprout producers.
The Netherlands is one of the main producers of fruit and vegetables in the EU and a top importer of seed for sprouting.
Factors such as farm or farm size and production volume have not been taken into account but will be part of a new risk analysis system. At the time of the audit, frozen berries and vegetables and pre-cut vegetables had the same inspection frequency as potatoes and other vegetables intended for consumption after cooking, and non-compliances were not used for the risk-based plan.
A project to determine compliance with microbiological criteria in fruit and vegetables in cutting plants was canceled in 2020 due to the COVID-19 pandemic.
For example, if a food company has a BRC or FSSC 22000 certified third party assurance system, the frequency of audits could be reduced, but this is not the case for primary production.
breeders and sprout producers
In primary production, controls are carried out by special projects focusing on pesticides. Each year a crop category is determined and a number of food companies are randomly selected for microbiological inspections. Regardless of the result, a different area will be chosen the following year and it is not clear when a category with a problematic result will be re-inspected.
A focus on chemicals means that non-compliance with microbiological requirements is less likely to be identified and problems identified do not affect future planning. This could result in the associated food safety risks being underestimated, weakening the system of official controls and the enforcement of EU legislation, say the auditors.
In response, the Dutch Food and Consumer Product Safety Authority (NVWA) said it was examining how to prioritize microbiological inspections at farm level. A food safety risk assessment of crops, including products intended for raw consumption, is to be published in 2022. It is used to improve monitoring and enforcement.
For 2021, the Dutch authorities planned inspections on the management of microbiological risks at primary production sites. Most aimed at the production of soft berries for consumption raw, some for products such as lettuce.
Deficiencies in checking compliance with import certificates and national rules on sampling frequencies of finished products, which do not comply with EU legislation, weaken controls of sprout producers and could lead to contaminated products being placed on the market. A special checklist for sprout producing companies has been available since 2021 to ensure inspectors see the actual import certificates.
The NVWA pledged to revise the national guideline in 2021 to remove the option for reduced sampling frequency and to notify sprout producers.
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