ASAGA- World Congress on Oils & Fats. Rosario AR- 4 th Nov 2015 JM Aspar

Transcription

1 ASAGA- World Congress on Oils & Fats Rosario AR- 4 th Nov 2015 JM Aspar 1

2 Agenda Agribusiness in the European Union. Quality, Sanitary and Sustainability considerations and rules for Grains, Oilseeds and products thereof. 2

3 Agenda. 1. Some quick definitions on Safety, Quality, security 2. Why is SAFETY so important for traders? 3. Are all traded products concerned? 4. How are we regulated in Europe?- EU Food Law 5. Follow up of EU regulatory changes by traders 6. Main Categories of Contaminants and Hazards 7. Main tools to detect, mitigate and prevent such risks 8. Monitoring and controls basics (sampling, testing, recordings) 9. Training, Claim and Crisis management and communications 10. Focus on some Quality & Safety issues of Argentinian goods 11. The new EU GMO debate and potential impacts 12. Sustainable Food & Feed: the new European Credo? 13. More infos on EU Food & Feed Safety rules 14. Some questions or doubts? 3

4 1- Some Quick definitions on Safety, Quality, Security It is important to use the correct words when we speak about Quality and Safety. As a general understanding we could say that: QUALITY for a product means that it is suit for the purpose for which it is traded. It implies that the product delivered fulfills the contractual and expected specifications. it should also be Sound, Fair/Legal and Merchantable which implies that it also complies with normal applicable norms for its intended uses. Most often, quality deviations can be solved by commonly agreed financial discount or premiums SAFETY for a product is a relative notion that implies that it would not cause harmful impact on the health of human, animal or to the environment when properly used, handled and stored nor causes diseases, hazards, injury or toxicity and that the product complies with official norms on contaminants or undesirable substances. A non SAFETY compliance would most often imply a rejection of the cargo by authorities, a downgrading/deviation in intended uses (from FOOD to FEED or to Industrial grade) or its destruction. 4

5 1- Some Quick definitions on Safety, Quality, security we can also mention also important definitions for other terms such as SECURITY or SUSTAINABILITY SECURITY: In our FOOD and FEED operations, the word SECURITY is more linked to the guarantee of obtaining the needed quantities of Safe products, at the good time and with expected Quality and price. SUSTAINABILITY: The most common definition for a sustainable product is that its production, processing and handling have been done in a balance respect of 3 main pillars: Environmental, Social and Economical. In addition, for some specific products such as Biofuels in the EU, a certification for some Sustainability and GHG criteria's is needed SHE is not addressed in this presentation 5

6 2- Why is SAFETY so important? Ensuring the Safety of traded products means that the goods we purchase and sell need to be safe for Humans, for Animals or for the Environment and that their intended uses will not cause any harm or diseases or any such kind of equivalent impacts. A food or feed safety problem can have huge impacts for an operator : Financial impact Image Impacts Marketing impact Legal impacts (if intentional can be considered as a fraud or even criminal). Reputational impacts Internal impacts: on company s Employees. 6

7 3- Are all traded products concerned? Most traded products and operations implies that goods are SLM (Sound, Fair/Legal and Merchantable) and even if we try to only source safe products from reliable suppliers, the operational steps under our control/responsibility can also contaminate the products and add some unexpected hazards to the cargo during transport/handling/storage operations. We have responsibilities towards our customers, our suppliers, the market, the authorities, the environment, our shareholders and other partners Most traded products are concerned by Safety aspects The supply chain steps in which a trader is engaged do imply risk of occurrence of safety hazards. 7

8 3- Are all traded products concerned? Some non exhaustive examples of accidents the occur regularly in grains and oilseeds sectors: Aflatoxine crisis in maize or other mycotoxins or harmful botanical impurities in Cereals Aflatoxins or moulds or not authorized GMOs in Rice Salmonella or Dioxins or Heavy metals or foreign bodies in Oilseeds or oilseed meals Non EU authorized GMOs in meals or oil seeds or in maize Dioxins or PAH /BaP or fraud (mineral oil) or PPP residues in VegOils PPP/ or storage pesticides residues in cereals, oilseeds or meals Sea wreckage and marine pollution or spillage of live GMO into the environment from chartered transport units 8

9 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Sets the general principles and requirements of food law, Etablisses the European Food Safety Authority, the RASFF and Lays down procedures in matters of food safety Based on Treaty establishing the European Community, and in particular Articles 37, 95, 133 and Article 152(4)(b The free movement of safe and wholesome food is an essential aspect of the internal market The Community has chosen a high level of health protection as appropriate in the development of food law, which it applies in a non-discriminatory manner whether food or feed is traded on the internal market or internationally. to ensure the safety of food, it is necessary to consider all aspects of the food production chain as a continuum from and including primary production and the production of animal feed up to and including sale or supply of food to the consumer because each element may have a potential impact on food safety food and feed exported or re- exported from the Community complies with Community law or the requirements set up by the importing country. 9

10 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Some quick definitions: Risk means a function of the probability of an adverse health effect and the severity of that effect, consequential to a hazard Risk analysis means a process consisting of three interconnected components: risk assessment, risk management and risk communication; Hazard means a biological, chemical or physical agent in, or condition of, food or feed with the potential to cause an adverse health effect; Traceability means the ability to trace and follow a food, feed, foodproducing animal or substance intended to be, or expected to be incorporated into a food or feed, through all stages of production, processing and distribution; stages of production, processing and distribution means any stage, including import, from and including the primary production of a food, up to and including its storage, transport, sale or supply to the final consumer and, where relevant, the importation, production, manufacture, storage, transport, distribution, sale and supply of feed; 10

11 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Which steps of the supply chain are concerned: EU Food law applies to all stages of production, handling, transport, processing and distribution of food and feed. It shall not apply to primary production for private domestic use Who is concerned: Any FBO: food business operator means any undertaking, whether for profit or not and whether public or private, carrying out any of the activities related to any stage of production, processing and distribution of food (same applies for FEED) including any producer producing, processing or storing feed for feeding to animals on his own holding; 11

12 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Article 5: General Objectives : Insure high level of protection of human life and health and the protection of consumers' interests, including fair practices in food trade, taking account of, where appropriate, the protection of animal health and welfare, plant health and the environment. Ensure free movement in the Community of food and feed Article 6:, food law shall be based on risk analysis Article 7: Principle of Precaution as a basis Article 8: protection of Consumer s Interest vs. fraud, adulteration of food and other misleading practices Articles 10 &11: Public transparency and Information Article 11: Food and Feed imported into EU or exported from EU and marketed in EU to comply with EU Food law basic requirements 12

13 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Article 14: Food safety requirements : Food shall not be placed on the market if it is unsafe, i.e (a) injurious to health and/or (b) unfit for human consumption. Article 15: FEED safety requirements Feed shall not be placed on the market or fed to any food- producing animal if it is unsafe. (Unsafe feed= have an adverse effect on human or animal health and/or make the food derived from food-producing animals unsafe for human consumption) Conformity of a food or feed with specific provisions applicable to that food or feed shall not bar the competent authorities from taking appropriate measures to impose restrictions on it being placed on the market or to require its withdrawal from the market where there are reasons to suspect that, despite such conformity, the product is unsafe 13

14 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Article 17: RESPONSIBILITIES of Food and FEED operators. A general obligation of results MS to enforce food law, and monitor and verify that the relevant requirements of food law are fulfilled by food and feed business operators at all stages of production, processing and distribution. MS to maintain a system of official controls Consequences: Member States shall also lay down the rules on measures and penalties applicable to infringements of food and feed law. The measures and penalties provided for shall be effective, proportionate and dissuasive. 14

15 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Article 18: TRACEABILITY To be established at all stages of production, processing and distribution. Food and feed business operators shall be able to identify any person from whom they have been supplied OR to which their products have been supplied IT Systems: to be in place and efficient Labeling and Identification obligations For some products, specific additional labeling indications may be compulsory. 15

16 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Article 19 : RESPONSIBILITY for FOOD business Operators If a food /feed business operator considers or has reason to believe that a food which it has imported, produced, processed, manufactured or distributed is not in compliance with the food safety requirements, it shall immediately initiate procedures to withdraw the food in question from the market where the food has left the immediate control of that initial food business operator and inform the competent authorities thereof. Where the product may have reached the consumer, the operator shall effectively and accurately inform the consumers of the reason for its withdrawal, and if necessary, recall from consumers products already supplied to them when other measures are not sufficient to achieve a high level of health protection Principle of Precaution: A food business operator shall immediately inform the competent authorities if it considers or has reason to believe that a food which it has placed on the market may be injurious to human health. 16

17 4- How are we regulated in Europe?- Basic EU Food Hygiene Regulation Nr 178/2002 Article 20: RESPONSIBILITY for FEED business Operators If a feed business operator considers or has reason to believe that a feed which it has imported, produced, processed, manufactured or distributed does not satisfy the feed safety requirements, it shall immediately initiate procedures to withdraw the feed in question from the market and inform the competent authorities thereof. Where the batch, lot or consignment does not satisfy the feed safety requirement, that feed shall be destroyed, unless the competent authority is satisfied otherwise. Users of the feed to be duly informed for its withdrawal, with, if needed, product recall when other measures are not sufficient to achieve a high level of health protection. Principle of Precaution: A food business operator shall immediately inform the competent authorities if it considers or has reason to believe that a feed which it has placed on the market may not satisfy the feed safety requirement. FBO to collaborate with the competent authorities on action taken in order to avoid risks posed by a feed which they supply or have supplied. 17

18 5- Follow up of EU regulatory changes by EU traders and 1 st processors on Safety issues In order to better understand, monitor, and if possible influence legislation in Europe, main EU traders and processors are active in working groups or management level in various organizations at National or Brussels's base level such as, for our grains and oilseeds activities: COCERAL: The EU Grains, Oilseeds and co-products trader s association (members are national organizations) FEDIOL Bruxelles. The EU based oilseeds crush associations SYNACOMEX France (French grains and oilseed and oil meals traders) And our local national entities are also actively participating to the working groups of national equivalents trade and 1 st processing associations We are also active in organization such as GAFTA, FOSFA in Europe and same applies in the rest of the world And in close contacts with other organizations of our food or feed supply chains, from farmers to first processors and feed industries, such as FEFAC, AAF, EUROPABIO, EFM, COPA-COGECA, EBB, FDE, etc.. 18

19 5- Follow up of EU regulatory changes by EU traders and 1 st processors on Safety issues Our main activities in these organizations are to: Share with our pairs expertise, experience and knowledge Promote best practices Discuss with national or European authorities, via the associations, on the preparation, modification or implementation of the legislation, at national or European level, using a neutral sectorial hat! Organize crisis management and sectorial workshops Collect data's on contaminants Communicate on the sector s specificities with the authorities Join forces to give more political strength to our Supply Chain Coalitions towards the EU Commission, Parliament and Council 19

20 6- Main Categories of Contaminants and Hazards for our traded products The SAFETY hazards that can effect the products traded / imported in the EU can be classified in the following main (non exhaustive) categories, often linked to their origins, linked to the environment in which products are grown, stored, processed, transported and to the human activities involved These hazards can be pathogenic and/or toxic or be indicators of bad hygienic practices or resulting from cross-contamination or fraudulent practices or adulteration Physical hazards Chemical hazards (micro) biological, microbial Radiological In some case, the presence of some «hazards» may not represent a direct risk for health but be linked to non compliance with existing rules (i.e non EU approved GMO, wrong labeling or allergens) but may need to be managed under same procedures 20

21 6- Main Categories of Contaminants and Hazards for LDC traded products Each kind of hazards has its own kind of origin/cause and toxicity effects (immediate or cumulative) or health impact, which will request specific categorization, sampling method (homogeneous distribution or not), severity, frequency and detectability Agriculture products safety status is also strongly influenced by climate during growth and cultivation and storage steps which can deeply affect the hazards levels of batch. A specific risk assessment needs therefore to be applied to each product/hazard in order to best target the monitoring an control actions aiming at removing the risk or bring it down to an acceptable level IMPORTANT: EU legislation does not authorize «dilution» practices on goods that are considered as non compliant! 21

22 7- Main tools to detect, mitigate and prevent such risks There are various combined means of reducing our exposure to such risks Have a updated and deep knowledge of existing legislation Assessing the main risks Sourcing from «safe» areas, reliable registered customers and service providers («insured sources»), if possible certified under recognized Quality and Safety Insurance schemes (such as Coceral GTP-Code, GMP+, GMP of Ovocom, EFISC, Q&S, ISO22000-PAS, etc..) Implementing and promoting Good Trading, Good production and Good Manufacturing Practices Training and educating our employees and partners (including farmers if possible) Correct implementation of HACCP principles Implement Good Housekeeping/cleaning practices in stores and handling equipment's as a pre-requisite 22

23 7- Main tools to detect, mitigate and prevent such risks Implement serious monitoring plans for contaminants detection, based on recognized norms, standards and certification/ accreditations rules for sampling and testing Apply efficient control and cleaning rules on transport means to avoid cross contamination with previous cargoes (=> sistematic LCI issuance and adequate hold cleaning procedures prior to loading a vessel) Organize efficient database management Implement adequate reporting and communication tools Check traceability tools with regulars testings for recalls or withdrawals Cooperation and dialogue with control authorities Systematical follow up of all quality and safety claims Implement efficient traceability and labeling tools 23

24 7- Main tools to detect, mitigate and prevent such risks A legal obligation for European Food & Feed operators to have internal Quality Control systems based on Codex s HACCP principles (Hazard Analysis and Critical Control Point) The HACCP Principles procedure is the basis for any serious FOOD and FEED Risk analysis and the EU Hygiene legislation requires by law any EU Food and Feed chain operator to: Be registered with its local authorities Implement internally a QUALITY CONTROL System based on HACCP Principles Implement internally a full traceability system (one step up and one step down) 24

25 8- Monitoring and control basics: Sampling and testing/analysis Monitoring for contaminants means also that depending on each identified hazards, specifics and applicable procedures of sampling and testing need to be implemented Determine the hazard distribution in product and its detectability /frequent or not, homogeneously distributed or not) Use sampling method (adapted to the concerned hazard and intended use, to the size and kind of cargo, enabling to extract a representative sample of the cargo Send the appropriate sample qties and instructions to accredited labs (if possible under ISO 17025) for performing analysis as per official or standardized methods keep remaining samples for sufficient time in case of problems Request labs to indicate in the certificate the accreditation details and norms uses, measurement uncertainty and recovery factors for testing validations Keep all records for a minimum of 3 to 5 years In case of positive testing, apply appropriate procedures 25

26 9- Training, Communications, Claim and Crisis management Internal training of employees is of upmost importance to mitigate Educating suppliers and service providers on Safety issues helps in reducing risks Claim management is a must, with records and follow-up Internal and external Communication in case of safety incident or crisis is a very important and sensitive issue Have Crisis management procedures ready (and tested regularly) 26

27 10- Focus on some Quality & Safety issues of Argentinian goods Latest RASFF alerts on Argentina Origin Products: Mainly Salmonella, PPP residues and mycotoxins SALMONELLA in Oilseed meals: a rising risk for EU importers after the ban of formaldehyde and development of Multi antibiotic resistant traits: the sector needs to strengthen good manufacturing and storing/handling practices PESTICIDES Residues: a growing concern on Storage Insecticides (less active substances) and lower MRLs due to implementation of EU Endocrine Disruptor rules. Need for better legislation mirroring and stricter controls on correct implementation of law by Argentinian authorities as well as better farming and storage practices by producers via adequate education and communication GLYPHOSATE: a new potential threat if the substance is classified as carcinogenic by EU EFSA- A reduction of current MRLs could impact EU imports of crops making extensive use of this molecule 27

28 10- Focus on some Quality & Safety issues of Argentinian goods MYCOTOXINS: o Impact of EU Aflatoxine in Maize crisis: need more monitoring and implementation of better drying and storage practices DIOXINS-PCBs- PAH- B(a)P: o Highly mediatized Crisis in the EU have triggered intense and expensive controls and complex implementation of the EU Feed catalog naming. A new version of the EU Feed Catalog is under discussion but not finalized so far. Meanwhile Reg EU 2015/1905 published 22/10/2015 has simplified Annex II to Reg 183/2005 for the Dioxins testing of Oils and fats for feed uses which should remove the current systematic Dioxins testing required on imported Meal feed o Need to implement better drying practices and use of safe «fuels» to reduce such risks CONCLUSIONS: o It is Important to adopt and implement more adequate Safety management schemes such as GTP Code, EFISC, GMP+ or other recognized valuable certified insurance schemes 28

29 11- The new EU GMO debate and potential impacts EU GMO Opt-out proposal for uses of GM Food and FEED o rejected by EU Parliament on Oct 28th but battle not finished Cultivation of GM Crops in the EU o EU members states will massively uses the possibility granted by EU Directive No 2015/412 to prohibit the cultivation of GM crops on their territory or regions Approval of new GM events o Need to continue timing approval of new GM events as nothing moving since April 2015 Situation of Argentine : o potential risk on Soy Enlist (DAS-44406) or Optimum GAT Maize (DP ) and for some stacked events crops not fully approved by EU Biotech Companies Royalties/ Local Patent issues on some GM crops needs also to be solved quickly 29

30 12- Sustainable Food & Feed: the new European Credo 2009: EU RED Directive for Biofuels: Compulsory certification of biomass and biofuels + traceability, mass Balance management and GHG calculation 2015: New Directive EU 2015/1513 amending RED: mandate capping, ILUC factors, more Stringent GHG reduction levels, more certification criteria s and request to 3rd countries to supply regional GHG emission values at cultivation level an opportunity for Argentina? A growing debate for «Clean and Sustainable Supply chains» related to deforestation, protection of HCV and HCS Lands, protection of local community, labor issues with aggressive Civil Society Campaigns targeting the food sector with valuable brands and going down to the EU feed sector SOY becomes a «high reputational risk ingredient»! Many certifications schemes, mostly multi-stakeholders based popping up (RTRS, RSPO, Pro-Terra, ISCC+), pushed by Northern Europe customers 30

31 12- Sustainable Food & Feed: the new European Credo FEFAC, the EU Compound Feed Association, promotes a market push approach via its recently published Soy Sourcing Guidelines, a professional recommendation aiming at harmonizing the existing schemes via a benchmark tool managed by ITC Geneva FEFAC guidelines are based on 6 principles + various criteria s related to Environmental responsibility, legal compliance, GAP, responsible Working conditions, protection of land rights and community relations, verification processes and adequate traceability tools and continuous improvement Implementing such principles and criteria s in the Argentinian SOY supply chain via good practices and pragmatic verification process, from Farmers to Exporters become a pre-requisite for any export to Europe. A quick move is needed and a sectorial approach is needed in order to facilitate a quick and efficient implementation and capture these new market opportunities Carbon Footprint and measures of GHG emissions with adequate LCA will be the next steps 31

32 13-More info's on EU Food & Feed Safety rules? EU Commission DG Sante Website EU official Journal Some certification schemes DG SANTE Pesticides Database DG SANTE GMO Register Biosafety Ch: RASFF Website EU EFSA European Food Safety Agency Others websites 32

33 12- Some questions or doubts? Information on all aspects of : EU Hygiene Legislation on Food and Feed Safety issues and contaminants MRLs. On RASFF aspects On quality schemes. On monitoring results. On EU Feed and GMO Labeling rules. On GMO authorizations and labelling/testing rules On contaminants. On norms, sampling, testing On Sustainability Etc 33

34 12- Some questions or doubts? Please contact : Jean-Michel ASPAR jeanmichel.aspar@ldcom.com Phone : Mobil November 4 th