Better Training for Safer Food Initiative

Transcription

1 Better Training for Safer Food Initiative OF/SI Outcome of the Prague workshop Ir. Christophe Keppens

2 Prague Workshop

3 Goal Not standard BTSF Open discussion on most important outstanding problems in the ABP OF/SI system FVO audits 10 most important OF/SI issues

4 Method 3 discussion groups Standard scenario: Presentation by moderator 1 key question Discussion Answer to key question Presentation outcome in general assembly by moderator Summary by the EU Commission

5 Future The EU Commission now has the opinion of EU member states officials (not the official MS opinion) Proposal by the EU Commission to Legislation FAQ Mandate to JRC...

6 What are OF/SI?

7 Organic fertilizer

8 What is a fertilizer A substance of which the nutrition of a plant is the primary function Organic (plant, animal origin) or mineral (rock/sediment or chemical synthesis) fertilizers Estimate that 30 to 50% of crop growth is due to commercial fertilisers

9 Fertilizers: what does a plant need? Primary nutrients N,P & K Most often limiting factor for growth Secondary nutrients Other essential macronutrient Na, S, Ca, Mg Trace elements Present in small quantities B, Co, Cu, Fe, Mn, Mo, Zn Absolutely vital Low dosage in soils (e.g. 20kg Zn/ha, 100g Mn/ha)

10 Availability of nutrients to plants Soil solution Clay-humus complex Organic material in soil

11 Types of organic fertilizers? Straight fertilizer N or P or K

12 Types of organic fertilizers? Straight fertilizer Compound fertilizer NPK subtypes Complex fertilizer Blended fertilizer

13 Types of organic fertilizers? Compound complex fertilizers: each kernel contains the labeled content of NPK, secondary & trace elements NPK NPK NPK NPK NPK NPK NPK NPK

14 Types of organic fertilizers? Compound blended fertilizers: Bulk blending Not each kernel contains the labeled nutrients NP NK K N NPK Ca PK Mg P

15 Examples Blood meal = fast available N Bone meal = slow release of P and N (helps composting process) Horn meal = slow release of N

16 Soil improvers

17 What is a soil improver Material added to the soil with the primary function to improve the physical and/or chemical and/or biological properties of the soil Reference values: OF = 100kg/ha, SI= 10 ton/ha

18 What is a soil improver Organic SI Physical SI Supply organic matter Micro-organismen Improves soil structure Depending on nature product Humus (NPK, Ca, Mg) Water absorption Soil structure Water infiltration Water retention Aeration Compaction

19 Dangers of OF/SI with ABP?

20 Possible dangers Bypass of the feedban Spread of animal diseases Spread of antibiotic resistance Contaminants in environment...

21 The OF/SI control systrem

22 Q8 Non exhaustive overview of OF/SI control system Danger /// Stage OF/SI chain Raw materials No Cat 1 BSE (Breach feedban) Animal diseases Contaminants in environment Supporting measures for control No cat 1 Article 48 Processing Manufacturing OF/SI Use on land Separation of non ABP OF/SI Add Mixing component Label 21 days 21 days waiting period Processing standards MB criteria MB criteria Q3 Q1 Q2 Q6 Q5 Q4 Approval Traceability Article 48 Approval Traceability Registration Register Q9 Q7 Q10

23 The 10 Prague issues

24 Q1: Must the mixing component (MC) exclude or avoid feeding?

25 Wording of Legal Basis What must be mixed? (art & AN XI, chpii) OF/SI which consist of or which have been produced from: MBM cat 2 to be used in OF/SI PAP to be used in OF/SI Goal To exclude the subsequent use of the mixture for feeding

26 Situation in MS No MS found MC that made OF/SI unpalatable UK coloured wood shavings, PL quicklime, some MS sludge wastewater or default products BE option was bitrex (not suitable) In 3 MS visited by FVO no component Only use the derogated OF/SI (<50kg or max 100kg bigbags) (so no MC must be mixed and real bulk is not possible)

27 Next step JRC will look for suitable MC Q: Can we settle for avoiding of or do we need exclusion for feed purposes? A: MC must exclude feeding for at least ruminants under normal conditions.

28 Q2: If the JRC could identify an effective, inexpensive and non-interfering MC, do we still need the derogations?

29 Wording of Legal Basis MC not needed for: (AN XI, chpii) OF/SI in ready -to-sell packages < 50kg for use final consumer OF/SI in big bags < 1000kg (then special labelling) Assessment big bags Risk likelihood of a potential diversion to farms keeping animals or to land to which farmed animals have access

30 Situation in MS 50kg packages go to farms (including keeping animals) Some MS do not use derogation 50kg (legal possible?)

31 Next step JRC will look for suitable MC Q: If perfect MC why would we need derogations? A: there is no need for derogations all products should be mixed

32 Q3: Do products derived from ABP other than MBM & PAP used as an OF/SI need to be mixed (made unpalatable) or marked (identified)?

33 Legal Text Reg 1069/2009 art 32 says: cat2 MBM and PAP intended for OF/SI must be mixed with a component to exclude subsequent use for feeding Reg 142/2011 annex X says: OF/SI shall be produced by applying any of the processing methods 1 to 7 when category 3 material is used as starting material which is not used for the production of PAP

34 Problem Outlined There is a requirement to mix cat 2 MBM and PAP with a component because there is a risk that otherwise the OFSI maybe used for feeding However, there is no requirement that other ABPs which when processed do not produce PAP should be mixed. Is there then a risk that such processed material could be inadvertently used for feeding?

35 Next Steps Q: Can we identify which processed ABPs might be used and the risks they present if they are not mixed? A: an assessment on which other derived products must be mixed must be done

36 Q4: Do we need to register farms actually using OF/SI, compost, digestate or manure or can we register them by default?

37 Wording of Legal Basis Art With a view to registration, operators shall before commencing operations, notify the competent authority of any establishments or plants under their control which are active at the use of animal by-products and derived products

38 Situation in MS In several MS deficiencies: traders, transporters & users Traders not well known Problems with commercial document (trader does not want the client to know supplier) Users include, beside farmers, also recreational users and also for derogated OF/SI (no MC), compost, manure & biogas residues Some MS say pointless: all farmers, up-to-date list?

39 Next Step Q: can one register by default or must we need to (and can we) know the users who are at present using OF/SI? A: one should register the actual users. However the legislation should exempt certain operators (users and distribution)

40 Next Step Q: can one register by default or must we need to (and can we) know the users who are at present using OF/SI? A: one should register the actual users. However the legislation should exempt certain operators (users and distribution)

41 Q5: Is there room to relax traceability rules after the stage of production of OF/SI?

42 Legal Text Reg 1069/2009 art 21 says: operators consigning, transporting or receiving OFSI must keep records and use commercial documents (or in case of imports health certificates) to ensure traceability

43 Problem Outlined These traceability requirements apply throughout the chain from production, transport, storage, distribution and use by the final consumer no end point. Particular problems have been identified with use of CDs by intermediaries selling to farmers. Part of the problem is that intermediaries do not wish rendering plants to know identification of clients (farmers) to protect their commercial position

44 Next Steps Q:Is there room to relax traceability rules after the stage of production of OF/SI? A: there is no room for relaxation for operator not exempted under the proposal of Q4.

45 Q6 :Do microbiological criteria have sense for compound OF/SI before their placing on the market?

46 Legal requirements (Microbiology 1) Microbiological criteria for OFSI (final products prior to their placing on the market): For PAP or MBM from Cat. 2 or Cat. 3 material (by reference to feed material!): Salmonella: absence in 25 g: n = 5, c = 0, m = 0, M = 0 Enterobacteriaceae: n = 5, c = 2, m = 10, M = 300 in 1 g

47 Legal requirements (Microbiology 2) For compost and digestion residues during or immediately after transformation Escherichia coli or Enterococcaceae: n = 5, c = 1, m = 1 000, M = in 1 g on withdrawal from storage Salmonella: absence in 25 g: n = 5; c = 0; m = 0; M = 0

48 Problem outlined Different microbiological standards apply for different components which may be used and mixed into OF/SI No microbiological testing is required for some suggested mixing components (manure, slurry, etc.) which may be applied to land without any treatment

49 Next steps Q:Would it be appropriate to require microbiological criteria only for certain components before mixing? What microbiological standards should be applied for components used in OF/SI? A: The legislation needs harmonisation on the materials & stage where MB criteria apply

50 Q7: Do we need to register retail establishments, since these establishments sell mostly to private persons and have almost no legal requirements to follow?

51 Legal Text Legal requirement to register all OFSI operators under art 23 of 1069/2009 In addition under art 24 storage of OF/SI (except at place of application) requires approval No exceptions under above Articles or Article 20 of 142/2011 for registration of retail establishments

52 Problem Outlined No end point in chain for handling OF/SI. Therefore currently a requirement for retail establishments selling OF/SI to private consumers to be registered Also a requirement where OFSI stored in the retail chain for approval. This seems disproportionate given the risk. Unlikely that once OF/SI in retail chain that it will be diverted or used by farmers where livestock might gain access

53 Next Steps Q: Do we need to register retail establishments? A: Exclusion of some operators by finetuning legislation or guidance document

54 Q8 : Will we alter the definition of OF/SI in order to exclude growing media like potting soil?

55 Legal text Definition OF/SI (Reg. 1069/2009): materials of animal origin used to maintain or improve plant nutrition and the physical and chemical properties and biological activities of soils, either separately or together; they may include manure, nonmineralised guano, digestive tract content, compost and digestion residues no exclusion of any substance improving plant nutrition

56 Problem outlined Growing media are specific substrates produced for use in horticulture, greenhouse culture, house plants, etc. Risk of diversion into feed seems very limited By current definition of OFSI, there is no exclusion of any substance improving plant nutrition -> all requirements would apply!

57 Next steps Q: Should growing media be regarded as OF/SI? A: finetuning of legislation in order to reduce controls after certain production point of growing media and potting soil.

58 Q9: Is art 48 applicable to OF/SI containing MBM or PAP (only one of the ingredients)?

59 Wording of Legal Basis Art Talks of Category 1 material, Category 2 material and meatand-bone meal or animal fat derived from Category 1 and Category 2 materials and Processed animal proteins.

60 Situation in MS MS divided if the wording also includes products containing the mentioned products So hinders intracommunity trade for operators

61 Next Step Q: Do we read art. 48 in the strict sense of the wording or not? A: No agreement: clarification in guidance document EU Commission viewpoint.

62 Q10: In order to always inform professional users, do the words indicating the 21 days waiting period need to be indicated on the CD?

63 Wording of Legal Basis AN VIII, chpt II Label on packaging, container or vehicle: Category Organic fertilizers of soil improvers/ no grazing of farmed animals or use of crops as herbage during at least 21 days following application Not for 50kg packages, 100kg big bags (must indicate not destined for application to land to which farmed animals have access)

64 Situation in MS Legislation is followed but seems inconsistent with goal No message to farmer if bulk (CD is only thing remaining) No message if 50 kg Different message if 100kg big bags

65 Next Step Q: Do we need to inform and if so how to inform all potential users and with which message? A: Farmers must receive information either by label or commercial document

66 Thank you for your attention Questions?