OVERVIEW OF THE RESULTS OF A SERIES OF MISSIONS CARRIED OUT DURING TO EVALUATE CONTROLS OVER PIG MEAT PRODUCTION IN MEMBER STATES

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1 EUROPEAN COMMISSION HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL Directorate F - Food and Veterinary Office Doc. No. DG(SANCO)/9005/2002 OVERVIEW OF THE RESULTS OF A SERIES OF MISSIONS CARRIED OUT DURING TO EVALUATE CONTROLS OVER PIG MEAT PRODUCTION IN MEMBER STATES 19/11/

2 1. EXECUTIVE SUMMARY INTRODUCTION MAIN FINDINGS Transposition of EU legislation National authority control systems Registration of farms, animal identification and movement of animals Certification and commercial documentation Official supervision of establishments Trichinellosis controls Traceability Hygiene of operations Operator-checks in establishments Animal welfare FOLLOW-UP TO INSPECTIONS RECOMMENDATIONS Member States ANNEX I RECORD OF MISSIONS UNDERTAKEN

3 1. EXECUTIVE SUMMARY The Food and Veterinary Office carried out a series of missions in Member States to evaluate controls over pigmeat production during It was noted that, at central level, Member States are aware of consumer concerns over food safety, and several have established food safety authorities in order to improve standards throughout the food chain. These initiatives are welcome, but are generally too recent to have had a major impact. Most of the Member States have sufficient resources to carry out the tasks assigned to them under the relevant EU legislation in this sector. Nevertheless in some Member States the number of official veterinarians and assistants was insufficient. Some concerns as to the independence and expertise of official personnel were raised. Shortfalls in the implementation and operation of effective, documented, supervisory systems over the performance of official personnel, and standards in establishments, were noted. Procedures for the approval of establishments, or for action where non-compliance with legislative requirements was noted, were not always respected. In some instances, establishments that did not meet these requirements had, nonetheless, been approved. Derogations from certain EU rules had been granted to establishments which did not meet the eligibility criteria. The situation in respect of ante and post mortem inspection was variable. Ante mortem inspection was generally carried out satisfactorily, although record keeping and examination of high risk animals was not always fully satisfactory. Significant failings in post mortem inspection were seen in most Member States, including shortfalls in record keeping. The uncertainty over the requirements for testing for the presence of trichinellosis in existing EU legislation was reflected in the situation in the Member States 1. This led to instances where pigmeat was not properly tested prior to its placing on the market. Traceability systems were in place in most Member States. Nevertheless the absence of fully effective traceability systems in others meant that effective action in the face of disease outbreaks or human health risks could be compromised. In a majority of Member States, hygiene conditions fell below an acceptable standard in too many of the establishments visited, with meat being exposed to contamination during processing and storage. Responsible national authorities need to be given sufficient legal powers and resources to implement the improvements that this series of missions has shown to be required. 1 The Commission is already addressing this point by drafting new legislation on the examination for Trichinella in products of animal origin. 3

4 2. INTRODUCTION The Food and Veterinary Office visited all the Member States during January April 1999 to review the beef production sector (slaughterhouses, cutting premises, cold stores). It found evidence of serious failings in the levels and performance of (official) veterinary supervision in premises, coupled with shortfalls in the performance of ante- and post-mortem inspection, and unacceptable hygiene standards. As part of the follow-up to these findings, a second programme of missions to all Member States was performed during February November 2001, in order to evaluate the situation regarding the production of pigmeat. An additional objective for these missions was to assess the checks carried out for the presence of Trichinella spiralis (a parasitic zoonosis, associated with the consumption of raw, or under-processed, pig (and, less often, horse meat). The completion of this series of missions was delayed by the impact of the foot and mouth disease outbreaks in four Member States during 2001, and shortages in the number of suitably qualified inspection personnel during this period. This report provides a summary of the situation found in individual Member States during this series of missions. The planning for these missions is given in Annex I. The individual reports are available on: 3. MAIN FINDINGS It should be emphasised that the deficiencies identified below were not necessarily present in all Member States or establishments visited, but they were sufficiently widespread to warrant concern Transposition of EU legislation In eight Member States, elements of EU legislation had either not been transposed, or had only been partly transposed. In many cases, however, these were relatively minor issues, relating to specific technical elements National authority control systems Structure of national authorities This varied significantly between Member States. Particularly, where regional authorities enjoyed considerable degrees of autonomy, lack of consistency in the implementation and enforcement of legislative provisions, and in the maintenance of harmonised standards, was detected. Several Member States had already established, or were in the process of establishing, food safety authorities, with varying tasks, responsibilities and status. Generally the authorities had been added to existing official control 4

5 structures, and given a general, overarching, responsibility for food safety issues, rather than actually replacing these structures. In some Member States, there was evidence of uncertainty and conflict as to the partition of responsibilities between the new authorities and existing government bodies Resources The number of veterinary staff available to carry out the obligations set out in EU legislation was generally satisfactory. However, in six Member States it was noted that the number of veterinary staff at different levels within the official control systems was such that difficulties were experienced in carrying out all their supervisory tasks Independence The ability of official veterinarians to act independently of commercial pressures was satisfactory, although some reservations were expressed in three Member States Training In general the knowledge and expertise of veterinary staff employed in fresh meat establishments was sufficient to allow them to undertake the full range of their duties. However, in two Member States the knowledge of some veterinary staff could have been improved, so as to ensure a more effective operation of official controls Supervision In ten Member States, there were insufficient controls over the performance of officials at establishment level. In particular, the frequency of checks carried out by regional/central staff was not always sufficient to allow effective monitoring of performance, or failed to follow up problems. In addition, a lack of uniformity in the implementation and enforcement of legislation was noted. In eight Member States effective guidelines and instructions were provided. However, in the other Member States, further attention was needed to this issue to promote a uniform and consistent approach to veterinary supervision. Records of official controls carried out in establishments in seven Member States did not always reflect the severity of the problems found during the FVO missions Registration of farms, animal identification and movement of animals In most Member States satisfactory systems were in place for the control of these issues. However, some operational failures were identified in a few Member States, including failures (in one Member State) to update list of registered holdings, inadequate identification of animals (in four Member States) and shortcomings in movement controls (in three Member States). 5

6 3.4. Certification and commercial documentation The requirement for official certification to accompany fresh meat in movements within and between Member States was largely revoked with the advent of the Single Market. However, in six Member States health certificates and/or commercial documentation was issued without the necessary supporting information being available Official supervision of establishments Approval of establishments Effective procedures for approving and monitoring establishments are in place in the Member States. However it was noted that, in nine Member States, establishments not fulfilling all EU requirements had been approved, or had retained approved status, even though significantly non-compliant. In four Member States the central authorities did not always check the standards used in granting approvals. In one Member State, non-compliant establishments were granted repeated "temporary approvals" (a concept not foreseen in EU legislation). Derogation from certain requirements of EU legislation can be granted to slaughterhouses with a throughput below a fixed maximum figure. In nearly all Member States this derogation was correctly applied. However, in two Member States, this derogation had been granted to establishments with higher throughputs, whilst one Member State did not have up-to-date listings of the establishments concerned Official supervision There were wide variations between Member States, and between individual establishments, in the effectiveness of official supervision. In several Member States, as indicated below, shortfalls in relation to specific areas were noted Ante-mortem inspection Ante-mortem inspection was generally carried out properly in all Member States. Nevertheless in three Member States, some animals slaughtered for human consumption might not have received this inspection. Shortfalls in the number of veterinarians employed in the meat sector meant that antemortem inspection was undertaken by auxiliaries in five Member States. In some cases, even high risk animals, eg. emergency slaughter, old or sick animals, were not targeted for inspection by a veterinarian. The correct maintenance of records of the performance and outcome of antemortem inspection results was seen in a majority of the Member States Post-mortem inspection Full compliance with these rules were noted in four Member States. 6

7 Shortfalls in existing post-mortem inspection requirements were noted in eleven Member States. These generally involved relatively minor downgrading of the required inspection, e.g. lymph nodes which should have been opened were only palpated, those which should have been palpated were only visually examined and those which should have been visually examined were ignored. In addition, the following more serious shortfalls were seen: - failures in the performance of post-mortem inspection, associated with inadequate veterinary supervision, insufficient numbers of qualified auxiliaries or the use of non-qualified auxiliaries, were seen in three Member States. - four Member States failed to keep records of the performance and outcome of post-mortem inspection results. - a failure to ensure correlation between carcases and offals on dressing lines was seen in three Member States Health marking There were inadequate controls over the use (eg. storage, issuance to operators, records of use etc) of health marks in thirteen Member States, and of their application (numbers and placing on carcases, failure to apply health marked labels correctly etc) in ten Member States. In three of these Member States, their application before completion of post-mortem inspection was seen Trichinellosis controls There was considerable uncertainty as to the application of existing EU legislation in many Member States 1. In principle, every pig carcase intended for human consumption must be tested for trichinellosis. However, EU legislation 2, allows for a derogation from this principle for fresh pigmeat intended for marketing in a Member State's territory or intended for any Member State having recourse to the same derogation. Member States using this derogation must inform the Commission and the other Member States. Although several Member States were using this derogation, it could not be confirmed in all cases that the above notification requirements had been respected. Furthermore, pigmeat which had not undergone trichinellosis testing was being produced in eight Member States and being sent to other Member States which were still operating 100% checks on their national production. 1 The Commission is already addressing this point by drafting new legislation on the examination for Trichinella in products of animal origin. 2 Council Directive 92/120/EEC of 17 December 1992 on the conditions for granting temporary and limited derogations from specific Community health rules on the production and marketing of certain products of animal origin. Article 3. O.J. no. L 62, 15/03/1993 P

8 In ten Member States, the methods used for trichinellosis testing did not fully satisfy the criteria laid down in EU legislation. In addition, meat was marked as fit for human consumption before the results of these tests were available. In two Member States, there were doubts as to whether the personnel performing the tests were independent of the operator, or whether tests were adequately supervised Traceability Effective traceability systems were considered to be in place within fresh meat establishments in a majority of Member States. It was less clear that such systems operated outside these establishments, allowing tracing along the whole food chain Hygiene of operations In nine Member States, deficiencies in the hygiene of routine operations, which were sufficiently serious to cause contamination of meat, were found. These involved both direct contamination of meat, eg. from external skin surfaces, faeces, gut contents, grease etc, and indirect contamination due to contact with work surfaces, unhygienic operational practices etc. There were deficiencies with the provision of cleaning and sterilising facilities, and with the excessive use of water from drop hoses, which exposed meat to a risk of secondary contamination, through splashing of dirty water. In three Member States these problems were considered to pose a direct threat to consumer health, and immediate corrective action was required Operator-checks in establishments EU legislation requires operators to establish and operate certain auto-control systems. Although generally satisfactory, some deficiencies in the implementation of these checks were found in eleven Member States Animal welfare Problems in this area were seen in eight Member States, although these were generally restricted to individual slaughterhouses rather than being indicative of widespread problems. There is a general need to ensure that all involved are made aware of the importance of animal welfare, and that abuse of animals is prevented. 4. FOLLOW-UP TO INSPECTIONS After each mission, outstanding issues were followed up by the FVO with the Member State concerned. In the majority of cases, satisfactory assurances have been received that recommendations for action had been respected, and the necessary improvements made. Where this has not yet been the case, the Commission's services are pursuing the action required to bring them to a satisfactory conclusion. 3 In 2002, the Food and Veterinary Office started a series of missions to all Member States to examine controls over traceability of beef meat and meat products. 8

9 5. RECOMMENDATIONS 5.1. Member States (1) The official services responsible for controlling pigmeat production and processing standards should be given sufficient financial, human and administrative resources and legal powers to carry out their duties. To facilitate their work, there should be clear management and communication lines between central, regional and local authorities. (2) The operation and outcome of official control systems in the pigmeat sector should be fully documented, and subject to appropriate internal audit procedures. (3) Procedures for the approval of establishments should be an integral part of the official control system, and care should be taken to confirm that compliance with EU legislation is achieved before approval is granted. (4) Official control systems should include the monitoring of compliance with EU legislation, and official action should be taken where compliance is not achieved. In particular, ante and post mortem inspection procedures, the use of official health marks and requirements regarding operational hygiene, must be respected. (5) Consideration should be given to the development of systems allowing the tracing of meat through the whole production chain. 9

10 6. ANNEX I RECORD OF MISSIONS UNDERTAKEN Member State Mission ref. No. Date Title Austria 3189/2001 April 2001 Evaluer le contrôle des conditions sanitaires de production et de mise sur le marche de viandes fraîches porcines, de préparations de viandes de viandes hachées et de produits a base de viande Belgium 1059/2000 February March 2000 To evaluate the operation of controls over the production of fresh meat (porcine including investigation for trichinosis) Denmark 1228/2000 December 2000 To evaluate the operation of controls over the production of fresh meat Finland 1225/2000 December 2000 To evaluate the operation of controls over the production of fresh meat France 1083/2000 June 2000 To evaluate the operation of controls over the production of fresh meat Germany 1218/2000 September 2000 To evaluate the operation of controls over the production of fresh meat Greece 1192/2000 September 2000 To evaluate the operation of controls over the production of fresh meat Ireland 3362/2001 October 2001 To evaluate the operation of controls over the production of fresh meat, wild and farmed game meat and rabbit meat Italy 1219/2000 October 2000 To evaluate the operation of controls over the production of fresh meat Luxembourg 3357/2001 October 2001 Evaluer les opérations de contrôle concernant la production et la mise sur le marche de viandes fraîches porcines, de viandes hachées et préparations de viandes, de produits a base de viande Luxembourg 3465/2001 November 2001 Evaluer les opérations de contrôle concernant la production et la mise sur le marche de viandes fraîches, de viandes hachées et préparations de viandes, de produits a base de viande The Netherlands 1086/2000 June 2000 To evaluate the operation of controls over the production of fresh meat Portugal 3364/2001 September 2001 Evaluer les opérations de contrôles effectuées sur la production et la mise sur le marche de viandes fraîches porcines, ainsi que de viandes de gibier et de lapin Spain 1087/2000 June 2000 To evaluate the operation of controls over the production of fresh meat Sweden 3370/2001 November 2001 To evaluate the operation of controls over the production of fresh meat UK 1179/2000 June 2000 Evaluer le contrôle des conditions sanitaires de production et de mise sur le marche de viandes fraîches porcines 10

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