Better Training for Safer Food Initiative. Inspection and quality assurance, upon traceability and FVO audits

Transcription

1 Better Training for Safer Food Initiative Inspection and quality assurance, Cliquez HACCP pour modifier systems, le style des sous-titres du Control masque upon traceability and FVO audits C. ALEXANDER, C. ALMEIDA, A. LEBOUCHER Health and Consumers

2 Aims of the presentation Bring information about basic checks performed during inspection Define links between inspection and own-checks including quality assurance Offer tools to verify HACCP plan Acquire information to perform official controls regarding traceability Propose examples of National control programs (NCP) Give an overview of the Food Veterinary Office control

3 Program of the Presentation Legal basis Own-checks and quality assurance Official controls in ABP chain, especially upon: o HACCP plan o Traceability National control program FVO audit

4 Legal basis Regulation (EC) No 1069/2009 in Articles 21, 22, 28, 29, 30, 45, 49 but also 44, 46, 47 and 48 for controls enforces FVO on-the-spot-checks to insure harmonized application of ABP rules Regulation (EU) No 142/2011 in Art. 17, 32 defines traceability and UE model for Commercial Document (CD) Annex VIII, Chapter III defines official control according to MS national program based on risk analysis (Annex XVI, Chapter III) with respect to Reg. (EC) No 882/2004 Regulation (EU) No 142/2011 in Art. 6, 8, 9, 10, 18 CA should only approve plant if complies with requirements laid down in Annexes III, IV, V, IX, X, XI, XIII

5 Program of the presentation Legal basis Own-checks and quality assurance Official controls in ABP chain National control program FVO audit

6 Own-checks in ABP plants* Must comply with : written procedures, implemented procedures (to be own-checked on the spot), inspected procedures, registered inspection In particular must exist : cleansing and disinfection procedures including vehicles, containers, areas used by means of transport, especially when ABP are handled preventative measures against pests regular inspection of environment and equipment handling and storage of derived products to prevent recontamination traceability for all products and registration of non compliance * List may be shorter depending on activities performed, see annex III, IV, V, IX, X, XI and XIII of Reg. (EU) No 142/2011 setting requirements for each activity

7 Own-checks in ABP plants Links with GGP and Quality Assurance ISO or other QA system : is convenient to describe the process taking place in ABP plants, insuring a safety management system, other certifications may exists related to feed industry, pharmaceutics FBO or else : IFS, etc.) still ISO or other certification is not approval nor registration under Reg.(EC) No 1069/2009

8 Program of the presentation Legal basis Own-checks and quality assurance Official controls in ABP chain upon o HACCP plan otraceability National control program FVO audit

9 Official controls in ABP plants Tools for the inspection staff Official staff have legal rights to entering plants during ABP processing national organization of controls Officials may use a check list to perform control : Example : Ishikawa diagram/fishbone diagram for items to be checked Machine (technology) Method (process and procedures) Material (raw or derived, include waste) Man Power (staff) Measurement (Inspection) Milieu/Mother Nature (Environment)

10 Official controls in ABP plants Tools for the inspection staff Officials may use a check list to perform control In order to review ABP plants but also ABP operators 1 or more check lists for checks upon: o plants, premises, approved or registered o material at starting point, in plants, including during Veterinary checks according to Directive No 89/662 EEC o traceability of products under control of registered operators (traders, transporters, etc.) In order to report information about compliance: to CA, other MSs and operators

11 Official control in ABP chain Whole chain is concerned but with major concern for processing plants National risk analysis applies - mostly on approved plants for 10 activities listed in Article 24 (1) of Reg. (EC) No 1069/ Must also apply on registered plants including operators (traders, etc.) listed in Article 23 and other specific official controls

12 Official control in ABP chain Other specific official controls concern Marking of derived products (MBM/Fat of Cat 1 and 2) with GTH On site inspection of low capacity incineration plants handling SRM on a yearly basis Some activities listed on Articles 16 and 18 of Reg. (EC) No. 1069/2009 Specific issues : UE trade, importation (art 8 of Directive 97/78 EC) and Using of OF/SI, unpalatable component,..

13 Official controls in ABP chain Take place primarily during procedure for approval Are conducted : o according to National Control Program (NCP) o especially in approved ABPs plants Official controls check: general conditions of hygiene of the premises, equipment and staff efficacy of own-checks for all operators (including ownchecks upon traceability) implementation of HACCP if compulsory standards of derived products after treatment, including sampling for analysis storage conditions links with other units located on the site such as farm, unit approved or registered according to Regulations (EC) No. 852 or 853/2004

14 Official Control upon HACCP plan Will have to check for : named experience of own-checks as prerequisites (PrP) description of derived products to be put on the market existence of hazard analysis which : - Has to be oriented towards ABP, categorisation, public and animal health, - Postulates that ABP is at risk (all cat) but derived product are to be safe experience of description of the process, is to be check on the spot verified flow chart

15 Official Control upon HACCP plan verify plant layout and flow chart

16 Official Control upon HACCP plan way of determination of steps which are CCP -especially for processing methods which have to be authorised by CA -including official verifications of registration and e existence of corrective actions on products and pr existence of internal audit, documentary system revi

17 Official Control upon HACCP plan takes time and trained inspectors leads CA to ask for corrective actions up to stopping of activity produces a report pointing out : - observed non compliances with ABP and trade regulations - acceptable/unacceptable items especially concerning processing safety

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19 In biogaz plant receiving manure from 100 breeding farms, mainly duck and bovine stock, hazard analysis does not identify any microbiological hazards and proposes no CCP nor PrPo steps for the biogaz production, which will not include any hygienisation step, residues of digestion are intended to return on land. Is the HACCP method has to be considered as : A. - Fully implemented on a process aiming to reduce and maintain hazards to an acceptable level B. - Missing hazard analysis especially about the health status of farmed animals producing manure (step 1 of HACCP method) C. - Missing the identification of critical points (step 2 of HACCP method) D. - Lacking of verification and documentation of the process (steps 6 and 7 of HACCP method) The question will open when you start your session and slideshow. # votes: 0 Closed Internet TXT Twitter This text presentation box will be used has been to describe loaded the without different the message Shakespeak sending add-in. methods. Want The to applicable download explanations the add-in for will free? be inserted Go to after modify the appearance of this text you have started a session. It is possible to move, resize and box.

20 In biogaz plant receiving manure from 100 breeding farms, mainly duck and bovine stock, hazard analysis does not identify any microbiological hazards and proposes no CCP nor PrPo steps for the biogaz production, which will not include any hygienisation step, residues of digestion are intended to return on land. Is the HACCP method has to be considered as : A. B. C. D. Internet TXT Twitter - Fully implemented on a process aiming to reduce and maintain hazards to... - Missing hazard analysis especially about the health... - Missing the identification of critical points (step 2 of HACCP method) - Lacking of verification and documentation of the process (steps 6 and % We will set these example results to zero once you've started your session and your slide show. 50.0% In the meantime, feel free to change the looks of your results (e.g. the colours). 75.0% 100.0% Closed This text presentation box will be used has been to describe loaded the without different the message Shakespeak sending add-in. methods. Want The to applicable download explanations the add-in for will free? be inserted Go to after modify the appearance of this text you have started a session. It is possible to move, resize and box.

21 Official Control upon HACCP plan Shakespeak question the HACCP method has to be considered : 2. Missing hazard analysis especially about the health status of farmed animals producing manure (step 1 of HACCP method) operator must assess the hazard of mixing all these manures from different farms and using the mixture in anaerobic conditions which may not be equal to directly return on land. Assessment must prove there is no more risk in the residues of digestion than for sole manure going back to land. Duck manure often carries low level of clostridium botulinum, this hazard should be especially assessed. Hazard analysis as the 1 st step of HACCP method has to 1. Describe hazards to be encountered in ABP materials and 2. Give information about the possible survival of these hazards during process

22 Official Control upon traceability at plants, traders, transporters, etc. at starting point, end point or during final use during VET checks on products/documents during EU trade, import, export on TRACES system include verification on documents: CD/DOCOM exist CD fully completed expedition/destination And transporters on EU/TC lists

23 Official Control upon traceability* In ABP plants, take place on: material introduced: search for links with CD and on site still existing material material at expedition: search for links between process, including batch, material of origin, CCP compliance, CD and autorised destination balance should be made for: - input/output material - capacity of processing and storage equipements *Traceability is part of own-checks for all ABP operators

24 Official Controls upon ABPs and ABP plants, including HACCP need Training of CA, including HACCP assessment and traceabilty Tools for inspectors : check list, sampling equipment CA reporting And... National Control Program

25 Program of the presentation Legal basis Own-checks and quality assurance Official controls in ABP chain National control program FVO audit

26 National Control Program Shall take place On yearly basis On approved plants AND other operators Based on risk assessment National Risk assessment will use Typology of existing operators using National List : art 47 of Reg.(EC) No. 1069/2009 Operators skills to corrective actions toward NC pointed out during previous inspections

27 National Control Program National Risk assessment will create Indicator Linked with inspection frequencies ABP plants level of risk Inspection rate, and indicator are national Detailed program, time-table, organisation will be local or national depending on size, organisation of MSs

28 National Control Program 2 examples: Slovenia and France Slovenia: 100 approved plants, among which 50 biogas plants, 1 rendering plant for Cat. 1, territory is middle size France: 600 approved plants among which 10 rendering plants for Cat. 1, 50 petfood producers, 50 biogaz plants and 130 composting plants, territory is large size Each MS has risk assessment and NCP

29 National Control Program SI : based on an indicator taking into account different items Risk Scale : HIGH, MED, LOW for each item: use of the same scale Indicator is composed of 7 items 1. Activity, 2. Cat, 3. Material origin, 4. Technical state, 5. Cooperation, 6. Ownchecks including traceability, 7. Placing on the market. Minimum rate of inspection to be followed by CA is: High risk plant: 2/year Medium risk plant: 1/year Low risk plant: 1/2 years

30 National Control Program FR : based on an indicator, calculated yeach year by local CA I =AxbxSxM A: level of risk of approved plant (activity, CAT and material origin) 15 to 40 b: yearly tonnage of derived products (outcoming material, scale depending upon activities) 1 to 4 S: activity sensitivity regarding human and animal health policy 1 to 2 M: management of plant, including ownchecks, HACCP, traceability, cooperation 1 to 4 I = value from 15 up to 1280 Minimum rate of inspection depending of national priorities and staff available 1/year >480 1 / 2 years <480 but >200 1/3years <200 but >100 and ¼ years if <100

31 National Control Program MSs create o Different indicators o Different scales o But based broadly on the same criteria MSs define or calculate o Indicators but not in the same manner o as typology of plants, Ms organisations are different MSs have NCP o Based on risk assessment odefining a yearly inspection rate, to be followed by officials MSs as CA get a general overview upon o Implementing ABP rules by ABP plants and o Level of safety of the whole chain

32 The Food Veterinary Office (FVO) of the Commission s Health and Food Safety Directorate General (DG SANTE) - audits Important tool of DG SANTE for comprehensive and harmonized rules in the UE For operators and competent authorities Based on EU/ program of audits, according to main topics in ABP chain, such as links with feed ban, TRACES and animal health

33 FVO audits Take place to check for harmonization and difficulties to implement regulations for MS Through campaign choosing several MSs: : ABP and OF/SI 2014/2015 traceability/feed ban Necessarily general, as it covers principles of regulation (EC) No 1069/2009 But precise according to implementing Regulation (EU) No. 142/2011 Help to adapt regulation mixing component Point out difficulties or frauds but also Good implementation and checks by MSs and operators

34 Controls upon management of safety Controls are of the heart of ABP risk management system Take place mainly in ABP approved plants Should include all ABP operators especially for traceability For which, GGP, HACCP, Quality Assurance, traceability are tools for operators to identify, check and supervise the ABP hazards Official controls (FVO/CA) must observe and check the implemented system in order to control it as supervisor to prevent any risk appearing from ABP for public and animal health

35 A NCP including sole ABP approved operators [art 24 (1)] of Regulation (EU) No. 1069/2009 is considered: A. - completed according to Reg. 882/2004 B. - completed according to Reg. 142/2011 (annex XVI) C. - Partly completed according to FVO audits as it does not cover registered plants listed on EU lists of ABP establishments D. - Partly completed as it does not cover starting points such as FBO or breeding farms and Art 23 registered operators The question will open when you start your session and slideshow. # votes: 0 Closed Internet TXT Twitter This text presentation box will be used has been to describe loaded the without different the message Shakespeak sending add-in. methods. Want The to applicable download explanations the add-in for will free? be inserted Go to after modify the appearance of this text you have started a session. It is possible to move, resize and box.

36 A NCP including sole ABP approved operators [art 24 (1)] of Regulation (EU) No. 1069/2009 is considered: A. B. C. D. - completed according to reg 882/ completed according to reg 142/2011 (annex XVI) - Partly completed according to FVO audits... - Partly completed as it does not cover starting % We will set these example results to zero once you've started your session and your slide show. 50.0% In the meantime, feel free to change the looks of your results (e.g. the colours). 75.0% 100.0% Closed Internet TXT Twitter This text presentation box will be used has been to describe loaded the without different the message Shakespeak sending add-in. methods. Want The to applicable download explanations the add-in for will free? be inserted Go to after modify the appearance of this text you have started a session. It is possible to move, resize and box.

37 Last Shakespeak question A NCP including sole ABP approved operators (art of regulation EU No 1069/2009) is considered: 1. Fully implemented according to Reg. EC No 178/ Fully implemented according to Reg. EU No 142/2011 (Annex XVI) 3. Partly implemented according to FVO audits as it does not cover registered plants listed on EU lists 4. Partly implemented as it does not cover starting points such as FBO or breeding farms and Art 23 registered operators NCP should apply to the whole ABP chain, which includes starting point (art 4) and all operators dealing with ABP or derived products including those registered under Art 23 and those who do not have to notify ABP production (FBO, animal keepers, etc.)

38 Thank you for your attention Questions?

39 JVL Consulting s.a. Rue Matagne 15 B-5020 Vedrin Belgium Website: Better Training for Safer Food BTSF European Commission Consumers, Health and DRB A3/042 L-2920 Luxembourg Health And Food Agriculture Executive and