DG(SANCO)/ MR

Transcription

1 Response of the Competent Authorities of Indonesia and plan of action to the recommendations of Report ref. DG(SANCO)/-6702-MR of an audit carried out from 25 February to 07 March in order to evaluate the control systems in place governing the production of fishery products intended for export to the European Union N. Recommendation Action Proposed by the Competent Authority Timeframe 1 To ensure that an official controls of all aquaculture farms providing fishery products to EU listed establishments provide guarantees that they meet provisions at least equivalent to those mentioned in Annex I of Regulation (EC) No 852/2004. To improve the OC system by integrating a Certification Scheme to be implemented by the Provincial Services under the control and supervision of DG Aquaculture. 15 Provinces are being prepared and given the authority to issue GAP certificates to farms complying with GAP requirements. To carry out intensive certification process on Good Aquaculture Pratices to target 7000 certified farms in (certified farms in 2012 were 3.196). The certification process follows the training and technical assistance programme delivered at local level to the farmers in the province CA will request to all fish establishments bearing EU approval number to identify all uncertified farms supplying raw material to their processing plant. These farms will be in particular receiving priority from the certification process. In addition CA will perform official control to these farms by including all uncertified farms which are before not yet covered in the National Residue Monitoring Plan. CA will request to all fish establishments bearing EU Approval Number to perform tightenned monitoring including laboratory testing on potential hazards (veterinary drugs/antibiotics) on incoming raw material received from farms not yet bearing GAP certificate.

2 Starting on June 2 To ensure that official controls include inspections at regular intervals of vessels providing raw material to EU listed establishments to verify whether the fishery products are handled correctly, the cleanliness of the vessels and their equipment, staff hygiene and to check that applicable hygiene and temperature requirements as per Chapter I, point 1 (b) of Annex III to Regulation (EC) No 854/2004 are met. CCA will strictly coordinate and monitor application of these measures. In order to address the deficiencies of the Official Control system in respect to raw materials supplied from fishing vessels the following will be organized: - Formation of a task force comprising staff from Directorate of fishing vessels, fishing ports, secretariat of DG Capture fisheries and CCA to address specifically the deficiencies of the system and therefore to develop the following actions; - Re-organization and implementation of the system to cover adequately licensing/registering and approval of fishing and freezer vessels, against EU hygiene and temperature requirements; - Re-organization and implementation of the routine and regular inspection system (timeframe and inspection contents) to fishing and freezer vessels, as well to unloading of fishery supplies. - Disseminate the revised inspection system to fish inspector from fishing ports and fishing and freezer vessels. The EU funded Project TSP II will deliver technical assistance in the implementation of above mentioned actions

3 3 To ensure that fishing vessels providing fishery products to EU listed establishments meet standards at least equivalent to the requirements laid down in Annex I to Regulation (EC) No 852/2004 and in Section VIII, Chapter I of Annex III to Regulation (EC) No 853/ To ensure, as established in Part II.1 of the health certificate, that fishery products exported to the EU have been caught and handled on board freezer vessels implementing a programme based on HACCP principles in accordance with Article 5 of Regulation (EC) No 852/2004. CA will request to all fish establishments bearing EU Approval Number to perform tightenned monitoring including laboratory testing on appropriate potential hazards (namely histamine and microbiological pathogens linked with lack of hygiene) on incoming raw material received from fishing vessels which has not yet undergone official control. The above (2) re-organised inspection system to cover adequately the inspection and enforcement of the specified EU requirements (laid down in Ministerial Decree number KEP 01/MEN/2007 to all fishing vessels supplying raw material to the fish estalishments bearing EU Approval Number). CA will verify through inspection during unloading that all fishing vessels supplying raw material to the fish establishments bearing EU Approval Number meets standards equvalent to the EU requirements. CA will revise Decree of Minister for Marine Affairs and Fisheries (MAFF) No KEP 01/MEN/2007 concerning requirements of quality assurance and safety of fishery products in production, processing and distribution to include that freezer vessels shall implement a programme on HACCP principles. CA will conducts training for the operator of freezer vessels

4 on the implementation of HACCP in freezer vessels supplying raw material to the fish establishments bearing EU Approval Number CA will request to operator of freezer vessels supplying raw material to the fish establishments bearing EU Approval Number to implement programme based on HACCP Principles. The re-organised inspection system (above mentioned in 2) will include verification on HACCP based programme through inspection during unloading of fish. 5 To ensure that fishery products exported to the EU are only handled in establishments that meet the relevant requirements laid down in Annex II to Regulation (EC) No 852/2004 and Chapter 1-4 in Section VIII of Annex III to regulation (EC) No 853/2004. Regarding the non-conformities (some quite basic and serious) found during the FVO mission, the CA shall undertake an evaluation survey to determine the reasons which allowed for such to be present. Following to the results of the survey developed the CA will undertake the necessary corrective actions at the level of routine inspection, annual approval of establishments, and also verification, audit and evaluation of inspection performance. The overall inspection system will be evaluated and revised for improvement. The EU funded Project TSP II will also deliver technical assistance to capacity building specifically in strengthening the quality management system under which the CA operates CA will also carry out comprehensive re-dissemination on the EU regulation no 852/2004 to all approved

5 establishments in 5 regions followed by specific enforcement programme: - West Java, Lampung and Banten region will be held in Jakarta - East Java and Central Java region will be held in Surabaya - Bali, NTB, NTT and Kalimantan region will be held in Bali - Sulawesi, Maluku, and Papua held in Makassar - Sumatera Region will be held in Medan 24 May 14 May May 6 To ensure that all establishments handling raw material used in the manufacture of fishery products intended for export to the EU are supervised by CA as laid down in Article 12, point 2 (b) of Regulation (EC) No 854/2004. CA will re-evaluate the compliance of fish establishments with the EU regulations, and any fish establishments do not comply with, will undergo to suspension and not allowed to export their products to the EU until they take appropriate measures on all non-conformities within determined period. If they fail to meet the requirements, their EU approval number will be proposed to be deleted CA will revise Ministerial Decree of Marine Affairs and Fisheries KEP.01/MEN/2007 on Requirements of Production, Processing and Distribution by including specific requirements for suppliers. CA will request to all approved establishments to identify suppliers that perform handling of fish and supply raw material to the approved establishments Based on identification, CA will establish list of registered suppliers that will be then maintained CA will carry out dissemination on handling of raw materials June December June and July

6 for suppliers in Surabaya, Makasar, Tarakan and Bali 7 To ensure that, as established in Part II.1 of the health certificate, that fishery products exported to the EU have satisfactorily undergone the official controls laid down in Annex III to Regulation (EC) No 854/2004, in particular concerning dioxins, PCBs and poisonous fish. CA will evaluate handling of raw materials in suppliers that supply raw materials to the approved establishments CA will tighten surveillance through monitoring and sampling in suppliers that supply raw materials to the approved establishments CA will conduct Good Handling Practices certification for suppliers or miniplants which perform fish handling for raw materials supplied to the approved establishments. Official Control PCBs including dioxin have been already listed as tested substances in NRMP for. Testing will start being implemented in september CA will revise accordingly the Ministerial Decree of Marine Affairs and Fisheries KEP.01/MEN/2007 on Requirements of Production, Processing and Distribution by including requirements of labeling for poisonous fish. The inspection system will be upgraded to include accordingly verification of the implementation of requirements of labeling for poisonous fish during inspection. CCA will follow-up with specific evaluation of implementation. CA will revise accordingly the DG Decree Processing and Marketing KEP.135/DJ-P2HP/2009 to update testing criteria for dioxins and PCBs. Starting on July Starting on July 2014

7 8 To ensure that, as established in Part II.1 of the health certificate, fishery products exported to the EU have satisfactorily undergone the official controls laid down in Annex III to Regulation (EC) No 854/2004, in particular that histamine testing is in line with Regulation (EC) No 2073/2005 and that maximum limits applied for heavy metals are in line with Regulation (EC) No 1881/ To ensure that only potable water is used as laid down in Chapter VII of Annex II to Regulation (EC) No 852/2004. CA will revise accordingly the DG Decree of Processing and Marketing of Fisheries Product KEP.135/DJ-P2HP/2009 to update testing criteria for heavy metals. CA will establish and implement requirements of heavy metals for fishery products equivalent with Regulation (EC) No 1881/2006 specifically for exporting to the EU. The CA will insure that the testing requirements will be accordingly followed and implemented by the laboratories (PL-FIQC) CA will ensure validation of histamine testing method using HPLC, and will use HPLC for routine CA will establish technical guideline regarding sampling for histamine analysis equivalent with Regulation (EC) 2073/2005. CA will develop new mandatory guidelines for potable water testing (microbiological, chemical and physical parameters) and request to EU exporting establishments and Laboratories to follow accordingly. However, due to lack of laboratory capacity to undertake testing of 60% of chemical parameters required by the EU Regulations, the CA is not able to ensure full compliance of the required testing for potable water. Therefore CA will work together with the laboratories to try to find solution for obtaining full capacity of coverage of all the required parameters in the medium-term. In the mean-time it will be required to the establishments to undertake full testing at least once a year in neighbor countries in approved

8 laboratories. CA will revise Ministerial Decree of Marine Affairs and Fisheries KEP.01/MEN/2007 on Requirements of Production, Processing and Distributionin order to include the requirements of potable water used for fish processing in accordance eith EU regulations. 10 To ensure that only additives listed in Annex II to Regulation (EC) No 1333/2008 are used in fishery products intended for export to the EU. 11 To ensure that laboratories performing official control analyses apply the principles of internationally recognised quality assurance techniques and are evaluated and/or accredited under officially recognised quality management and assurance programmes equivalent to CA will request to all approved establishments to ensure that the use of additive for fishery products intended for export to the EU should comply with Annex II to Regulation (EC) No 1333/2008. CA will integrate specific measure to verify labeling of fishery products in this respect, before issuing of Health Certificate. Inspection system will also give specific attention for the compliance of this requirement. CA will revise accordingly the DG Decree Processing and Marketing KEP.135/DJ-P2HP/2009 to update the utilization and testing criteria for food additives. CA will conduct technical meeting with Head of Laboratories to discuss FVO findings and necessary corrective actions. CA will specifically request to laboratories to address the type of non-compliances found during the FVO mission in order to upgrade their testing performance, in particular to consistency of quality assurance techniques during testing on samples taken during official controls. CA verification and evaluation over laboratory testing will

9 international standards, such as ISO/IEC 17025, to ensure the reliability of analytical results. focus on the fulfillment of the requirements of ISO Laboratories that do not fulfill the requirements of ISO will be given administrative sanction being excluded from official control testing. Note: Accreditation Body of Indonesia has issued the accreditation certificate number LP-088-IDN valid untill 20 March 2017 to PL-FIQC Surabaya and number LP-018-IDN valid untill 20 February 2017 to PL-FIQC DKI Jakarta. The EU funded Project TSP II will also deliver technical assistance in strengthening and improving the capacity of the laboratories to the extend it is deemed necessary