FVO Audits on Live bivalve molluscs

BETTER TRAINING FOR SAFER FOOD
BTSF
<strong>FVO</strong> <strong>Audits</strong> on Live bivalve molluscs
MARKUS BRUNNER
FOOD HYGIENE AND CONTROLS
PROGRAMME 2012-2013
Live Bivalve Molluscs
20 - 24 May 2013 – Chioggia, Italy
Health and
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Health & Consumers Directorate General
DG SANCO
Food and Veterinary Office
Unit F3
Food of animal origin:
birds and fish
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Health and
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Organisation and Staff F3
• Total staff: 22
• Management and coordination
• Head of Unit: Stefan Hönig
• Assistant to HoU: Jakub Hrabák
• Administrative support
• Report Coordinator: Gearóid Mathews
• Assistants
Gráinne Ní Chuirc
Margaret Prendergast
Catherine Davern
Maria Rusu
• Inspection resources: 15 staff organised in 2
sectors (8 in fish and 7 in poultry)
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THE FISH SECTOR
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The Fish team
Head of Sector: Graham Wood
Auditors:
• Åsa Bergquist
• Bruno Brigaudeau
• Markus Brunner
• Ana Goncalves
• Miguel Mendes
• Julia Uriol
• Pedro Moreno Valenzuela
• Telmo Valinhas
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Live bivalve molluscs
mussels, oysters, clams
mussels, oysters, clams
live echinoderms, tunicates and marine gastropods
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Key areas of focus when auditing
(LBM)
Public health controls all along the food chain for
live bivalve molluscs:
• production areas,
• dispatch centres,
• purification centres,
• monitoring programmes (microbiological
contamination, marine biotoxins,
contaminants),
• laboratories,
• processing establishments,
• own checks, etc.
Traceability
Certification (third countries)
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<strong>FVO</strong> specific MS audits for LBM
Member State Date of visit Report
Ireland 9-20 May 2011 2011-6007
France 12-23 September 2011 2011-8882
Spain 10-21 October 2011 2011-8881
Greece 11-21 October 2011 2011-8883
United Kingdom 16-27 April 2012 2012-6469
Netherlands 17-27 April 2012 2012-6468
Sweden 29 May-7 June 2012 2012-6545
Italy 16–26 October 2012 2012-6542
Denmark 12-19 November 2012 2012-6526
Portugal September 2013 2013-6667
Germany October 2013 2013-6668
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<strong>FVO</strong> specific audits for LBM
Findings/observations
COMPETENT AUTHORITY
Staff resources/technical competence
Co-ordination co-operation between responsible services
CCA regard classification/monitoring as overly burdensome
Debate between more prescriptive legislation/guidelines and the
option to develop approach suited to their own marine
environment.
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CLASSIFICATION OF PRODUCTION AREAS
• Improvement since 2004. Discussions in working groups in
relation to sanitary surveys (e.g. re-evaluation cycles)
• Tolerance in A areas for e.coli above 230 MPN (already
discussed in working groups – EURL making evaluation)
• Maintenance of classification with non-adequate data
• Lack of sanitary surveys or reclassification without re-evaluation
• Geographical distribution of sampling points not clearly
defined/identified (representative for area?)
• Sampling technique unreliable
• CEFAS good practice guide not fully taken into account
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CONTROL/MONITORING OF CLASSIFIED PRODUCTION AREAS
General monitoring: Official samples taken by FBO and in some cases
from non-representative (e.g. during harvesting) or insufficient number
of locations
• Representative for viruses?
Widespread weaknesses in the monitoring of biotoxins (most MS
visited)
• Not all relevant biotoxins determined
• Reduced frequency or sporadic biotoxin testing (sometimes only when
there are unfavourable plankton results) without adequate risk analysis
• Monitoring does not cover all toxin producing plankton species
Tolerance applied to biotoxin results for indicator species (if "sentinel" –
no tolerance")
Biotoxin/plankton monitoring – clear rationale for the timing?
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CONTROL/MONITORING OF PECTINIDAE
HARVESTED OUTSIDE CLASSIFIED
PRODUCTION AREAS
Official controls on pectinidae/gastropods harvested outside classified
production areas are not carried out, or carried out incorrectly
• (legislation well adapted to this situation? – challenging situation -
extensive production in small volumes from multiple suppliers)
• Monitoring for ASP not carried out considering limits in Regulation
853/2004 and methods defined in Regulation 2074/2005
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Establishments
• Lack of validation of the effectiveness of water treatment for
purification in FBOs or not performed as foreseen (particularly
relevant for "B" areas)
• Issues remain with end-product testing FBO/CA
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Laboratories/analytical issues
• Official samples taken by FBOs not CCA
• Biotoxin methods – significant improvement since 2004.
Infrequently - methods not in scope of accredited/
validation awaited/non recognised method
• A few laboratories were not accredited
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For discussion
• Is it necessary to check toxins, contaminants and microbiology (Reg
854/2004, D.2) at all stages of production, processing and
distribution?
• Do sampling points need to be fixed to be as representative as
possible?
• Status of the EURL guidelines?
• How big an influence is cost on analytical work performed by MS CA?
• Is consistency maintained between production areas classified
before changes introduced by the "hygiene package" and those
classified more recently.
• Guidance needed in relation to phytoplankton and biotoxins?
• Different interpretation for decisions after monitoring (e.g. area
closure v mitigating measures such as obligatory purification).
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Unit F3.01 Fish sector
Risks associated with LBM
• Contaminants
• Heavy metals (Pb, Cd, Hg)
• Dioxins and dioxin-like PCBs
• Parasites ?
• Listeria monocytogenes: ready-to-eat products (smoked
shellfish)
• Salmonella: cooked molluscan shellfish
• E.coli
• Vibrio parahaemolyticus, V. vulnificus
• Campylobacter
• Viruses: Norovirus, Hepatitis A,…
• Biotoxins: Lipophilic toxins (Okadaic acid, Azaspiracids,
Yessotoxins, Pectenotoxins, Dinophysistoxins), Amnesic
toxins (ASP – Domoic acid), Paralytic toxins (PSP -
Saxitoxins)
• Other biotoxins: Neurolytic toxins (NSP), Palytoxin,…
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Unit F3.01 Fish sector
Risk associated with fish and LBM – RASFF
RASFF 2011 from third countries
RASFF 2011 from Member States
Bad temperature control 97 Contaminants 58
Contaminants 95 Microbiological contamination FP 54
Parasites 77 Parasites 40
Failed physical check in BIP 58 Microbiological contamination LBM 18
Histamine 27 Contamination with marine biotoxins 11
Residues 24 Failed physical check 8
Microbiological contamination FP 17 Packaging - labelling defects 7
Packaging – labelling defects 11 Histamine 6
Absence – irregular certificate 9 Additives 6
Additives 6 Residues 3
Microbiological contamination LBM 5 Illegal operation 1
Illegal operation 3 212
Contamination with marine biotoxins 1
430
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Thank you for your attention!
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