EU TWINNING PROJECT

Mission Report

SR12-IB-AG-02

General Information
Project / Capacity building for Upgrading of Food establishments and Animal By-Product management
Component / 2. UPGRADING OF FOOD ESTABLISHMENTS
Activity / Activity 2.2 Development of Check-lists and procedures for the assessment of food establishments
Activity 2.4 Organisation and execution of inspection assessment of structural conditions and classification of food establishments.
Reference number TOR / Mission no. 30
Short Term Expert / Mr. Janis Altenburgs, LV
Mr. Edzart Bruinier, NL
Period STE Mission / Arrival / 17.08.2015
Working days / 18-21.08.2015
Departure / 21.08.2015 after work or 22.08.15
Persons Interviewed/Workgroup Members / Please find list of attendees enclosed
Used documentation/information
Other delivered products concerning TOR
(Please attach a copy of the terms of reference
provided by the resident Twinning Adviser,
Programme, day, date, Introduction
documentation, Power Point Presentation, etc.)
This Mission Report includes appendix(es) / General Report (part of this document)
Information Analyse (phase 1)
Advise and recommendations (phase 2)
Description of implemented products (phase 2)
Training report (phase 3)
Study visit/ Internship report (phase 3)
Other:

1Description of the activities during visit

The first day of this mission was used to coordinate the procedures followed during the evaluation visits and to receive an update on the work that has been done on the checklists and procedures for the upgrading process. A checklist was presented including a general part (Reg. (EC) 852/2004) and a part specific for slaughterhouses for domestic ungulates. The BC had arranged visits in three establishments. The inspectors were asked to do an inspection using the draft checklist to evaluate the drafted checklist. The evaluation of the inspectors’ use of checklist took place during the theoretical part in the afternoon. In addition a discussiontook placeon which category the establishment would be placed in if this had been an actual assessment visit.

Establishment 1:

A large amount of incompliances was detected. Lack of maintenance has resulted in many structural deficiencies. Lack of proper hygiene was omnipresent.In theory, with no financial constraints and unlimited labour available this could be corrected within 6 months, but history of not cooperating and current financial situation will probably get this establishment in category 3 at best. Enforcement of national legislation should have prevented the current situation. Irrespective of categorization, correct enforcement measures need to be taken against an establishment like this.

Establishment 2:

The second establishment visited had few incompliances. The ones found will be corrected within 6 months according to the owner. It could be placed in category II. However the structural improvements could maybe be eligible for IPARD funding (can this be the case also for cat II or only for cat III?) There was no PM-examination of all carcasses together with their offal, even if the amount of inspectors increased of FBO was allowed to provide trained official staff, then the slaughter line has to be changed to present offal together with the carcass.

Establishment 3:

The third establishment had deteriorated somewhat since last year, showing that the upgrading process in itself is no guarantee that an establishment will be able to maintain the correct level for accession. Proper supervision by inspectors should safeguard this in future. The owner recognized the problem and intends to correct these (no timeframe promised). Biggest problems were ventilation/condensation, lack off maintenance of floor, walls, ceilings and doors and a general lack off proper cleaning. Some situations were encountered where meat was contaminated by condensation dripping from ceiling and fixtures. Enforcement needs to be taken in these situations, irrespective of the categorization process, to prevent risk to consumers.

2Comment on progress in candidate country

TheBC drafted the checklist for slaughter houses for meat of domesticated ungulates.

3Recommendations for future actions or STE missions

Checklist for slaughter houses for meat of domesticated ungulates:

During the inspections it turned out that the inspectors understood the checklist and only few questions were raised.

It is not clear if all requirements of the stunning equipment and lairage facilities are understood by the inspectors. The BC should update the checklist according to these questions:

  • Some DATA ON GENERAL AND SPECIFIC CONDITIONS IN ESTABLISHMENTS FOR PRODUCTION AND TRADE OF FOOD OF ANIMAL ORIGIN can be re-evaluated taking in to account it`s importance to an establishment assessment process, e.g. national supplier list, list of importers, Re-approval after changes-reconstruction of object;
  • The checklist for the slaughterhouse needs a box with requirements for suitable facilities for the veterinary inspectors doing AM and PM control (in poultryslaughterhouse it is not possible with the establishments structure to do PM control according to EU legislation, each animal incl. offals should be controlled)
  • For Questions 1-4 (page 3) “Building exterior” there is incorrect reference to Annex II, Chapter I, 1

Chapter I, 2, as this provisions are relataed to interior of a building.

  • Question 43-45, “Facilities for washing food” (page 6), could be deleted as this would not be relevant in a slaughterhouse. (RE (EU) 852/2004 annex II, chapter I, 1 and 4 , and chapter II, 3)Except if the general part of the Protocol will be used in all company inspections.
  • Question 63 (page 8), this question needed further explanation: it means that any food that needs to be cooled in order to remain safe, has to be cooled as quickly as possible after last preparation stage (after cutting for meat, after mincing for minced meat after boiling for boiled sausage, after washing for lettuce, etc) RE (EU) 852/2004 annex II, chapter IX, 6). There is missing in the check-list specific temperature conditions set by RE (EU) 853/2004 annex III, section I, chapter VII, 1a), 2, 3;
  • Question 66 (page 9), this question needed further explanation. This question refers to RE (EU) 852/2004 annex II, chapter IX, 8. Hazardous and/ or inedible substances could be e.g. cleaning and disinfection substances and these needs to be clearly identified and stored separate and in secure containers.
  • Question 71-76 (page 10) “Heat treatment” this section needs clarification. This question refers to RE (EU) 852/2004 annex II, chapter XI, 1a-b, chapter VII, 6, chapter XI,2-3, chapter I, 2d. It refers to the heat treatment of products packaged in such a way before heat treatment that there is no way the effect of the heat treatment on the product can be directly monitored by observing the state of the product without opening the package. (canned food, food heated in vacuum packaging, etc.)
  • Question number 50 (page 19) is not from EU-legislation and can be removed
  • Question 56-57 (page 20). This question refers to RE (EU) 853/2004 annex III, section I, chapter II, 5.

Detained means: secured and not released for sale pending final decision by the official veterinarian

Declared unfit: decision by the official veterinarian that the meat is not fit for human consumption and therefore becomes ABP.

  • A checklist for poultry and lagomorph should be produced and all checklists should include cutting facility questions. Also ABP questions related to these operations should be added. It is advisable to put the questions on lairage after the questions on the inside of the slaughterhouse because this follows the natural order of the inspection visits (clean before dirty). Before training on dairy establishments can commence the appropriate checklist needs to be completed.
  • Referrals to RE (EC) 853/2004 should include Annex number and Section number before Chapter and point

Procedures

The BC needs to finalise the procedure for assessment, categorisation and upgrading. During the mission the questions listed below came up and they need to be decided on and described in the procedure in order for the process to be uniform, clear for the inspectors and transparent for the FBO’s.

  • Is it only category III establishments (these establishment has to submit an action plan for upgrading) that can apply for IPARD funds? If so then it might be better for some establishments to be categorised as category III than II.
  • After the assessment visit the FBO might need time to decide if he is able to upgrade in 6 month and be a category II or he need more time for upgrading and goes into category III. The time needed depends on how quicklythe FBO can get suggestion for repair from construction/consultants companies, and acceptance for a financial plan form the bank. The reasonable time for this might be 2-4 weeks, but it depends on the Serbian situation.
  • When doing the assessment and categorisation the FBO’s history should be taken into account, has there been willingness in investing in maintenance of the establishment, is the FBO trust worthy etc.
  • What happens if an establishment has been categorised as cat. IV and the FBO suddenly finds funding and is now interested in upgrading?
  • ?
  • What will the procedure be if a cat. II is not ready be classified as cat I after 6 month. What if the FBO only needs 1,2 or 3 weeks more due to delay in constructionworkers or other things that can be explained? What is the limit and what is the procedure or does the establishment always automatically turn into cat. III? (see national programme for upgrading.)
  • What happens in case of change of ownership? Does a new categorization take place or are approval requirements sufficient for being cat I?
  • What is the procedure for a cat. III establishment if the FBO can’t fulfil his own action plan. If it is a delay in construction or other situations that can be explained/ or justified is there a possibility for extension of the action plans deadlines or will the establishment turn into a cat. IV?
  • It should be made clear that even a cat. I or II establishment could have immediate food safety issues that should be dealt with separately and according to the existing legislation, and that this has to take place at once.
  • It should be described how to deal with immediate food safety issues that is discovered during the assessment visits (e.g. condensation dripping on products, risk of cross contamination).
  • A plan for correct enforcement of already existing legislation should be made. As this might be a general problem in the inspectionthere is a need for developing an intervention policy, so that inspectors do this during the same period of time and in the same uniform manner. It is recommended to inform the FBO/ and their organisations on this for this process to be transparent.
  • Who will report the findings/conclusions to the FBO the Special inspection team or the local inspector?
  • Will the local inspector always participate in assessment visits, this is recommended if the local inspector will do the follow up visit.
  • Who will give the decision on the category and how should it be done via the checklist or should it be done by a separate letter. A separate letter is advisable. Report on findings (SIT), response FBO (to SIT?), decision of category (by CWG?)
  • It was discussed how detailed the comments in the checklist should be, and if every hole or crack in the floor should be noted. It is suggested to put in the procedures that the FBO is responsible for complying with the legislation at any time also without being inspected. So if something is found not to be in line during inspection the FBO is responsible for taking notes to be aware and to deal with the incompliances, even the incompliances that were not found by the inspectors. So the inspectors could put in general terms: the floor in the slaughter section need to be in compliance with the relevant article in the legislation, instead of counting holes and cracks.
  • It was suggested that establishment assessment should be performed while it is in operation.

Please also see the recommendations from the previous mission no. 25 in this activity regarding the procedures and checklist.

Appointment of the special inspection teams

It is imperative that the special inspection teams are appointed and the work on the SIT is prioritised, before the trainings can start. When appointing the special inspection teams it is important to choose inspector that are committed to the process, and can convey the importance and urgency of this process to the FBO’s, as the FBO’s will only take this process serious if the inspectors do.

Please also see recommendations from mission report no. 22.Details of any follow-up actions by STE.