Department of Agriculture, Food and the Marine

Department of Agriculture, Food and the Marine

Trader Notice MH 25/2013

To: All approved meat plants and coldstores

Subject: Sealing of packages, commercial documents and lists of suppliers /customers.

Background: The recent investigation into the presence of equine DNA in meat products has lead the Department to consider the steps required to make the substitution of meat more difficult. This includes ensuring that the relevant parts of EU food law are strictly observed by food business operators. This legislation includes Section 1.C of Annex II of Regulation (EC) No. 853/2004 and Commission Implementing Regulation (EU) No. 931/2011. There will also be increased emphasis on the traceability requirements of Article 18 of Regulation (EC) No. 178/2002.

Compliance with this legislation is a condition of approval under S.I. No. 432 of 2009.

Sealing of Packages

Annex II, Section I.C.10 of Regulation 853/2004 relates to the application of identity marking;

‘In the case of packaging containing cut meat or offal, the mark must be applied to a label fixed to the packaging, or printed on the packaging, in such a way that it is destroyed when the packaging is opened. This is not necessary, however, if the process of opening destroys the packaging. When wrapping provides the same protection as packaging, the label may be affixed to the wrapping.’

In the case of pallets of polyblock frozen meat, the identity mark is often on a label applied to the wrapping. Such labels can easily be removed and not destroyed when the wrapping is removed. This makes substitution easier and makes it difficult for the Competent Authority to ascertain accurate traceability of this meat.

This type of pallet should be sealed using strapping (4 straps) with the identity mark printed on the strapping, or by using outer polythene wrapping with the identity mark printed on the polythene itself.

Commercial Documents

Commission Implementing Regulation (EU) No. 931/2011 came into force in July 2012. It specifies the information which must be on any commercial document (either paper or electronic) which accompanies consignments of products of animal origin.

Article 3

1. Food business operators shall ensure that the following information concerning consignments of food of animal origin is made available to the food business operator to whom the food is supplied and, upon request, to the competent authority:

(a) an accurate description of the food;

(b) the volume or quantity of the food;

(c) the name and address of the food business operator from which the food has been dispatched;

(d) the name and address of the consignor (owner) if different from the food business operator from which the food has been dispatched;

(e) the name and address of the food business operator to whom the food is dispatched;

(f) the name and address of the consignee (owner), if different from the food business operator to whom the food is dispatched;

(g) a reference identifying the lot, batch or consignment, as appropriate; and

(h) the date of dispatch.

This information must be entered onto a commercial document which bears a serial number. While most of the points are self explanatory, some clarification may be helpful:

An accurate description of the food: This must include the species and meat cut e.g. beef striploins, pig heads, sheep carcases, etc.

The name and address of the food business operator to whom the food is dispatched. This is not always included on CMRs. The name and address of the FBO buying the product (eg a meat trader) may be included, but the name and address of the establishment to which the meat is being dispatched must also be present to allow for proper traceability.

A reference identifying the lot, batch or consignment, as appropriate. It must be possible to verify that the commercial documents describe a particular consignment. This could be done by including details of all batch numbers on the commercial document. However, it can also be done by linking a dispatch document (which will have the details of the consignment, eg of pallets or of individual quarters) to the commercial documents by recording the serial number of the dispatch document on the commercial document. CN codes can also be used to achieve this outcome.

Role of Food Business Operators:

Food Business Operators must ensure that they have documented procedures to ensure compliance with both pieces of legislation.

Producers and dispatchers of manufacturing meat ( including cold stores) must have in place documented procedures which ensure that each package of meat leaving their establishment is wrapped, labelled and sealed in accordance with the legislation and that each consignment leaving the establishment is accompanied by a commercial document which fully meets the requirement of Regulation 931/2011.

Food business operators receiving consignments of manufacturing meat (including cold stores) must include in their documented procedures checks that each consignment is accompanied by a commercial document which fully complies with Reg. 932/2011 and that each package is wrapped, labelled and sealed in compliance with Community legislation. Records of these checks must be maintained and made available to DAFM officials on request.

FBO must have a documented procedure stating what action they will take if presented with a consignment which fails to meet all the requirements described above, and maintain records of those actions.

Traceability

Food Business Operators must comply with the traceability requirements of Article 18 of Regulation (EC) No. 178/2002. All plants must have a traceability system in place to make the following information available on demand:

·  Names and addresses of suppliers/customers

·  Approval numbers of suppliers/customers, if applicable

·  An accurate description of the product e.g. CN code, beef striploin, beef paddywhack, beef hearts, pork livers etc

·  Whether the product was supplied directly or via an agent/trader

·  Names and addresses of traders/agents, where applicable

This information should be available electronically on a standardised Excel spreadsheet.

This system must be in place by 1st August 2013.

It is suggested that FBOs consider using the TRACE format document to provide this information. The TRACE template was developed by the Department in consultation with industry and is attached below, along with a note on its use.

Role of DAFM

The Department will include these requirements in audits of establishments. Non-compliance by FBOs will be subject to appropriate regulatory sanction.

Meat Hygiene Section

22nd July 2013