Environment &

Food Safety,

overview

Dario DongoCIAA, Food Safety Management / Hygiene Task Force, v.chairman

Global Food Safety Initiative Tech. Committee, CIAA representativeISO TC34 SC17 (Food Safety Management), CIAA representative

Federalimentare, Regulative Policies, responsible

Ankara, 19 April 2010

EU food law. . .

in a nutshell

Scope

Food & feed exported (or re-exported

from the EU) for placing on the market of a third country

shall comply with the EU food law

Food & feed imported into the

EU shall comply with the

EU requirements of

food law

EC Reg. 178/02, General Food Law, Art. 11, 12

Food Safety

• Unsafe food can’t be placed on the Market as:

1)harmful (in the short-mid-long term /

cumulative effects / sensitivities of specific categories of consumers)

2)unfit to human consumption (ie. physical

contamination, deterioration, putrefaction, deacay)

EC Reg. 178/02, General Food Law, Art. 14

“Farm to Fork” policy

• All those who participate to the food/feed chain are responsible for

� the hygiene of their process and

� the safety of their output

• No exemption or limitation of responsabilities

• The safety assurance must be continuos,

from primary production (animal or vegetal) to final distribution (including catering)

EC Reg. 178/02, General Food Law, Art. 17

Traceability

All operators must

• be able to identify their suppliers – who supplied what (food & feed, food contact materials)

• be able to identify the business operators to

whom they have delivered their products - whohas received which product

• inform the competent authorities on what

above, whenever requested

EC Reg. 178/02, General Food Law, Art. 18

Environment & Food Safety

PesticidesMRL’s

[GMO’s]

Micotoxins…

DioxinsPCB’s

Water

Allergens

Food Contact

Materials

HeavyMetals

Process

contaminants

Land

Food and feed crops may uptake soil contaminants.

This may affect the quality of products and, in due course, the human and animal health

EC proposal for a Soil Framework Directive (COM(2006) 232)

FROM THE FARM …

Dioxins, PCB’s (1)

Dioxins and polychlorinated biphenols (PCBs) are chemicals that get into food

from the environment

• Dioxins may be formed as unwanted

by-products in a variety of industrial and

combustion processes, including household fires

• PCBs have been largely used since the early 1930s, mainly in

transformers, refrigerators, hydraulic oils and as all round chemicals. Despite their production was stopped in the 1970s-’80s,

they are still present in many environments

Dioxins, PCB’s (2)

Dioxins from the environment can be presentin vegetables and other foods [ie. Indian guar

gum, ’08. Swiss-made thickening agent Unipektin, ’07]

EC Reg. 1881/06 sets maximum levels for specific contaminants in

foodstuffs

EC Reg. 1883/2006, sampling and analysis methods for determining the

levels of dioxins and dioxin-like PCBs in specific foodstuffs

About 95% of the average person’s exposure to dioxins occurs through consumption of food, especially food containing

animal fats

High levels of dioxin can be found in food of animal origin (ie. eggs, milk, meat), when feedwith dioxin had been used [ie. Irish pork, ’08. NL

milk, ’06 … Belgian feed scandal, ‘99]

Water (1)

Ground water may be contaminated by a variety of

biological and chemical hazards, which include:

• bacteria and viruses

• domestic waste

• nitrate nitrogen

• synthetic organic chemicals

• heavy metals

• petroleum residues

• combustion products (ie. from roadways)

Water Framework Directive, 2000/60/EC

Urban waste water treatment Directive, 91/271/EEC (amended by Dir.

98/15/EEC)

Drinking water Directive, 98/83/EC

IPPC Directive, 2008/1/EC (Integrated Pollution Prevention and Control), under review, concerning industrial emissions. Integrated permits system covering

52,000 industrial and agricultural installations in the EU

Water (2)

Its treatment and use in agriculture is therefore strictly regulated. Never in feed production, nor to be left to

grazing animals [’98-’99 food crisis in F, NL: knackeries,

gelatine factories]

Sewage sludge - rich in nitrogen,

phosphorus and organic matter - can be a

useful fertilizer or soil improver

Directive 86/278/EEC on use of sewage sludge in agriculture

However, it concentrates heavy metals, dioxins, antibiotics and resistant

bacteria

Other contaminants

Lead: old paint is the most important source of

contamination of the environment. Lead water pipescan also be dangerous, especially when they transport hot water

EC Reg. 1881/06 sets maximum levels for cadmium, lead and

mercury in certain foods

EC Reg. 333/07 provides sampling & analysis methods for the official

control of lead, cadmium, mercury, inorganic tin, 3-MCPD and

benzo(a)pyrene in foodstuffs

Methyl-mercury: fishery products from polluted waters are major sources of methyl-mercury contamination

…

Crops

agriculture raw materials

… INTO THE SUPPLY CHAIN …

Pesticides (1)

Food operators must ensure that the

amounts of these residues are

- safe for consumers and

- as low as possible.

Never above the Maximum Residue Levels (MRLs) established

by EC Reg. 396/05

Pesticides are widely used in the

production and storage of fruits,

vegetables, cereals and animal products. Residues frequently occur in

food

http://ec.europa.eu/sanco_pesticides/public/index.cfm

Pesticides (2)

Farmers, processors, traders and

importers are responsible for

food safety, which includes compliance with MRL’s

If pesticide residues are found on

food in the EU at a level of concern for consumers, the RASFFcirculates the information and measures are taken:

- border rejection- withdrawal from the market

Mycotoxins: aflatoxins (1)

Aflatoxins are naturally occurring toxins that

are metabolic byproducts of fungi, which grow on

many food crops under favorable conditions

Most prone to contamination are corn, peanuts, tree nuts (pistachio nuts,

pecans, walnuts, hazelnuts, Brazil nuts),

dried fruits and milk

Aflatoxins (2)

EC Reg. 1881/06 – amended by EU Reg. 165/10 - sets maximum levels of aflatoxins (B1, B2, G1, G2, M1)

EC Reg. 401/06 – amended by EU Reg. 168/10 - provides sampling

& analysis methods for the official control of mycotoxins, including

aflatoxins

EC Reg. 1152/09, imposing special conditions governing the

import of certain foodstuffs from certain third countries due to

contamination risk by aflatoxins:

-> from Turkey:

• dried figs

• hazelnuts (in shell or shelled)

• pistachios

• mixtures of nuts or dried fruits (containing figs, hazelnuts or pistachios)

• fig paste, pistachio paste and hazelnut paste

Ochratoxins

EC Reg. 1881/06 lays down maximum levels of ochratoxin A for

cereals, dried vine fruit, coffee, wine, grape juice, cereal-based foods. For spices and liquorice, EU Reg. 105/10

EC Reg. 401/06 (as amended by EU Reg. 178/10): sampling &

analysis methods for official control of ochratoxin A

Good practices, example: woven poly bags for green beans in a warehouse that ideally should

remain <65% relative humidity. Note the ventilation windows in the wall

Another (carcinogenic) mycotoxin is Ochratoxin A (OTA), produced by moulds which grow in high temperatures and high moisture during harvest, handling, drying, storage and transport

Other mycotoxins

Fusaria toxins. Fusaria moulds which produce wrinkling of plant

parts produce also fusaria toxins. Currently, no official limit for fumosins in food [however, the EU has proposed a limit of 500

microgrammes per kg]

DON (deoxynivalenol), one of the most important of these

toxins, occurs in grains such as wheat, barley, oats, rye, and

maize, rice, sorghum. It may coexist with Zeralenone

-> cereals, baby-food issues, ’03 onwards

Codex regulatory limit for DON is 1mg/kg food

Patulin is a toxic chemical produced from a number of moulds. Apples

tend to be the major source, yet any mouldy or rotten fruit could

contain this toxin -> fruit juices

Codex Alimentarius is considering reducing the maximum level to 25ppb from 50ppb (because of high intake of apple juice by young children)

Risk reduction, example

• Very small amounts of dry matter loss due to mould activity can be

tolerated. A dry matter loss 0.5% is a signal of visible moulding, mycotoxin contamination and downgrading of lots

• To control the growth of moulds during grain storage:

modified atmospheres, fumigation (with sulphur dioxide and ammonia and CO2 of 75%).Preservatives (based on aliphatic acids, essential oils and

anti-oxidants) for feed

• An effective post-harvest management requires clear

monitoring criteria, hygiene and the implementation of

key critical control points during harvesting, drying and storage stages in the cereal production chain to minimisemycotoxin contamination

Post-harvest control strategies to reduce risk of mycotoxins in

grain storage

Magan N, Aldred D.: Post-harvest control strategies: minimizing mycotoxins in the food chain. Int J Food Microbiol. 2007 Oct 20;119(1-2):131-9. Epub 2007 Jul 31 -> http://www.ncbi.nlm.nih.gov/pubmed/18258326

GMO’s

Strictly speaking, GMO’s are not a food safety issue, since the European Food Safety Authority is deemed to check the

absence of risk prior to their authorization

EC Reg. 1829/03, regarding GMO’s on foods and consumer info

EC Reg. 1830/03, on GMO’s traceability

Yet, having considered the various political stances on this argument, the European legislator has provided comprehensive

rules on GMO’s authorization, their use in food and feed,

consumer information, traceability

Worth of notice: some GMO’s traits are made to prevent harmful contaminations of the crops [ie. the genotoxic pyralid]

GMO’s

Some morepositive

examples

Factory Environment

• SUPPLY• PROCESS• PACKAGING

… UP TO THE PROCESS …

Allergens

Food containing allergenic substances not mentioned on their labels are unsafe

-> They must be withdrawn and/or recalled

Food labels must indicatethe presence - even if just in traces - of

allergenic substances, and/ormaterials derived thereof

[except those mentioned in Dir. 2007/68/EC]

X-contamination risk

Fraudulent supplies

Sudan dyes: synthetic azo dyes, hystorically used to colour products (as shoe polish, automotive paints and petroleum derivatives).

-> ’03, chili powder and related products contaminated with Sudan I-IV crisis (over 1,000 products withdrawn from the EU market)

Melamine: an industrial chemical found in plastics was found to have been fraudulently added to wheat gluten and rice protein from China-> ‘07, USA, pet foods crisis-> ‘08, worldwide, infant milk powder and other protein sources (milk, soy, gluten, rice) crisis

Adulterated oils: mineral or industrial-use oils mixed with, and sold as, oils for human consumption-> ‘09, EU-Ukraine, sunflower-mineral oil mix import-> ‘94, the “Spanish toxic oil syndrome” (adulterated rapeseed oil)

Process contaminants (1)

Acrylamide: is formed in food by traditional cooking methods such as baking, frying and roasting at high temperatures (>120° C)

• Potato products (crisps, chips)

• Coffee• Savoury snacks (e.g. crackers)

• Toasted cereal products• Bread and bakery products

CIAA “Acrylamide Toolbox”, best practices for monitoring and reduction

PAHs: Polycyclic aromatic hydrocarbons occurr in oil, coal, tar deposits (byproducts of fossil fuel and biomass burning). Foods - ie. cereals, oils and fats (smaller intakes come from vegetables and cooked meats) - may become contaminated through- direct environmental exposure- migration from packaging material, or- thermal processing of food (baking, grilling, frying, smoking)

-> Benzo(a)pyrene

Process contaminants (2)

3-MCPD (3-monochloropropanediol) is formed

in a variety of industrially and domestically produced foods. The main area of concern is its occurrence inhydrolysed vegetable proteins, widely used ingredients and a major factor in soy sauceproduction (itself an ingredient in many products)

Furans: highly volatile cyclic ethers that can be formed unintentionally in foods during traditional heat-treatments, such as cooking, bottling, and canning

Ethyl carbamate (also known as EC or urethane) is a

well known, potent carcinogen, found in fermented foods in low concentration as a naturally occurring by-product of the fermentation process

Food contact materials (1)

• Food contact materials shall be safe. They shall not transfer their components into the food in quantities that could endanger human health, change the composition of the foodin an unacceptable way or deteriorate the taste and odour of foodstuffs

Framework Regulation EC 1935/04

If an article is intended for food contact it shall be labelled for food contact or bear the symbol with a glass and fork [except in cases where the intention for food contact is obvious by the nature of the article e.g. knife, fork, wine glass] ..

Food contact materials (2)

• Traceability is applied also to FCM. Safety problems concerning FCM are reported into the RASFF. In these cases, the European Commission and MS shall take appropriate measures:

- border rejections

- withdrawal from the market

Emerging risks: BPA (a synthetic resin used in food packaging and polycarbonate plastic products -> EFSA latest opinion in May, 2010), BBP (a widely used plasticiser used in food wraps and cosmetics), organotin compounds (heat stabilizers for PVC and as catalysts in polyurethanes and in silicones used in FCM, biocide agents in both plastics and wood -> EFSA set migration limits in its 2005 opinion)

Recent crisis due to FCM risks: BADGE, BFGDE, ESBO, 3-MCPD, ITX

Solutions ?

0 Risk is never given,

Risk analysis always needed !

FROM THE FARM TO THE FORK …

How to proceed (1)

In order to comply with the EU rules and to ensure

food safety, operators are requested to:

Implement HACCP-alike systems within

each organization

Thoroughly apply Good Agricultural Practicesand Good Manufacturing Practices

at any stage of the food chain

+

http://ec.europa.eu/food/food/biosafety/hygienelegislation/register_national_guides_en.pdf

A systematic method of

documenting that

food safety hazards have been

addressed

=

How to proceed (2)

In order to address the international markets expectacions and qualify as a

reliable supplier:

Applicable GMP’s

(Pre-Requisites)

certification

ISO 22000

+