Workshop on the implementation of HACCP- principles in small food producing establishments...

Workshop on the implementation of HACCP-principles in small food producing establishments

Requirements according to Regulation (EC) 852/2004 for food

producing establishments

AGR 32375, Zagreb

Dr. Harald Fötschl

20th April 2009AGR 32375, Zagreb 2Dr. Harald Fötschl

Austria

Styria

Republic of AUSTRIACapitol: Vienna9 Federal states

Federal state of STYRIACapitol: Graz17 Districts


Some facts of Styria

3

1

1

21

1

11

11

3

2 3

3

34

3

34 official Vets

in 17 Districts

244 authorised Vets

3 official assistants in

Meat Inspection

52 official assistants in

Trichinella inspection

16.300 farms with 331.000 cattle17.800 farms with 850.000 pigs27.500 farms with 6.500.000 poultry

20th April 2009AGR 32375, Zagreb 4Dr. Harald Fötschl852/2004


Simplification of 17 Directives

Hygiene of foodstuffs 93/43

Fresh meat – production and marketing 64/433

Fresh meat – intra community trade 72/461

Fresh Poultry meat - production and marketing 71/118

Fresh Poultry meat - 3rd Countries 91/494

Pig Meat – 3rd Countries 77/96

Meat Products - production and marketing 77/99

Meat Products – intra community trade 80/215

Egg Products – production and marketing 87/437

Bivalve molluscs: production and marketing 91/492

Fishery products: production and marketing 91/493

Fishing vessels 92/48

Rabbit and farmed game 91/495

Wild Game 92/45

Milk Products – production and marketing 92/46

Milk Production 89/362

Minced Meat 94/65

Since 2006

Since 2006

1 Package -

4 New

Rules

1 Package -

4 New

Rules

Merge

Simplify

Harmonise


The Hygiene Package

Rules for all foods

Rules for food of animal origin

Rules for FBOs

Rules for official

controls

Hygiene of Foodstuffs (852/2004) Hygiene Rules for

Food of Animal Origin (853/2004 )

852/2004+

Official control of feed and

food (882/2004)

Official control on products of animal origin (854/2004)

882/2004+


EU-Legislation

White Paper on Food safetyFrom stable to table - concept

Regulation (EC) No 178/2002laying down the general principles and requirements of food law, establishing the

European Food Safety Authority and laying down procedures in matters of food Safety

Food-Business Operator (FBO) Competent authorities

Regulation (EC) No 852/2004 on the hygiene of foodstuffs

Regulation (EC) No 853/2004laying down specific hygiene rules for

the hygiene foodstuffs of animal origin

Regulations (EC) No 882/2004 on official controls performed to ensure the verification of compliance with

feed and food law, animal health and animal welfare rules

Regulation (EC) No 854/2004 laying down

specific rules for the organisation of official controls on products of animal

origin intended for human consumption

specific

general

20th April 2009 AGR 32375, Zagreb 8

852

853854

882178General food safety requirements

Primary Production/Requirements for all FBOs

Slaughter, Cutting and Processing

Retail & Catering

Consumption



concerns food hygiene rules with a view to establish

a comprehensive and integrated policy, that covers all food from the farm to the point of sale to the consumer

From Stable to Table

From Farm to Fork

From Conception to Consumption



focuses on

defining the food safety objectives to be achieved

the food operators responsibility to guarantee food safety

Main principles

primary responsibility for food safety rests with the food business operator

food safety shall be ensured throughout the whole food chain, starting with primary production

maintaining the cold chain, if it is required


Main principles

FBOs responsibility should be reinforced by

general implementation of procedures based on the HACCP principles

application of good hygiene practice

microbiological criteria and temperature control requirements based on a scientific risk assessment shall be established


Regulation (EC) No 852/2004 on the hygiene of foodstuffs - Scope

to ensure the hygiene of foodstuffs at all stages of the production, from primary production up to and including sale to the final consumer

It does not cover issues relating to nutrition or to the composition or quality of foodstuffs

applies to all food businesses, except …

Scope



does not apply to

primary production of food for private domestic use

the domestic preparation of foodstuffs for private consumption

the direct supply of small quantities of primary products by the producer to

the final consumer

local retail establishments directly supplying the final consumer

collection centers and tanneries – deemed FBOs because they handle gelatine/collagen

For governing these activities MS shall establish rules under national law, that shall ensure the achievement of the objectives of the Regulation



shall apply to all stages of

production

processing

distribution of food

without prejudice to more specific requirements relating to food hygiene.


Regulation (EC) No 853/2004

the Regulation 853/2004 applies to

unprocessed and processed products of animal origin

processed products of animal origin used to prepare food, that contains also products of plant origin

does not apply to

food containing both, products of plant origin and processed products of animal origin

e.g. Production of Salami under provisions of 853/2004, but production of Pizza with Salami under provisions of 852/2004


Unprocessed Products

processing

any action that substantially alters the initial product, including heating, smoking, curing, maturing, drying, marinating, extraction, extrusion, or a combination of those processes unprocessed products = raw products

have not undergone processing

frozen products of animal origin remain unprocessed products


Unprocessed Products

An unprocessed product combined with a product of plant origin remains a raw product (e.g. skewer containing fresh meat and vegetables)

under provisions

of 853/2004 !


Primary Production

defined in Article 3 (17) of Regulation (EC) No 178/2002

production, rearing or growing of primary products including

harvesting

milking

farmed animal production prior to slaughter

includes hunting and fishing and the harvesting of wild products


Primary Products

defined in Article 2, paragraph 1, point (b) of 852/2004

products of primary production including products of the soil, of stock farming, of hunting and fishing

Primary products include inter alia

Products of plant origin, e.g. grains, fruits, vegetables, herbs, mushrooms

Products of animal origin, e.g. eggs, raw milk, honey, fishery products, live bivalve molluscs

Products harvested wild either from plant or animal origin, e.g. mushrooms, berries, snails etc.


General and specific hygiene requirements

FBOs shall ensure that all stages of production, processing and distribution of food under their control satisfy the relevant hygiene requirements

FBOs carrying out primary production and associated operations shall comply with

general hygiene provisions of part A of Annex I

any specific requirements provided for in Reg. (EC) No 853/2004.



Operations associated with primary production (Part A of Annex I)

transport, handling and storage of primary products at the place of production, where their nature has not been substantially altered

the transport of live animals, where this is necessary

transport of products of plant origin, fishery products andwild game from the place of production to an establishment without substantially alteringtheir nature


Annex I – Hygiene provisions

Hygiene provisions for primary production

As far as possible, food business operators are to ensure that primary products are protected against contamination

FBOs must comply with national and EC regulations

control of contamination

animal health and welfare

monitoring and control of zoonosis


Annex I – Hygiene provisions

FBOs producing primary products of animal origin must

keep facilities and equipment clean and disinfected

ensure cleanliness of animals for slaughter

use potable water

ensure staff healthy and trained

Pest control

Waste control

Disease control (public health interest)

Correct use of additives/Veterinary Medicine


Annex I – Record keeping

FBOs must keep records on

Feed

Veterinary medicines/treatments/biocides

Disease occurrence

Sampling and analysis

Pest control

Maintained in appropriate manner and for appropriate period

on request records shall be available to the competent authority and receiving food business operators



FBOs carrying out any stage of production, processing and distribution of food after primary production shall comply with

general hygiene requirements of Annex II

any specific requirements provided for in Reg. (EC) No 853/2004.



Chapter IGeneral requirements for food premises (other than those specified in chapter III)

Chapter IISpecific requirements for rooms where foodstuffs are prepared, treated or processed (excluding dining areas and those premises specified in chapter III)

Chapter IIIRequirements for

movable and/or temporary premises (such as marquees, market stalls, mobile sales vehicles)

premises used primarily as a private dwelling-house but where foods are regularly prepared for placing on the market

vending machines


Annex II - General Hygiene Requirements

Premises - Layout design and construction

Transport vehicles

Equipment – construction and cleaning

Food Waste - removal and disposal

Water supply - potable

Personal Hygiene – protective clothing and visitors

Prevention of cross contamination – pest control

Provisions for wrapping and packaging of food

Temperature control / heat treatment

Training of personnel


Annex II - Specific Hygiene Requirements

Compliance with Microbiological Criteria

Procedures to meet objectives of Regulation

Temperature control

Maintenance of cold chain

Sampling and analysis


Microcriteria Regulation (EC) 2073/2005

Compliance with this regulation is required under (EC) 852/2004

Sampling requirements including frequencies laid down

Process hygiene criteria

Food safety criteria


Official Controls -Registration and Approval of Food BusinessesFBOs shall cooperate with the Competent Authorities

FBOs must notify competent authorities

Competent Authority has to register the businesses

FBOs must ensure CA has up to date information on establishment

Food of animal origin – approval required



Artikle 13 (3)

Member States may adapt the requirements laid down in Annex II to accommodate the needs of food businesses

which are situated in regions suffering from special geographical constraints or affected by supply difficulties

which are serving only the local market or

to take account of traditional methods of production and the size of farms

The objectives of food hygiene shall be met by the national legislation

Regulation (EC) No 852/2004 on the hygiene of foodstuffs - HACCP

The HACCP System


Regulation (EC) No 852/2004 on the hygiene of foodstuffs - HACCP

All FBOs (except primary production) shall apply the principles of the system of hazard analysis and critical control points (HACCP) introduced by the Codex Alimentarius

These principles prescribe a certainnumber of requirements to be metthroughout the cycle of

production

processing

distribution

in order to permit, via hazard analysis, identification of the critical points which need to be kept under control in order to guarantee food safety (and not food quality!)


HACCP

Food business operators shall

put in place

implement

maintain

permanent procedures based on the HACCP principles

does not apply to FBOs in primary production or associated operations


HACCP principles

HACCP principles referred to in 852/2004 consist of

identifying any hazards that must be prevented, eliminated or reduced to acceptable levels

identifying the critical control points at the steps at which control is essential to prevent or eliminate a hazard or to reduce it to acceptable levels

establishing critical limits at critical control points which separate acceptability from unacceptability for the prevention, elimination or reduction of identified hazards


HACCP principles

establishing corrective actions when monitoring indicates that a critical control point is not under control

establishing procedures, which shall be carried out regularly, to verify that the measures are working effectively

establishing documents and records commensurate with the nature and size of the food business to demonstrate the effective application of the mentioned measures


HACCP - Flexibility

HACCP requirements should be applicable in all situations, including in small businesses

if in certain food businesses CCPs can not be identified, good hygienic practices (GHP) can replace the monitoring of CCPs

undue burdens for very small businesses in the requirement of retaining documents shall be avoided

should not compromise food safety


Austrian legislation

Therefore MS shall encourage the

development of national guides to good practice by food business operators, which shall include

guidance on compliance with the general rules of hygiene

the HACCP principles

GuidelinesGuidelines



provisions in connection with 852/2004

Supply of small quantities of wild growing food of plant origin

all primary products must be protected against contamination

all used equipment and transport vehicles have to be clean and have to be cleaned and sanitised before using them again

Provisions in connection with 853/2004 (next slide)

what we did …what we did …

Food Direct Marketing RegulationFood Direct Marketing Regulation



Large wild game (fresh, not frozen, in whole, unskinned)

hunter has to examine the abdominal viscera

trained person has to examine the carcass and the thoracic viscera

declaration of examination, signed by hunter and trained person

Vet has to inspect the carcass, if abnormal characteristics were found

temperature requirements (7°C for carcass, 3°C for offal)

marketing within 7 days

What we did …What we did …




Small wild game (fresh, not frozen, unskinned, unfeathered)

trained person has to examinethe carcass, vet has to inspect, if abnormal characteristics are found

temperature requirements (4°C)

no declaration of examination is required





cutted meat of wild game

marketing only by hunter himself

every contamination has to be avoided

temperature requirements for storage and transport

special labelling on marketing ("wild game meat in direct marketing")





meat of poultry and lagomorphs

control in the holding once a year (animal diseases, zoonoses, residues,…)

ante and post mortem inspection by a special trained person

post mortem by a Vet, if there were abnormal findings

temperature requirements for storage and transport

special labelling on marketing ("slaughtered on farm")

special provisions for direct marketing of eggs, raw milk and fish




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Workshop on the implementation of HACCP- principles in small food producing establishments...

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