inspection and quality assurance, haccp systems, control upon ... · • officials may use a check...

Health and

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Inspection and quality assurance, HACCP systems, Control

upon traceability and FVO audits

Better Training for Safer Food Initiative

A. LEBOUCHER

Health and

Consumers

Aims of the conference

• bring information about basic checks performed during inspection • define links between inspection and ownchecks including quality assurance • offer tools to verify HACCP plan • acquire information to perform official controls regarding traceability • propose examples of National control programs (NCP) • give an overview of FVO control

Health and

Consumers

Program of the conference

• Legal basis • Own-checks and quality assurance • Official controls in ABP chain, especially upon :

o HACCP plan o Traceability

• National control program • FVO audit

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Consumers

Legal basis • Regulation (EC) No 1069/2009 in Articles 22, 28, 29, 30, 45, 49 but also 44, 46, 47 or 48

• for controls enforces FVO on-the-spot-checks to insure harmonized application of ABP rules

• Regulation (EU) No 142/2011 in Art. 17, 32 • defines traceability and UE model for CD (annex VIII) • defines official control according to MS national program based on risk analysis (annex XVI) with respect to regulation (EC) No 882/2004

• Regulation (EU) No 142/2011 in Art. 6, 8, 9, 10, 18 • CA should only approve plant if complies with requirements laid down in • Annexes III, IV, V, IX, X, XI, XIII

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Consumers


• Legal basis • Own-checks and quality assurance • Official controls in ABP chain • National control programm • FVO audit

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Consumers

• Must comply with :

• written procedures, • implemented procedures (to be own-checked on the spot), • inspected procedures, • registered inspection

In particular must exist : • cleansing and disinfection procedures including vehicles, containers, areas used by means of transport, especially when ABP are handled • preventative measures against pests • regular inspection of environment and equipment • handling and storage of derived products to prevent recontamination • traceability and registration of non compliance

* List may be shorter depending on activities performed, see annex III, IV, V, IX, X, XI and XIII of Reg (EU) No 142/2011 setting requirements for each activity

Own-checks in ABP plants*

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Links with GGP and Quality Assurance

• Own-checks may be developed by operators through QA methodology • GGP describe and document practical tools for pre-required procedures for operators

• EU GGP exist : petfood only, since 2007

Own-checks in ABP plants

Safety

Regulation 183/2005/EC on Feed Hygiene lays down basic principles of safe production

and safety of all feed, including pet food. Sectors active in the feed chain were invited to

develop voluntary Guides to Good Practice validated by the EU and the 27 Member States.

FEDIAF's Code was validated already in 2007, an updated version

was subsequently EU validated in 2010.

Please click on "Safety" on the left navigation bar for downloading the latest,

officially validated version of the FEDIAF Guide to Good Practice plus a set of training modules.

Health and

Consumers

Links with GGP and Quality Assurance

•ISO 22000 or other QA system : √ is convenient to describe the process taking place in ABP plants, √ insuring a safety management system √ other certifications may exists (related to feed industry, pharmaceutics or else) √ still ISO 22000 certification is not approval nor registration under regulation (EC) No 1069/2009

Own-checks in ABP plants

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Consumers


• Legal basis • Own-checks and quality assurance • Official controls in ABP chain upon

o HACCP plan o Traceability

• National control programm • FVO audit

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Consumers

Tools for the inspection staff

• Official staff have legal rights to entering plants during ABP processing

• national organization of controls

• Officials may use a check list to perform control : Example : Ishikawa diagram/fishbone diagram for items to be checked

• Machine (technology) • Method (process and procedures) • Material (raw or derived, include waste) • Man Power (staff) • Measurement (Inspection) • Milieu/Mother Nature (Environment)

• In order to review all the plant during operations, including processing, own-checks, HACCP, general conditions on premices • In order to report information about compliance : to CA and operators

Official controls in ABP plants

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Consumers

Official control in ABP chain

• All chain is concerned but with major concern for processing plants • National risk analysis applies mostly on approved plants for 10 activities listed in Article 24 1 of regulation (EC) No 1069/2009 • Other specific official controls concern

√ Marking of derived products (MBM/fat of Cat 1 and 2) with GTH √ On site inspection of low capacity incineration plants handling SRM on a yearly basis √ Some activities listed on Articles 16 and 18 of regulation (EC) No 1069/2009, UE trade, importation and OF/SI

Health and

Consumers

Official controls in ABP chain

• Take place primarily during procedure for approval

• Are conducted : ●according to national control program ●especially in approved ABPs plants

Official controls check

● general conditions of hygiene of the premises, equipments and staff ● efficacy of own-checks ● implementation of HACCP if compulsory ● standards of the derived products after treatment, including sampling for analysis ● storage conditions ● links with other units located on the site such as farm, unit approved or registered according to regulations (EC) No 852 or 853/2004

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Consumers

•Will have to check for : o Experience of own-checks named as prerequisites (PrP) o Description of derived prodcuts to be put on the market o Existence of Hazard analysis which :

Has to be oriented towards ABP, categorisation, public and animal health, Postulates that ABP is at risk (all cat) but derived product are to be safe

o Experience of description of the process, is to be check on the spotb (chart flow)

Official Control upon HACCP plan

Health and

Consumers

way of determination of steps which are CCP especially for processing methods which

have to be authorised by CA including official verifications of registration

and efficacy of critical limits

existence of corrective actions on products and process

existence of internal audit, documentary system review


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Consumers

• takes time and trained inspectors

• leads CA to ask for corrective actions up to stopping of activity

• produces report pointing out - observed non compliances with ABP regulation - acceptable/unacceptable items especially concerning processing safety


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Consumers

Case study

• In CAT3/approved processing plant, chart flow is proposed

•Plant is producing PAP for petfood (meat meal) and for fertilizer (feather meal

including blood)

•Chart flow is for Petfood PAP


Health and

Consumers

Health and

Consumers

Case study

• In biogaz plant, a CCP proposed is the “hazard of the vehicle content to be spoiled on the road”

• Hazard identified : contamination of environment

• Critical limits is “spoilage of the soil and on land”

Comments : ?

• IDENTIFICATION OF HAZARDS : is road spoiling a hazard for biogaz production ?

• CCP=processing STEP, defined through critical limits- measurable values

• Such as … pasteurisation (70°C during 60 minutes)

or at least temperature and pH during anaerobic digestion !


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Consumers

Shall take place • during plant inspection, transport, at the starting point, before or during final use or at end point

In ABP plants, take place on • introduced material : search for links with CD and on site still existing material • material at expedition : search for links between process, including batch, material of origin, CCP compliance, CD and autorised destination • specific controls must apply for UE TRADE (PAP-Cat3/MBM-FAT-Cat1-2) or import/export

*Traceability is part of ownchecks for all ABP operators

Official Control

upon traceability*

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Consumers

Control upon ABPs plants

To conclude plant and inspection :

• To control ABP chain : need for knowledge about ABP regulation as well as other Reg (Feed/Food/Waste, ...)

Case study

• In a processing plant, an inspector previously in charge of waste and environmental topics has autorised

• on the same location, but not with the same equipment : 2 processing lines : 1 for PAP from poultry

meat to produce petfood material, 1 for feather and sludge to produce fertilizer.

• HACCP described only M7 and PAP/Cat3 from sole meat

• plant has been approved for processing PAP/cat3 for petfood use

•Questionable ?

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Consumers

Official Control upon ABPs and ABP plants, including HACCP

need • Training of CA, including HACCP assessment • Tools for inspectors : check list, sampling equipment • CA reporting

And ...

• National Control Program

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Consumers


• Legal basis • Own-checks and quality assurance • Official controls in ABP chain • National control program • FVO audit

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Consumers

Shall take place

●On yearly basis

●On approved plants

●Based on risk assessment

National Risk assessment will use

• Typology of existing plants (Nat list in 47) • Operators skills to corrective actions toward NC pointed out during previous inspections

National Control Program

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● Inspection rate, and indicator are national

● Detailed program, time-table, organisation will be local or national depending on size, organisation of MSs

National Risk assessment will create


Indicator

Linked with

inspection frequencies

ABP plants level of risk

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2 examples : Slovenia and France

Slovenia : 100 approved plants, among which 50 biogaz plants, 1 rendering plant of Cat1, territory is middle size

France : 500 approved plants among which 10 rendering plants Cat1, 50 petfood producers, 30 biogaz plants and 90 composting plants, territory is large size

Each MS has risk assessment and NCP

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SI : based on an indicator taking into account different items

Scale : HIGH, MED, LOW risk for each item : use of the same scale Indicator is composed of 7 items (activity, Cat, material origin, technical state, cooperation, ownchecks includ traceability, placing on the market)

Minimum rate of inspection to be followed by CA is : High risk plant : 2/year

Medium risk plant : 1/year Low risk plant : 1/2 years

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Consumers

FR : based on an indicator, calculated yeach year by local CA I =AxbxSxM

A : level of risk of approved plant (activity, CAT and material origin) : 15 to 40 b : yearly tonnage of derived products (outcoming material, scale depending upon activities) : 1 to 4 S : activity sensitivity regarding human and animal health policy : 1 to 2 M : management of plant, including ownchecks, HACCP and cooperation, 1 to 4

I = value from 15 up to 1280 Minimum rate of inspection depending of national priorities

and staff available 1/year >480

1 / 2 years <480 but >200 1/3years <200 but >100 and ¼ years if <100


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National Control Program To be calculated by officials in charge of ABP plant

An exercice: RENDAC in NL

A : level of risk of approved plant (activity, CAT and material origin) : C1 processing = A ? b : yearly tonnage of derived products (outcoming material, scale depending upon activities) : Sole plant in the NL b ? S : activity sensitivity regarding human and animal health policy : 1 to 2

In FR Cat 1 is “2” sensitive M : management of plant, including ownchecks, HACCP and cooperation, M ?

I = ? Minimum rate of inspection depending of national priorities

and staff available 1/year >480 for inspection (premices + HACCP+ traceability)

Will last 1 full day at minimum

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Consumers


• MSs create o Different indicators o Different scales o But based broadly on the same criteria

• MSs define or calculate

o Indicators but not in the same manner o as typology of plants, Ms organisations are different

•MSs have NCP o Based on risk assessment o Defining a yearly inspection rate, to be followed by officials

•MSs as CA get a general overview upon o Implementing ABP rules bu ABP plants and o Level of safety of the whole chain

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FVO audits

• Important tool for comprehensive and harmonized rules in the UE • For operators and competent authorities • Based on UE program of audits, according to main topics in ABP chain, such as links with feed ban, TRACES and animal health

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FVO audits

• Take place to check for harmonization and difficulties to implement regulations for MS • Through campaign choosing several MS 2012 – 2014 : ABP and OF/SI, 10 MS in 2012 • Necessarily general, as it covers principles of regulation (EU) No 142/2011 • But precise according to implementing regulation (EU) No 142/2011 • Help to adapt regulation component • as for unpalatable component • for OF/SI for PAP-Cat3/MBM-CAT2 • See BTSF/WG july Prag 2013

Health and

Consumers

• Are controls of the heart of ABP risk management system • Take place mainly in ABP approved plants • For which, GGP, HACCP, Quality Assurance, traceability are tools for operators to identify, check and supervise the ABP hazards • Official (FVO/CA) must observe and check the implemented system in order to control it as supervvisor to prevent any risk appearing from ABP for public and animal health

Thank’s for attention Questions on the spot ?

Controls upon management of safety

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