The effectiveness of a control system for food of non-animal origin in Poland, which verifies that microbiological risks are detected and reduced, has been questioned in an audit report.

The assessment by DG Sante, the European Commission’s unit for food safety and health, covered microbial safety of food of non-animal origin (FNAO). It found authorities do not know the amount of unregistered primary producers and inadequate controls at processing plants impacts enforcement as non-compliances were rarely detected.

An audit from late June to early July 2019 included three frozen green vegetables and soft fruit processors, one farm handling green leafy vegetables, and three producing red and black currants. The National Reference Laboratory for foodborne viruses in food of non-animal origin and one regional lab for microbiology were visited.

The visit reviewed the official controls for food hygiene to prevent microbiological contamination in FNAO, including seeds intended for sprouting and sprouts. It looked at planning and implementation of official checks, control procedures and sampling performance.

A previous audit in 2016 raised issues such as performance of official controls and lab testing, notably reliability of results. Recommendations made at that time on low control frequencies, their inconsistent application, and incomplete registration of primary producers had still not been addressed in the 2019 audit.

Primary producer problem
Primary producers of FNAO must by law apply for a registration but authorities are aware not all such producers are registered. The number of registrations increased from about 57,000 in 2016 to 85,000 in 2019; 43,000 of these were producers of FNAO intended to be eaten raw. Official controls of primary producers from 2016 to 2018 revealed only one non-compliant sample because of Salmonella.

A factory processing and freezing vegetables and soft fruit in one district was involved in several RASFF alerts, the last one in 2018 for norovirus in frozen red currants. Overall, 23 primary producers had been identified as suppliers for this consignment but none were registered at the time of the RASFF notification. This sites supplier list for 2019 still contained unregistered primary producers of soft fruit.

Auditors found that during investigations of RASFF alerts, in most cases no official samples were taken to confirm the results of checks by operators.

Controls should take place once per year if the operator is in the high risk category, once every 18 months for medium risk sites and once every 66 months for low risk plants. In 2018, out of 85,000 primary producers of FNAO below 3,000 were inspected and 75 found to be non-compliant.

The audit team found that in the region responsible for the most registered primary producers of soft fruit and ready-to eat vegetables, the number has risen from 8,658 in 2016 to 13,563 in 2018. However, inspections decreased from 543 to 452 during this period.

DG Sante said the primary producer risk assessment system lacks efficiency because of the shortage of key parameters at registration, such as crop surface and production volumes, and does not allow limited resources to be directed to the riskiest primary producers.

There are 283 FNAO freezing processors approved in Poland and 512 inspections were carried out in 2018. Data from official controls of freezer and processing establishments shows there were no non-compliant samples from 2016 to 2018.

In one of three freezing factories visited, the audit team noticed several non-compliances. Authorities issued an administrative decision and production was temporarily halted. An action plan was put in place to correct the shortcomings.

Knock on impact
The audit team was shown staff training files but instruction on the risks caused by Listeria monocytogenes in FNAO production were not included. Environmental swabs to detect the pathogen were only taken correctly in one of three processors visited, and responsible officials were not aware of the correct procedures to take these samples.

This has a negative impact on effectiveness of official controls aimed at verifying potential microbiological risks are adequately detected and reduced to an acceptable level by food businesses, according to DG Sante.

Because of shortages in resources the official control frequencies for primary production could not be fully implemented. This was caused by the increasing workload and rise of registered primary producers without more staff, according to the report.

In the processing plants visited, planned frequencies were met or surpassed. However, the inspectors doing official controls of FNAO processors have a low number of inspections per year, which makes it difficult for them to gain and maintain a sufficient level of expertise.

Due to this, official controls cannot always be implemented effectively, resulting in inadequate checks at some processors. This impacts enforcement, as non-compliances were rarely detected.

At the time of the audit, the National Reference Laboratory for foodborne viruses was recently nominated in this role and had not started work because of a lack of budget. The audit found cooling capacities for samples in both labs was limited and if there was a foodborne outbreak they would probably not be able to handle and store the high amount of samples necessary.

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