European officials have evaluated the way the United States controls microbiological contamination in food of non-animal origin that is destined for Europe.
The review by DG Sante, the European Commission’s unit for food safety and health, found there are no specific microbiological hazard control procedures for exports of almonds, leafy vegetables and frozen soft fruits bound for the EU.
The audit in September 2019 included six farms producing almonds, leafy greens, strawberries, raspberries and blueberries, five companies processing and packing for exports to the EU and three EU exporters.
It assessed the system of official controls in food hygiene to prevent microbiological contamination during production of food of non-animal origin (FNAO), such as almonds, seeds for sprouting and fresh and frozen fruit and vegetables for direct consumption.
Seeds for sprouting sole shortcoming
The official control system for FNAO was in the first phases of implementing new requirements set in the Food Safety Modernization Act. Official controls at primary production on potential microbiological risks in non-sprout produce for EU export started in spring 2019, but inspections of sprout farms began in autumn 2017.
The system largely ensures FNAO were produced under conditions which meet the EU’s hygiene rules for primary production and processing. Potential risks from lack of official controls are mitigated as most processors or exporters were part of producer groups; third party certified against international food safety standards and regularly received inspections and audits including some of primary producers from customers.
Shortcomings were seen related to implementation of traceability and verification of Good Agricultural Practices (GAP) for seed growers on the spot which was not in line with EU requirements. This could lead to exports of seeds for sprouting that were not produced under conditions which comply with EU regulation and could be of higher microbiological risk, according to DG Sante.
The Seeds for Sprouting Export Certification Program destined for EU export is overseen by the Agricultural Marketing Service of USDA. Audit requirements include a traceability exercise and mock recall reflecting EU regulations. Exporters of seeds for sprouting need to be approved and import certificates must be issued by AMS.
In 2017, exports of leafy vegetables from the United States. to EU was 3,042 tons and decreased in 2018 to 607 tons. The United States sent 658 tons of fresh strawberries to the EU in 2017, and 651 tons in 2018. For fresh cranberries, bilberries and other such fruit, exports were 1,683 tons in 2017, and 1,211 tons in 2018, according to Eurostat data.
In 2018, 264,000 tons of almonds were sent to the EU based on FDA and Almond Board of California statistics. Almonds sent to the EU without being treated to control Salmonella are labeled “unpasteurized.”
Processors considered to be high risk have routine inspections every three years and low risk are every five years. There is a risk specific and HACCP based official control system for handlers and processors that leads to different inspection requirements and approaches for different commodities.
Examples of testing results
The audit team visited an almond handler involved in a Rapid Alert System for Food and Feed (RASFF) notification for Salmonella in untreated almonds. The previous inspection report from FDA indicated two shortcomings that were rectified. The processor implemented a HACCP plan, and took samples consisting of 20 incremental samples for microbiological testing of each consignment before shipping to the EU. After the RASFF notification, the food safety plan was revised to increase the size of the analytical sample from 25 grams to 350 grams.
The audit team was told that from 406 samples in the previous year, four were Salmonella positive. According to the firm, these consignments were pasteurized and not exported.
The auditors also went to a processor of leafy vegetables that is exporting to the EU and processes leafy vegetables from an estimated 250 growers. The processor has official controls every three years.
A microbiological sampling program of produce in the field before harvest tested for Salmonella, E. coli, enterohemorrhagic E. coli (EHEC) and E. coli O157:H7.
The processor took about 32,000 samples in 2015, with six positives; in 2016 about 35,000 samples with six positives; in 2017, about 25,000 samples with one positive, and in 2018 about 30,000 samples with five positives. About 62 percent of positive samples contained EHEC, a third had Salmonella and 4 percent contained E. coli O157:H7.
When a positive sample is found, the associated production plot is excluded from harvesting and a sampling campaign is performed at the plot to identify the root cause of contamination.
The audit team also visited a processor of frozen berries and frozen vegetables subject to official controls by FDA every three years. In a microbiological sampling program of incoming frozen produce and final product, samples were analyzed for Salmonella, E. coli, Listeria, Norovirus and Hepatitis A.
In 2018, about 70,000 samples were taken with one or two positive for non-pathogenic Listeria. FDA was informed about the result in time and the related batch and similar consignments were rejected at reception. The company told auditors that the supplier destroyed the batch.
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