A remote audit has found that Norway complies with European hygiene requirements for ready-to-eat (RTE) food but there are areas for improvement.

The EFTA Surveillance Authority (ESA) findings follow an assessment during 11 days in October 2020. The European Free Trade Association (EFTA) has jurisdiction in Iceland, Liechtenstein, Norway and Switzerland.

ESA looked at how Norway implements European Economic Area (EEA) food hygiene requirements for RTE foods such as cheese, cured meats and smoked salmon.

A caterer that makes RTE meals for in-flight services, a dairy producing cheese from unpasteurized milk, a salad and sandwich producer, four fishery sites, one meat product plant ,and the National Reference Laboratory (NRL) for food pathogens were included in the audit.

The ESA noted conclusions of the remote audit are limited in certain aspects because the team was unable to verify authority activities at the establishment level. Verification may be needed in the future when travel is permitted.

Risk based controls assessed
The Norwegian Food Safety Authority (Mattilsynet) is developing a new model for risk based official controls. Frequency of current official controls basically remained the same from one year to the next and RTE establishments received one visit each year.

The audit team reviewed authority actions during an outbreak of Listeria monocytogenes. No inspection or document control was carried out at the retail level as described in the guidance and no follow-up inspection was performed to see how much product had been returned to the producer despite very high levels of Listeria in the recalled batch.

The same business failed to inform authorities of positive Listeria monocytogenes results in brine used to produce the affected batch, which had been detected months earlier. No enforcement measures were taken when authorities became aware of this information.

Auditors said the measures taken in relation to some non-compliances were weak as long periods were given for corrective actions and follow-up was not always adequate.

The current approach is not paying enough attention to HACCP based programs and microbiological requirements in EU regulation 2073/2005. In an establishment reviewed by the audit team, the site had been operating for years with no food safety procedures based on Hazard Analysis and Critical Control Point (HACCP) principles. It had only recently been told to correct this non-compliance within three months, which was extended for a further three months.

Some authorities did not fully understand the technical microbiological requirements for RTE foods. Two inspectors considered the requirement for sampling processing areas and equipment for Listeria monocytogenes was met if only brine was sampled and not all staff were aware environmental sampling should occur during production rather than after cleaning of the premises.

Business registration
The system for registration and approval of establishments is generally working well. However, guidance is not always followed and has resulted in non-approved sites placing food on the market and product being transported between factories with no identification mark.

Auditors reviewed how one department implemented the process for a recently approved RTE food establishment. Following the food business owner’s application, the authority did an onsite visit and granted conditional approval for three months. However, this approval came five weeks after production had started. During this period, the establishment placed food on the market with an identification mark.

The recently approved RTE establishment was given the approval number of the site it replaced. However, authorities confirmed there was a period when both were operating and using the same identification mark with product transported from one plant to the other for marking.

The audit team made five recommendations including authorities should ensure an establishment subject to approval does not operate unless this has been granted, check that food firms apply an identification mark before items leave the site of production, and when non-compliances are identified action is taken to ensure the operator solves the situation and prevents it from happening again.

In response, Mattilsynet said there are plans to revise the control template for approval of food businesses by April 2021. Guidance on the description of using an identification mark when an establishment is moving to a new premises will also be looked at by October 2021.

Findings from the remote audit will be presented to regional officials where it will be emphasized that in the case of non-compliance, it is important to decide proportional measures and time limits. A focus will also be on the importance of follow-up by verifying non-compliances are corrected within a defined period.

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