Two audits by the European Commission’s health and safety agency have studied the microbial safety of food of non-animal origin (FNAO) in Estonia and the Netherlands.

The first remote DG Sante audit, in April 2021 in Estonia, found the official control system was effective but there was a lack of flexibility and issues with follow-up of Listeria positives.

It covered before, during and after harvest of FNAO including seeds intended for sprouting and sprouts. It was the first time DG Sante had looked at controls on FNAO in Estonia. There are not many sprout-producing establishments in the country.

The Agriculture and Food Board, created in January 2021, is responsible for official controls along the supply chain at businesses covered in the audit. Certification against private food safety schemes is not common among operators in Estonia.

Risk-based work
Auditors said the procedure for allocating the risk level to operators lacks flexibility.

The minimum risk score is given when production is below 25 tons per year; from 26 to 300 tons is considered as medium risk, and above 300 tons as high risk. However, there is no link from quantities to the type of product. So, a big producer of sprouts would rarely fall under the high-risk category for production volumes, while it is more likely that arable farms such as cereals or potatoes, even with a relatively low number of hectares, would be categorized as the highest risk.

Some elements can only be assessed after the inspection, such as number of non-compliances and the inspector’s assessment of the operator’s own-checks. However, risk can be and is recalculated after an official control. Good agricultural practices and good manufacturing practices implemented by operators are not taken into account for the risk assessment to set the frequency of official controls.

The audit team noted that despite deficiencies found at a sprout producer in 2020, the recalculated risk assessment concluded it fell under the medium risk category due to production volume.

There is a monitoring plan of processors to identify contamination with Listeria. The system was effective to detect contamination in the plant. However, corrective actions after finding Listeria fall short in ensuring that operators follow-up on the contamination to ensure it does not happen again.

After positive Listeria findings at two processing firms, monitoring plans were amended, increasing the number of environmental samples to detect Listeria monocytogenes from once a year to once every quarter or twice a year. However, Estonian guidance states that if there is a positive result the frequencies for analysis should be higher, such as once a week.

The 2021 plan included, for the first time, norovirus and hepatitis A virus in berries that were analyzed in an accredited lab of another country. Auditors said a lack of checking temperature of incoming official samples prevents labs from identifying failures in temperature management that may compromise the reliability of results.

Dutch audit findings
The second remote audit, in March 2021 in the Netherlands, praised training and staff knowledge but found issues with primary production and checks on sprout producers.

Netherlands is one of the main producers of fruits and vegetables in the EU and a top importer of seeds for sprouting.

Factors such as size of the farm or establishment and production volume were not taken into account but will be part of a new risk analysis system. At the time of the audit, frozen berries and vegetables and pre-cut vegetables had the same inspection frequency as potatoes and other vegetables to be eaten after cooking and non-compliances were not used for the risk-based plan.

A project to establish levels of compliance with microbiological criteria on fruits and vegetables at cutting plants was cancelled in 2020 because of the COVID-19 pandemic.

If a food business has a third-party assurance scheme certified to BRC or FSSC 22000, for example, the frequency of audits could be reduced but this does not apply to primary production.

Growers and sprout producers
In primary production, controls are done by special projects with an emphasis on pesticides. Each year, a crop category is identified and a number of food companies are randomly selected for microbiological inspections. Regardless of the outcome, a different area is chosen the following year and it is not clear when a category with a problematic outcome will be inspected again.

A focus on chemicals means the likelihood of finding non-compliances with microbiological requirements is lower and problems detected do not influence future planning. This could lead to associated food safety risks being underestimated, weakening the system of official controls and enforcement of EU legislation, said auditors.

In response, the Netherlands Food and Consumer Product Safety Authority (NVWA) said it was evaluating how to prioritize microbiological inspections at grower level. A food safety risk assessment of crops, including products intended to be eaten raw, is scheduled to be published in 2022. It will be used to improve surveillance and enforcement.

In 2021, inspections on management of microbiological risks at primary production sites were planned by Dutch authorities. Most were aimed at production of soft berries to be eaten raw and some on products like lettuce.

Shortcomings in verifying compliance with import certificates and national rules on sampling frequency of final products that are not in line with EU legislation weaken controls of sprout producers and could result in contaminated product being placed on the market. A specific checklist for sprout-producing firms has been available since 2021 to ensure inspectors see actual import certificates.

NVWA promised to revise the domestic guideline in 2021 to remove the option of a lower sampling frequency and to notify sprout producers.

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