The European Commission’s health and safety unit has published two reports assessing controls on food of non-animal origin (FNAO) in Germany and Greece.

An audit in Germany in June 2023 found a system for official controls on food of non-animal origin, with a robust monitoring plan and suitable lab capability, but several problems impacted effectiveness.

These included stages before and during harvest being excluded from official controls for non-risk-based reasons and poor knowledge by inspectors concerning Hazard Analysis and Critical Control Point (HACCP) verification and the requirements on Listeria monocytogenes in ready-to-eat food.

Deficiencies were hardly reported and rarely followed up. Also, the legislation for sprouts was not correctly applied by food businesses and not enforced systematically by authorities.

Checklist problems
At the time of the audit, 15 sprout-producing establishments were approved in the country.

Saxony-Anhalt representatives informed the audit team that official controls before and during harvest started in May 2023. Bavarian officials said such inspections were requested but not carried out due to staff shortages. From 2023, controls before and during harvest will be done annually.

Inspectors in Bavaria told auditors they did not need a checklist for inspecting processors as they have adequate training and experience. They found deficiencies, such as rusty equipment and condensation on the ceiling, that were not detected during previous visits. However, shortcomings in staff behavior while handling and processing products were overlooked.

Inspectors of sprout-producing sites missed that import certificates for mung beans are a legal requirement and that these certificates were unavailable at the premises.

There was no written evidence of follow-up inspections on the numerous recurring non-conformities identified during the official control. The audit team also found that issues with hygiene requirements were not always remedied by the business within the required deadline, as instructed by authorities.

In both states, authorities did not verify that companies making ready-to-eat foods take samples of the processing areas and equipment for Listeria monocytogenes following EU regulations. Not all inspectors were aware of environmental control measures for Listeria that firms have to implement or of which measures to take in the case of positive results.

Seven recommendations covered official controls before and during harvest, ensuring sprout-producing sites meet requirements in EU legislation, the need for authorities to provide technical support and training, and checking controls that looked at business measures to reduce the risk associated with Listeria monocytogenes.

Greek findings
The audit in Greece in May 2023 found the planning for official controls did not include checks at the farm level before and during harvest. Three recommendations were made.

Later stages of the production chain are covered by an official control system and supported by a network of official laboratories. However, deficiencies are rarely reported, and when recorded, they are rarely followed up, weakening the system’s effectiveness.

The review covered official controls for food hygiene to prevent microbiological contamination in food of non-animal origin, including seeds intended for sprouting and sprouts. There are no establishments registered and approved for sprouts and seeds for sprouting.

The audit team accompanied inspectors visiting processors and found that they did not identify shortcomings, such as potential cross-contamination by staff, dirt over the exposed products, or condensation on the ceiling of cooling rooms.

Several private good agricultural practice (GAP) schemes include monitoring for microbiological risks of FNAO. These schemes have not yet been considered in the planning of official controls. International buyers also inspect processors.

Inspectors told auditors that deadlines for corrective actions are not set if the non-compliances are minor. Still, if they are significant, a deadline is specified for the company to take action.

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