Two audits by the European Commission’s health and safety unit have looked at controls on food of non-animal origin (FNAO) in Hungary and Bulgaria.
An audit by DG Sante, in May and June 2022 in Hungary, found that a shortage of staff and experience was weakening the system of official controls. Attention focused on primary production, frozen products, pre-cut fruits and vegetables, sprouts and seeds intended to germinate.
The development of a guide on GAP for the production of fruits and vegetables, which includes information on how to prevent microbiological contamination for primary producers, is still in progress, the same as during the previous audit in 2019. Progress was noted in the system of official control of FNAO and three of six recommendations made in 2019 had been addressed by the 2022 evaluation.
The audit team was told that in 2019, 2020 and 2021, 183 of the 240 planned inspections in primary production were carried out for green leafy vegetables and soft fruits, resulting in non-compliance. The difference between planned and performed checks was due to a shortage of resources and the COVID-19 pandemic, according to officials.
Problems along the supply chain
During the same three years, 157 of 164 inspections were conducted at FNAO freezing and pre-cut establishments, resulting in 20 non-compliances related to areas such as cleaning and incorrect or non-existent procedures for environmental sampling of Listeria monocytogenes and 36 official non-compliant samples. .
In the processing plants, 167 official inspections of 183 planned visits were carried out and 20 non-compliances were detected in topics such as hygiene, hazard analysis and critical control points, maintenance, pest control, workers’ health certificates, analysis plans for samples and risk. product classification.
In primary production, non-compliances are rarely detected and compliance with requirements is affected. The effectiveness of official controls is limited by emphasizing testing over good practices during production, the auditors said.
At the time of the audit, in most counties, if the analytical result is satisfactory, no corrective action is required by the company as the inspection was deemed to be compliant. Due to this approach, detected breaches were not documented or rectified. However, new procedures are being implemented so that sampling only has a monitoring function and for each nonconformity, a corrective action plan will be required.
From 2019 to 2021, out of 1,030 official samples, 57 were positive for Listeria monocytogenes. In a retail survey of frozen vegetables, out of 288 official samples, 104 tested positive, demonstrating the system’s ability to detect Listeria but also the discrepancy between official controls and the food companies’ own controls. The findings did not trigger any action by authorities.
Whole-genome sequencing of Listeria isolates in retail frozen vegetable samples in 2018, 2020, and 2022 found no match to a strain that caused an outbreak in multiple countries between 2015 and 2018 with 54 cases and 10 deaths.
An audit by DG Sante, in May 2022 in Bulgaria, found a mixed picture at different points in the supply chain. Some shortcomings were also noted during the last audit on the same topic in 2015.
In primary production, the criteria for targeting official controls are not adequate to identify crops or farms at higher risk. Combined with the authority not having adequate data on the number of operators or the nature of their production, this hampers the effectiveness of the control system in identifying higher-risk products, the auditors said.
National staff told the audit team that microbiological risks would be irrelevant pre-harvest in soft fruits and leafy vegetables because they undergo treatments such as rinsing at pickers and processors. The auditors said there is scientific evidence outlining the risks, as well as an EU guidance document on microbial risks in primary production. EFSA’s views on the microbiological risk classification of different crops had not been taken into account when planning the controls.
The auditors said that the control system for outbreak production sites is not capable of identifying non-compliances or effectively enforcing EU requirements. For processors, the system is satisfactory but has some weaknesses in monitoring Listeria monocytogenes.
Bulgarian officials said the training will be provided to inspectors and will include guidance on hygiene from the European Association of Sprout Producers. Guidelines and a checklist for carrying out official controls at sprout production sites will also be developed.
Some facilities at the National Center for Food Safety in Sofia were outdated, including the norovirus and hepatitis A laboratories. Due to lack of funding, sufficient quantities of all consumables required for testing were not available. There were also no accredited methods for the detection of norovirus and hepatitis A but accreditation is planned for 2023.
The auditors also found that the composition and pooling of the samples were not verified, which could lead to false negative results.
The audit team followed up on a 2021 RASFF notification on hepatitis A in raspberries with raw material from Bulgaria and Poland. The corresponding investigations were carried out in the processor and another batch with the same raw material was negative. However, the investigations did not cover the primary producers of raspberries and authorities were unable to identify the root cause.
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