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In response to information provided by the Competent Authority, any factual error noted in
the draft report has been corrected; any clarification appears in the form of a footnote.
EUROPEAN COMMISSIONDIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY
Health and food audits and analysis
DG(SANTE) 2014-7151 - MR
FINAL REPORT OF AN AUDIT
CARRIED OUT IN
BELGIUM
FROM 12 NOVEMBER 2014 TO 21 NOVEMBER 2014
IN ORDER TO
EVALUATE THE FOOD SAFETY CONTROL SYSTEMS IN PLACE GOVERNING THE
PRODUCTION AND PLACING ON THE MARKET OF POULTRY MEAT AND
PRODUCTS DERIVED THEREFROM
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Executive Summary
This report describes the outcome of an audit in Belgium. The audit took place from 12 to 21
November 2014 to assess whether the organisation of the competent authorities and the
implementation of national provisions, in respect of controls of poultry meat and products derived
therefrom comply with EU requirements.
The report concludes that a consistent and well documented food safety control system covering
poultry meat and products derived therefrom is in place in Belgium. The system works generally
well. Some non-compliances were identified, mainly related to the actual implementation of the
control system.
The report includes a number of recommendations addressed to the competent authority aimed at
enhancing the control system in place.
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Table of Contents
1 Introduction ....................................................................................................................................1
2 Objectives and scope......................................................................................................................1
3 Legal Basis.....................................................................................................................................2
4 Background ....................................................................................................................................2
4.1 Previous Audits .......................................................................................................................2
4.2 Production information............................................................................................................2
5 Findings and Conclusions ..............................................................................................................2
5.1 Legislation and implementing measures .................................................................................2
5.2 Competent authority ................................................................................................................3
5.3 Official controls of production and placing on the market......................................................7
5.3.1 Controls at farm level.......................................................................................................7
5.3.2 Approval procedures........................................................................................................8
5.3.3 Controls in slaughterhouses: Ante-mortem inspection and post-mortem inspection .....9
5.3.4 Animal welfare at slaughter...........................................................................................11
5.3.5 Controls at establishment level ......................................................................................11
5.3.6 Controls on FBO compliance with microbiological criteria for foodstuffs- official
sampling .......................................................................................................................................145.3.7 Controls on traceability-Labelling-Identification..........................................................16
5.3.8 Controls on the use of food additives.............................................................................17
5.4 Rapid Alert System for Feed And Food (RASFF) ................................................................17
5.5 Laboratories...........................................................................................................................18
6 Overall Conclusions .....................................................................................................................19
7 Closing Meeting ...........................................................................................................................19
8 Recommendations........................................................................................................................20
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ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT
Abbreviation Explanation
BELAC Belgian Organisation for AccreditationCA Competent Authority
COCO Coordinated Inspections
DG Directorate General
DG(SANCO) Health and Consumers Directorate-General
DMO Appointed Veterinarian
EC European Community
EU European Union
FASFC Federal Agency of the Safety of the Food Chain
FPS-HSFCE Federal Public Service for Health, Safety of the Food Chain and
Environment
FBO Food Business Operator
FCI Food Chain Information
HACCP Hazard Analysis – Critical Control Points
IEC Department of Import and Export ControlMD Ministerial Decree
MSM Mechanically Separated Meat
NICU National Implementation and Co-ordination Unit
NRL National Reference Laboratory
PCU Provincial Control Unit
RASFF Rapid Alert System for Feed and Food
RD Royal Decree
SNCP Salmonella National Control Programme
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3 LEGAL BASIS
The audit was carried out under the general provisions of EU legislation and, in particular,
Article 45 of Regulation (EC) No 882/2004 of the European Parliament and of the Council of
29 April 2004 on official controls in Member States performed to ensure the verification of
compliance with feed and food law, animal health and animal welfare rules.
A full list of the EU legal instruments referred to in this report is provided in the Annex and
refers, where applicable, to the last amended version.
4 BACKGROUND
4.1 PREVIOUS AUDITS
A previous audit took place in 2009 (ref. DG(SANCO)/2009/8063). This audit highlighted
shortcomings in relation to notification of national legislation concerning direct supply by the producer to final consumer of small quantities of meat from poultry slaughtered on farm,
approval of establishments, shortcomings in relation to EU requirements at establishment
level and washing of carcases before post-mortem inspection (PMI).
The audit report, which is published on the SANTE Directorate-General Internet site at
http://ec.europa.eu/food/fvo/audit_reports/details.cfm?rep_id=2400
made a number of recommendations to the CA. Written guarantees have been received from
the CA in relation to the implementation of those recommendations.
4.2 PRODUCTION INFORMATION
The audit team was informed by the CA that 478,049 tonnes of poultry meat were produced
in Belgium in 2013.
5 FINDINGS AND CONCLUSIONS
5.1 LEGISLATION AND IMPLEMENTING MEASURES
Legal requirements
Article 4.2 (e) and Article 8 of Regulation (EC) No 882/2004.
Articles 1(3) (d), Article 1(4) and Article 10 of Regulation (EC) No 853/2004.
Findings
The CA for the poultry sector is the Federal Agency of the Safety of the Food Chain
(FASFC). FASFC informed the audit team that it follows the relevant EU and national
legislation.
The law of 4 February 2000, regarding the creation of FASFC, gives the CA the authority toimplement the control system. The Royal Decree (RD) of 22 February 2001, regarding the
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organisation of the controls performed by the FASFC, is the legal basis for the CA to carry
out control activities and take measures.
Other relevant pieces of legislation as regards the scope of this audit are:-
RD of 16 January 2006 laying down the rules for the registration, authorisation and
approval of establishments.
RD of 22 December 2005 establishing the frequency of inspections requiring the
presence of a staff member of FASFC at premises of the meat and fish sector within
the context of the control programme of the FASFC.
RD of 14 November 2003 on own-checks, notification requirement and traceability in
the food chain.
Ministerial Decree (MD) of 22 March 2013 on the flexibility of own-checks and
traceability rules.
In addition, the CA has prepared RDs as regards hygiene requirements which aresupplementary to Regulations (EC) Nos 852/2004, 853/2004 and 854/2004.
There is national legislation (RD of 07 January 2014) concerning the direct supply by the
producer, of small quantities of meat from poultry slaughtered on the farm to the final
consumer or to local retail establishments directly supplying such meat to the final consumer
as fresh meat (Article 1 (3) d of Regulation (EC) No 853/2004). The relevant national
legislation has been notified to the European Commission.
A wide range of detailed procedures, checklists and internal instructions have been put in
place by the CA to assist all staff performing official controls. These are available via CA
website.
A comprehensive review of Belgian legislation and documented procedures for official
controls in the poultry sector was not carried out as part of this audit. However, the audit
team noted that some discrepancies exist between EU legislation applicable to
microbiological criteria and instructions for officials on this topic (for more information see
Chapter 5.3.6).
Conclusions
National legislation related to the performance of official controls on the production and
placing on the market of poultry meat and products derived therefrom has been issued and, in principle, is in line with EU legislation.
Documented procedures for official controls have been produced and in principle are in line
with EU requirements with the exception of the instructions for official staff related to
microbiological criteria.
5.2 COMPETENT AUTHORITY
Legal requirements
Article 4, 6, 8 and 54 of Regulation (EC) No 882/2004.
Section III of Annex I to Regulation (EC) No 854/2004, in particular Chapter III and IV.
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Findings
A detailed description of the CA responsible for official controls in Belgium can be found in
the country profile at:
http://ec.europa.eu/food/fvo/controlsystems_en.cfm?co_id=BE
The two main responsible authorities as regards food safety are the Federal Public Service for
Health, Safety of the Food Chain and Environment (FPS–HSFCE) and the FASFC.
The FPS–HSFCE is responsible for the preparation of product standards and general policy
for food of animal origin.
The FASFC is the CA for the control, testing and inspection of food at all stages of the food
chain, including poultry meat and products derived therefrom. It is also responsible for the
preparation of process standards in the form of operational legislation.
Within FASFC, the Directorate General (DG) Control co-ordinates control activities while its
eleven Provincial Control Units (PCU) carry out inspections and enforce corrective measures
at establishment level within their territories.
The supervision of PCUs is the responsibility of two regional directors (one for Flanders and
the second covering Wallonia) who are the co-ordinators between PCUs and the central CA.
An important role as regards co-ordination of controls and uniform implementation of
procedures at PCU level is played by the National Implementation and Co-ordination Unit
(NICU). Every year NICU organises co-ordinated inspections known as COCO missions, the
purpose of which is to harmonise controls across Belgium and increase food business
operator (FBO) professionalism, auditors' competence and efficiency of controls. Duringthese inspections, which are carried out in establishments by NICU's representatives and
officials working at central and PCU level, NICU is in the position to verify the consistent
application of instructions and detect problems weakening the control system. NICU report to
the Directorate General (DG) Control and propose improvements when problems are
identified.
The official tasks are carried out at establishment level by official veterinarians, either PCU
officials or private veterinarians appointed by FASFC known as DMOs. The CA informed
the audit team that there are no official auxiliaries in Belgium.
DG Laboratories, which is another directorate within FASFC, co-ordinates all activities on
analyses carried out by the five official CA laboratories and CA approved external
laboratories.
Training
The CA at central level co-ordinates training for FASFC officials and in conjunction with
each PCU decides what training should be provided. Training plans are drafted taking into
consideration the presence of new control areas or findings i.e. from internal/external audits
and COCO missions. Training needs of officials are identified by the PCU through the annual
appraisal system and training tailored on a case by case basis.
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The CA does not provide training to DMOs but these are obliged to ensure their own ongoing
training. At PCU level, DMOs are annually evaluated as regards their performance and
training undertaken.
Evidence of training provided to CA staff was available to the audit team.
In general staff met in various locations by the audit team were suitably qualified and in
general familiar with national and EU requirements.
Audits
Among others, an internal audit on the organisation and inspection of own-check system in
the processing sector was conducted in 2013 by the internal audit service (AIQP) of the CA
on the PCU of the Luxembourg province. This audit did not specifically cover poultry meat,
nevertheless poultry establishments were visited. An action plan was prepared, deadlines for
the shortcomings identified were set and some corrective actions had been already taken. The
audit team noted that one shortcoming related to traceability in a poultry establishment had been identified by the AIQP auditors.
Organisation of official controls
Establishments are subject to official controls at frequencies planned centrally by the CA
every year and on the basis of risk assessment criteria. The official controls at establishment
level are carried out by either PCU officials or DMOs following an annually established
inspection programme.
A fixed frequency is applied to each category of establishment which can be adapted to an
FBO’s risk profile. This risk profile is established applying a score system which takes into
consideration factors such as presence or absence of a CA validated own-check system and
FBO compliance history (both inspection results of the last three years and record of
enforcement measures of the past two years). The higher the score given to an establishment,
the lower its allocated frequency of inspection. The audit team noted that the results of
inspections are taken into account with a time-lag of up to 14 months.
The establishments must have an HACCP programme in place for their approval.
Nevertheless Belgium has introduced an additional guarantee concerning the HACCP plans:
FBO could apply for the validation of the own-check systems on a voluntary basis. The
validation of the own-check system is carried out through audits by either the CA or CA
approved independent auditing bodies. A list of the approved auditing bodies, which hold
accreditation issued by the Belgian Organisation for Accreditation (BELAC), is available on
the CA website. Validation of own-check system is dependent on a favourable audit result
from the CA or independent auditing body and this has an impact on the determination of the
inspection frequency which is reduced.
When the above mentioned audits are carried out by auditing bodies, the report with the
outcome of the audit is only given to the FBO audited. However, where the auditing body
identifies serious deficiencies posing a risk to public health they must inform the CA. The CA
official responsible for the control of such an establishment has discretion as to whether or
not she/he asks the FBO to provide the audit results and take them into account during
official inspections (for more see Chapter 5.3.5 under the section Findings related to HACCP
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based procedures).The CA informed the audit team that a new procedure which allows them
to suspend the validation when official controls identify that establishments do not meet the
necessary requirements has been introduced1.
The audit team noted that:-
based on the inspection results in the three preceding years, the highest an
establishment can score is 20 points (positive results),
where no infringements have been recorded over the last two years the highest an
establishment can score is 20 points,
an establishment with a validated own-check system is awarded 40 points.
In one meat processing establishment visited where multiple activities were taking place,
(one of which had a validated own-check system), the general hygiene conditions were
inadequate and a low inspection frequency (four inspections per year) was allocated by the
CA. The audit team observed that according to CA instructions, the establishment should be
inspected eight times per year. The PCU had not questioned the low frequency allocated by
the central CA to this establishment although there was a history of numerous repeated
shortcomings detected on-site during official visits. The CA at central level explained that a
mistake had been made in the calculation of the frequency and the PCU should have checked
the inspection plan received and informed the central CA as regards its correctness.
All the establishments visited were under regular official control and the inspection frequency
was respected in all cases. Evidence was seen that the PCUs receive the annual inspection
programme produced by the CA, which indicates the number of inspections to be performed
and the areas (known as scopes) to be covered in each establishment during official controls.
In all establishments except slaughterhouses, the PCU official is obliged to carry out at least
an annual comprehensive inspection while the DMO performs checks in specific targeted
areas as planned by the CA. In the case of slaughterhouses, exclusively comprehensive
inspections are carried out and always performed by PCU officials. DMOs conduct specific
checks on animal welfare, refrigerated vehicles and own-check systems.
Several uniform checklists specifically weighted for each area to be inspected and for each
type of establishment are used during official visits and are available to relevant staff via
intranet and internet. When an official creates an inspection (called a mission) in a CA
database known as FoodNet, the electronic system generates automatically the requiredchecklists along with the technical sheets to facilitate the official while performing controls.
The areas covered by the checklists to verify compliance with legal requirements are, among
others: infrastructure, equipment and hygiene, own-check system, microbiological criteria,
animal by-products, packaging and labelling, traceability and animal welfare. Each item sets
out the legal requirement the FBO has to comply with, has a specific score and is ranked into
one of the three possible categories (major, minor or item weighted 0 where a different
authority is competent). The final results of these checklists are categorised automatically and
1 In their response to the draft report the CA noted that it is correct that there was no procedure drawn up by theCA before November 2014, but the possibility of suspension was already provided for in the legislation (Royal
Decree of 14 November 2003) and this possibility of suspension was implemented, although rarely, by the CA
before November 2014, based solely on the Royal Decree.
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indicated as favourable, favourable with remarks or unfavourable. Each control report is
countersigned by the FBO and the information recorded in the checklists is entered by the
official into FoodNet, which is accessible at central level.
The audit team was informed by PCU officials and it was noted during visits to the
establishments that enforcement measures are not always taken when non-compliances aredetected during the official inspections. The checklist system in place identifies whether or
not the specific non-compliance/s detected require corrective actions and follow-up.
Consequently it was observed that some non-compliances which did not requir e corrective
actions/follow-up were recorded as remarks in the relevant checklists and were repeatedly
reported.
The audit team noted that inspection reports produced by the DMOs are not recorded in
FoodNet and as a result do not impact on the determination of inspection frequency. The
audit team was informed by the CA that the shortcomings detected by DMOs may be
considered by PCU officials at their discretion during their official visits at the premises (seechapter 5.3.5 – General findings).
Conclusions
The CA responsible for official controls along the poultry production chain is clearly
designated.
In line with Articles 4 and 8 of Regulation (EC) No 882/2004 Belgium has put in place a
system for ensuring co-ordination and consistency in the performance of official controls and
for the verification of their effectiveness.
A training system to ensure competence of all official staff involved in official control
activities has been implemented.
An internal audit system involving on-the-spot visits to food businesses is in place. Poultry
meat establishments are covered by this system.
Belgium has put in place a risk-based system for the determination of the frequency of
official controls in order to meet the requirements of Article 3 (1) of Regulation (EC) No
882/2004.
5.3 OFFICIAL CONTROLS OF PRODUCTION AND PLACING ON THE MARKET
5.3.1 Controls at farm level
The audit team did not visit poultry farms during this audit. A recent poultry audit on
Salmonella National control Programmes (SNCP) (ref. DG(SANCO)/2014/7152) was carried
out from 9 September to 18 September 2014 in Belgium covering the official controls
performed at farm level by the CA. The report of that audit has been published on the
SANTE Directorate- General Internet site at:-
http://ec.europa.eu/food/fvo/audit_reports/details.cfm?rep_id=3478
http://ec.europa.eu/food/fvo/audit_reports/details.cfm?rep_id=3478http://ec.europa.eu/food/fvo/audit_reports/details.cfm?rep_id=3478http://ec.europa.eu/food/fvo/audit_reports/details.cfm?rep_id=3478http://ec.europa.eu/food/fvo/audit_reports/details.cfm?rep_id=3478
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At the time of that audit, farms were found by the audit team appropriately registered and
under regular official supervision. Controls were in place at farm level to prevent Salmonella
contamination. However, some shortcomings concerning official controls on biosecurity
standards were detected.
5.3.2 Approval procedures
Legal requirements
Article 6 of Regulation (EC) No 852/2004.
Article 4 of Regulation (EC) No 853/2004.
Article 31 (2) of Regulation (EC) No 882/2004.
Findings
The PCUs are responsible for the approval of establishments located in the area under their
control. Approval is granted following favourable result of the assessments carried by PCU
officials to verify FBO compliance with EU requirements.
The CA has established comprehensive procedures for the approval, withdrawal and
suspension of food business establishments. The approval procedures require official staff to
use the same checklists used during routine official inspections.
An FBO who wishes to start an activity requiring approval has to submit an application form
to the PCU. Under national legislation the FBO is also obliged to provide to the PCU a plan
of the establishment indicating facilities and process flows. If the review of this
documentation is satisfactory, the PCU carries out an on-site visit to verify infrastructural
conditions and to take a decision as regards the granting of conditional approval. A second
visit takes place after three months to verify operational conditions and to decide whether to
either grant definitive approval or to extend the conditional approval for a further three
months.
The approval procedures indicate that definitive approval cannot be granted if establishments
do not comply with EU legislative requirements. This was confirmed during examination of
the approval process through documentary reviews carried out by the audit team at
establishment level and in the PCU office visited. All documents reviewed were found
satisfactory as regards timeliness and procedures applied.
In one establishment the audit team noted that after the initial approval visit the FBO was told
by the PCU he could start operating prior to receiving the official letter which was sent ten
days later than the given date to start operations.
All establishments visited were approved by the CA for activities carried out on-site and the
approval documents were provided to the audit team.
The updated list of approved poultry establishments are publicly available on the CA website.
Conclusions
Establishment approval procedures are in place and aligned with relevant EU requirements.
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5.3.3 Controls in slaughterhouses: Ante-mortem inspection and post-mortem
inspection
Legal requirements
Article 4 and 5 of Regulation (EC) No 854/2004.
Findings
Ante-mortem inspection (AMI) :
AMI is carried out by a DMO at slaughterhouse level.
The MD of 20 September 2010 lays down the model form and the contents of the Food Chain
Information (FCI). In all slaughterhouses visited the FCI was received by the DMO 24 hours
before the arrival of the poultry flock at the premises. In all cases reviewed, poultry flocks
were accompanied by the FCI which included, among others, production data, veterinary
treatments and Salmonella test result. The FCI was always signed by the farmer and checked
by the slaughterhouse FBO before being submitted to the DMO.
The AMI consisted of:-
documentary check covering the examination of the FCI;
identification of the consignment;
check on animal welfare;
clinical examination of the birds, including check on dead birds.
In all the slaughterhouses visited the AMI was performed as required. All relevant
information, including the outcome of the AMI, was entered in a CA database known as
Sanitrace, which is also accessible to the FBO as regards its own data.
PMI:
PMI is carried out either by the DMO or slaughterhouse staff under his/her supervision.
The poultry slaughterhouses can use their own slaughterhouse staff to perform PMI if
conditions set by relevant national legislation (RD of 25 January 2011 laying down rules for
the organisation of involvement of slaughterhouse staff in poultry slaughterhouses) are met,
namely:-
the possession of a CA validated own-check system, which must be under the
responsibility of the veterinarian of the establishment,
the effective application of good manufacturing hygiene practices based on HACCP
principles during at least twelve months before the FBO request,
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the presence of a minimum number of staff members of the slaughterhouse available
to assist the DMO with PMI.
According to the information provided by the CA, theoretical and practical training for the
training of staff assisting with PMI is organised by the FBO. The FBO's own veterinarian and
the DMO provide respectively training as regards infrastructure/hygiene and slaughtered poultry and meat.
Staff must pass a test set by the PCU official who grants the certificate if the outcome of the
test is satisfactory. Evidence of training and related certificates was provided to the audit
team.
As regards the performance of slaughterhouse staff participating in PMI, detailed rules are
described in a memorandum available to relevant officials. Regular performance tests on the
individuals helping the officials with this specific task must be carried out and recorded.
Procedures have been prepared by the CA to standardise this evaluation which is based on a
score system. If the result of this assessment is unfavourable, the operative concerned is
removed from this duty and extra training is provided by the FBO to the individual before
he/she is allowed to carry out this task again. The audit team noted that, although CA
procedures indicate that slaughterhouse staff has be assessed on a monthly basis, the
evaluation of each individual was taking place every six months in one of the two
establishments visited where slaughterhouse staff participated in PMI.
In the slaughterhouses visited the audit team noted that the DMO personally carries out the
daily inspection of the viscera and body cavities of a representative sample of birds (first
1000 birds of each flock). These checks were documented.
All the birds rejected by the authorised slaughterhouse staff are kept for the DMO who
carries out detailed PMI. The audit team noted that PMI results are adequately recorded by
the DMO in Sanitrace, related to each flock and communicated to the relevant FBO. The
audit team noted that the FBO provides feedback to farmers as regards the outcome of the
PMI related to the flocks from their holdings.
In four out of five slaughterhouses visited, the PMI was not fully in line with EU
requirements. Precisely:-
In one slaughterhouse the location of the PMI point did not allow the DMO to inspect
the offal and to view all external surfaces of the carcasses.
In another slaughterhouse the correlation between carcasses and offal was not
maintained, the liver was removed by an operative before PMI and all external
surfaces of the carcasses could not be viewed by the DMO.
In a third establishment, the design of the automatic slaughter line combined with its
speed did not allow PMI staff to exclude carcases when a decision taken on the
related viscera deemed the carcass unfit for human consumption.
In a fourth slaughterhouse a batch system was established and offal of birds of the
same origin was collected in a container for PMI. The audit team was informed by the
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DMO that the batch of carcases is declared fit for human consumption also when the
condemnation of the batch of offal should require the rejection of the correlated
carcasses. (i.e. in case of generalised septicaemia, pyaemia, toxaemia or viraemia).
Conclusions
The EU requirements as regards AMI are complied with by the CA.
The control system in place complies with EU requirements with regard to training provided
to slaughterhouse staff involved in PMI and supervision of their work by the official
veterinarian to ensure suitable performance.
PMI is not carried out fully in accordance with the requirements of Regulation (EC) No
854/2004 on PMI, in particular as regards the inspection of all parts of the carcasses and
accompanying viscera and the decision taken on meat.
5.3.4 Animal welfare at slaughter
CA official controls on FBO’s compliance with animal welfare requirements were not
checked during this audit as an audit to evaluate the animal welfare controls in place at
slaughter and during related operations took place from 24 November to 5 December 2014
(ref. DG( SANCO)/2014/7059) in Belgium. The report has been published on the SANTE
Directorate- General Internet site at:-
http://ec.europa.eu/food/fvo/audit_reports/details.cfm?rep_id=3432
5.3.5 Controls at establishment level
Legal requirements
Article 4 of Regulation (EC) No 854/2004.
Findings
General findings
In the majority of the establishments visited the CA had already identified some non-
compliances related to structural/hygiene conditions and practices noted by the audit team.
However, a number of deficiencies repeatedly detected and recorded by the CA in their
inspection reports were still present at the moment of our visits.
In one slaughterhouse visited the audit team reviewed the last inspection report. The report
did not contain references to numerous deficiencies which were detected by the audit team
during the inspection visit (i.e. absence of hygiene facilities, lack of pest control, insufficient
separation between lairage and slaughter-hall, structural deterioration of a wall etc.). The
official responsible of the inspection explained to the audit team that he did not consider
these shortcomings as significant. The audit team noted also that the score allocated to this
establishment was the highest (resulting in four visits per year for this type of establishment)
and that a DMO was present on a daily basis on site. In the adjacent cutting plant the
inspection frequency allocated was high (16 times per year), however numerous non-
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compliances detected by the audit team had not been considered as significant by the official
(e.g. absence of or hygiene facilities not suitably located). Furthermore, in the freezer
approved as a cold store, heavy ice and snow formation which could not have built up
recently was present on walls, ceiling, floor and packaged meat. No records of such
deficiencies were available to the audit team.The audit team identified a number of shortcomings not previously detected/recorded during
official controls (not all present in each establishment). In some cases the officials recognised
that the problems had been overlooked, in other cases they had been considered as not
significant2. For example:-
Regarding maintenance and structure:
Premises not protected against condensation and ice formation. Dripping of
condensation over exposed meat in some cases. Several wet and damaged meat packages boxes caused by the ice were observed in a cold store.
Some rusty elements of equipment and rusty fittings in processing areas.
Premises with a lack of wash-hand basins in production rooms, in the majority of
cases not suitably located and in one case not accessible to permit operatives washing
of hands and tools when necessary. Where wash-hand basins were available, in some
instances splashing on exposed meat and meat packages could not be avoided.
Absence of hygiene facilities for washing shoes for personnel entering clean areas
from dirty areas such as animal by-products room or lairage.
Insufficient protection of production areas from contamination i.e. incomplete
separation between lairage or adjacent compressor room from slaughter-halls, no
isolation of production area from parts of premises still under construction).
In two establishments the work layout could not ensure that the flow of operations would not
cause cross contamination (i.e. cooked products and raw products transiting in the same area,
operations on cooked products and meat preparations taking place in the same room and insome cases on the same working table).
Regarding hygiene of operations:
Inadequate storage conditions of wrapping and packaging material (i.e. storage of
packaging and wrapping material in corridors). Contaminated wrapping material
being used which was in contact with dirty equipment and with waste material in
production room (cooking area). Storage of cardboard boxes in cutting room with
liners in contact with the wall.
2 In their response to the draft report the CA noted that in the light of the audit findings, a warning was issued to
the operator.
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Storage of unused equipment and machinery (in some instances damaged and in a
dirty condition) in production rooms.
Unsatisfactory cleaning of crates used for storage of meat.
Dirty moulds being used in processing plants.
Wooden pallets in close proximity to work station where packaging of exposed meat
was taking place.
Storage of dirty trolleys in close proximity of a slaughter-line or food conveyor belts
during production.
Knives with wooden handles used to bleed birds.
Inadequate pest control in place (i.e. gaps under external doors, storage of dirtyanimal by-product containers in the external area, inadequate separation between
lairage and slaughter-hall).
Unfit meat collected in containers used also for meat fit for human consumption,
although a colour code system was established by FBO.
Liquid waste from leaking containers running on the floor of the slaughter-hall.
As regards disinfection of tools in establishments the CA had issued a circular stating that if a
FBO wishes to use an alternative disinfection system, it is necessary to have prior approvalfrom the FASFC. In two establishments visited alternative methods for disinfecting tools
which did not have CA approval were in use. In one case the official has considered in his
checklist the unapproved alternative method used by the FBO as in compliance with legal
requirements.
Findings related to HACCP based procedures
A guide has been prepared by the industry for FBOs "Generic guide for own-checks for
slaughterhouses and cutting plants for poultry and for establishments of production of minced
meat, preparations of meat and MSM from poultry ". This guide has been validated by
FASFC and is available on the CA's intranet. Information on the distribution of this guide is
available on the internet.
All the establishments visited by the audit team had a documented own-check system based
on HACCP principles. Two uniform checklists were used during inspections which cover
respectively the full HACCP based procedures or some items of it on a random basis. In the
majority of cases where these were reviewed no significant deficiencies were found by the
audit team.
The validated own-check system is audited once a year by the CA or an independent auditing
body authorised by the CA. Evidence of detailed audit reports were provided to the audit
team. When deficiencies were detected an action plan was produced by the FBO with
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indication of deadlines and, depending on the type of shortcoming, the establishment was re-
visited or a documentary check was performed by the auditors concerned.
The audit team noted that the resulting audit reports might be taken into consideration at the
discretion of the officials while conducting their inspections.
Conclusions
A regular and documented system of official controls of poultry meat and products derived
therefrom is in place at establishment level. However official controls do not ensure that
FBOs meet all relevant EU requirements as some shortcomings are not detected/reported
during the inspection visits.
Moreover, when non-compliances which are deemed minor by the CA are detected, the CA
does not take actions to ensure that the FBO remedies the situation3.
HACCP based procedures were present in all the establishments visited which were,
generally, well implemented.
5.3.6 Controls on FBO compliance with microbiological criteria for foodstuffs-
official sampling
Legal requirements
Article 4 of Regulation (EC) No 854/2004.
Article 11 of Regulation (EC) No 882/2004.
Regulation (EC) No 2073/2005, in particular Article 1.
Findings
In one establishment visited the FBO was extending the shelf-life of incoming products after
repackaging. The audit team was informed by the FBO that this practice was based on an
internal instruction which gives an extension of the shelf-life of seven days to all re-packaged
products. The decision on extending the shelf-life of the product was not supported by any
study carried out in accordance with Article 3.2 of Regulation (EC) No 2073/2005.
Checklists for official controls do not include a specific question in relation to shelf-life
studies.
FBO sampling activities
In all establishments visited sampling and testing for the relevant food safety and process
hygiene criteria were in place. Guidelines approved by the CA are available for FBO own-
check system implementation in slaughterhouses, cutting plants and establishments producing
minced meat, meat preparations and MSM.
3 In their response to the draft report the CA noted that it is only in the case of isolated, minor non-compliances
that these corrective measures are not imposed.
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Microbiological analyses of products, water and surfaces were carried out in private
laboratories (either FBO laboratories or external laboratories) and in most cases the results
observed by the audit team were compliant with EU requirements. FBO laboratories are not
obliged to be accredited but must participate as a minimum in collaborative testing and use
approved analytical methods.In all the slaughterhouses visited the neck skin samples had been collected and analysed for
Salmonella as foreseen by EU requirements except in two cases where alternative methods
for analysis were used without being validated by the CA. A checklist requires officials to
verify the use of CA authorised methods, however the officials interviewed confirmed that
the laboratory method in use is not checked during their official controls.
As mentioned under Chapter 5.1 – Findings, a comprehensive review of Belgian documented
procedures was not carried out by the audit team. However, the team noted that some
discrepancies exist between EU legislation applicable to microbiological criteria and both CA
validated guidelines for FBOs and instructions for officials, namely:-
As regards sampling for Salmonella in fresh poultry meat, the limit set is “absence in
1g” instead of the “absence in 25g” as required by EU legislation. Nevertheless, in all
relevant establishments the FBO was applying the correct criteria.
Concerning the testing against the food safety criteria in ready-to-eat products
(Listeria monocytogenes), the sample consisted of one sample unit instead of the
required five. This had led to an incorrect number of sample units being taken by the
FBO in two establishments visited.
In one establishment visited the hygiene process criteria applied for minced meat indicates
limits of E. coli ten times above the limits required under EU legislation (500-5000 instead of
50-500). This was not detected during official controls. However, the analyses results
reviewed by the audit team did not exceed the limits set by the relevant EU Regulation.
A national derogation exists for establishments slaughtering less than 150,000 birds per year
and producing less than ten tonnes of poultry meat per week. The audit team visited two such
establishments with this derogation. The audit team was informed by the CA that no risk
analysis had been carried out to justify the derogations.
Official sampling
In Belgium, the CA takes official samples to verify the implementation of FBO own-check
sampling programmes. In addition, other microbiological criteria are monitored.
The official sampling is planned at central level and the resulting plan is sent to the PCUs on
a monthly basis for their implementation. The PCU is instructed by the CA at central level on
the number of samples to be taken for each commodity, the parameters to be analysed, the
technical sheets to be used and at which stage of the food chain the samples must be
collected. The PCUs allocate the specific samples to be taken to the various establishmentsunder their responsibilities.
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The audit team was informed by the CA that guidelines for official sampling are available to
the PCU staff in the form of specific technical sheets, which are based on the provisions of
Regulation (EC) No 2073/2005. The CA has prepared technical documents for each type of
commodity included in the official sampling plan.
The official sampling programme at establishment level includes residues (Directive96/23/EC) and food additives.
Conclusions
CA controls do not ensure that studies are conducted by the FBO in order to investigate
compliance with microbiological criteria throughout a product's shelf-life.
In general the CA regularly verifies the implementation of FBO own-check sampling
programmes and their results. However this verification and FBO implementation are
weakened respectively by instructions for officials and CA approved guidelines for FBOs that
in some instances differ from EU requirements, and by the failure to perform checks on theuse of approved analytical methods.
The derogation applied in small establishments for the exemption from the sampling
frequencies is not in line with the provisions of Regulation (EC) No 2073/2005 as no risk
assessment has been carried out by the CA to justify it.
The CA takes official samples for microbiological testing from poultry meat cuts, meat
preparations, meat products and ready-to-eat products in order to verify FBO compliance
with microbiological criteria.
5.3.7Controls on traceability-Labelling-Identification
Legal requirements
Traceability: Article 4.6 of Regulation (EC) No 854/2004
Labelling: Chapter IV, Section V, Annex III of Regulation (EC) No 853/2004
Identification marking: Article 4.6 of Regulation (EC) No 854/2004
Section I, Annex II of Regulation (EC) No 853/2004
Findings
Evidence was provided to the audit team that checks on traceability, identification mark and
labelling are part of official controls. Uniform checklists are available to officials for this
purpose.
Traceability systems were in place in all the establishments visited. Traceability was
satisfactory other than in one establishment where some packages of meat and offal were
found without label and as a result the traceability was lost. In all other establishments labels
and identification marks were correctly applied.
In two out of three establishments producing MSM, the denomination “MDM” (MechanicallyDeboned Meat) was used on the label of final products containing MSM.
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Conclusions
Traceability systems were in place all the establishments visited and in general
implementation was satisfactory. The CA performs traceability checks during official
controls.
In general labels and identification marks were correctly applied and their application is
under regular official control.
The CA controls do not ensure that the labelling of final products containing MSM is in line
with EU legislation.
5.3.8Controls on the use of food additives
Legal requirements
Regulation (EC) No 1333/2008.
Findings
The use of food additives were included in the HACCP based procedures reviewed by the
audit team in poultry processing establishments.
A checklist includes a general question for the verification of FBO compliance with
Regulation (EC) No 1333/2008 (the use of permitted food additives for products to which
they are intended and the respect of legal maximum quantities) Specific guidelines for
official staff have not been prepared by the CA. The CA explained that the officials have
access to the relevant EU legislation via the CA website.
Control on food additives was found to be satisfactory in the establishments visited by the
audit team.
A pre-defined risk-based annual sampling plan drafted by the CA is in place. The samples are
analysed in laboratories that are approved by the CA.
Conclusions
The CA ensures that food additives are used in a manner permitted under the relevant EU
Regulation.
5.4 R APID ALERT SYSTEM FOR FEED AND FOOD (RASFF)
Legal requirements
Article 50 of Regulation (EC) No 178/2002; Chapter I, Title VII of Regulation (EC) No
882/2004.
Findings
The Department of Import and Export Control (IEC) from DG Control of the CA, is the
contact point with the RASFF network.
IEC is responsible for managing RASFF notifications within Belgium, through the exchangeof information between stakeholders, PCUs and RASFF network. The CA explained to the
audit team the flow of information and actions to be taken in cases where RASFF
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notifications are triggered from Belgian stakeholders or in cases where RASFF notifications
are generated from food from other Member States.
In Belgium, every FBO is statutorily obliged to immediately notify FASFC, through its
provincial interface, PCUs, if it considers or has reason to believe that a product that was
imported, produced, grown, raised, processed, manufactured or distributed may bedetrimental to human, animal or plant health. Relevant forms are available on the CA
website.
There have been 24 RASFF notifications linked with poultry meat and products derived
therefrom since the last audit, of which 14 RASFF were due to Salmonella presence (7
occurred in 2014).
The audit team visited two establishments whose products had triggered RASFF notifications
in 2014 (presence of Salmonella in poultry meat and product derived therefrom).
In both cases, the FBO notified the relevant PCU on the same day Salmonella positive resultswere received from the laboratory. The PCU carried out an investigation in the
establishments involved and checked FBO documentation related to the batch in question.
The result of this investigation was sent to IEC, along with the location of the batch. The
audit team noted that further investigation, in the case of result positive to Salmonella spp, is
carried out after serotyping.
Conclusions
There is a system in place for notifications of RASFF. The CA takes appropriate action in
response to RASFF notifications.
5.5 LABORATORIES
Legal requirements
Articles 11, 12 and 33 of Regulation (EC) No 882/2004
Findings
In Belgium, the National Reference Laboratory (NRL) for Listeria monocytogenes,
Salmonella, Coagulase-positive staphylococci, including Staphylococcus aureus, Escherichiacoli, including Verocytotoxin producing Escherichia coli, Campylobacter and food borne
infections is the Scientific Institute for Public Health of the Ministry of Public Health.
Serotyping of all isolates from food samples is carried out in this NRL.
There are five official laboratories designated for analysis of official food samples. These
laboratories are integrated in DG Laboratory within FASFC and must be approved by the CA
to perform the above mentioned tests. In order to be approved, laboratories must be
accredited according to ISO 17025.
BELAC carries out accreditation of the laboratories. The accreditation scopes of thelaboratories can be found on BELAC website while the list of approved laboratories is
available on the CA website.
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Two official laboratories perform testing for microbiological parameters of food samples
(excluding the NRL) and functions as dispatch centres for official samples collected
respectively in the southern and in the northern area of Belgium. The electronic system in
place (known as FoodLIMS) in the two dispatch centres ensures that the samples are
forwarded to the laboratories accredited and approved by the CA to perform the specific tests.The audit team visited one official laboratory. The laboratory visited was accredited and
approved by the CA. The current accreditation is valid until 21/06/2015.
The methods used for testing of poultry meat and products derived therefrom are either the
EU reference methods or validated alternative methods recognised by NRL. These methods
used were within the scope of accreditation and are published on the website of the CA.
Evidence was seen that the official laboratory was subject to audits carried by the CA twice
per year and resulting reports were made available.
The laboratory receives scientific and technical support from DG Laboratory and from the NRL. Meetings are organised at least three times per year with the NRL to discuss, among
other topics, new techniques, new methods and validation.
The audit team noted that staff regularly participate in training.
Evidence of successful participation of this laboratory in the relevant collaborative testing
schemes for food pathogens was available (i.e. for Salmonella and Listeria monocytogenes).
The official laboratory visited had adequate equipment and qualified staff.
Conclusions
Laboratories have been designated by the CA to perform analyses on official samples in the
poultry sector in accordance with Articles 11 and 12 of Regulation (EC) No 882/2004.
6 OVERALL CONCLUSIONS
A consistent and well documented food safety control system covering poultry meat and
products derived therefrom is in place in Belgium. The system works generally well. Some
non-compliances were identified, mainly related to the actual implementation of the control
system.
7 CLOSING MEETING
During the closing meeting held in Brussels on 21 November 2014, the CA acknowledged
the main findings and preliminary conclusions presented by the audit team.
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8 R ECOMMENDATIONS
No. Recommendation
1. To ensure that requirements of Regulation (EC) No 854/2004 on PMI are
respected, in particular Part D, Chapter II, Section I of Annex I concerning
inspection of all parts of the carcasses and accompanying viscera and Point 1,
Chapter V, Section II, Annex I concerning the exclusion of the carcase and
related viscera when the decision taken on one element deems both unsuitable
for human consumption.
2. To ensure that as required by Article 4 of Regulation (EC) No 854/2004
official controls verify FBO compliance with all the relevant EU
requirements; in particular the CA has to ensure that the official controls at
establishments cover all the relevant requirements laid down in Regulations(EC) Nos 852/2004 and 853/2004 and verify their compliance.
3. To ensure that when the CA identifies non-compliances that have been
classified as minor, appropriate actions are taken to guarantee that the FBO
remedies the situation in order to meet the requirements of Article 54 of
Regulation (EC) No 882/2004. In particular the CA should take into account
the operator's past record with regard to non-compliances which are classified
as minor and should ensure these are followed-up and rectified.
4.To ensure that official controls cover all the requirements of Regulation (EC)
No 2073/2005, in particular the carrying out of studies established by the FBO
in order to investigate compliance with microbiological criteria throughout the
shelf-life of its products, as required by Article 3.2 thereof.
5. To ensure that controls covering Regulation (EC) No 2073/2005 include the
correct requirements, in particular to ensure that CA instructions and FBO
protocols comply and are implemented in accordance with this Regulation,
and that such controls are performed to verify the use of approved analytical
methods.
6. To ensure that, when the exemption of small slaughterhouses andestablishments from the sampling frequencies is authorised by the CA as
permitted by Annex I, Chapter 3.2 to Regulation (EC) No 2073/2005, the
exemption is justified on the basis of a risk analysis.
7. To ensure that products containing MSM destined to final consumers are
correctly labelled, in order to meet the requirements of Article 3 of Directive
2000/13/EC.
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The competent authority's response to the recommendations can be found at:
http://ec.europa.eu/food/fvo/rep_details_en.cfm?rep_inspection_ref=2014-7151
http://ec.europa.eu/food/fvo/rep_details_en.cfm?rep_inspection_ref=%3cproj_component.object_name/%3e
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ANNEX 1 – LEGAL REFERENCES
Legal Reference Official Journal Title
Dir. 96/23/EC OJ L 125, 23.5.1996,
p. 10-32
Council Directive 96/23/EC of 29 April 1996
on measures to monitor certain substances
and residues thereof in live animals andanimal products and repealing Directives
85/358/EEC and 86/469/EEC and Decisions
89/187/EEC and 91/664/EEC
Dir. 2000/13/EC OJ L 109, 6.5.2000,
p. 29-42
Directive 2000/13/EC of the European
Parliament and of the Council of 20 March
2000 on the approximation of the laws of the
Member States relating to the labelling,
presentation and advertising of foodstuffs
Reg. 178/2002 OJ L 31, 1.2.2002, p.1-24
Regulation (EC) No 178/2002 of theEuropean Parliament and of the Council of
28 January 2002 laying down the general
principles and requirements of food law,
establishing the European Food Safety
Authority and laying down procedures in
matters of food safety
Reg. 852/2004 OJ L 139, 30.4.2004,
p. 1, Corrected and
re-published in OJ L
226, 25.6.2004, p. 3
Regulation (EC) No 852/2004 of the
European Parliament and of the Council of
29 April 2004 on the hygiene of foodstuffs
Reg. 853/2004 OJ L 139, 30.4.2004,
p. 55, Corrected and
re-published in OJ L
226, 25.6.2004, p. 22
Regulation (EC) No 853/2004 of the
European Parliament and of the Council of
29 April 2004 laying down specific hygiene
rules for food of animal origin
Reg. 854/2004 OJ L 139, 30.4.2004,
p. 206, Corrected and
re-published in OJ L
226, 25.6.2004, p. 83
Regulation (EC) No 854/2004 of the
European Parliament and of the Council of
29 April 2004 laying down specific rules for
the organisation of official controls on
products of animal origin intended for humanconsumption
Reg. 882/2004 OJ L 165, 30.4.2004,
p. 1, Corrected and
re-published in OJ L
191, 28.5.2004, p. 1
Regulation (EC) No 882/2004 of the
European Parliament and of the Council of
29 April 2004 on official controls performed
to ensure the verification of compliance with
feed and food law, animal health and animal
welfare rules
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Reg. 2073/2005 OJ L 338,
22.12.2005, p. 1-26
Commission Regulation (EC) No 2073/2005
of 15 November 2005 on microbiological
criteria for foodstuffs
Reg. 1333/2008 OJ L 354,
31.12.2008, p. 16-33
Regulation (EC) No 1333/2008 of the
European Parliament and of the Council of16 December 2008 on food additives