Foodlaw-Reading
Dr David Jukes, The University of Reading, UK
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FSA Enforcement Letter (ENF/E/16/061), 20 October 2016
The Directorate General for Health and Food audits and analysis (Directorate F, formerly the Food and Veterinary Office (FVO)) conducted an audit from 18th – 29th April 2016 in order to evaluate the food safety control systems in place governing the production and placing on the market of fishery products in the UK.
This routine audit was part of their annual programme of audits of EU member states. The auditors focused on the South West of England and Wales. The FSA would like to thank all the LAs who supported and participated in the audit.
The report was generally positive and Directorate F auditors were satisfied with the official control system based on EU requirements and national legislation that the UK has in place.
However the Directorate F auditors made two recommendations to the FSA as the Central Competent Authority to address what they considered to be gaps with regards to delivery of official controls, with the objective of enhancing the control system in place. These are detailed below, along with the FSA advice to LAs:
Recommendation 1.
The CA should ensure that all fishing vessels are inspected as required under Annex III, Chapter I, part 1(b) of Regulation (EC) No 854/2004 and that requirements of Chapter I, Section VIII of Annex III to Regulation (EC) No 853/2004 are met.
LAs currently prioritise their inspections of vessels based on local intelligence including that shared with other regulators and inspecting bodies in the UK such as when those bodies have concerns over the hygiene or safety of fishing vessels they inspect, as well as the risk score generated from the Food Law Code of Practice.
The FSA is content that this approach, which allows LAs to target their interventions on a risk basis to the highest priority establishments, is acceptable. However in order to better facilitate the sharing of information we intend to put more formal arrangements in place with other regulators and inspection bodies by the end of March 2017. We will keep LAs informed of the progress with this action.
Recommendation 2.
As required in Article 7 of Regulation No 854/2004 the CA should ensure that all of the elements detailed in Annex III chapter II on official controls of fishery products are included in the scope of official controls of fishery products, in particular random organoleptic examinations, and random testing to ensure compliance with histamine limits and the presence of parasites.
LAs should include random organoleptic testing of fishery products as part of their official controls and consider sampling and analysis where appropriate as part of official controls and interventions at fishery products establishments. LAs should take a risk based approach to sampling taking into account whether concerns are identified with the HACCP-based procedures or the FBOs own sampling and testing.
We have developed a series of Aides Memoires which can be used by LAs as the basis of forms to be utilised during their interventions and inspections at approved establishments which will include advice on sampling and testing These forms are currently available for comment on the FSA website as part of a public consultation and we welcome views from LAs on the content by 28th October 2016. The forms can be found here: http://www.food.gov.uk/news-updates/help-shape-our-policies/consultation-on-aide-memoires-for-food-enforcement-officers
Full details of the audit can be found using the following link: http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3666
