Foodlaw-Reading
Dr David Jukes, The University of Reading, UK
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Commission Consultation, 21 February 2017
The Commission has published a draft Regulation for consultation. The following are available on this site:
The following is the introductory recitals from the draft:
Having regard to Regulation (EC) No 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs1, and in particular Article 4(4) thereof,
Whereas:
(1) Commission Regulation (EC) No 2073/20052 lays down the microbiological criteria for certain micro-organisms and the implementing rules to be complied with by food business operators in respect of the general and specific hygiene requirements referred to in Article 4 of Regulation (EC) No 852/2004.
(2) In particular, Regulation (EC) No 2073/2005 lays down process hygiene criteria which set indicative contamination values above which corrective actions are required in order to maintain the hygiene of the process in compliance with food law.
(3) The "European Union summary report on trends and sources of zoonoses, zoonotic agents and food-borne outbreaks in 2015"3 published by the European Food Safety Authority (EFSA) and the European Centre for Disease Prevention and Control (ECDC) states that human campylobacteriosis is the most reported human food-borne illness in the Union with around 230 000 cases reported annually .
(4) In 2010 the EFSA published the analysis of the baseline survey on the prevalence of Campylobacter in broiler batches and carcases4. The baseline survey was carried out at slaughterhouse level in 2008 to obtain comparable figures on the prevalence and the level of contamination of broilers in the Union. EFSA concluded that broiler carcases were contaminated at an average of 75.8% with significant variations between Member States and slaughterhouses.
(5) According to the EFSA Scientific Opinion on the risk of human campylobacteriosis linked to broiler meat5, published in 2010, handling, preparation and consumption of broiler meat may account for 20% to 30% of human cases of campylobacteriosis, while 50% to 80% may be attributed to the chicken reservoir as a whole.
(6) The EFSA Scientific Opinion on control options for Campylobacter along the poultry meat production chain, published in 20116, suggests a number of control options both at farm and at slaughterhouse level and estimates their impacts on the reduction of the number of human cases, including the introduction of a process hygiene criteria for Campylobacter. The EFSA estimates that a public health risk reduction from the consumption of broiler meat of more than 50% could be achieved if carcases complied with a limit of 1000 cfu/g and highlighted that significant different contamination levels exist between neck skin and breast skin samples.
(7) The EFSA also published in 2012 a Scientific Opinion on the public health hazards to be covered by inspection of poultry meat, which identifies Campylobacter as of high public health relevance7, and recommends the adaptation of the current inspection methods of poultry carcases to address Campylobacter. In particular the EFSA suggests introducing a process hygiene criterion for Campylobacter on broiler carcases..
(8) Based on the EFSA opinions of 2010 and 2011, the Commission commissioned an analysis of the costs and benefits of setting certain control measures for reduction of Campylobacter in broiler meat at different stages of the food chain8. The main conclusion of this cost-benefit analysis is that setting a process hygiene criterion to Campylobacter in broiler carcases would provide one of the best balances between reducing human campylobacteriosis attributed to the consumption of poultry meat and economic consequences from the application of the criterion.
(9) The process hygiene criterion for Campylobacter in broiler carcases aims at controlling contamination of carcases during the slaughtering process. In addition in order to ensure a whole chain approach as recommended by the EFSA opinion on control options for Campylobacter, control measures should also be considered at farm level.
(10) Control of Campylobacter continues to prove challenging, as vertical transmission does not appear to be an important risk factor and all depends on how effective the biosecurity measures are at excluding Campylobacter from the broilers. A step by step approach should therefore be considered, making the process hygiene criteria gradually stricter in time. Nevertheless to maintain the same level of protection in Member States where such level of protection has been already achieved, Article 5(5) of Regulation (EC) No 2073/2005 provides sufficient flexibility to apply a stricter process hygiene criterion as such alternative criterion provides for at least equivalent guarantees as the reference criterion set in Regulation (EC) No 2073/2005.
(11) In order to reduce the administrative burden for food business operators, the sampling plan for the criterion on Campylobacter should follow the same testing approach as for the process hygiene criterion set for Salmonella in poultry carcases. The same neck skin samples used for testing compliance with the process hygiene criterion set for Salmonella in poultry carcases may therefore be used for the Campylobacter analyses.
(12) The international standard EN ISO 10272-2 is the horizontal method for the enumeration of Campylobacter in food and feed stuffs. It should therefore be laid down as a reference method verifying compliance with the criterion for Campylobacter in poultry carcases.
(13) It is appropriate to defer the date of application of this Regulation in order to give sufficient time for food business operators to adapt their current practices to the new requirements and to allow laboratories performing Campylobacter analyses to implement the new test methods laid down in this Regulation.
(14) Regulation (EC) No 2073/2005 should therefore be amended accordingly.
(15) The measures provided for in this Regulation are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed Committee.
