Two audits by the European Commission’s health and safety unit have looked at milk and dairy products in Poland and the Netherlands.
A remote DG Sante audit, in March 2021 in Poland found the system was well-designed but a lack of training and internal audits weaken the effectiveness.
Dairy products with traditional characteristics are sold at national level and made in non-approved establishments, which is in breach of EU legislation. Procedures for approving, registering and listing facilities part of the dairy product supply chain are also not fully in line with EU rules, said auditors.
Summary of issues found
The audit team noted gaps in understanding or knowledge for some inspectors interviewed in areas such as assessment of microbiological criteria for Listeria monocytogenes in dairy products, and Hazard Analysis and Critical Control Points (HACCP)-based procedures. They said this has a negative impact on the level of staff competence for official controls in the sector.
Official tests of dairy products for microbial criteria in 2018 and 2019, detected Listeria monocytogenes in 32 batches of 1,973 sampled and Salmonella in two batches out of 695 tested. Sampling for process hygiene criteria found Coagulase positive Staphylococci in 33 of 1,146 batches and E. coli in 22 batches out of 757 tested.
Steps taken in cases of alerts for dairy products were not fully satisfactory and not in line with instructions, said officials.
The audit team assessed actions by authorities in relation to two RASFF alerts in 2019 for detection of Salmonella in milk powder and Listeria monocytogenes in cheese. In the Salmonella example, unsatisfactory process hygiene of a production line was identified as the cause. Authorities suspended operations on this line and it was later closed but they didn’t take samples of other batches possibly made on the same line, as required by the guidelines.
For the Listeria case, authorities only noted non-compliance after 20 days. This delay was linked to an agency’s misunderstanding of the requirements and actions to be taken for positive samples below the 100 colony forming units per gram limit.
“Corrective actions were limited to the food businesses and districts involved and no evidence was available that the acquired information was used to improve relevant aspects of the control system and to prevent possible reoccurrence elsewhere,” according to the report.
Polish authorities said the recommendations would be addressed through training, reminding officials of certain rules and revised checklists.
Netherlands audit highlights
The other virtual assessment in the Netherlands in October 2021 identified issues with the system for approval of food businesses.
The Dutch Food and Consumer Product Safety Authority (NVWA) and Netherlands Controlling Authority for Dairy and Eggs (COKZ) are understaffed, which has an impact on the effectiveness of official controls.
Staff involved in official controls in the dairy sector said work overload has sometimes resulted in delayed inspections – mainly concerning follow-up, reporting and enforcement.
Training, lab capability and cooperation between different agencies were noted as positives.
The audit team said inspectors used mostly the lowest grading for non-compliances despite some of them requiring a warning and follow-up action. They also found delays, sometimes up to three months from the date of inspection, in the delivery of reports and written warnings, which impacted timely correction of non-compliances.
In 2020, a project examined 46 samples of soft and matured cheese made with raw milk for Shiga-toxin producing E. coli (STEC). It was found in two samples from the rind of matured cheeses. Another study looked at raw milk for direct delivery to consumers. In 2020, out of 100 samples of raw cow milk, five were positive for high counts of coagulase-positive Staphylococci, four for STEC and the only sample of raw goat milk tested positive for STEC.
The audit team followed up five RASFF notifications on Listeria monocytogenes, Salmonella and E. coli in cheese, and one for undeclared allergens in cheese, reported in 2020 and 2021. All investigations and follow-up were judged to be effective.
In response, Dutch officials said the approval shortcomings relate to so-called farm dairy processors. This is a group of more than 500 farmers who process part or all of their raw milk production into regional products, often in a traditional way. They represent only 4 percent of the total milk flow in the Netherlands with the other 96 percent not affected.
COKZ will review the procedure in relation to approvals and adjust it by September 2022. The agency will also develop an assurance system to ensure timely assessment for those with conditional approval. COKZ will also make sure a re-inspection is performed within three months of the original visit and that shortcomings are communicated at the end of the inspection.
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