An assessment of controls at companies in the dairy sector in Ireland has found the system works well overall but there are several areas that need improvement.
The audit covered official controls by a Department of Agriculture, Food and the Marine (DAFM) division in the dairy production chain. Eleven businesses were audited between August and November 2022.
The Food Safety Authority of Ireland (FSAI) audits the effectiveness and appropriateness of the controls implemented by other agencies.
Following onsite audits at two companies, one small scale and one very small, the audit team found that official controls were not effective and the assessment of compliance against food law was not adequate. Compliance notices were issued to both firms by the DAFM unit.
At one very small company, no food safety management system and associated records were available on the audit day. The business could partially demonstrate one-step forward traceability but not one-step-back traceability, as EU legislation requires.
Cheese issues
In one region, following an increase in controls, a series of non-compliances with food law had been identified by DAFM at one company between 2021 and 2022. Following these checks, compliance notices were issued. At the time of the audit, four such notices remained in place.
As a result of official controls carried out on downgraded cheese, a RASFF alert was made regarding the unauthorized placing on the market of cheese unfit for human consumption, which originated from this firm.
During an audit, non-compliance with food law was identified, resulting in almost 4.5 tons of cheese deemed unfit for consumption and disposed of as a Category 2 Animal By-Product (ABP). The cheese processor was also requested to review all stock within the establishment. This resulted in 42 tons of product disposed of as Category 2 ABP.
Subsequent audits in another region by FSAI identified more product being stored and or consolidated for this company, these products were also judged to be unfit to eat and were disposed of in the same way.
Official controls were effective in identifying non-compliance but actions taken to address the issues did not prevent further occurrences, said auditors.
Findings from 11 audits by the FSAI team resulted in enforcement action taken by the DAFM division on four firms and the continuation of pre-existing actions on a fifth.
Auditors found the trading activities of one large multi-site manufacturer were not registered or approved by the DAFM unit, so it was not subjected to official controls. DAFM had contacted the firm about registration at the time of the audit.
Assessing DAFM performance
The audit team reviewed the risk rating and official control program for 2021 and 2022. On numerous occasions, non-compliances were noted. Not all establishments under the remit and supervision of the DAFM division were risk-assessed in 2021, and eight controls were missed. The 2021 official control plan was outdated and did not identify all sites requiring planned checks.
Not all storage and distribution sites were risk-assessed or approved for the re-packaging of cheese in 2021 and 2022. Cheese re-packing has ceased in all three sites since September 2022.
There were three missed official controls in 2021 for the handling and re-packaging of cheese, and three controls were not identified in the 2022 plan.
Auditors also found scores assigned to certain parameters were inaccurate, resulting in a change to the risk rating of three establishments.
In 2021, there were 241 planned controls and 537 reactive controls. Reactive checks were performed at four sites concerning the 11 missed planned official controls.
In one region, auditors noticed that one very small-scale plant did not receive the required frequency of food safety and process hygiene sampling controls as outlined in the 2021 sampling plan. DAFM explained that due to COVID-19 and reduced production, sampling frequency was halved for this firm. During an onsite inspection, the FSAI found that this company had not performed any product testing in line with EU regulations and relied on official control sampling to verify compliance with food safety requirements.
Concerns were raised by the audit team about the long periods, up to three years in one case, in which establishments remained approved or registered despite having either ceased operations or having approval or registration proposed for suspension or canceled. Since early 2022, additional resources have been allocated to improve the management and control of suspensions and revocations.
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