compliance and enforcement - food safety authority of · pdf filecompliance and enforcement of...

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Compliance and enforcement of food legislation

- including flavourings!

Rhodri Evans

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This Man Delivers…

35 Products

60 Countries

5 Continents

…in 1 Box

* This is for illustrative purposes only

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In Just One Pizza!

Dough FranceUK PolandUSAYeastUKIrelandGermanySaltUKFranceChina

SugarBrazilIndonesiaJamaicaUK

Tomato pasteItaly SpainGreeceFrance Netherlands

HerbsGreece, ItalySpain, Kenya, Uganda,Tanzania, Morocco

And Then the Toppings…Cheese from Switzerland, Ireland, France, Italy, Spain, UK,Netherlands; Ham from Ireland, Netherlands, Germany, UK, Chile, Brazil, Belgium; Chickenfrom Thailand, Brazil, Ireland, UK, Netherlands, Germany; Chilli Peppers from Africa, Asia, South America; Anchovies from Peru, Argentina, Italy, Falkland Islands; Spain; Iceland Denmark; Pepperoni from Poland, Italy Ireland, UK Denmark, USA; Vegetables such as garlic, mushrooms, sweet pepper, onions, olives, from a host of Mediterranean countries; Olive oilfrom Italy, Greece, Spain,

Flavours/flavourings can be used in many

ingredients

* This is for illustrative purposes only

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The value of food and drink exports in 2011

was €9 billion

€9 billion

Ensuring Irish products are safe for consumers

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Europe – 27 Member StatesOne Market

that trades internationally…..

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Regulation 178/2002: “General Food Law”

Food safety

requirements

Risk Analysis

Protection of

consumer interests

Presentation

Import & Export

Transparency

Withdrawal &

Notification

Traceability

Crisis management &

emergencies

Rapid Alert

Food Business

Operator

Responsibility

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FSAI

Enforce

Food

Law

Scientific Advice for Policy and

Risk Management

Partnership

With

Stakeholders

Efficient and Effective

Organisation

FSAI - Four Strategic Priorities

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Types of Regulatory Systems…

• Multiple Agencies Responsible For Food Control

• A Single Unified Agency For Food Control

• A National Unified Integrated Approach

Food SafetyAUTHORITY OF IRELAND

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Department of Health

Department of Agriculture, Food and the

Marine

Food Safety

Authority of Ireland

Sea Fisheries Protection Authority

National Standards

Authority of Ireland

Marine Institute

Department of Agriculture, Food and the

Marine

Local Authorities( 27 County

Councils, 1 City Council)

Health Service Executive

Customs & Excise

Radiological Protection Institute of

Ireland

Government Department: legislation and policy

Central Competent Authority, responsible for enforcing food laws

Official Agencies: enforce food laws under Service Contracts with FSAI

Other Agencies involved in food safety which have MoUs with FSAI

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Animal Feed Manufacture

Primary Production

Slaughter / Harvesting

Manufacture / Processing

Wholesale / Distribution

Retail /Catering

Consumption

Import

LAs

DAFM

HSE

SFPA

FSAI

Irish controls throughout the food (+feed) chain

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Multi Disciplinary Working

DAFM

Veterinarians

Dairy Inspectors

Egg Inspectors

Laboratory Personnel

LA (31)

Veterinarians


HSE

Environmental

Health Officers


SFPA

Four Main Agencies

Sea-Fisheries Protection Officers

Marine Institute –Laboratory

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Co-ordination of CAs: FSAI role

• Ensuring consistent enforcement of food legislation

• Identifying gaps or overlaps in the system

Examples:

• Cross-agency group to agree supervision arrangements

• Training

• Guidance Notes

• Producing National Control Plan & reports

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What do we do in Ireland?

Competent Authority role

• Representing Interests of Irish Consumers and Industry on issues of National Importance at EU and Codex meetings

• Legislation/enforcement interpretation

• Guidance to Industry and Agencies on legislation

• Aim to prevent problems before they happen!

Surveillance

• Ad-hoc surveys

• Co-ordination of national monitoring programmes

Risk (exposure) assessment

• EFSA’s role on EU-wide basis

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Vet Drugs

Pesticides

Dioxins, PCBs, etc.

Marine Biotoxins

Radio isotopes

Mycotoxins

Nitrates

Metals

Additives

Central Meat Control Laboratory State LaboratoryIrish Equine CentreAshtown Food Research Centre

Pesticide Control Service, DAFF

State Laboratory Pesticide Control Service

Marine Institute

Radiological Protection Institute

Public Analyst Laboratories

Testing programmes

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Role of Food Business Operators (FBOs)

• Must not place food on the market that is unsafe

• Injurious to health

• Unfit for human consumption

• Ensure that foods satisfy the requirements of applicable

food law

• Ensure imported food complies with EU food law

• Ensure that exported food complies with EU food law

unless 3rd country has own specifications

• Establish traceability systems

• Establish recall systems

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Key issues for controls on flavourings:

1. Controls based on the production flow-charts/recipes and the HACCP plan of the company.

2. Consideration of recipes and whether flavourings are used according to legislation (any restrictions on use?)

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Commission Flavourings database

https://webgate.ec.europa.eu/sanco_foods/main/?event=display

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caffeine

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3. Sampling and analysis of ingredients and/or end products? – active principles

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Sampling and analysis

• Annex III of Regulation 1334/2008 lists 15 substances that shall not be added to foods as such:

Agaric acid Aloin Capsaicin

Coumarin Hypericine β-asarone

Thujone (α and β)Estragol

Teucrin A

Hydrocyanic acid Menthofuran Methyleugenol

Safrole Pulegone Quassin

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Active principles

• Often major flavouring component of particular foods with flavouring properties (e.g. estragol in tarragon)

• Limits adopted in food considered to contribute most to dietary intake

• Analysis for certain of the active principles in target foods (MLs established) undertaken each year as part of the chemical monitoring programme undertaken by EHS/Dublin PAL

• Controls should be in place at food manufacturing level

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Examples of restrictions

Substance Food Max. level

mg/kg or mg/l

Estragol Dairy products, Processed fruits 50

vegetables, nuts and seeds 50

Fish products 50

Non-alcoholic beverages 10

Hydrocyanic acid Nougat, marzipan or its

substitutes or similar products 50

Canned stone fruits 5

Alcoholic beverages 35

Menthofuran Mint/peppermint-containing

confectionery, except ….. 500Micro breath freshening

confectionery 3000

Chewing gum 1000

Mint/peppermint containing 200

alcoholic beverages

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Labelling - Main points to remember

• Don’t forget the requirements of general (and other) labelling legislation – all of it

• Consider who the customer is – B2B or consumers?

• Definition of “natural”

• Permutations of “natural flavouring” labelling

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Question 1

“Artificial flavouring” is a term defined in Regulation

1334/2008

True

False

It’s no longer a recognised term in flavourings legislation

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Question 2

How many flavouring categories are listed in Regulation

1334/2008?

6

5

7

8

a) natural flavouring substance

b) flavouring substance

c) flavouring preparation

d) thermal process flavouring

e) precursor flavouring

f) other flavouring

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Question 3

Which of the options below apply to the following flavouring compound?

80% derived from raspberry (recognisable flavour)

10% derived from apple

10% derived from strawberry

Natural raspberry flavour

XIt would have to be above 95% from raspberry and recognisable as raspberry

Natural flavour X It would have to be not recognisable

as raspberry or not from raspberry

Natural raspberry flavour with other natural flavours

Provided <95% and recognisable

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Question 4

Which of the options below apply to the following flavouring compound?

95% derived from orange but the flavour isn’t recognisable as orange?

Natural orange flavour X

It would have to be above 95% from orange and recognisable as orange

Natural flavour It’s not recognisable as orange

Natural orange flavour with other natural flavours

XIt would have to be <95% and recognisable

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