EU HYGIENIC REQUIREMENTS in BULGARIAand their IMPACT ON AGRICULTURAL PRACTICES
in HIGH NATURE VALUE AREAS of
HNV SeminarVillage of Brashlyan, Strandzha Nature Park
26 – 27 June 2007
Stanimir Stoychev Independent Consultant
STOYCHEV Consult ЕООD
Emil Petrov Independent Consultant HACCP
STRUCTURE OF THE PRESENTATION
Overview of the ЕU hygiene legislation Overview of the harmonized BG hygiene
legislation Analysis (scenarios) of potential impact of
hygiene legislation on SMALL and MEDIUM-SIZE agricultural producers and processors in High Nature Value (HNV) areas
Conclusions Recommendations
THE QUESTION IS ...
Can traditional practices of milk and meat production and processing in HNV areas be preserved observing existing increased hygienic requirements in accordance with the
national legislation?
Overview of the EU hygiene legislation
Regulation (EC) 852/2004 laying down common rules
on food producing enterprises concerning foodstuffs
hygiene
Regulation (EC) 853/2004 laying down specific hygiene
rules on food of animal origin
Concerning buildings and equipment
Concerning indicators for TNM and TNSCs
Overview of EU hygiene legislation
3. This regulation 853/2004/ЕС shall not apply to:
a) primary production intended for private home use;
b) home preparation, handling or storage of food for private home consumption;
c) the direct supply, delivered by the producer, of small quantities of primary products to the end consumer or to local retail establishments directly supplying the end consumer;
d) the direct supply, delivered by the producer, of small quantities of meat from poultry and lagomorphs slaughtered on the farm to the enf consumer or to local retail establishments directly supplying such meat to the enf consumer as fresh meat;
(e) hunters who supply small quantities of wild game or wild game meat directly to the end consumer or to local retail establishments directly supplying the end consumer.
4. Member States shall establish, according to national law, rules governing the activities and persons referred to in paragraph 3 (c), (d) and (e). Such national rules shall ensure the achievement of the objectives of this Regulation..
Overview of the harmonised BG hygiene legislation (1)
Strategy for the development of milk animal-breeding and improvement of the quality of raw cow’s milk for the period 2006-2009
Law on the support of agricultural producers Law on the veterinary activities Law on foods Law on fodder Law on animal-breeding Regulation No.44/20.04.2006 on the veterinary requirements
concerning animal-breeding sites Regulation No.51/20.04.2006 concerning the national reserve,
individual milk quotas, approval of buyers and the buying up of cow’s milk
Regulation No.61/09.05.2006 concerning the conditions and order for identification of animals, registration of animal-breeding sites and access to the database of the identified animals
(draft) REGULATION CONCERNING THE SPECIFIC REQUIREMENTS of THE PRODUCTION, STORAGE AND TRANSPORTATION OF RAW COW’S MILK AND THE REQUIREMENTS FOR THE TRADE AND PLACEMENT ON THE MARKET OF DIARY PRODUCTS
Overview of the harmonised BG hygiene legislation (2)
Good Manufacturing Practices (GMP) for buying out and processing of raw cow’s milk
Conditions for maintaining the land in good agricultural and environmental condition (Good Agricultural and Environmental practices)
EXAMPLES of the REQUIREMENTS under Regulation 44
Up to 2009, a farm must meet the following requirements : To have separate premises for animals of different
technological groups conforming to the requirements relating to the parameters of the living environment
To have production equipment and premises for storage of milk until its delivery for processing which shall comply with the veterinary-sanitary and hygiene requirements relating to milk production
To ensure adequate conditions for veterinary care and stationary treatment of the animals
To have isolated maternity boxes or to create a delivery premise
To ensure conditions for movements of the animals To possess premises and grounds for open-air breeding
of calves complying with the regulations related to the protection and humane treatment during calf-breeding
To keep and handle waste in a manner preventing environmental contamination.
OBJECTIONS to Regulation 44
This regulation should only apply to large animal-breeding complexes
This regulation provides no requirements related to the pastures and meadows needed for ruminant animals (cattle and sheep)
This regulation does not apply to traditional animal-breeding practices, e.g. breeding sheep herds in movable pens (sheepfolds) on harvested fields
The requirements related to summer mountain animal camps are not addressed
Mountainous breeding of calves and weaned lambs are not addressed
This regulation describes “bookish” norms for animal-breeding but it has been forgotten that norms depend on the applied breeding technology
This regulation should provide conditions for the development of not only “large” but “small” farms, as well
EU Legislation
Presents complicated requirements
within large limits
Makes possible interpretations
Implementation of these large
requirements into practice is not
accompanied by concrete requirements
and model implementation scenarios
No clear relation of EU hygienic
requirements with the EU policy
relating to rural development exists
Presents very well translated hygiene
requirements contained in EU
regulations with increased and ambitious
objectives
Limited transitional period for
implementations
Poorly presented to farmers and limited
transparency relating to specific
requirements
Diverse interpretation on local level
Improperly trained officials for the
control of hygienic requirements
Lack of clarity with respect to direct sale
practices
BG Legislation
SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR (intensive regions)
Plovdiv Region: 30 registered milk buyers
Farms of group 1 129 farms with 7,696 dairy cows Average herd size: 60 cows Varying from 11 to 792 cows
Farms of group 2 112 farms with 2,707 dairy cows Average herd size: 24 cows Varying from 5 to 78 cows
Sliven Region: 18 registered milk buyers
Farms of group 1 72 farms with 4,180 dairy cows Average herd size: 58 cows Varying from 11 to 550 cows
Farms of group 2 59 farms с 1,115 dairy cows
Average herd size: 19 cows Varying from 6 to 70 cows
SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR (areas of HNV)
Bourgas Region: 7 registered milk buyers
Farms of group 1 38 farms with 2,131 dairy cows Average herd size: 56 cows Varying from 11 to 296 cows
Farms of group 2 35 farms with 640 dairy cows Average herd size: 18 cows Varying from 4 to 146 cows
Smolyan Region: 12 registered milk buyers
Farms of group 1 59 farms with 667 dairy cows Average herd size:– 11 cows Varying from 5 to 79 cows
Farms of group 2 25 farms with 303 dairy cows Average herd size:– 12 cows Varying from 5 to 75 cows
EXAMPLES of the REQUIREMENTS of REGULATION 853/2004
CATEGORYMilk farm
Transitional period TNM TNSC BUILDINGS
Group I up to 100,000/ml
up to 400,000/ml
Requirements met
Group II
Start 2008End 2009
from 300,000/ml
up to 100,000/ml
up to 400,000/ml
Requirements met
Up to end 2007
from 500,000/ml
up to 300,000/ml
от 500,000/mlUp to
400,000/ml
Group III Up to end 2007
up to 500,000/ml
up to 500,000/ml
Requirementsnot met
SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR– as of 1 June 2007
STRUCTURE OF MILK HERDS IN BULGARIA
78%
8%
14%
1
2
3
INDICES CATEGORYGroup 1 Group 2 Group 3
Number of farms 1,145 1,353
?Number of diary cows 47,970 28,779
Average number per farm 42 21
Total number of dairy cows as of 2005: 350,000 Total number of milk producers with quotas for shipment and direct sale: 96,572
CONCLUSIONS
Greatest impact have the requirements concerning milk
hygiene and the requirements concerning buildings
Lack of clarity on how direct sales have to be carried out
Lack of clarity with respect to milk processing at farm level
Lack of nationally represented organisation for protection of
small and medium-size milk processors
Existing conflict of the legislation regulating cow’s milk
producers organisations
RECOMMENDATIONS
Introducing amendments in BG legislation correcting 2 things: Milk processing on “farm” level practicing “direct sales”
Establishing a national organisation of “small” milk processors processing on “farm” level and applying direct sales
Establishment of milk producers groups on regional principle practicing traditional methods of agriculture who will be able to apply for support of up to EUR 3,000 for the production of traditional products under the RDP (2007–2013)