general rules of traceability of abp · definition of traceability (art.3) and some requirements...
TRANSCRIPT
Introduction
Remember
BSE crisis in 1996 and 2000
Dioxin crisis in 1999
….
Have illustrated the particularly importance of being able to swiftly identify and isolate unsafe products
Introduction
• Regulation CE no.178/2002 (General Food Law) laid down definition of traceability (art.3) and some requirements for traceability (art.18(1))
• Traceability is a risk-management tool used by:– Operators to trace and follow the ABP/derived products and to
take appropriate measure in case of non-compliance with law.
– Competent Authorities to perform their duties as regard officialcontrol
Introduction
Main objectives of traceability in ABP sector
� To prevent contamination of food by ABP
� To prevent contamination of feed by category 1 & 2 ABP
AGENDA
• Part I - General Principles
• Part II - Obligation of operators along the chain• Part III - Official control
Starting point (R.1069/2009, art.4(1), whereas (21))• It is considered the moment when ABP are produced
and consequently ABP fall under incidence of ABP regulation
• Once a product is considered as ABP (starting point), the producer of ABP must apply ABP traceabilityrules.
Part I - General principles
Principle n° 1 :The traceability applies at the starting point
SCOPE of ABP regulation
Products of animal origin or
raw material fit for humanconsumption
ABP « By Law »
Decision by operator
Irreversible
ABP« By choice »
Traceabilityaccording ABP rules
Traceability according Food rules
Starting point
Hygiene package
End point (R.1069/2009, art.5, whereas (22))• It is considered the moment when derived products
are no longer under incidence of ABP regulation• After end point no traceability and official control are
required under Regulation no.1069/2009• End point is specified for derived products mentioned
in art.33, 35 and 36
Part I - General principles
Principle n° 2 :The traceability applies until the disposal or use of
ABP, unless it exists an end point
TR
AC
EA
BILIT
Y
Derived productsdisposed of,intended for
feeding farmedanimals and
OF/SI
STARTING POINT
Derived productsintended for
pet food, feedingfur animals and
technicalproducts other
than OF/SI
END POINTStep n
Step 0
CollectionTransport
Storage of ABP Treatment Processing
TransformationStorage of DP
DistributionPlacing on the
marketUse
Generationof ABP
ABP Traceability
rules
TR
AC
EA
BILIT
Y
Step 1
Step 2
Step 3
In the SCOPE of ABP regulation
ABPABP
Pigintestines
Mucus Heparin
Traceability according ABP rules
Traceability according CE legislation on
medicinal products
End point
An example of manufacturing chain with end point
Storage
Placing on the market
Handling / Treatment of ABP
Approval
Registration
Manufacturing of Medicinal
products
Producer of ABP(slaughterhouse)
Part I - General principles
Principle n° 3 :To ensure the separation between the 3 categories
of ABP at each stages of ABP chain
= obligation of operators (R.1069/2009, Art. 4(2))
Principle n° 4 :To ensure the correct destination of ABP
Part I - General principles
Principle n° 5 :To ensure that an adequate system is in place that
guarantees the correct destination of ABP
= obligation of Member States (R.1069/2009, Art. 4(3)(4))
• Operators have responsibility regarding collection, identification by categories, transport and traceability of ABP (R.1069/2009, Art 21(1) and (2), Art 22(1) and (2))
Part II. Obligations of operators along the chain
- separation of ABP produced by each category
Slaughterhouses
Farms FoodIndustry&
retails
Cat 1
Cat 2
Cat 3
PRODUCTI
ON OF ABP
Cat 1
Cat 1
Cat 1
Cat 2
Cat 3
DEDICATED
CONTAINERS
Part II.1. Production of ABP (Starting point)
– Identification of ABP (mandatory for SRM – Annex V, point 3 of Regulation CE no.999/2001)
– Temporary storage of ABP in dedicated containers and identification of containers for each category.
Production of ABP: Example of slaughterhouses
– Producers of ABP shall have an adequate procedure to ensure correct destination of ABP (eg: use a national list of ABP plants)
Transport of liquid ABP (blood)Collection of fallenstock in farms
Collection of ABP at slaughterhouse
Part II.2. Collection and transportation of ABP(Art.4(2), Art.21(1) and (2), Art.22(2))
� Collection of ABP without undue delay
� Registered transporters
� Identification of means of transport/containers/package
� Transport of ABP/derived products in dedicated means of transport/containers� link with Regulation CE no.999/2001 (Annex IV, part II and
III) – PAP must be transported in dedicated facilities and not together with feedingstuff for ruminants
� link with Regulation CE no. 852/2004 (Annex II, Chapter IV)
� Hygiene requirements and leak proof
� Controlled temperature for transport of category 3 material > 24hours
Part II.2. Collection and transportation of ABP
Identification of container
Category 1
Colour code : black
Specific mention : « For disposal only »
Category 2Colour code : yellowSpecific mention : « not for animal consumption »
or, when Category 2 material is intended for thefeeding of animals, « for feeding to …+ the name of the specific species of those animal(s) »
Category 3Colour code : greenSpecific mention : « not for human consumption ».
CAT. 1For disposal only
CAT. 2Not for animal consumption
CAT. 3Not for human consumption
Similar to previouslegislation
Identification of container
Specific mention for certain ABP or derived products
NEW : gathered in the same regulation (R. 142/2011, Annex VIII, Chapter II)
• C1 used for manufacturing of derived products
• milk, milk-based products, milk-derived products, colostrum and colostrum products
• gelatin, collagen
• raw pet food
• fish and derived products from fish intended for feed for fish
• blood products from equidae for purposes other than in feed
• horns, hooves and other materials for the production of organic fertilisers and soil improvers
• organic fertilisers and soil improvers
• manure and digestive tract content
• intermediate products
• material used for feeding (derogations)
• research and diagnostic samples
• trade samples
• display items
Part II.3. ABP establishments or plants(R.1069/2009, Whereas (26), Art. 22(2), 23, 24)
- Approval : Operators shall ensure that establishments or plants under their control are approved by the competent authority for a dedicated category
- Registration: Operators shall notify the competent authoritybefore commencing operations in establishments or plants under their control for a dedicated category
- At each stage of chain (from starting point to final use/disposal or end point if it exists), establishments or plants generating ABP or handling ABP/DP shall have an adequate procedure to ensure correct destination of ABP/DP (eg: use of national list of ABP plants)
Marking of MBM
- WHY?- to differentiate MBM cat 1&2 from PAP cat 3
- to trace any cross contamination of MBM cat 1&2 with PAP cat 3
- HOW ? With GTH
- WHERE ? In processing plants/establishments
Part II.4. Marking of certain products
Part II.4. Marking of certain products
Marking of organic fertilisers and soil improvers
- WHY? To prevent any cross contamination of OF-SI with feed
- WHERE ? In any plants / establishments located in OF-SI manufacturing chain
- HOW? Mixing with a sufficient minimum proportion of a component which is authorised by the competent authority of the Member State where the product is to be applied to land
- Lime, manure, urine, compost, digestion residues from biogas or mineral fertilisers
- Component determined on the basis of an assessment of the climatic and soil conditions
- List of the authorised components made available by CA to the Commission and to other MS
All operators involved in ABP chain (producers of ABP, transportersand registered/approved plants/establishments) shall:
- keep the records of consignments of ABP/derived products and related commercial documents or health certificates
- ensure that ABP/derived products are accompanied during transport by a commercial document and when is necessary by a health certificate
Part II.5. Registry, commercial documents and health certificate
(R.1069/2009, Art.21(2) and(3), Art. 22(1))
� Once end point are reached , there is no longer obligation to keep records and commercial documents/health certificates according of Regulation CE no.1069/2009
Model of commercial documents
- European model of commercial document described in R. 142/2011 (Annex VIII, Chapter III)
- For transportation within Member State : CA can adopt their own model of commercial document BUT taking into account the specification set up in R.142/2011.
Similar to previouslegislation
Part II.6. DEROGATIONSfrom applying rules of traceability
No obligation to keep registry and without commercial documents/health certificate (R. 1069/2009, Art.21(2) 2nd
paragraph, (6)(b), Art.22(1) 2nd paragraph) :
- For transport of manure within same Member State ONLY with authorization from competent authority
- For transport of certain derived product (details arementioned in R. 142/2011)
• In implementing rules are mentioned derogation from traceabilityfor “compound feed” produced from ABP/derived products, as defined in Art.3(h) of Regulation 767/2009.
• For compound feed, no need for :
- identification and labeling- commercial documents and records
DEROGATIONBorder between ABP rules and Feed rules
DEROGATION Organic fertilisers and soil improvers
No obligation of labelling for:
• OF/SI in ready-to-sell packages of not more than 50 kg in weight
• OF/SI in big bags of not more than 1000 kg in weight– If authorised by the competent authority of the Member State
based on an assessment of the possibility of diversion of material to farms or pasture which are accessed by cattle
– If it is indicated on those bags that they are not destined for application to land to which farmed animals have access.
Part III. Official controls(R. 1069/2009, Art.45, Art.47 and Art.48)
The competent authority shall at regular intervals carry out official controls and supervisions along the ABP chain as regard traceability
1. Official control of separation and identification of ABP and of means of transport
2. Official control of correct destination of ABP/derived products
3. Official control of registry/commercial documents and cross-check of commercial documents
4. Official control of dispatching ABP/derived products to other Member States
Inspection report
Non compliancesidentified
Operator
Competent authority
Official controlsAt producer level (starting point)Along the chain���� categorization, separation, identification, destination of ABP/DP���� registry / commercial documents and cross-check of documents
Corrective action plan
- Procedure to ensure correct categorization of materials
- Procedure to ensure correction separation and identification of ABP
- Procedure to ensure correct destinations
���� Training of personnel
Official control of correct destination of ABP/derived products
An essential tool for ensuring a correct destination and to perform official control is “The list of ABP approved/registered plants/establi shments”which are available on web page of each Competent Authority
Link of European Commission web page – List of approved ABP establishments
http://ec.europa.eu/food/food/biosafety/establishments/list_abp_en.htm
New technical specifications
for codification of lists
The Competent Authorities shall verify if:
- Approval by CA of destination : the application submitted by operators from Member State of origin are approved by Competent Authority from Member State of destination for intracommunity trade of C1 and C2 material and MBM and fat derived from C1 and C2 material (model in R.141/2011)
� No longer required for PAP
- Notification by TRACES system for C1 and C2 materials, MBM and fat derived from C1 and C2 material and PAP
- Transporters of ABP/derived product are registered and means of transport/containers are identified as required (color coding)
Part III.3. Official control of dispatching ABP/DP to other Member States
Reduction of administrative
burden
Thank you for your attention !