Environment & Food Safety


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A brief overview of the relationships between the environment and food safety. Clues on the EU food law, Codex Alimentarius, food safety management schemes

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Environment & Food Safety

  1. 1. Environment & Food Safety, overview Ankara, 19 April 2010 Dario Dongo CIAA, Food Safety Management / Hygiene Task Force, v.chairman Global Food Safety Initiative Tech. Committee, CIAA representative ISO TC34 SC17 (Food Safety Management), CIAA representative Federalimentare, Regulative Policies, responsible
  2. 2. EU food law ... in a nutshell
  3. 3. Scope Food & feed imported into the EU shall comply with the EU requirements of food law Food & feed exported (or re-exported from the EU) for placing on the market of a third country shall comply with the EU food law EC Reg. 178/02, General Food Law, Art. 11, 12
  4. 4. Food Safety • Unsafe food can’t be placed on the Market as: 1)harmful (in the short-mid-long term / cumulative effects / sensitivities of specific categories of consumers) 2)unfit to human consumption (ie. physical contamination, deterioration, putrefaction, deacay) EC Reg. 178/02, General Food Law, Art. 14
  5. 5. “Farm to Fork” policy • All those who participate to the food/feed chain are responsible for the hygiene of their process and the safety of their output • No exemption or limitation of responsabilities • The safety assurance must be continuos, from primary production (animal or vegetal) to final distribution (including catering) EC Reg. 178/02, General Food Law, Art. 17
  6. 6. Traceability All operators must • be able to identify their suppliers – who supplied what (food & feed, food contact materials) • be able to identify the business operators to whom they have delivered their products - who has received which product • inform the competent authorities on what above, whenever requested EC Reg. 178/02, General Food Law, Art. 18
  7. 7. Environment & Food Safety Heavy Allergens Metals Process contaminants Pesticides MRL’s Food Micotoxins Contact … Materials Dioxins PCB’s Water [GMO’s]
  8. 8. FROM THE FARM … Land Food and feed crops may uptake soil contaminants. This may affect the quality of products and, in due course, the human and animal health EC proposal for a Soil Framework Directive (COM(2006) 232)
  9. 9. Dioxins, PCB’s (1) Dioxins and polychlorinated biphenols (PCBs) are chemicals that get into food from the environment • Dioxins may be formed as unwanted by-products in a variety of industrial and combustion processes, including household fires • PCBs have been largely used since the early 1930s, mainly in transformers, refrigerators, hydraulic oils and as all round chemicals. Despite their production was stopped in the 1970s-’80s, they are still present in many environments
  10. 10. Dioxins, PCB’s (2) About 95% of the average person’s exposure to dioxins occurs through consumption of food, especially food containing animal fats Dioxins from the environment can be present in vegetables and other foods [ie. Indian guar gum, ’08. Swiss-made thickening agent Unipektin, ’07] High levels of dioxin can be found in food of animal origin (ie. eggs, milk, meat), when feed with dioxin had been used [ie. Irish pork, ’08. NL milk, ’06 … Belgian feed scandal, ‘99] EC Reg. 1881/06 sets maximum levels for specific contaminants in foodstuffs EC Reg. 1883/2006, sampling and analysis methods for determining the levels of dioxins and dioxin-like PCBs in specific foodstuffs
  11. 11. Water (1) Ground water may be contaminated by a variety of biological and chemical hazards, which include: • bacteria and viruses • domestic waste • nitrate nitrogen • synthetic organic chemicals • heavy metals • petroleum residues • combustion products (ie. from roadways) Water Framework Directive, 2000/60/EC Urban waste water treatment Directive, 91/271/EEC (amended by Dir. 98/15/EEC) Drinking water Directive, 98/83/EC IPPC Directive, 2008/1/EC (Integrated Pollution Prevention and Control), under review, concerning industrial emissions. Integrated permits system covering 52,000 industrial and agricultural installations in the EU
  12. 12. Water (2) Sewage sludge - rich in nitrogen, phosphorus and organic matter - can be a useful fertilizer or soil improver However, it concentrates heavy metals, dioxins, antibiotics and resistant bacteria Its treatment and use in agriculture is therefore strictly regulated. Never in feed production, nor to be left to grazing animals [’98-’99 food crisis in F, NL: knackeries, gelatine factories] Directive 86/278/EEC on use of sewage sludge in agriculture
  13. 13. Other contaminants Lead: old paint is the most important source of contamination of the environment. Lead water pipes can also be dangerous, especially when they transport hot water … Methyl-mercury: fishery products from polluted waters are major sources of methyl-mercury contamination EC Reg. 1881/06 sets maximum levels for cadmium, lead and mercury in certain foods EC Reg. 333/07 provides sampling & analysis methods for the official control of lead, cadmium, mercury, inorganic tin, 3-MCPD and benzo(a)pyrene in foodstuffs
  14. 14. … INTO THE SUPPLY CHAIN … Crops agriculture raw materials
  15. 15. Pesticides (1) Pesticides are widely used in the production and storage of fruits, vegetables, cereals and animal products. Residues frequently occur in food Food operators must ensure that the amounts of these residues are - safe for consumers and - as low as possible. Never above the Maximum Residue Levels (MRLs) established by EC Reg. 396/05 http://ec.europa.eu/sanco_pesticides/public/index.cfm
  16. 16. Pesticides (2) Farmers, processors, traders and importers are responsible for food safety, which includes compliance with MRL’s If pesticide residues are found on food in the EU at a level of concern for consumers, the RASFF circulates the information and measures are taken: - border rejection - withdrawal from the market
  17. 17. Mycotoxins: aflatoxins (1) Aflatoxins are naturally occurring toxins that are metabolic byproducts of fungi, which grow on many food crops under favorable conditions Most prone to contamination are corn, peanuts, tree nuts (pistachio nuts, pecans, walnuts, hazelnuts, Brazil nuts), dried fruits and milk
  18. 18. Aflatoxins (2) EC Reg. 1881/06 – amended by EU Reg. 165/10 - sets maximum levels of aflatoxins (B1, B2, G1, G2, M1) EC Reg. 401/06 – amended by EU Reg. 168/10 - provides sampling & analysis methods for the official control of mycotoxins, including aflatoxins EC Reg. 1152/09, imposing special conditions governing the import of certain foodstuffs from certain third countries due to contamination risk by aflatoxins: -> from Turkey: • dried figs • hazelnuts (in shell or shelled) • pistachios • mixtures of nuts or dried fruits (containing figs, hazelnuts or pistachios) • fig paste, pistachio paste and hazelnut paste
  19. 19. Ochratoxins Another (carcinogenic) mycotoxin is Ochratoxin A (OTA), produced by moulds which grow in high temperatures and high moisture during harvest, handling, drying, storage and transport Good practices, example: woven poly bags for green beans in a warehouse that ideally should remain <65% relative humidity. Note the ventilation windows in the wall EC Reg. 1881/06 lays down maximum levels of ochratoxin A for cereals, dried vine fruit, coffee, wine, grape juice, cereal-based foods. For spices and liquorice, EU Reg. 105/10 EC Reg. 401/06 (as amended by EU Reg. 178/10): sampling & analysis methods for official control of ochratoxin A
  20. 20. Other mycotoxins Fusaria toxins. Fusaria moulds which produce wrinkling of plant parts produce also fusaria toxins. Currently, no official limit for fumosins in food [however, the EU has proposed a limit of 500 microgrammes per kg] DON (deoxynivalenol), one of the most important of these toxins, occurs in grains such as wheat, barley, oats, rye, and maize, rice, sorghum. It may coexist with Zeralenone -> cereals, baby-food issues, ’03 onwards Codex regulatory limit for DON is 1mg/kg food Patulin is a toxic chemical produced from a number of moulds. Apples tend to be the major source, yet any mouldy or rotten fruit could contain this toxin -> fruit juices Codex Alimentarius is considering reducing the maximum level to 25ppb from 50ppb (because of high intake of apple juice by young children)
  21. 21. Risk reduction, example Post-harvest control strategies to reduce risk of mycotoxins in grain storage • Very small amounts of dry matter loss due to mould activity can be tolerated. A dry matter loss 0.5% is a signal of visible moulding, mycotoxin contamination and downgrading of lots • To control the growth of moulds during grain storage: modified atmospheres, fumigation (with sulphur dioxide and ammonia and CO2 of 75%).Preservatives (based on aliphatic acids, essential oils and anti-oxidants) for feed • An effective post-harvest management requires clear monitoring criteria, hygiene and the implementation of key critical control points during harvesting, drying and storage stages in the cereal production chain to minimise mycotoxin contamination Magan N, Aldred D.: Post-harvest control strategies: minimizing mycotoxins in the food chain. Int J Food Microbiol. 2007 Oct 20;119(1-2):131-9. Epub 2007 Jul 31 -> http://www.ncbi.nlm.nih.gov/pubmed/18258326
  22. 22. GMO’s Strictly speaking, GMO’s are not a food safety issue, since the European Food Safety Authority is deemed to check the absence of risk prior to their authorization Yet, having considered the various political stances on this argument, the European legislator has provided comprehensive rules on GMO’s authorization, their use in food and feed, consumer information, traceability Worth of notice: some GMO’s traits are made to prevent harmful contaminations of the crops [ie. the genotoxic pyralid] EC Reg. 1829/03, regarding GMO’s on foods and consumer info EC Reg. 1830/03, on GMO’s traceability
  23. 23. GMO’s Some more positive examples
  24. 24. … UP TO THE PROCESS … Factory Environment • SUPPLY • PROCESS • PACKAGING
  25. 25. Allergens Food labels must indicate the presence - even if just in traces - of allergenic substances, and/or materials derived thereof [except those mentioned in Dir. 2007/68/EC] X-contamination risk Food containing allergenic substances not mentioned on their labels are unsafe -> They must be withdrawn and/or recalled
  26. 26. Fraudulent supplies Sudan dyes: synthetic azo dyes, hystorically used to colour products (as shoe polish, automotive paints and petroleum derivatives). -> ’03, chili powder and related products contaminated with Sudan I-IV crisis (over 1,000 products withdrawn from the EU market) Melamine: an industrial chemical found in plastics was found to have been fraudulently added to wheat gluten and rice protein from China -> ‘07, USA, pet foods crisis -> ‘08, worldwide, infant milk powder and other protein sources (milk, soy, gluten, rice) crisis Adulterated oils: mineral or industrial-use oils mixed with, and sold as, oils for human consumption -> ‘09, EU-Ukraine, sunflower-mineral oil mix import -> ‘94, the “Spanish toxic oil syndrome” (adulterated rapeseed oil)
  27. 27. Process contaminants (1) Acrylamide: is formed in food by traditional cooking methods such as baking, frying and roasting at high temperatures (>120° C) • Potato products (crisps, chips) • Coffee • Savoury snacks (e.g. crackers) • Toasted cereal products • Bread and bakery products CIAA “Acrylamide Toolbox”, best practices for monitoring and reduction PAHs: Polycyclic aromatic hydrocarbons occurr in oil, coal, tar deposits (byproducts of fossil fuel and biomass burning). Foods - ie. cereals, oils and fats (smaller intakes come from vegetables and cooked meats) - may become contaminated through - direct environmental exposure - migration from packaging material, or - thermal processing of food (baking, grilling, frying, smoking) -> Benzo(a)pyrene
  28. 28. Process contaminants (2) 3-MCPD (3-monochloropropanediol) is formed in a variety of industrially and domestically produced foods. The main area of concern is its occurrence in hydrolysed vegetable proteins, widely used ingredients and a major factor in soy sauce production (itself an ingredient in many products) Furans: highly volatile cyclic ethers that can be formed unintentionally in foods during traditional heat-treatments, such as cooking, bottling, and canning Ethyl carbamate (also known as EC or urethane) is a well known, potent carcinogen, found in fermented foods in low concentration as a naturally occurring by-product of the fermentation process
  29. 29. Food contact materials (1) • Food contact materials shall be safe. They shall not transfer their components into the food in quantities that could endanger human health, change the composition of the food in an unacceptable way or deteriorate the taste and odour of foodstuffs If an article is intended for food contact it shall be labelled for food contact or bear the symbol with a glass and fork [except in cases where the intention for food contact is obvious by the nature of the article e.g. knife, fork, wine glass] .. Framework Regulation EC 1935/04
  30. 30. Food contact materials (2) • Traceability is applied also to FCM. Safety problems concerning FCM are reported into the RASFF. In these cases, the European Commission and MS shall take appropriate measures: - border rejections - withdrawal from the market Recent crisis due to FCM risks: BADGE, BFGDE, ESBO, 3-MCPD, ITX Emerging risks: BPA (a synthetic resin used in food packaging and polycarbonate plastic products -> EFSA latest opinion in May, 2010), BBP (a widely used plasticiser used in food wraps and cosmetics), organotin compounds (heat stabilizers for PVC and as catalysts in polyurethanes and in silicones used in FCM, biocide agents in both plastics and wood -> EFSA set migration limits in its 2005 opinion)
  31. 31. FROM THE FARM TO THE FORK … Solutions ? 0 Risk is never given, Risk analysis always needed !
  32. 32. How to proceed (1) In order to comply with the EU rules and to ensure food safety, operators are requested to: Thoroughly apply Good Agricultural Practices and Good Manufacturing Practices at any stage of the food chain http://ec.europa.eu/food/food/biosafety/hygiene legislation/register_national_guides_en.pdf + A systematic method of Implement HACCP- documenting that alike systems within = each organization food safety hazards have been addressed
  33. 33. How to proceed (2) In order to addressthe international markets expectacions and qualify as a reliable supplier: ISO 22000 + Applicable GMP’s (Pre-Requisites) certification