Hygiene rules on the hygiene of foodstuffs in Europe: Which challenges for small scale producers?Elisa BiancoSlow Food Studies CentreApril 2012
A need for changeSeries of food scares at the end of 90s E.g. BSE DioxinFoot-and-mouth desease GENERAL FOOD LAW Reg (EC) No 178/2002 FOOD HYGIENE PACKAGE Reg (EC) No 852/2004 Reg (EC) No 853/2004 Reg (EC) No 854/2004
New challenges for producers and competent authorities The pillar of the general framework is A sort of industrialization Flexibility of manufacturing both for producers and processes for competent authoritiesInterpretation may become an Potential requirement of new issue structures, equipments, furniture, ecc
At the end what do producers complain about? Most of the problems arise with foodstuff of animal origin (specificRegulation) Too many requirements for new equipment and for spatial separationof processes (i.e. needing new infrastructures) Cost increase and time delay due to implementation of lawrequirements In-house slaughtering becomes impossible
Raviggiolo cheese offers a good case studyCow raw milk cheeseAvailable only from October to MarchFor more info:http://www.presidislowfood.it/ita/dettaglio.lasso?cod=118&id_regione=&id_tipologia=9& Slow Food Presidium since 2002 Produced in the Apennines mountains in Emilia-Romagna
Raviggiolo cheese offers a good case studyEspecially the story of one producer can teachsomething: the case of Azienda Agricola Bresciani Bresciani farm transformed 5 litres of milk per day Communication activities The farmer decided to increase his production trying to fully comply with the initial authorities requirements
Azienda Agricola Bresciani: a never-ending story End of 2002: the producer asks for the approval of a 20 sqm transformation laboratory Beginning of 2003: first anticipatory approval is given by local governmental authorities. Bresciani starts the construction of the lab, health authorities are asked to verify the compliance with the law Mid 2003: health authorities give their positive opinion…… then at the beginning of 2004 new requirements were asked: 50 sqm transformation laboratory instead of 20 sqm Minor modifications to infrastructure (i.e. water plant) and manufacturing process (i.e milk pasteurization became essential)
Azienda Agricola Bresciani: the end of the story Beginning of 2006: the lab was active, its final cost was over 70,000 € Bresciani had to increase his production and cover the investment (90 litres of milk per day) Out of the Presidium project because of the pasteurization … While those who followed the path withSlow Food and the health authority of Forlì Prepared a proper technical documents fully describing real risks and precautions needed Smaller modification of manufacturing process (costs dropped to 30,000 €) No need to pasteurize the milk
Raviggiolo Presidium: final lessons learnt Need of protecting traditional products before their manufacturing process is modified to comply with new or inappropriate rules Importance of consortium instead of single producers alone Importance of technical knowledge both for producers and for competent authorities Preparation of technical guidelines describing manufacturing process in order to protect the history of the products and the knowledge of producers Derogations are possible with proper documentation folders But what about small-scale producers not linked to peculiar traditional products?
The case of Bolzano province (Trentino-Alto Adige region) Decree no 52 issued by the province of Bolzano on 26th September 2008 All producers located within the province may take advantage of the law Many derogations are made for these producers, i.e. the possibility of avoiding spatial separation of processes, using home kitchen for the manufacturing or avoiding to stamp each eggHowever, as far as meat production is concerned, exceptions are granted only for poultry and rabbits. No exceptions for ovine, equines, pork or cattle.
Take home message Flexibility offers a lot of solutions: it may open manyrelevant opportunities but technical knowledge, expertise and collaboration between producers, technicians and competent authorities are crucial for the things to work properly Thank you for your attention!