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

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. EU food law
...
in a nutshell

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. 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. “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. 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. Environment & Food Safety
Heavy Allergens
Metals Process
contaminants
Pesticides
MRL’s Food
Micotoxins
Contact
…
Materials
Dioxins
PCB’s
Water
[GMO’s]

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. 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. 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. 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. 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. 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. … INTO THE SUPPLY CHAIN …
Crops
agriculture raw materials

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. 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. 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. 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. 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. 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. 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. 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. GMO’s
Some more
positive
examples

24. … UP TO THE PROCESS …
Factory Environment
• SUPPLY
• PROCESS
• PACKAGING

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. 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. 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. 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. 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. 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. FROM THE FARM TO THE FORK …
Solutions ?
0 Risk is never given,
Risk analysis always needed !

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. 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