national control plan - fsai

ANNUAL REPORT ON IRELAND’S

NATIONAL CONTROL PLAN

for the period 1 January 2013 to 31 December 2013

1

Introduction

This annual report on Ireland’s national control plan (NCP), covers the period from 1 January

2013 to 31 December 2013. It has been prepared in accordance with the requirements of Regulation (EC) No. 882/2004 by the Food Safety Authority of Ireland and the Department of Agriculture, Food and the Marine.

Contact point

All enquiries regarding the annual reports of Ireland’s National Control Plan should be directed to:

Responsibility for official controls of food

Contact point: Food Safety Authority of Ireland

Address: Abbey Court, Lower Abbey Street, Dublin 1.

Email address: [email protected]

Telephone: +353-1-8171320

Fax: +353-1-8171301

About

The Annual Report is presented in a tabular form. The section numbers in the left column of the tables refers to COMMISSION DECISION of 24 July 2008

1 on guidelines to assist Member States

in preparing the annual report on the single integrated multiannual national control plan provided for in Regulation (EC) No 882/2004 of the European Parliament and of the Council. The responsibility for enforcement of food legislation is managed through service contracts between FSAI and a number of competent authorities, also known as ‘official agencies’; a section for each official agency is provided in the Report along with sections covering the other elements of the country’s Multi-Annual National Control Plan.

1 http://mancp-riskbasedplanning.wikispaces.com/file/view/Dec_2008_654.pdf

http://www.fsai.ie/WorkArea/DownloadAsset.aspx?id=1216

http://mancp-riskbasedplanning.wikispaces.com/file/view/Dec_2008_654.pdf

http://mancp-riskbasedplanning.wikispaces.com/file/view/Dec_2008_654.pdf

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Contents

Introduction ...................................................................................................................................................... 1

Contents ........................................................................................................................................................... 2

Glossary ........................................................................................................................................................... 3

The Food Safety Authority of Ireland ................................................................................................................ 4

ANNEX: FSAI1 ................................................................................................................................ 10

The Department of Agriculture, Food and the Marine .................................................................................... 14

ANNEX DAFM1 - VIAP Risk Assessment Form .............................................................................. 62

ANNEX DAFM2 - SVI Risk Assessment Form ................................................................................. 65

ANNEX DAFM3 - 2013 - Summary of Legal Notices served ........................................................... 68

ANNEX DAFM4 - Risk Assessment Protocols of VPHIS ................................................................. 70

ANNEX DAFM5 - VPHIS Training.................................................................................................... 72

ANNEX DAFM6 - Plant Health Control information.......................................................................... 75

Health Service Executive (HSE) ..................................................................................................................... 79

Appendix: HSE1............................................................................................................................... 82

Sea-Fisheries Protection Authority (SFPA) .................................................................................................... 87

ANNEX: SFPA1 ............................................................................................................................... 90

Local Authorities (LA) ..................................................................................................................................... 92

Annex: LAVS1 ................................................................................................................................. 95

The Marine Institute (MI) ................................................................................................................................ 98

Annex: MI1 - Sampling & Analysis ................................................................................................. 101

The National Standards Authority of Ireland (NSAI) ..................................................................................... 104

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Glossary

ABP: Animal By-Products

BIP: Border Inspection Post

DAFM: Department of Agriculture, Food and the Marine

FBO: Food / Feed Business Operator

FSAI: Food Safety Authority of Ireland

HSE: Health Services Executive

MI: Marine Institute

MRL: Maximum Residue Limit

NSAI: National Standards Authority of Ireland

SFPA: Sea-Fisheries Protection Authority

SVSIAG: State Veterinary Service Internal Audit Group

TSE: Transmissible spongiform encephalopathies

VPHIS: Veterinary Public Health Inspection Service

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The Food Safety Authority of Ireland

The FSAI is the competent authority with overall responsibility for the enforcement of food legislation in Ireland. The responsibility for enforcement of food legislation is managed through service contracts between FSAI and a number of competent authorities, also known as ‘official agencies.’ There were 33 such official agencies in 2013:

The Department of Agriculture, Food and the Marine;

The Sea-Fisheries Protection Authority;

The Health Service Executive;

The Marine Institute;

28 Local Authorities (comprising of 27 County Councils and one City Council); and,

The National Standards Authority of Ireland.

These official agencies are subject to audit by the Authority to verify the effectiveness and appropriateness of food controls and to monitor conformance by official agencies with the terms and requirements of their respective service contracts. All Authority audit reports and corrective action plans are published on the Authority’s website. Information on the areas of responsibility for the official agencies can be found in Annex FSAI1 (table 4). The Authority retains some direct enforcement responsibility for specific areas of activity, for example the Authority is the competent authority for irradiated food, genetically modified food and novel foods. The Authority is the national central control point for information and communication relating to food incidents and food alerts, and provides 24/7 emergency cover. The Authority is also the Irish contact point for the European Commission’s Rapid Alert System for Food and Feed. Scientific risk assessments are conducted by the Authority in respect of identified hazards found in food. These assessments are used as the basis for risk management decisions. This supports food control activities to ensure that actions are based on science.

MANCP Section

Title Information

9.1 List Official Control (OC) activity

In 2013, the FSAI received 11 Foods for Particular Nutritional uses (PARNUTS) notifications and 108 foods for special medical purposes notifications; a 330% rise in the number of notifications since 2012 (32)

1,697 notifications for food supplements were received, an increase of 55%, compared to 2012.

The FSAI conducted safety assessments on four novel foods:

milk fermented with Bacteroides xylanisolvens;

resveratrol;

Creatine Magnapower; and,

organic silicon.

The safety assessments of seven novel foods or food ingredients carried out by other Member States were reviewed:

Methylcellulose;

Isomaltooligosaccharides;

DHA and EPA rich algal oil;

DHA rich algal oil;

Clostridium butyricum;

Chia seed oil; and,

Tetraselmis chuii.

Nine applications were accepted for opinions on the substantial

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equivalence of novel food ingredients to similar ingredients already on the EU market. Positive opinions on:

Baobab fruit pulp X 2;

Lactoferrin;

DHA algal oil;

Beta glucan;

Chia seed;

GOS;

Vitamin K2; and,

Resveratrol.

The Authority issued 40 original Rapid Alert System for Food and Feed notifications in 2013:

30 in respect of food;

Two in respect of feed;

Eight for food contact materials;

Ireland was the country of origin of products for 28 of the notifications issued through RASFF in 2013 for food or food contact materials, an increase of ten compared to 2012;

During 2013, a total of 85 of the original RASFF notifications processed through the system involved the distribution to Ireland (71 relating to food, seven to feed and seven to food contact materials).

In 2013, the Authority handled 449 food incidents (See Annex FSAI1), an increase of 11%, compared with 2012. Incidents were categorised as full food incidents, minor food incidents and cross-country food complaints.

In 2012, a new category was introduced for food incidents relating to food fraud.

217 full food incidents (including nine food fraud incidents) were investigated in 2013, compared to 55 in 2012:

Chemical hazards were most frequently identified (70); followed by microbiological hazards (47); other hazards (44); allergens (24) and other biological hazards including mycotoxins (16);

Most of the 70 chemical hazards were as a result of composition/additives (28); pesticides/residues of veterinary medicines (13); chemical contamination (12) and migration from food contact materials (8);

141 minor incidents were investigated in 2013; a decrease of 23 (16%), compared with 2012;

91 cross-country food complaints were handled in 2013, compared with 75 in 2012;

There were 39 countries of origin for foods associated with the 449 incidents and 17 of these were European Union Member States;

The Republic of Ireland was the country of origin in 36% (160) of the incidents, followed by the United Kingdom 19% (85), Northern Ireland 5% (24), Poland 3.1% (14), France 2.9% (13) and China 2.7% (12).

25 food alerts were handled by the FSAI during 2013 relating to 24 incidents.

Nine of these were Category 1 alerts for action;

16 were Category 2 alerts for information;

Nine of these food alerts related to microbiological spoilage or possible presence of pathogenic organisms;

Five related to horsemeat; four to the the presence of

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foreign bodies; four to contaminants; one to incorrect labelling; one counterfeit product and one to food supplements containing illegal ingredients;

The Authority also published 13 food allergen alerts in 2013 (a similar number to 2012), ten of these related to undeclared allergens on the labelling, while three related to inconsistent/ incorrect labelling.

The Authority provided 147 risk assessments to support incident management in 2013. These were in the areas of veterinary medicine, pesticide residues, food allergens reviews, irradiation, microbiology reviews and nutrition.

Provisional data from the Health Protection Surveillance Centre indicate that in 2013, food was reported as the suspected cause of eight outbreaks of gastroenteritis (infectious intestinal disease):

four salmonellosis outbreaks; two outbreaks of verocytotoxigenic Escherichia coli (VTEC) infection; one outbreak of acute infectious gastroenteritis and one outbreak of norovirus infection;

These eight outbreaks accounted for 102 cases of illness of which three were hospitalised;

One VTEC outbreak of E. coli O157 was epidemiologically and microbiologically linked to a raw milk cheese.

A total of 2,846 complaints were handled by the Authority’s Advice Line (up 12.5% on 2012).

A total of 91 food samples were analysed for irradiation with one (a food supplement) being found to have been irradiated and not labelled appropriately.

Food Authenticity Verification Survey

The Authority studied salami, beef meals and beef burger products for traces of pork, beef and horsemeat;

Results showed that ten of the 27 beef burgers sampled were adulterated with horsemeat, one of which contained 29% horse DNA relative to the beef DNA;

Additional testing for the presence of residues of veterinary drugs was also undertaken and all the results were negative;

When the Authority published the results, it was on a sound scientific basis and the results withstood the challenges from the industry and elsewhere. The work of the Authority uncovered an EU-wide incident where a number of beef products were adulterated with horsemeat ;

The European Commission coordinated a survey on the authenticity of beef products on the market in April 2013, the results showed that 4.7% of products were adulterated with more than 1% horsemeat, some at a level of 100%;

This incident created huge media interest and the Authority’s press office handled in excess of 780 queries from the media, both in Ireland and overseas.

The Authority also coordinated the sampling and analysis of 55 food samples by the Environmental Health Service of the Health Service Executive and the Public Analyst Laboratories respectively, for the authorised presence and appropriate labelling of genetically modified ingredients. All samples analysed were found to be compliant with the relevant legislation.

The Authority, in collaboration with the Marine Institute has carried out a further surveillance study of levels of dioxins (PCDDs), furans (PCDFs) and polychlorinated biphenyls (PCBs) in fish, in addition to those already carried out in 2001 and 2004. The study was carried out in a variety of wild and farmed finfish species, and also prawns and cultivated mussels available on the Irish market. It was undertaken due to concern about the possible effects on human health of these bio-persistent environmental contaminants, known to be present in a number of foodstuffs including, in particular, fish, meat, eggs and dairy products. Furthermore, the

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study also proactively monitored fish and other seafood for a number of emerging new contaminants, in order to contribute to the knowledge base on the occurrence of these contaminants in food and to aid national and international efforts in their management. The results were published and showed that dioxin levels remained low.

9.2 Statement of compliance (with this OC)

Overall compliance Overall in compliance in those areas for which the Authority has direct responsibility was good.

9.2.2.1 & 9.2.2.2

What proportion of the checks identified non-compliance

Checks on notifications for food supplements resulted in 60 products being referred to the Irish Medicines Boards as suspected medicines.

161 products shown not to be food supplements were refused that designation.

What were the main types of non-compliance identified

Information on this specific point is not available.

Were the non-compliances clustered or randomly distributed

Randomly distributed.

Categorise these non-compliances into major, moderate and minor and give the proportion/frequency


9.2.2.3 What was/were the root cause/s of the non-compliances identified


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9.4.1

Actions to ensure compliance by Food and Feed Business operators and other relevant business operators with official controls.

The Food Safety Authority of Ireland Act, 1998 grants authorised officers the power to inspect food businesses for compliance with food safety legislation. Under this Act, authorised officers may, if conditions present risks to public health, serve an Improvement Notice (requiring remedial work to be carried out); an Improvement Order (issued by the District Court as a result of non-compliance with an Improvement Notice); a Closure Order (closing a business down) or a Prohibition Order (placing restrictions or prohibitions on the use of food). The Health Service Executive has additional powers under the EC (Official Control of Foodstuffs) Regulations, 2010 (S.I. No. 117 of 2010) to serve Closure Orders or Prohibition Orders for non-compliance with food legislation. Actions taken to deal with non-compliances

In 2013, the FSAI and its official agencies served 466 Enforcement Notices and Orders on 429 food businesses. This represented a 12% increase on the number of notices and orders served in 2012 (See Annex FSAI1).

The majority of notices were served by the Health Service Executive, which supervises the majority of food businesses in Ireland.

119 Closure Orders were served in 2013, an increase of 31% on the previous year.

The Authority was notified of 13 successful prosecutions, all undertaken by the Health Service Executive, an increase of three on the previous year. Most (nine) prosecutions were against food businesses in the service sector.

The Authority’s carried out a number of targeted (or focused) audits to examine food business operators’ compliance with respect to a specific aspect of food law:

In 2013, an audit of poultry meat labelling and traceability in catering and retail businesses was carried out. The audit focused on the businesses food safety management system with regard to labelling and traceability of poultry meat and the information provided to customers;

An audit to assess the appropriateness and use of food additives such as nitrites, sulphites, phosphates and colours, in meat products and meat preparations, was also undertaken by the Authority as part of the 2013 planned programme of targeted audits.

9.4.2 Actions to ensure effectiveness of Official Controls (by the CA)

In 2013, the Authority established a Food Fraud Task Force consisting of representatives from national agencies from across different enforcement arms of the State. It is an advisory group which acts as a communications, coordination and networking group where intelligence and research can be shared at national and international level. The work of the Food Fraud Task Force includes raising awareness, improving mechanisms for monitoring and surveillance and training of enforcement officers.

In 2013, the Authority carried out two audits of official controls by the Health Service Executive in Category 2 classified food businesses, and in food supplements manufacturers, packers and distributors.

An audit of the official controls carried out by the Department of Agriculture, Food and the Marine’s inspectorate in small cheese manufacturers was also undertaken in 2013 together with an audit of the Department’s official controls in milk producers, which commenced 2013.

The Authority also carried out an audit of the Sea-Fisheries Protection Authority to assess progress on the corrective actions introduced in response to the findings outlined in the FVO Mission Report DG(SANCO) 2011-6007, which was carried out to evaluate the official food safety control system in place governing the production and placing on the market of bivalve molluscs.

9.5 Statement of Overall compliance within the sector

The Authority considers that overall compliance within the sector during 2013 was satisfactory.

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Comment on the appropriateness and suitability of the MANCP

Did the programme of OC’s identify any necessary amendment to MANCP No.

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ANNEX: FSAI1

11

Year Full

Incidents Minor

Incidents

Cross-country

Complaints

Food Fraud

Full incident /

Food Fraud

Minor incident /

Food Fraud

Total

2013 208 141 91 5 3 1 449

2012 162 167 75 404

2011 147 170 79 396

2010 129 165 60 355

2009 98 120 64 297

Table FSAI1: Number of Food Incidents, 2009 – 2013.

2009 2010 2011 2012 2013

Closure order 34 57 66 91 119

Improvement order 7 4 7 3 5

Prohibition order 13 12 11 15 20

Improvement notice 275 254 294 307 322

Total 329 327 378 416 466

Table FSAI2: Enforcements Served, 2009 - 2013

2009 2010 2011 2012 2013

Service Sector Business 23 45 55 79 89

Retailers 9 9 7 9 19

Manufacturer / Packer 2 1 2 3 5

Distributors / Transporters 1 6

Manufacturer Selling Direct 1 1

Primary 1

Total 34 57 66 91 119

Table FSAI3: Closure Orders Served, 2009 – 2013

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2009 2010 2011 2012 2013

Department of Agriculture, Food and the Marine

Meat Processors 156 154 154 153 154

Egg Producers 264 285 376 354 369

Milk Processors 231 230 233 240 231

Total 651 669 763 747 754

Health Service Executive*

Primary Producers 30 27 23 21 0

Manufacturers and Packers 1649 1921 2253 2534 2956

Distributors & Transporters 1246 1370 1487 1472 1162

Food Service Businesses 31055 30567 31404 30311 28214

Retailers 10533 10732 11166 10978 10972

Manufacturers Selling Primarily on a Retail Basis

790 1738 724 695 0

Other 115

Total 45303 46355 47057 46011 43419

*The total number of establishments supervised by the Health Service Executive Environmental Health Service shows a significant drop in 2013 compared to previous years, due to the development of a new IT system for recording establishments and inspections.

Sea-Fisheries Protection Authority

Approved Establishment 177 183 183 189 180

Aquaculture Sites** 86 86 0 0 0

Factory & Freezer Vessels (Approved – Irish)

21 23 23 34 36

Fishing Vessels 2095 2129 2201 2216 2155

Ice Plants 12 13 12 12 12

Molluscan Production Areas 150 130 131 131 133

Registered Food Business on Land 35 45 56 81 75

Total 2576 2609 2606 2663 2591

** Inspection of aquaculture sites transferred to the Department of Agriculture, Food and the Marine in 2010.

Local Authorities

Slaughterhouses 237 219 212 206 202

Small Meat Manufacturing Plants 186 175 180 189 180

Poultry Plants 27 37 41 35 34

Other 7 20 17 26 24

Total 457 451 450 456 440

Table FSAI4: Number and Type of Food Businesses Inspected by Official Agencies, 2009 – 2013

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2009 2010 2011 2012 2013 % Change 2009-2013

Department of Agriculture, Food and the Marine (not

including temporary veterinary inspectors engaged in meat inspection).

501 511 454 433 438 -12%

Health Service Executive

Environmental Health Service 379 361 333 344 307 -19%

Food Microbiology Laboratories 83 79 74 73 71 -14%

Public Analyst Laboratories 67 69 68 65 66 -1%


46 43 45 42 41 -11%

Local Authorities 75 72 72 71 73 -3%

Marine Institute 28 28 31 28 27.4 -

National Standards Authority of Ireland

0.1 0.1 0.1 0.1 1.1*

Food Safety Authority of Ireland (not including consultancy

staff or staff on short-term contract) 84 75 74 72 71 -15%

Total 1263 1238 1151 1128 1096 -13%

Table FSAI4a: Number of Staff (Whole Time Equivalent) Working in Official Control

*The National Standards Authority of Ireland increased the number of staff engaged in food safety contact materials

2009 2010 2011 2012 2013 % Change 2009-2013

Department of Agriculture, Food and the Marine

(Inspections in meat, milk and egg processors).

14303 13169 11495 10830 9547 -33%

Health Service Executive 45485 41966 37973 36584 33971 -25%


2792 2521 2330 2386 2114 -24%

Local Authorities - - 5156 4630 5021 -3%*

Total 62580 57656 56954 54430 50653 -11%

(2011-2013)

Table FSAI4b: Number of Inspections by Official Agencies, 2009-2013

*Inspection activity before 2011 was recorded differently and the numbers are not comparable. The % change is for 2011-2013

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The Department of Agriculture, Food and the Marine

Official Control Activity

Department of Agriculture, Food and the Marine – Veterinary Public Health

Number planned

Total number of planned official controls: 3035. Total number of actual official controls: 5153. This compares with a planned number of official controls in 2012 of 3210 The number of official controls carried out in 2012 was 5153. There has been a decrease of 6% in the planned number of official controls from 2012 to 2013 There has been a decrease of 16% in the actual number of official controls carried out.

Annex DAFM1 contains a copy of the Veterinary Inspection and Audit Programme (VIAP) Risk Assessment Form used in 2013.

Annex DAFM2 contains a copy of the Superintending Veterinary Inspector Risk Assessment Form used in 2013.

% completed

100% of planned official controls took place in 2013.

An additional 2118 official controls were also carried out.

Comment

The reason for the discrepancy between planned and actual controls includes:

Specific investigations / complaints e.g. equine DNA investigation

New approvals for activities in existing plants, or new approvals of new establishments.

Preparation for internal and external audits.

Close out of audits and inspection findings.

A considerable increase in certification of product to Third Country destinations, or pre-export for eventual TC destinations.

Third country delegation preparations, visits and close outs.

Specific checks for Third Country criteria

VPHIS exercises a structured risk based approach to undertaking official controls. The additional ad hoc controls, increasingly represent a resource issue for VPHIS in an environment of diminishing budgets and staff. The added work includes meeting FBO requirements for trade [certification] and ad hoc controls arising from findings / complaints / audits / delegations over which the VPHIS has no direct control.

The list of Audits in 2013 includes

1. FVO HACCP Audit 2. FVO Poultry Meat/poultry meat products 3. IAG Equine Audit 4. IAG Sheep Audit 5. FSAI audit on the “Supply and Use of Food Additives in Meat Products and Meat

Preparations in Food Business Operators”. 6. IAG Chemical and Microbiological testing – Animal By Products 7. IAG audit on Wild Game 8. FSAI Follow up and close out audit of non-compliances in meat premises

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Department of Agriculture, Food and the Marine – Animal By-Products

Control Activity No of planned Official

Controls No

completed

Number OC (inspections) that disclosed non-

compliance

ABP Biogas Plant Total 8 8 4

ABP Collection Centre Total 6 4 2

ABP Composting Plant Total 21 20 9

ABP Fish Meal Total 12 9 3

ABP Handling and Storage (other) Total 3 2 1

ABP Haulier Cat1 Total 28 13 4



ABP Hide Store Total 7 2 4

ABP High Capacity Incinerator Total 1 1 1

ABP Knackeries Total 84 84 44

ABP MBM/Tallow Store Total 2 3 1

ABP Meat Feeder Total 16 183 59

ABP OF/SI End Users Total 6 5 4

ABP Poultry Farm Total 20 9 1

ABP Rendering Plant (CAT 1) Total 8 8 4

ABP Rendering Plant (CAT 3) Total 8 8 4

ABP Technical Plant Total 3 3 1

ABP Wool and Hair Store Total 14 13 11

Department of Agriculture, Food and the Marine – Animal Breeding Delivery


Controls No

completed


compliance

Bovine Embryo collection 20 22 2

Bovine Semen Collection 8 8 0

Bovine semen storage 10 10 0

Equine Semen Collection 11 11 4

Ovine Semen Collection 0 0 0

Porcine Semen Collection 7 7 0

Department of Agriculture, Food and the Marine – Animal Welfare delivery


Controls No

completed


compliance

Bovine at risk herd 497 595 325

Bovine calf 190 181 68

Bovine general 190 101 20

Broiler 36 21 16

Equine 0 30 18

Incident Bov on farm 0 366 249

Incident Ovine on farm 0 105 49

International Type 2 147 456 30

National Type 1 98 73 2

Ovine 126 105 11

Porcine 0* 99 68

Domestic fowl, ducks, geese, turkeys 0 11 1

Poultry Barn & Free Range 18 7 3

Poultry Enriched 10 6 4

Type 2 Transport 0 292 37

Checks on transport at meat plants 425 425 24

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Department of Agriculture, Food and the Marine – Bovine ID and registration checks


Controls No

completed


compliance

Bovine ID checks 4653 4653 1087

Department of Agriculture, Food and the Marine – Assembly centre checks


Controls No

completed


compliance

Assembly Centre Inspections 4 4 0

Department of Agriculture, Food and the Marine – ERAD TB and Brucellosis checks


Controls No

completed


compliance

Annual testing Previously reported to the EU Commission

Consequential testing

Investigations 0 747 69

PVP supervision 119 143 16

Department of Agriculture, Food and the Marine – Trade and List A Disease


Controls No

completed


compliance

Bovine consignments 6059 6059 13

Investigations following list A alerts 1 1 1

Ovine consignments 172 172 5

Porcine consignments 3451 3451 3

Poultry consignments 745 745

Department of Agriculture, Food and the Marine – Controls at Livestock Marts


Controls No

completed


compliance

Annual inspection 84 70 18

Compliance inspection 937 819 80

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Department of Agriculture, Food and the Marine – Animal Remedies


Controls No

completed


compliance

Bovine Bovine Pos residue 28 28 0

Bovine Regular 204 184 48

Caprine Cervine 232 267 3

Compound feedmill inspections

Dealer medicines 5 4 1

Eggs 267 281 0

Equine 494 487 0

Honey 100 118 2

Licensed Merchants inspection 100 108 33

Milk 1108 1208 2

On-farm feedmill inspections

Ovine 1800 1960 6

Ovine Regular

Porcine

Porcine Pos residue 2 2 0

Porcine Regular 21 22 0

Poultry 1255 1296 2

Poultry Pos residue 2 2 0

Poultry Regular

PVP/practice insp 95 84 58

Wholesaler insps 12 12 0

Residue sampling at meat plants 2126 1971 35

Department of Agriculture, Food and the Marine – Sheep and Goat herd visits


Controls No

completed


compliance

Goat inspections 4 4 1

Sheep inspections 229 205 0

Department of Agriculture, Food and the Marine – Zoonoses


Controls No

completed


compliance

Broiler breeders 61 64

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Department of Agriculture, Food and the Marine - Pesticide Controls

Section 2 of the National Control Plan for Ireland for the period from 1st January 2012 to the 31st December 2016 (MANCP) includes details on the control of pesticide residues in food on the Irish market. These controls are carried out by the Pesticide Controls Division of DAFM with the cooperation of the Pesticide Control Laboratory. DAFM and the FSAI agree the annual programme for controlling pesticide residues in food and submit a copy to the EU Commission as required by Regulation (EC) No. 396/2005. The EU Co-ordinated Monitoring Programme for pesticide residues is incorporated within this programme.

Area controlled Controls

applied 2013

% of target programme achieved.

Comments

Sector: Food of plant origin.

Pesticide residues in food of plant origin.

946 samples of Fruit & Vegetables (W/R/P).

101% of 2013 plan for fruit & vegetables was achieved.

Delivery is in line with 2013 programme requirements, and includes the commodities specified in the EU coordinated programme, Commission Implementing Regulation (EU) No 788/2012. Samples are selected randomly and are traceable to producer/country of origin except in the case of processed products (which were not traced to the original producer).

100 planned samples of cereals (W/P).

72% of plan for cereals was achieved.

All cereal samples were selected randomly and traceable to producer/country of origin.

Increased control of pesticide residues in certain foods of plant origin as set by Commission Regulation (EC) No 669/2009

11% of all consignments subject to the increased level of controls were sampled.

With the exceptions of Tea from China, all target sampling frequencies were attained.

Total consignments for 2013 = 779, an increase of 172% on 2012.

Reactive Programmes

Pesticide residues in food.

20 planned samples (estimated as follow up to all breaches in 2012).

120% of the reactive programme was achieved.

Delivery in line with the 2012 Control plan

Follow up to RASFF notifications relevant to Ireland.

No consignment was encountered in Ireland which related to a RASFF notification.

No follow up action required.

W=wholesale; R=retail; PP=primary processing

Area controlled Controls applied


Comments

Sector: Food of animal origin (FAO)

Pesticide residues in food of animal origin. (FAO)

395 planned samples, including kidney fats of bovine, cervine, equine, ovine, porcine, poultry and game, as well as milk, eggs, honey and ham.

105% of the plan was achieved.

FAO samples were analysed using multi-residue methods which cover the organochlorine and organophosphorus pesticides, as required in Directive 96/23/EC, and a wide range of other pesticides. The programme includes samples specified in Commission Implementing Regulation (EU) No 788/2012.

Pesticide residues in infant formula and follow on formula samples

30 planned samples of infant formula.

133% of the plan was achieved.

Samples analysed as specified in Commission Regulation (EU) No 788/2012 and in accordance with Commission Directive 2006/141/EC.

References to detailed area report

Pesticides Residues in Food

Detailed report outlining the results of the 2013 Pesticide Residue Monitoring Programme will be submitted to the Commission in accordance with the requirements of Regulation (EC) No 396 of 2005. http://www.efsa.europa.eu/cs/Satellite. The national residue report for 2013 will be uploaded at http://www.pcs.agriculture.gov.ie/.

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Department of Agriculture, Food and the Marine - Animal Feedingstuffs Controls

Section 3 of the National Control Plan for Ireland for the period from 1st January 2012 to the 31st December 2016 deals with the control of feed on the Irish market. The Feedingstuffs, Fertiliser, Grain & Poultry Division in conjunction with the Crop Policy, Production and Safety Division is responsible for the monitoring, regulation and control of all stages of the animal feed chain. These two bodies combined are known as the Animal Feedingstuffs Control Group (AFCG). In line with the Commission Recommendation 2005/925/EC, results of the coordinated community inspection programme have been forwarded to the Commission.



Comments

Sector: Feedingstuffs

Feed Business Operators

1,276 Unannounced inspections .

78% Delivery broadly in line with 2013 plan requirements for prioritised inspections.

131 Audits. 88 % Reduced staff resources has resulted in some audit inspections being carried over into 2014 to allow for completion of programme.

Feed

1,554 samples taken and analysed. 1,476 labels inspected.

89%

Delivered in line with 2013 plan requirements; higher risk areas prioritised.

Feed Drying

85 samples of dried feed taken and analysed for PCB’s.

100% Grain (Harvest 2013) plus other native feed materials subject to drying e.g. seaweed meal.

Reactive Programmes

201 samples of feed materials and compound feeds checked for Dioxins.

This is in response to the 2008 dioxin incident.

Reference to detailed area reports

Feed Control In line with Commission recommendation 2005/925/EC specific reports are forwarded to the relevant sections of the Commission.

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Department of Agriculture, Food and the Marine - Horticulture Controls (Fruit & Vegetables)

Horticulture & Plant Health Division is responsible for implementing controls relating to fresh fruit and vegetables as well as honey (also see below and Section 2 National Control Plan for Ireland for the period from 1st January 2012 to the 31st December 2016). The controls are required by legislation and relate to general food hygiene in terms of fruit and vegetable production. The following EU legislation is applicable: Regulation (EC) No 178/2002, Regulation (EC) No 852/2004, Commission Regulation (EC) No 2073/2005 as amended, Commission Regulation (EC) No. 1881/2006 and Regulation (EC) No 882/2004.



Comments

Contaminants in horticultural produce

119 samples of Potatoes and other vegetables for Cd and Pb analysis Official samples (PP/W)

100%

Exceeded target number set in 2013 Plan.

822 samples of potatoes and vegetables for heavy metals (Cd and Pb) (Research Trials)

100% Exceeded target number set in 2013 Plan.

68 samples of lettuce, spinach and rocket for nitrates (PP/W)

100% Exceeded target number set in 2013 Plan.

10 samples of apple juice taken for patulin analysis (PP/P)

60%

Did not meet the target number set in 2013 Plan due to staff resources and poor harvest resulting in low availability of product to sample.

Microbiological samples

39 Horticultural produce for Food Safety

100% Delivery in line with 2013Plan.

45 Horticultural produce for Process Hygiene

100% Delivery in line with 2013Plan.

15 samples of sprouted seed for VTEC

100% Delivery in line with 2013 Plan.

67samples of water used in PP

100% Delivery in line with 2013 Plan.

Hygiene Inspections of horticultural producers

57 hygiene inspections (PP), 21follow-up inspections, 5 supervisory inspections

76% Staff resources and other issues resulted in target not being achieved.


Contaminants in horticultural produce

Detailed report outlining the results of the 2013 nitrate monitoring programme will be submitted to the EFSA in June 2014.

W=wholesale; R=retail; PP=primary processing

Department of Agriculture, Food and the Marine - Plant Health Controls

Section 5 of the National Control Plan for Ireland for the period from 1st January 2012 to the 31st December 2016 covers the control of plant health in Ireland. Detailed reports of the monitoring results, as required under Council Directive 2000/29/EC, are submitted to DG SANCO E.7 and F.4 via the Standing Committee on Plant Health. Official surveys were carried out for the relevant harmful organisms in the Annexes of Council Directive 2000/29/EC. All positive findings were notified and appropriate measures were taken for eradication or containment as necessary. In general Horticulture & Plant Health Division is responsible for implementing Plant Health controls, however in the case of potatoes, Crop Evaluation and Certification Division are involved in sampling and inspecting seed crops for quarantine organisms.

21

A summary of Plant Health controls for 2013 are appended to the report as Annex DAFM6.

Department of Agriculture, Food and the Marine - Milk & Milk Products Controls

Section 2 of the National Control Plan for Ireland for the period from 1st January 2012 to the 31st December 2016 outlines details of official controls implemented by DAFM including control of milk and milk products in Ireland. The Dairy Controls and Certification Division are responsible for carrying out official controls in milk processing establishments which include monitoring, audit, inspection and surveillance of these establishments, including official control procedures relating to the composition and labelling of infant formulae and follow-on formulae intended to be placed on the market in a Member State or intended for export to Third Countries. Controls governing milk and milk products are required by Regulation (EC) Nos. 178/2002, 852/2004, 853/2004, 854/2004, 2073/2005 (microbiological criteria) as amended by Commission Regulation (EC) 1441/2007. The Dairy Controls and Certification Division is also responsible for official sampling of raw milk under the national residue control plan drawn up under Council Directive 96/23/EC. In the infant formula sector controls are implemented in line with Directive 2006/141 (as amended), Directive 92/52 and Directive 1999/21 on dietary foods for special medical purposes. Controls also take into account other cross referenced legislation such as contaminants, additives and purity criteria, food contact materials, labelling, traceability, etc. The Dairy Controls and Certification Division is also responsible for official controls on milk and milk products under Regulation 1069/2009 and Regulation 142/2011 (health rules concerning animal by-products not intended for human consumption) in milk processing establishments. Under Regulation (EC) No. 882/2004 as amended, the Dairy Science Laboratory in Backweston is the National Reference Laboratory for the following specific parameters; Listeria monocytogenes, Coagulase positive staphylococci, total bacterial count and somatic cell count in raw milk and phosphatase activity in milk. The three Dairy Science laboratories situated at Backweston, Limerick and Cork are official designated laboratories for testing samples taken during official controls and all 3 are accredited in accordance with the European standards, EN ISO/IEC 17025.



Comments

Sector: Food of animal origin

Milk and milk products

217 planned official controls of milk processing plants, collection centres and stores. 46 planned Official Controls relating to Food Business Operators producing and/or collecting raw milk.

84 % 56%

Targets adjusted to account for 20 official controls which could not be completed because the FBO closed down or were not in production in 2013.

203 planned inspections of milk production holdings.

101 %

Successful delivery in line with 2013 plan

6,456 planned samples for food safety, process hygiene, antibiotics and heat treatment verification as per Reg. 2073/2005 (as amended), Reg. 853/2004 and Reg. 2074/2005. 997 additional samples were

88 %

Target adjusted to account for 1,063 samples which could not be taken because the FBO closed down or was not in production in 2013. The 7,453 samples equates to 11,808 test parameters including 33 tests carried out to confirm the absence of Staphylococci enterotoxin.

22



Comments

taken for new premises/new products in existing premises, for hygiene monitoring and for food safety samples to support export certification in line with a MOU with US FDA. Total 7,453.

285 planned samples of water under Directive 98/83/EC

97% Successful delivery in line with 2013 plan; chemical analysis not in place.

76 infant formula/ follow on formula controls relating to the inspection of label regulatory requirements and audits of FBO’s own controls under Directive 2006/141/EC and Council Directive 92/52/EEC

n/a

The frequency and type of control set down by inspecting officer as per SOP. 74 related to the inspection of label regulatory requirements and 2 audits of FBO’s own controls.

65 batches of infant and follow-on formula sampled under Directive 2006/141/EC and Council Directive 92/52/EEC for compositional and contaminant analysis under Regulation 1881/2006.

100 %

Successful delivery in line with 2013 plan. Samples from the 65 batches were tested for a range of 75 parameters. Pesticide screening was conducted on a percentage of the samples.

1,143 samples of milk taken for residues under Directive 96/23.

103 %

Delivery in line with 2013 National Residue Control Plan. Results are reported separately by the Veterinary Medicines Division.

30 planned samples for Dioxins and Dioxin-like PCBs in raw whole milk and vegetable oils & fats - Regulation 1881/2006.

97 %

Successful delivery in line with 2013 plan.

Food Contact Material Regulation 1935/2004, Regulation 2023/2006 and Regulation 10/2011.

Desktop survey of food contact material documentation continued in 2013 to ascertain level of compliance; 25 declarations of compliance examined from 11 establishments. 5 Liquid product in glass jar with gasket type seals were sampled for ESBO and Phthalates.

Animal By-products (Milk and milk products)

33 planned inspections and 240 samples taken with respect to the requirements of Regulation 1069/2009 and Regulation 142/2011.

N/a Targets for inspections/audits set down by inspecting officer.

23

Reactive Programmes

Milk & Milk products

325 Unplanned official controls of milk processing plants, collection centres and stores (including issuance of 91 compliance notices). 20 unplanned Official Controls relating to Food Business Operators producing and/or collecting raw milk.

These included official controls following the detection of non-compliances during planned inspections, detection of non-compliances during official testing, inspection relating to export certification, registration/approval inspections and re-import related issues (BIPs).

53 Follow up inspections of milk production holdings.

267 reactive samples for food safety and process hygiene [Reg. 2073/2005 (as amended)].

Samples taken on foot of food safety alerts or process hygiene notifications reported by the laboratory. The 267 samples equates to 298 extra test parameters completed.

The one year survey of the microbiological quality of raw milk produced in Ireland (June 2012 – June 2013) continued.

This work was undertaken for the FSAI to investigate the prevalence and characteristics of human pathogens in raw milk at the point of production. Report is not yet published. Arising from the this survey an investigation was carried out in 2013 at 1 small scale farmhouse cheese establishment which resulted in 105 product and 4 milk filter samples being taken for presence of VTEC. Samples were tested in HSE Public Health and Cork Co Council Laboratories. Actions taken are included in Table 9.4.1.

40 products and 31 milk filter samples taken as part of an interagency investigation following confirmed human illness from consumption of raw milk cheese.

DAFM, FSAI and HSE interagency investigation following confirmed human illness from consumption of raw milk cheese from 1 small scale farmhouse establishment. Samples were tested in HSE Public Health and Cork Co Council Laboratories for VTEC. Actions taken are included in Table 9.4.1, including the closure of the establishment on two occasions.

11 inspections / audits related to complaints.

Animal By-products (Milk and milk products)

45 Follow up controls conducted and downstream checks requested with respect to the requirements of Regulations (EC) No. 1774/2002 and 79/2005.

The unplanned inspection was as a result of findings in a planned inspection and disposal of Category 2 product.

24

Department of Agriculture, Food and the Marine – Organic Controls

In compliance with Article 27 of Council Regulation (EC) No. 834/2007, Ireland has set up an organic inspection system operated by approved Control Bodies (OCBs). There are five Control Bodies approved by DAFM to inspect and to certify organic operators. Furthermore, they also systematically inspect retail outlets, including farmers markets and country markets to ensure compliance with the EU Regulations. Section 2.3 of the National Control Plan for Ireland for the period from 1st January 2012 to the 31st December 2016 set out details of the Control Bodies involved in official controls in the organics sector.



Comments

Inspection of retail outlets.

227 inspections of retail outlets inspected.

100% Delivery in line with 2013 programme requirements.

Inspection of control bodies.

30 (% inspected reduced from 5% to 2%).

100% Delivery in line with 2013 programme requirements.

Department of Agriculture, Food and the Marine - Honey (Food of Animal Origin)

Horticulture & Plant Health Division is responsible for implementing controls relating to honey. Details of these controls are outline in Section 2 of the National Control Plan for Ireland for the period from 1st January 2012 to the 31st December 2016. These controls are required by legislation relating specifically to animal remedies as well as legislation relating to general food hygiene in terms of honey production. The following EU legislation is applicable to the use of animal remedies on bees: Council Directive 96/23/EC, Commission Decision 97/747/EC, Directive 2001/82/EC, Regulation (EC) No 726/2004, Regulation (EC) No 470/2009 and Commission Regulation (EU) No 37/2010. In addition, in terms of honey production the following EU legislation sets out requirements in terms of general honey hygiene and safety: Regulation (EC) No 178/2002, Regulation (EC) No 852/2004, Regulation (EC) No 853/2004, Regulation (EC) No 854/2004, Regulation (EC) No 882/2004 and Regulation (EU) No 931/2011.



Comments

Honey production

7 inspections at apiary level and 2 inspections at packer / distributor level.

90% Target number of inspections not met as some of selected FBO’s had ceased production.

Residues in honey

110 targeted honey samples and 8 suspect honey samples were submitted for residue analysis.

100%

Delivery in line with 2013 National Residue Control Plan. In addition to number of targeted samples set down in National Residue Control Plan, and 8 suspect honey samples, a further 8 samples (water and syrup – feed for bees) were taken as part of the follow-up investigations arising from the cases of elevated lead in honey detected in 2012.

Reactive Programmes

Residues in honey

Continued follow up action in light of elevated lead detected in two producer’s honey in 2012.

A total of 16 suspect samples of honey and related material were taken during 2013 in response to the two cases of elevated lead in honey identified in 2012. Investigations for one of these cases were fully concluded in 2013. The other case will require further investigation during 2014 when 2014 honey is available for sampling. This producer has had a problem with elevated lead in his honey in 2010, 2012 and in one of six suspect honey samples taken in 2013.


Honey residues Information can be found in the report of the National Residue Control Plan already submitted to the EU Commission in accordance with the requirement of Council Directive 96/23/EC.

25

Statement of Compliance


Overall compliance

Compliance ranges from highly satisfactory to unsatisfactory in a small number of cases. As per VPHIS procedures on enforcement, there are 3 categories of non-compliance:

Category 1 Non-Compliances are breaches of food safety or animal health legislation where the Veterinary Inspector considers that there is a serious and immediate risk to human or animal health in an establishment.

Category 2 Non-Compliances are other breaches of food safety legislation where there is a potential threat to human or animal health.

Category 3 Non-Compliances where there have been other technical breaches of the legislation.

Category 1 non-compliances

In 2013, there were a total of 11 category 1 non-compliances - see Annex DAFM 3 for details.

7 compliance notices B were served by the Competent Authority which serve to suspend an activity / work area

4 voluntary compliance notices, where the Food Business Operator (FBO) actively recognised the non-compliance and voluntarily suspended or ceased an activity or suspended work in an area.

Of these,

2 notices were resolved within 1 week

2 notices remained in place for up to 2 weeks

1 notice remained in place for up to 3 weeks

2 notices remained in place for 5 weeks and

4 notices are still in place – The fact that 4 Category1 notices are still in place reflects ongoing enforcement action and FBOs opting not to carry out the necessary remedial actions.

There was an increase in the numbers of Category 1 non-compliance notices served in 2013 when compared to 2012, up from 6 to 7 Compliance B notices and 4 voluntary closure notices.

Totals 2013 Category 1 non-compliances 11 (7 + 4 Voluntary closures)

Totals 2012 Category 1 non-compliances 8

This represents an increase in the incidence of Category 1 non-compliances.

Category 2 Non-compliances



Category 3 Non-compliances

Category 3 non-compliances are not reported to HQ, but are maintained on record at Veterinary office level in each FBO establishment, and are closed out by the OV.

The overall compliance levels, taking account of Category 1, Category 2 and voluntary suspensions by Food Business Operators (FBOs) is largely in line with previous years.


Sector Area controlled Statement of compliance

Food of plant origin

Pesticide residues in/on food (fruit & vegetables) on the Irish market.

Food of plant origin on the Irish market is generally compliant with pesticide legislative requirements. There is a high level of compliance at 98% in fruit and vegetables available to the public sampled in the framework of Regulation (EC) No 396/2005. 84% of targeted commodities from third countries listed in Regulation (EU) No 669/2009 with a history of non-compliance did not exceed the MRLs.

Pesticide residues in/on food (cereal) on the Irish market.

Food of plant origin (cereal) on the Irish market is compliant with pesticide legislative requirements. The samples taken are 100% compliant with Regulation (EC) No 396/2005.

26

Food of animal origin

Pesticide residues in/on food on the Irish market (Kidney fats, milks, eggs, honey, ham)

The monitoring programme indicates that food of animal origin on the Irish market is 100% compliant with Directive 96/23/EC and Regulation (EC) No 396/2005 for pesticide residues.



Feedingstuffs


A high level of compliance demonstrated.

Feed Analytical results were mainly within tolerance.




Contaminants in horticultural crops as per Reg. 1881/2006 as amended.

Food of plant origin on the Irish Market is generally compliant with contaminants/hygiene legislative requirements. There is a high level of compliance with contaminants maximum levels in horticultural produce. All samples of apple juice tested complied with the ML for patulin. All samples lettuce/ spinach/ rocket complied with the ML for nitrates. All samples of horticultural produce complied with the ML for Pb. Research on mitigation strategies for Cd contmanination is on-going.

Microbiological contamination as per Reg 2073/2005 as amended.

All food samples were found to be compliant with food safety criteria. In the case of Process Hygiene samples 3 samples (lettuce and strawberries) were found to contain E. coli but the levels were below those set for pre-cut fruit and vegetables. Follow-up inspections to ensure breakdown in hygiene practices were identified are on-going. Water used for irrigation and washing of RTE food was found to be non-compliant in 5 cases. Water non-conformances were reported for 4 samples due to the presence of E coli/ Enterococci and for 1 for the presence of VTEC. In addition 11 samples contained coliforms

Hygiene Inspections of horticultural primary producers.

There is a high level of non-compliance with hygiene legislation by horticultural producers. Non-compliances were recorded for 85 % of FBOS, but this is because of a lack of knowledge among producers. However only 19% non compliance recorded at time of follow-up inspections.



Plant Health

Plant passports Some minor non-compliances were found with the formatting of these documents.

Quarantine Organisms

See details in Annex DAFM6.

27




Milk and Milk products

The monitoring programme indicates a very high level of compliance in milk processing establishments, infant formula establishments, collection centres and stores during 2013.

Overall 96.1% of samples tested were found to be compliant.

Note that 93.5 % of the sample non-compliances which were taken during routine official controls related to small to medium scale operators mostly in the farmhouse cheese sector (see 9.2.1 for details).

Two small scale establishments were the subject of compliance notices (including closure notifications) following detection of VTEC in samples of cheese manufactured from unpasteurised milk but there were no major non-compliances detected during inspections.

92 % of official water samples were found compliant; of those found non compliant no major risk was indicated.

At primary production level, of the 203 production holdings inspected, 60 % of them had non-compliances detected.

Dioxins and Dioxin-like PCBs samples: No non compliances detected.

Food Contact Material: Survey indicated improvements in level of compliance required.

Residue samples: see National Residue Control Plan Report.

Milk animal by-products: The monitoring programme indicates a very high level of compliance with the requirements of animal by product regulations. There were 3 instances where samples were found with minor non-compliances.



Organic Farming

Organic production and processing

Organic operators were generally very compliant and in the few cases where residues were found, indicating a possibility of non-authenticity of the organic product, these generally related to imports. Appropriate action was taken.




Honey

With exception of two producer’s honey showing elevated lead concentration (both identified by follow-up investigations arising from the two cases of elevated lead in honey identified in 2012), analytical results indicate that honey is fully compliant with residues legislation.

Honey producers need to improve their level of compliance with the hygiene legislation requirements and in some cases also with animal remedies legislation. While overall the non compliances detected pose a very low risk for consumers, compliance levels must be improved.

28

Frequency and type of non-compliance


Category 1 non-compliances incorporating the service of an enforcement notice B are all reported to HQ – see ‘Statement of Compliance.’ Category 2 non-compliances incorporating the service of an enforcement notice A are all reported to HQ – see ‘Statement of Compliance.’ Category 3 non-compliances are not reported to HQ, but are collated and managed at local and regional level. Therefore the specific % of the checks that detect any non-compliance is not available. However as the Category 3 non-compliances are minor issues, representing technical breaches of the legislation, it can be calculated that the level of checks that detected immediate, serious or potential non-compliance is the total of the Category 1 (11) and the Category 2 (39) non compliances. On that basis, the proportion of checks that identify either Category 1 or Category 2 non-compliances is 50 detections in the course of 5153 official controls; 1% of official controls result in a Category 1 or Category 2 non-compliance being detected.

Department of Agriculture, Food and the Marine – Animal Health and Welfare

Sector

Inspections with

Serious non

compliance

Inspections with

Moderate non

compliance

Inspections with Minor

non compliance

Types of Major non compliance where

applicable Distribution

Animal By-Products

9 19 72

Records, storage, hygiene, structure, labelling, bio-security, transport

Random

Animal Breeding 0 2 4

Animal Welfare 146 253 625 Structural, records, management

Random

ERAD TB & Brucellosis eradication

33 27 26

Testing not carried out within prescribed timeline, delay in reactor removal

Random

Trade 23 0 0

Livestock Marts 264 388 314 Hygiene, Structural, records

Random

Animal Medicines 8 26 151 Records, writing prescriptions, display areas, lead in honey

Random


Sector Area controlled Non-

compliances

Classification of non-

compliances. Comments


Pesticide residues in/on food on the Irish market.

Regulation (EC) No 396/2005 Non compliances in 19 out of 951 surveillance samples.

1 (0.1%) moderate 18 (1.9%) minor

Moderate non compliances relate to breaches where short term intake concerns were identified. Minor non compliances relate to samples taken randomly, and where risk assessments indicate no short term concern for all consumer types.

29


compliances



Pesticide residues in/on food destined for the Irish market.

Regulation (EU) No 669/2005 Non compliances in 13 out of 82 consignments sampled.

2 (2.4%) moderate 11(13.4%) minor

Moderate non compliances relate to breaches where acute risks to the consumer cannot be ruled out. Two consignments (Okra from India and oranges from Egypt) were identified as posing potential risk to consumers. The former was destroyed and the latter re-dispatched. Associated RASFF notifications were issued. Minor non compliances relate to samples either not exceeding the MRLs with a 50% uncertainty, or when no short term intake concern was identified with the 50% uncertainty applied


Pesticide residues in/on food of animal origin on the Irish market.

0 (0.0%) samples of food of animal origin contained pesticide residues in excess of an MRL.

All samples of food of animal origin complied with EU regulations.

Pesticide residues in/on infant formula and follow on formula originated in Ireland.

0 (0.0%)Zero samples of infant formula contained pesticide residues in excess of an MRL.

No pesticide residue was detected above the limits of quantitation in any baby food sample.



compliances



Feedingstuffs


1,112 infringements detected during inspections

3 major 919 moderate 190 minor

Moderate and minor infringements mainly concerned deficient sample storage; deficient HACCP plans; hygiene issues and traceability. Major infringements were issued to FBO’s for failing to have a HACCP plan in place.

Feed

412 cases of analytical results out of tolerance


Moderate cases included, presence of packaging in bread product, Carryover of narasin above MPL in non-target feed, Arsenic result above the MPL in seaweed meal, Mercury above the MPL in feed material, dioxin like PCBs greater than the action threshold set in Reg (EC) No 277/2012 in a feed material, Salmonella Aberdeen / senftenberg in feed material sample, Saccharomyces cerevisiae MUCL 39885 in feed for lambs. Minor cases mainly involved nutritional analytes out of tolerance with declared values e.g., protein and fibre results.

217 cases of label contravention during inspections and 401 minor cases of incorrectly declared compounds.


Major infringements were issued to 2 FBO’s for failing to have a label on feed and both products were detained. Moderate and minor non-compliances relate mostly to non-compliance with E.C. Regulation 767of 2009 – incorrect declaration of trace elements, analytical constituents such as sodium not being declared, feed material names not in compliance with Community Catalogue of feed materials.

Feed Complaints None

30


Sector Area controlled Non-compliances

Classification of non-compliances.

Comments


Contaminants in horticultural crops.

Heavy Meals, Patulin and nitrates.

Minor

Minor non compliances related to ML exceedances with no consumer risk.

Hygiene inspections of horticultural primary producers. General hygiene.

20% Serious/ significant (Moderate/Major) Non-compliances. 60% minor non-compliances.

Minor non compliances related to general hygiene infringements with no consumer risk. Follow-up inspections in all cases. Moderate/ Serious non-compliances related to general hygiene infringements and also non-compliance of water used in production or washing (see below).

Microbiological Criteria

Major/moderate: 7.5% of water samples non-compliant.

Non-compliances of water samples related to the presence of E. Coli,/ Enterococci and in one case the presence of VTEC in water used for irrigation and washing of RTE food. In 16% of water samples coliforms also detected. Moderate non compliances also related to lack of implementation of Microbiological Criteria Regulation (Reg. 2073/2005), with potential consumer risk.



compliances



Plant Health

Plant passports Some discrepancies noted,

Mostly minor.

Most errors were caused by operator error using incorrect or no Protected Zone or batch codes. Other findings are presented in Appendix 1 below.


See details in Annex DAFM6 below



compliances




Milk and milk products.

1,599 non-compliances detected during official controls.

Inspections of Food Business Operators 52 moderate 578 minor

All Moderate and minor non compliances found generally related to failures in the FBO’s prerequisite programme and HACCP based procedures. See further detail in section 9.2.2.

Milk production holdings inspections 10 major 148 moderate 717 minor

In relation to the non conformances, the appropriate Compliance Notices were issued. See Table 9.2.2.3 and 9.4.1.

Samples for food safety, process hygiene, antibiotics and heat treatment verification 10 major 60 moderate

10 major non-compliances related to the detection of Listeria monocytogenes in product. In all cases FBOs were directed to take appropriate action(s). 52 moderate non-compliances related to the process hygiene criteria exceeded in product, with no immediate consumer risk. In all cases FBOs directed to take necessary action(s). 8 moderate non-compliances related to failures in heat treatment verification and as necessary FBOs were directed to take appropriate action(s). Follow up sampling, inspections and/or audits were conducted where necessary. See further detail in section 9.2.2.

31


compliances



Water 24 moderate

Non-compliances related presence of Escherichia coli (E. coli), coliforms and/or Enterococci in water.

Coliforms are an indicator parameter. The presence of coliform bacteria is not of itself a strong indication of potential presence of enteric pathogens and the procedure of issuing non compliances for coliform detection ceased during 2013. E. coli and Enterococci are minimum microbiological parameters. 88% of the non compliances related to E. Coli and/or Enterococci parameters exceeded.

9 complaints received.

9 minor

Minor complaints related to foreign bodies, product quality, presence of mould, labelling irregularities and date of durability. All complaints investigated and closed out in 2013.

1 human illness report from HSE

5 major compliance notices (CN1) issued related to VTEC

see detail in 9.1

1 investigation arising from raw milk survey

4 major compliance notices (CN1) issued related to VTEC

see detail in 9.1

Milk By-products 28 non-compliances detected

Inspections 25 minor

All minor non compliances related to other technical breaches of the legislation.

Samples 3 minor

Non-compliances related presence of Enterobacteriaceae in animal by-products.



compliances



Organic Farming

Control Body Inspections.

All 2002 operators were inspected once, with 5% also having an additional risk based inspection.

0 Major 32 Moderate

Generally non-adherence to organic requirements in all areas, e.g. inappropriate housing or feed, with removal of status of individual product/animals/areas Financial penalties imposed to cover additional inspections in case of suspicion.

DAFM inspection of retail units.

A total of 227 retail inspections were carried out, with 15 showing some level of non-compliance.

1 Moderate

Generally related to operators selling certified organic product, without having a licence to retail the product in the manner presented, i.e. loose fruit/veg, also claiming an organic ingredient without being licensed. Written to by DAFM, respondent either withdrew organic claim, or joined certification system.

DAFM re-inspection of organic operators.

A total of 30 (c. 2%) were re-inspected to identify any non-compliance of the Control Bodies in their inspection and certification work.

3 Moderate

Potential for an irregularity/deviation, e.g. poor record keeping etc. with potential for penalty or loss of organic status of individual animals/products/areas – all notified to Control Body for their attention. Also related to unavailability of complete records at the time of inspection - all notified to Control Body for their attention.



compliances




Honey

Breaches of hygiene or animal remedies legislation identified during

57% of producers had minor non-compliances 29% of producers inspected (2

Poor traceability and record keeping especially among small-scale operators were main problems identified. In 2 beekeeper’s cases inspections identified moderate breaches of hygiene

32


compliances



inspections of primary producers

beekeepers) had moderate non-compliances

legislation. These related to premises / risks associated with equipment used to deal with honey and in one case the use of an unauthorised medicinal product (oxalic acid based).

No breaches of hygiene legislation identified during inspections of honey packers / distributors

Elevated lead concentration in honey

2 x moderate identified through follow-up action in light of 2012 cases.

Two producer’s honey showed an elevated lead concentration. While a legal limit is not set for lead in honey this was considered to represent a food safety risk and appropriate action was taken in both cases.

33

Analysis of non-compliance

9.2.2.1 Occurrence of non-compliance & 9.2.2.2 Nature of the risk arising from non-compliance

What were the main types of non-compliance identified?


In 2013 the most serious non-compliances were related primarily to:

Animal identification

Labelling and Traceability

Structural deficiencies/unapproved installation

Inadequate FBO control


Area Controlled


compliances detected

Distribution of non-

compliances

Nature of Risk Comments

Sector: Food of plant origin


Regulation (EC) No 396/2005 1 moderate 18 minor

MRL exceedances are generally random in their occurrence when sampled under Regulation EC No 396/2005. No pattern, trend or cluster was detected in the 19 (15 imported and 4 domestic) non compliances.

Moderate A head cabbage of domestic origin containing Fluazifop butyl was found to exceed at 213% of the ARfD. This was destroyed at source. Minor No risk to the Irish consumers for the other 18 breaches, 16 of which were detected in imported samples

Regulation (EU) No 669/2009 2 moderate 11 minor

16% non-compliances found in targeted samples from selected third countries taken under Regulation (EU) No 669/2009.

Moderate Risks to the consumer could not be ruled out in an okra sample containing 5 different pesticides breaching MRLs, and in an orange consignment designated for juice processing. The former was destroyed and the latter was re-dispatched. Minor Where MRLs were breached but no risk to the consumers was identified, 5 consignments did not breach the MRL with a 50% uncertainty and were permitted to enter the country. Six samples from other consignments were found to breach the MRL with the 50% uncertainty applied and were destroyed.

34

Area Controlled




compliances


Sector: Food of animal origin

Pesticide residues in food. of animal origin

No non-compliance detected.

Not applicable


Area Controlled




compliances


Sector: Feedingstuffs


Inspections: 3 major 919 moderate 190 minor

No discernable pattern.

No potential impact on humans or animals

FBOs were instructed to take appropriate corrective action.

Feed

Analytical results out of tolerance: 0 major 16 moderate 396 minor Label Contravention 2 major 141 moderate 475 minor

No discernable pattern. No discernable pattern. Almost all related in non-compliance as regards Reg (EC) No 767/2009.

No potential impact on humans, however, potential impact on animals. No potential impact on humans or animals. No potential impact on humans or animals.



Area Controlled




compliances


Contaminants in horticultural crops

Minor

Non-compliances when produce grown on high soil cadmium sites.

Risk assessment (using dietary intake and exposure data) did not indicate a risk to Irish consumers.

ML exceedances for Cd are mainly due to the underlying impure limestone geology of the horticultural production region. There is no risk to consumers due to the presence of these ML exceedances.

Hygiene Inspections of horticultural primary producers

34 minor and 11 moderate/serious non-compliances.

Widespread.

Potential risk to human health.

Non-compliances due to poor controls by primary producers. This is because the legislation is a new requirement for these producers and there is a lack of knowledge on behalf of producers.

Moderate for Microbiological Criteria.

Widespread. Potential risk to Irish consumers.

Non-compliances due to inadequate controls by primary producers. Lack of knowledge by producers cause of non-compliance. Progress made on producing guide for primary producers.


Area Controlled




compliances


Plant Passports

Mostly Minor

Confusion among operator as to what information is required on plant passports for different species.

Minor risk to the environment as errors deemed mostly typographical for domestic produce.

Operators where discrepancies were noted were informed of correct use of plant passports.


See details in Annex DAFM6 below.

35


Area Controlled

Classification of non-compliances

detected


compliances


Milk and milk products

Product samples 70 product non compliances reported in 2013.

Overall 3.8% of samples tested were non compliant; 67% of these were products made from raw milk (small scale sector).

10 Major o 100% exceeding

food safety criteria

Major Low : <1% of samples tested for food safety criteria were non compliant. 4% of FBOs that had samples tested for food safety criteria had 1 or more non compliant batches All related to cheese; o 5 batches

related to cheese made where there is no heat treatment or a lower heat treatment than pasteurisation

o 5 batches related to pasteurised, ripened cheese

100% were small/medium scale operators. 30% were reactive samples following a previous similar non compliance.

Major Potential risk to consumers; in some instances product was not on the market at the time of detection of the non compliance. Where product was on the market directions to withdraw/recall product was given (9 such directions were issued in 2013)

Major In all instances, FBOs were instructed to take appropriate corrective action. Inspections and/or audits conducted where necessary.

36

60 Moderate o 87% exceeding

process hygiene criteria

o 13% related to heat treatment verification failures

Moderate 9% of samples tested for process hygiene criteria were non compliant. 4% of samples tested for heat treatment verification were non compliant No discernible pattern in relation to product type affected. o 2 related to

dried infant formula for infants < 6 months

o 2 related to Milk / Whey Powders

o 18 related to cheese made from raw milk

o 3 related to ripened cheese made from pasteurised milk

o 19 related to drinking milk (Pasteurised/ ESL /UHT) and other pasteurised liquid dairy products

o 14 related to Ice Cream and Frozen Dairy Deserts

o 2 related to Miscellaneous RTE products

27% of FBOs that had samples taken for process hygiene criteria and/or heat treatment verification had 1 or more non compliant batches 90% (n=54) were small/medium scale operators. Breakdown of the process hygiene non compliance:

60% Enterobacteriaceae,

38% Coagulase Positive Staphylococci,

2% E. coli and Coagulase Positive Staphylococci.

Moderate No immediate consumer risk for moderate non-conformances relating to process hygiene criteria being exceeded:

S. aureus in excess of 10

5 cfu/g is a

major risk if heat-labile enterotoxin is formed in product; all consumers are believed to be susceptible to this type of bacterial intoxication. 8 Batches which exceeded the Coagulase Positive Staphylococci criteria at levels greater than 10

5

cfu/g were tested for the enterotoxin; the enterotoxin was not found in any subsequent tests performed.

Enterobacteriaceae are indicators of hygiene and microbiological quality; this family of bacteria including Salmonella spp. and E. coli as well as environmental species.

E. coli is used as an indicator of faecal contamination. Most E. coli do not cause disease in humans, but certain types may cause diarrhoeal disease or more serious forms of illness.

Following investigation, there was no immediate risk to consumers for non-compliances relating to heat treatment verification checks.

Moderate Where necessary, FBOs were instructed to take appropriate corrective action. Inspections and/or audits conducted where necessary.

37

Inspection of Food Business Operators 52 moderate 578 minor

The mean ratio of non-compliances to inspection was 1.22 (range 0-25) no discernible patterns.

No immediate risk to consumers.

52 Moderate and 578 minor non compliances found generally related to failures in the FBO’s prerequisite programme and HACCP based procedures. FBOs were instructed to take appropriate corrective action


no discernible patterns.

Varies from low risk to serious and/or immediate risk to public health. There was no risk to consumers due to actions taken.

Large increase in major non compliances reported and milk production holdings were instructed to take appropriate corrective action

Water 24 moderate

8% of water samples taken in 2013 were non compliant. 15% of FBOs that had water samples taken in 2013 had 1 or more non compliant samples (n=20). 83% (n=20) from small/medium scale operators. 79% (n=19) of FBOs with non compliances were using ground water. 88% (n=21) of the non compliances related to E. Coli and/or Enterococci parameters exceeded.

No immediate risk to consumers

FBOs were instructed to take appropriate corrective action. Inspections and/or audits conducted where necessary. Coliforms are an indicator parameter. The presence of coliform bacteria on its own is not of itself a strong indication of potential presence of enteric pathogens and the procedure of issuing non compliances for coliform detection ceased during 2013

Complaints 9 minor

7 Food Business operators had complaints against them. 6 complaints against 4 large scale milk processing establishments. 3 complaints against 3small/medium scale farmhouse producers.

Varies from low risk to immediate risk to consumers.

Foreign objects = 3 Mould = 2 Quality = 1 Labelling = 2 Out of date = 1 Where possible complaints received were investigated. Where necessary, FBOs were instructed to take appropriate corrective action.

Milk by-products


76% (n=19) related to errors in commercial documentation The remaining related to errors in labelling and record keeping.

No risk to consumers.

Samples 3 minor

All related to Enterobacteriaceae in whey products.

No risk to consumers, some incidences of potential risk to animal health due to the presence of Enterobacteriaceae.

3 minor non compliances related to poor housekeeping in handling of animal by products.

38


Area Controlled


detected


compliances


Organic Sector: Control Bodies

0 major

32 moderate – individual animals/areas lost status or financial penalties imposed

Many in early stage of organic participation, others no discernible pattern.

32 Moderate – No risk to health of consumers.

Strong actions in early non-compliance ensures long-term effective control-cross reporting of these penalties and imposing financial sanctions onto their OFS payment should ensure a better compliance rate.

DAFM inspection of retail units

1 moderate Related to organic claim by un licensed operator.

No health risk. Products were generally organic, but operator involved were not registered to pack & label organic products.

DAFM proactive in pursuing non licensed operators. Follow up action taken to monitor compliance in individual cases.

DAFM re-inspection of organic operators

3 moderate

Moderate: In general related to producers vis-a-vis a deviations from standards: no discernible/significant pattern.

No risk to health, but does indicate occasional laxity at Control Body implementation level

Notification & interaction with Control Body in each case to agree corrective action should ensure stricter enforcement of requirements & enhance consume confidence in system.


Area Controlled


detected


compliances


Honey production

Inadequate records –minor non-compliance

Widespread.

Traceability of produce and record keeping was poor however low risk to human health.

Small scale producers, in general producing less than 1,000 kg of honey, but improved record keeping is required.

Inadequate hygiene controls – moderate non-compliance

2 cases detected at apiary level.

Risk of contamination of honey [risk to human health] .


Elevated lead concentration – moderate non-compliance

2 cases detected by follow-up investigations arising from 2012 non-compliances. A further 15 producer’s honey was tested for lead concentration in 2013 – all complaint.

Honey high in lead – risk to human health if prolonged exposure.

All 2013 honey produced by both producers with elevated lead in 2012 was detained pending analysis for lead concentration. In light of results obtained two batches with elevated lead were destroyed. Batches with acceptable lead concentration were released for human consumption.

39

Were the non-compliances clustered or randomly distributed?


VPHIS carries out an annual Risk Assessment on each DAFM approved plant. In general the non-compliances were randomly distributed amongst the approved DAFM plants. However, where a Risk Assessment identifies a plant as having a higher level of risk, which occasion a higher frequency of official controls, then there may be a tendency to have clusters of non-compliances. See Annex DAFM 4 for Risk Assessment protocols of VPHIS

40



see ‘Statement of Compliance.’

41

Root cause(s) of non-compliance

What was/were the root cause/s of the non-compliances identified?


Feedback from regional and local VPHIS staff and the analysis of the non-compliances during 2013, led to additional actions, which are intended to address and improve compliance by the FBOs.

Root Causes of the non-compliances

In general, the underlying causes of non-compliances relate to: (a) Lack of application by FBO to animal identification (b) Insufficient origin records. (c) Lack of oversight of employees carrying out tasks safely. (d) Lack of familiarity with obligation as an FBO VPHIS works with the Department’s Milk & Meat Hygiene Division (MMHD), Meat Policy Division (MeatPD) and the Milk Policy Division (MilkPD) in reviewing existing procedures to implement improvements. Note: Root causes are required when there is an apparent pattern to the non-compliances or where there are repeated offences.

Sector Root cause of Non-compliance

Animal By-Products Lack of awareness and/or understanding regarding requirements, cost of compliance, perceived lack of dissuasive sanctions.

Animal welfare Lack of understanding of requirements. Lack of care.

Livestock marts Lack of care and perception of non-dissuasive sanctions.

Animal medicines Lack of understanding of requirements, carelessness regarding records/withdrawal times, failure to follow data sheet instructions.

Department of Agriculture, Food and the Marine – Animal By-Products

Area controlled


Root causes of non-compliances

Comments

Animal By Products


All related to lack of knowledge of legislative requirements.

Samples 3 minor

Poor housekeeping in handling of animal by products.


Area controlled



Comments

Sector: Food of plant origin.

Pesticide Residues in food.

3 moderate 29 minor

Domestic In the case of MRL breaches for Irish producers, inspections found the following reasons for breaches in vegetables:

Unauthorised use of a plant protection product on head cabbage.

Possible cross contamination between treated and untreated potato tubers

A ‘technical’ breach with residues found in excess of the default MRL which was

42

Area controlled



Comments

set at the limit of quantitation. Not considered to be a deliberate act.

Imported The majority of pesticide MRL exceedances 22 (69%) are associated with produce from 3

rd countries. Information for

root causes of the non-compliances was not available. Where 3

rd country produce was

involved, warning letters were issued to relevant importers and information was transmitted to the 3

rd country

concerned through CODEX contact point. RASFF notifications indicating border rejections were issued.


Area controlled



Comments


Inspections: 3 major 919 moderate 190 minor

Mainly human/technical error or non-adherence to protocols laid down in quality manuals.

In general the feed industry is very aware of its obligations in relation to feed and food safety legislative requirements and have invested heavily in systems to ensure that standards are met.

Feed.

Analytical results out of tolerance 0 major 16 moderate 396 minor Label Contravention 2 major 141 moderate 475 minor

Presence of packaging detected in bread sample.

Carryover of narasin above MPL set in Directive 2009/8/EC detected in non target Poultry feed.

Arsenic result above the MPL of 40 mg/kg set for seaweed meal,

Mercury present in Fishmeal (Shark Cartilage) at levels greater than the MPL set in Directive 2002/32/EC.

Dioxin like PCBs detected in Complementary feedingstuff greater than the action threshold of 0.5 ng/kg set in Reg (EC) No 277/2012.

Salmonella Aberdeen / senftenberg detected in, seaweed meal and Salmonella Senftenberg detected in Soya (Bean) meal

Saccharomyces cerevisiae MUCL 39885 not authorised for lambs.

Mainly nutritional analytes out of tolerance with declared values.

Mainly human/technical error and manufacturers not updating labels in compliance with E.C. Regulation 767/2009

As above

43


Area controlled



Comments

Hygiene Inspections of horticultural primary producers

Minor and moderate/serious:General hygiene and pesticide non-compliances

Lack of knowledge and poor controls by FBOs.

A new Guide is being produced to assist FBOs.

Moderate: Microbiological samples

Lack of knowledge and poor controls by producers.

A new Guide is being produced to assist FBOs with compliance and trader notices are being prepared.


Area controlled



Comments

Plant passports

Minor Confusion among operators. Correct passporting of plants is identified across the EU as difficult to understand and is being reviewed.


Area controlled



Comments

Milk and Milk Products

Product samples 10 major 60 moderate

10 major non compliances related to Listeria monocytogenes, which were primarily deemed to be due to environmental contamination; 5 of the 10 related to cheese made where there is no heat treatment. Another 4 were found to be due to cross contamination and/or poor hygiene practices. The last was a reactive control, following on from earlier issues. Moderate non compliances: Not all investigations uncovered a root cause for the moderate non compliances There were heat treatment verification failures; four of which related to sampling procedures -one investigation found that the FBO’s process did not meet the time/temperature requirement.

VTEC failures 9 major compliance notices (CN1) issued related to VTEC

Presence of VTEC in the raw milk used to manufacture unpasteurised cheese (two small scale establishments).

Milk processing plants, collection centres and stores Inspections 52 moderate 578 minor

All moderate and minor non compliances related to failures in the food safety management systems.


All non compliances related to on-farm structural facilities and hygienic practices on milk production holdings.

In relation to the major non compliances the appropriate Compliance Notice was issued to the Food Business Operators prohibiting the collection of milk from the holding in question.

Water 24 moderate

A third of the non compliances had no root cause found. Where there was a root cause found, non compliances were due to:

water treatment system failures (31%),

the water source used (31%),

errors in the sampling procedure (25%), and

process equipment contamination (13%).

Complaints 9 minor

None of the investigations relating to foreign body complaints identified the foreign body originating at the milk

44

Area controlled



Comments

processor and one deemed that the foreign object was a visible processing aid. The mould complaints were deemed to originate due to random failure on one occasion and due to poor sealing on the other occasion. The quality complaint found no issue on investigation. One labelling issue found the label to be compliant and the other was due to FBO error. The out of date complaint found the use of third party logistics company as the root cause.


Area controlled



Comments

Organic Production

Major detected by Control Body.

None detected N/A

Moderate detected by Control Body

Expectation that non-compliance will not be detected/regulations will not be fully implemented

Control Body additional unannounced inspections are very effective where non-compliance is suspected.

Moderate detected by DAFM

At producer level, some lax enforcement by Control Bodies re. record keeping. Issues around interpretation of organic aquaculture standards still relevant – European issue. Similar situation for other non-compliances in many cases.

Notification of Control Body in each case is likely to ensure stricter enforcement of requirements. Introduction in 2012 of OFS non compliance penalties will strengthen control system. Each non-compliant operator is dealt with in an effective manner both verbally and in writing.

Minor detected by DAFM

At producer/processor level, infrequent lax enforcement by Control Bodies re. record keeping etc

Ongoing supervisory inspections of OCBs and liaison with OCB will improve the control system.


Area controlled



Comments

Honey

Minor non-compliances.

Hygiene and Animal Remedies requirements – minor non-compliances largely due to poor awareness of legislative requirements.

DAFM addressed beekeeping association’s annual meeting to raise awareness of legislative requirements and controls implemented. This is due to be repeated again in 2014. DAFM’s website developed to provide more information for beekeepers. A notice to reduce the risk of lead contamination of honey was published in the beekeeping association’s magazine. Beekeeping association will be encouraged and assisted to finalise hygiene guide for beekeepers in 2014.

Moderate non-compliances.

Hygiene issues associated with honey processing equipment and use of unauthorised veterinary medicine (unauthorised oxalic acid product).

In general compliance is acceptable. Where appropriate individual producers need to be informed that their compliance with food hygiene requirements must improve.

Elevated lead concentration leading to food safety risk.

Follow-up action for the two non-compliances identified in 2012. Once case closed out in 2013. Other case will require further follow-up action when 2014 honey is available.

45

Actions to ensure compliance by Food and Feed Business operators and other relevant business operators with official controls


Actions taken to deal with non-compliances

Veterinary Inspectors have been given the necessary powers under national legislation to take appropriate enforcement actions in the case of non-compliances or breaches of the regulations. In order to determine the appropriate enforcement actions to take in response to breaches of food safety legislation it is essential that non-compliances are categorised according to the risk which is posed to human health. Non-compliances may be categorised as major or minor. See point 9.2 for details of enforcement action in 2013. Where there has been persistent non-compliance, or where there has been a failure to take adequate corrective action in response to previous notices the Veterinary Inspector may decide to recommend to his/her hierarchy that the closure or suspension of activities may be appropriate. A compliance notice may be issued to suspend a particular activity but if the approval of an establishment is to be suspended or revoked, this must be conveyed by letter from the relevant Division When issuing a suspension notice the Veterinary Inspector must consult the Regional Superintending Veterinary Inspector who is required to obtain the approval of the appropriate HQ Senior Superintending Veterinary Inspector for the issuing of the notice. Each Veterinary Inspector is required to maintain in the Veterinary Office (in respect of each approved plant for which he/she is responsible) an Enforcement File containing all enforcement notices issued. The Veterinary Inspector must check the Enforcement File regularly to ascertain the progress being made in correcting non-compliances and to ensure that any specified deadlines set in the notices are respected. To ensure that enforcement is appropriate, dissuasive and effective, HQ actively engages with regional and local officers where major or minor enforcement issues are involved. Meetings between relevant personnel from HQ, regional, local staff and the Food Business Operator take place routinely. In 2012, there was a successful prosecution of a FBO with regard to the Animal By-Products Regulations, and in 2013 there are a further 2 active cases being pursued. The actions taken by VPHIS in conjunction with MMHD include:

1. Veterinary Inspection and Audit Programme (VIAP) The Working Group has been set up and a considerable amount of work has been done with regard to the electronic audit programme. It is envisaged that the system will trialled in a number of plants in the second half of 2014.

2. Trader Notices There were 37 trader notices issued by Meat Hygiene Division to the meat industry in 2013. Trader Notices are used by the Department to inform industry of various important developments including e.g. new certification requirements for third countries, new legislation, changes in sampling requirements etc. Trader Notices are a useful method of ensuring that industry is made aware in a timely manner of developments in relation to compliance requirements. All trader notices are copied to VPHIS staff and are also placed on the DAFM website. During 2013, Trader Notices were issued by the Meat Hygiene Division which encompassed information and guidelines to industry on Third Country Certification, strengthened horse identity checks in slaughter plants, sampling requirements, foreign language labelling criteria and animal welfare issues. Additional actions taken by VPHIS include:

1. Routinely updating Industry on meetings in Brussels in relation to changes in legislation, interpretations of the Hygiene Package and derogations. This is of particular importance taking account of the review of the Hygiene Package and Regulation 882/2004.

46

2. Routinely updating Industry on the requirements for trading with Russia, Russian Federation/Customs Union and USDA requirements and meetings between the Commission and the RF.

3. Ongoing meetings were held with industry representatives at which a range of issues were discussed. These 26 meetings included:

Lean Review updates

BSE testing

Bute testing

Issues arising from equine DNA investigation

Updates on Animal by Products legislation

DNA testing

Updates on review of the Hygiene Package legislation

RF/CU issues

FVO, FSAI and IAG audits.

Review of Reg. 882/04

Clean Livestock Policy

Regulation of Meat Traders

Mislabelling and traceability issues

Use of chemicals/additives/processing aids

Lactic Acid regulation

Meat Inspection Service – Cost avoidance/recovery proposals

Welfare of animals at slaughter – Reg. 1099/2009

Sheep identification

Update on South African certification

Minced meat labelling and compositional criteria

USDA Inspection Audit

Porcine Reproductive and Respiratory syndrome

Trichinella requirements

Salmonella Control Programme

Third Country markets

Pig condemnation data

4. Meetings with the Milk Industry took place in 2013 and similar meetings will continue in

2014.

In some instances, action other than enforcement action may be appropriate to ensure compliance by the FBOs e.g. training, stakeholder meetings and other consultative engagements.

Monitoring of the effectiveness of official controls is done by Regional SVIs and HQ. Each VI produces a quarterly report for each establishment and sends it to the RSVI. The RSVI produces a quarterly report, based on the VI returns, for each region and sends it to HQ.

Verification of the effectiveness of official controls is conducted by RSVI annually at each establishment. Audit reports are sent to HQ as VIs in future will be spending more time auditing the food business operators performance, more emphasis will be given to this role of RSVI as verifier of the effectiveness of official controls

When other duties permit, HQ SVIs and SSVIs visit establishments and verify the effectiveness of official controls.

47

Audits which are external to VPHIS (IAG, FSAI, FVO) give an overview of the effectiveness of official controls. Every effort is made to close out any recommendations from these audits in a timely manner.

Meetings with Industry [see point 9.2.2.3] involved a means of stakeholder feedback, and informs improvement and revision of the systems.

VPHIS Training The Performance Management Development System of DAFM allows for personnel to identify and state their training needs. Arising from the needs identified by staff, allied to the needs arising from external audits, changes in /new legislation, a range of VPHIS Veterinary and Technical staff attended courses during 2013. See Annex DAFM 5 for full details of training courses attended by VPHIS Veterinary and Technical staff in 2013 During 2013, training needs for VPHIS in 2014 were identified as follows (VI training needs profile for 2014):

1. Welfare – AHW Act training.

2. Meat Modernisation.

3. Vet. Training Officer is to examine PMDS returns to ascertain requirements.

4. Training day on General Sanitation Methods and Biocides Regs., BTSF speakers

5. Additives training

6. Workshop defining DAFM's strategy for its laboratories

7. Investigative Skills training

8. RF/CU Pre Audit Seminar for attendance by DAFM staff, Sea Fisheries staff and industry personnel

9. USDA Pre Audit Seminar for attendance by VPHIS staff and industry personnel

10. SRM refresher

11. TRACES training

12. Audit Training

TAO training needs profile for 2014

1. Regional workshops are planned to deal with Audit Training

2. Investigative Skills training

3. TRACES training

Sector Actions to ensure

compliance by FBOs Actions to improve

performance of FBOs Actions to improve performance

of Official Control system

Animal By-Products

Removal from register, Closure, issue notices followed by re-inspection.

Advice/information provided.

Training provided.

Animal welfare

Cross reporting (to single farm payment section), restriction on animals following checks at slaughter.

Continued checks and education, information provided

Training provided.

ERAD

Restrictions on animal movement, financial penalties viz-a-viz test payment or loss of compensation entitlement as appropriate, penalties on farm support payments, prosecution.

Livestock marts Warning letters, continuous inspections

Provide information and training.

Training and consistent application of the regulations.

Animal medicines

Increased sampling at slaughter, increased testing of milk.

Inspections, checks on records.

48


Sector Area Controlled

Control actions. Action details. Comment

Food of Plant Origin

Pesticide residues in food

Letters issued to FBOs involved in each MRL breach. Follow up inspections on domestic growers to identify root cause of non-compliances. Consignments found to be non-compliant with regard to pesticide residues were not allowed to enter the Irish market.

Food destroyed or removed from market when intake concern identified and legislative action taken against a domestic grower. Inspections carried out on 2 other growers were inconclusive and these produce are to be targeted as part of the 2014 reactive programme. Rejected consignments (8) were either destroyed or re-exported

Fixed penalty payment issued to grower.

Food of Animal Origin

Pesticide residues

No action required.

Pesticide residues in Infant formula

No action required.




Feedingstuffs

Feed Business Operators and Feed.

Restrictions/Prohibitions on the sale of feed materials / compound feed.

5 cases of detention of feed at inspection.

Main reasons include; Labelling particulars not satisfactory, Arsenic result above the MPL of 40 mg/kg set for seaweed meal, Mercury present in feed material at levels greater than the MPL set in Directive 2002/32/EC.

Trader notices issued. 4 Notices Issued.

These trader notices (3, 4, 7, 8) focus on the following:

Commission Regulation (EC) No 767/2009 of the European Parliament and of the Council of 13 July 2009 on the placing on the market and use of feed.

Regulation (EC) No 999/2001 of the European Parliament and of the Council lays down rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies (TSE's) in animals.

Export of Animal Feedingstuffs to Non-European Union (EU) Countries.

Destruction of feed material consignments.

Two consignments destroyed in 2013.

Products uncovered during inspection with no identifying labels were detained and disposed of in landfill.

Administrative fines/sanctions. No fines issued in 2013.

Withdrawal or Suspension of Approval/Registration.

No withdrawal or suspension of FBO licences.

49


Area Controlled Control actions. Action details. Comment

Contaminants in horticultural crops

Follow-up inspection and research on mitigation strategies.

Research is on-going to devise mitigation strategies to reduce uptake of Cd by crops. A new 4 year research project commenced in 2012. 3 project meetings held in 2013.

Hygiene Inspections of horticultural primary producers.

Follow-up inspections to ensure remedial actions carried out.

11 Compliance Notices Issued. 34 Warning letters issued.

Other State agencies updated on non-compliances.

Teagasc and Bord Bia informed.

New Guide being produced.

DAFM/Teagasc/Bord Bia collaborating to produce a guide to assist FBOs comply with hygiene legislative requirements.

Trader Notices issued to sprouted seed producers informing them of changes to legislation.

Trader Notice issued to all mushroom producers regarding use of unauthorised plant protection products




Plant Health Outlined in Annex DAFM6.




Compliance notice- Category 1 (CN1)

Compliance notice-Category 2 (CN2)

Compliance notice- Category 3 (CN3)

Compliance notice-Withdrawal (CN4)

Compliance notice- Processing direction (CN 5)

Notification of proposal to suspend/ revoke approval and/or registration (PRO)

Notification of decision to suspend/revoke approval and/or registration (DEC)

Proposal to Approve or Conditionally Approve or Register (APPR)

Compliance notice- Category 1 (FCN1)

Compliance notice-Category 2 (FCN2)

Compliance notice- Category 3 (FCN3)

Compliance notice-Withdrawal (FCN4)

20 Compliance notice- Category 1 (CN1)

77 Compliance notice-Category 2 (CN2)

171 Compliance notice- Category 3 (CN3)

137 Compliance notice-Withdrawal (CN4)

1 Compliance notice- Processing direction (CN 5)

0 Notification of proposal to suspend/ revoke approval and/or registration (PRO)

1 Notification of decision to suspend/revoke approval and/ or registration (DEC)

26 Proposal to Approve or Conditionally Approve or Register (APPR)

2 Compliance notice- Category 1 (FCN1)

26 Compliance notice-Category 2 (FCN2)

120 Compliance notice- Category 3 (FCN3)

15 Compliance notice-Withdrawal (FCN4)

50



Control Bodies

Number of OCB inspections carried out, producers 2.002 of which processors 375. (all operators inspected plus additional 5% random inspected)

28 compliance notice issued to producers. 4 compliance notice issued to processors.

Control regime via OCBs effective.

Removal of organic status from individual products/animals/areas

8 operators had organic status removed from individual lots/production runs.

Removal or organic status overseen by DAFM as competent authority.

Deregister of organic operators 5 operators deregistered in 2012.

As above: demonstration that system is Working.

DAFM retail inspection programme

Written notification to non-compliant operators

1 warning letters issued: with follow inspection to ensure the operator was compliant. .

Became registered/fully compliant with organic legislative requirements



Honey

Withdrawal and destruction of honey with elevated lead concentration. Prohibition on movement or consumption of honey with elevated lead concentration.

During 2013 Compliance Notices issued to two producers following the 2012 cases of elevated lead in honey.

Where appropriate, notice issued outlining specific action required for each individual producer / packer / distributor to achieve compliance with hygiene / animal remedies requirements.

Written notice allowing reasonable period of time to achieve compliance. Follow-up inspections where appropriate.

51

Actions to ensure effectiveness of Official Controls

On a general note, all Divisions take account of the reports from both internal and external audits when planning controls. Furthermore, a DAFM Agricultural Inspectorate Management/Co-ordination Committee is in place and meets twice a year to review and manage selected control programmes forming part of the MANCP.


Monitoring of the effectiveness of official controls is done by Regional SVIs and HQ. Each VI produces a quarterly report for each establishment and sends it to the RSVI. The RSVI produces a quarterly report, based on the VI returns, for each region and sends it to HQ. Verification of the effectiveness of official controls Is conducted by RSVI annually at each establishment. Audit reports carried out by RSVIs are sent to HQ. As VIs in future will be spending more time auditing the food business operators performance, more emphasis will be given to this role of RSVI as verifier of the effectiveness of official controls. When other duties permit and in response to identified need, HQ VIs, SVIs and SSVIs visit establishments and verify the effectiveness of official controls. Audits which are external to VPHIS (IAG, FSAI, FVO) give an overview of the effectiveness of official controls. Every effort is made to close out any recommendations from these audits in a timely manner Meetings with Industry [see point 9.2.2.3] involved a means of stakeholder feedback, and informs improvement and revision of the systems.

Audits

Of the seven audits planned for 2013, five were commenced and completed. The included the following:

SVSIAG 07/13: Follow up to Audit SVSIAG/06/11 carried out in order to evaluate the implementation of the system for equine identification and the controls carried out during equine slaughter.

SVSIAG 06/13: Report on a horizontal audit to evaluate the provision of training to veterinary field staff within the Department of Agriculture, Food and the Marine (DAFM)

SVSIAG 03/13: Report on DAFM Controls Relating to Sheep Slaughter Establishments

SVSIAG 02/13: Report of an Audit carried out by SVSIAG in order to evaluate the controls carried out for Cattle Feedlot Systems.

SVSIAG 01/13: Audit carried out by SVSIAG to evaluate the implementation of certain controls aimed at the prevention of brucellosis in bovine animals and monitoring in other species

Audits on (a) contingency and preparedness and (b) ‘schedule 8’ mastitis control programmes were not commenced

Key high-level findings of the 2013 audit programme

Control programmes are well implemented in many areas but not always consistently applied. There are shortcomings in the nature of controls and in the level and effectiveness of implementation in some areas. Thus verification of the effectiveness of official controls needs further strengthening.

Guidelines and instructions to staff are provided but are not always up to date and not always adhered to by staff. Training methodology and effectiveness of training need review and additional consideration.

There are some shortcomings as to quality controls and accreditation of methods within the official laboratory services.

Effective sanctions need to be available to ensure that official controls are effective in addressing non-compliances.

52

Other developments regarding how the audit function helped to raise the standard of overall performance

Highlighting of areas for improvement of official controls.

Identification of areas where shortcomings associated with official controls presented potential reputational risks for DAFM, and potential public health and animal health risks.

Pursuit of formulation and implementation of corrective actions to address identified weaknesses, deficiencies and non-compliances.

Department of Agriculture, Food and the Marine – Agricultural Inspectorate

Audits of controls implemented by DAFM’s Agricultural Inspectorate are currently carried out by DAFM’s Internal Audit Unit which completely independent of the inspectorates control activities. A charter and protocol for the conduct of these audits has been revised and up-dated. These audits focus on the areas of the MANCP, which come within the remit of the Agricultural Inspectorate, these areas include:

Dairy Controls and Certification Division

Dairy Laboratory Division.

Feedingstuffs, Fertiliser, Grain and Poultry

Pesticide Registration and Control

Organic Controls.

Plant Health, Pesticides & Seed Testing Laboratories.

Horticulture and Plant Health Division.

Crops Evaluation and Certification There is a systematic risk based approach taken when developing the annual audit programmes. Commission Decision 2006/677/EC gives guidelines on the conduct of audit under Article 4(6) of Regulation (EC) No 882/2204. The following table gives an overview of the outcome of the 2012 audit programme. In general official controls are largely effective and in line with legislative requirements.

Sector Audit title Audit

completed Y/N, if N give reason.

Effectiveness/suitability of the Official Controls

2

Feedingstuffs

Audit on DAFM controls on the use of former foodstuffs and ABP (milk and milk products) in the animal feed sector.

Audit undertaken in 2013.

Import control procedures are in place and largely reflect legislative requirements. However, a number of deficiencies were identified particularly in relation to techniques applied during sampling. Procedure are being amended in light of issues raised and Regulation (EC) No.691 of 2013.

Pesticides Procedures and controls relating to the marketing of Plant Protection Products.

Audit began in 2013 and finalised in 2014.

Pesticide Control Division and Pesticide Registration Division are participating in the European approval systems for new active substance. New plant protection products are generally authorised through mutual recognition. A control system is in place to ensure that plant protection products available for distribution, sale and in use in Ireland are sold in accordance with pesticide legislation. Staffing issues within the Division impacted on the delivery of the control programme and the rate of processing authorisation for new products and active substances.

Follow-up audit

Controls used to assess implementation of the Hygiene Package in the Apiculture Sector.

A number of follow-up audits were conducted in 2013.

A follow-up on a 2011 audit of Hygiene controls in the Api-culture sector was undertaken. Four of the non-compliances previously identified were closed and one remains open.

53

Audits and inspections of control bodies – Article 5(3) of Regulation (EC) No 882/2004

In accordance with Article 5 Regulation (EC) No 882/2004 and Council Regulation (EC) No 834/2007 DAFM delegates control tasks in relation to organics to Control Bodies.

Sector Audit title The extent to which the audit of Control Bodies

was completed.

Audit /inspection outcomes. Comment on the effectiveness of the Official Control

Bodies

Organics

Supervision of Control Bodies

Audit requirement fulfilled: re-inspection of c. 2% organic operators. DAFM attendance at OCBs’ decision making forum = Certification Panel meetings to advise re interpretation of regs etc.

There is generally a very well developed and effective control regime in place. Constant interaction with OBS’s via established fora and constant monitoring of their control activities provide confidence in the system and protects consumers interests. Organic legislative proposals by the Commission in 2013 to strengthen alignment of organic controls with Reg. (EC) No. 882/2004 will further enhance the control system. As in any control regime the system can be improved – developing more risk based control system will further improve effectiveness.

Organics

Supervision of Control Bodies (Via Cross –Reporting)

Introduction in late 2013 of cross-reporting of OFS penalties – allowing to audit the non-compliance applied by OCB.

Improved interaction with OCBs which resulted in a more transparent OCB inspection system.



Control actions Action details Comment



Programme reviews yearly and response to RASFF notifications.

Annual revision of control programme. 1x yearly reviews of progress with FSAI. Increase analytical scope to incorporate single residue methods in line with recommendation by the Commission 1* meeting on EU coordinated plan with MSs and Commission.

Update programme to take account of the most recent monitoring information from current programme and requests by the Commission.

Internal meetings between Division and laboratory .

Scope and capacity of laboratory incorporated into plan.

Training programmes. All staff receive regular training including appropriate BTSF courses

54




Feedingstuffs

Feed Business Operators and Feed

Review annual control programme periodically.

Internal meetings.

Meet with linked Divisions and relevant outside Agencies to review and update work programme

Liaise with the FSAI and the State Lab. as required.

Action taken to remedy non compliances detected.

Inspections, re-analysis, detention of product.

Risk based control programme.

Update risk assessments.

Trade informed of policy and legislative changes.

Trader notices issued.

Internal audit Remedy audit findings. New legislation Inform Trade.

New or Revised Procedures

Update procedures manuals; staff training as appropriate

In 2013, the procedures manual was updated to enhance information value from inspection forms. Changes were made to Section 7, and a new Annex XX, provides guidelines for completion of a new Pre-Inspection form.


Area Controlled


Hygiene and Contaminants of horticultural produce

Programme reviews.

Annual revision of control programme. 1x yearly reviews of progress with FSAI.

Programme updated by taking account of the most recent monitoring information.

Training programmes.

All staff receive regular training. In addition system of supervisory checks implemented in 2013 to verify quality of work.

In 2013 a minimum of two training courses attended by all staff. All staff received at least one supervisory check in 2013.

Attend Conferences/Meetings etc.

Contact with other MSs, current research.

Meet with linked Divisions and relevant outside Agencies to review and update work programme.

Liaise with other DAFM divisions, the FSAI, Teagasc, Bord Bia, HSE and the State Lab as required.

Internal meetings. Staff kept informed of changes. All staff made aware of updates.


Area Controlled


Plant Passports

Update plant passport information.

Liaise with business operators. On-going.

Quarantine organisms

Producers informed of requirements.

Meetings with producers to raise awareness.


Area Controlled



Programme reviews.

Meetings which took place in 2013:

7 meetings of Inspectors

2 MANCP Board meetings.

2 FSAI Liaison meetings.

1 Microbiological Criteria Working Group.

1 SOP revised and 1 new SOP prepared during the year: Sampling, testing, and reporting of results

Update by taking account of the most recent monitoring information.

55

Area Controlled


for Microbiological analysis of potable water at processing premises SOP No 26 was revised with effect from 22/03/2013.

National Supervisory System for Staff Performing Official Food Safety Controls SOP 16 was issued with effect from 01/03/2013. Under the National Supervisory System for Staff Performing Official Food Safety Controls SOP 16, there were 54 supervisory controls reported (including 16 accompanied inspections) in 2013.

New legislation. Legislation is monitored with emphasis on dealing with any gaps that are identified.

New guidance documents.

New guidance documents are circulated as they become available.

Training programmes.

Staff attended the following: 11 x BTSF- Training course on the hygiene and control of Baby Food Products or HACCP or Milk/milk products 24 x Milk Quality Workshop 24 x HACCP workshop 1 x PFGE training on Coagulase Positive Staphylococci 6 x Listeria Conference 1 x Chemistry Method validation 2 x ISO 17025 training 3 x Internal Auditing Training

Special initiatives.

A working group on laboratory related issues remained in place. Attendance continued at Teagasc Milk and product Forum. Progress continued throughout 2013 on introducing an IT system for reporting official controls (AFIT).

Audit findings, etc Programme reviews took account of findings of audit reports such as Internal Audit, FSAI and FVO.


Area Controlled


Supervision by DAFM of Control Bodies

Compliance Inspections.

2% of all organic operators now being inspected annually by DAFM.

DAFM also attends as observes OCBs Certification Panel meetings, to identify non-compliance and provide guidance with interpretation of and adherence to organic regulations.

DAFM Farmers Market inspections.

Internal Audit. Risk based control inspection system established since 2011.

Implementing SOP AAI monitoring of retail inspections. Ongoing liaison with Control bodies to improve control system and protect consumer interests. Increase level of targeted inspections in late 2013 as extra Local Office staffing levels available.

DAFM Organic Unit staff interacting with OBS’s at all levels to ensure the controls applied to the organic sector meet requirements and expectations. Changes were made to include Local Office AES staff to carry out Farmers Market Inspections this had the benefit of local knowledge.

56


Area Controlled


Honey

Action taken to remedy non compliances detected.

Compliance / written notices issued.

Risk based control programme.

Programme regularly updated in light of experience.

Training and supervision of Inspectors.

All Inspectors trained in honey sampling, hygiene and animal remedies inspections before commencing work in this area. Supervisory checks implemented to verify quality of work.

Beekeepers informed of requirements.

Meetings with Beekeepers, DAFM website developed and notice published in Beekeeper’s magazine to raise awareness.

Follow-up audit conducted to verify corrective action taken in response to 2011 Internal Audit to verify effectiveness of controls.

Four minor non-compliances detected by audit deemed closed out. One remains open pending development in legislation.

57

Statement of Overall compliance by sector

The strategic objectives set out in the MANCP are being progressed through co-ordinated and consistent control programmes. In the main the controls in place are effective and broadly reflect legislative requirements. Levels of co-operation and co-ordination both between and within Divisions have improved contributing to the overall achievement of the strategic objectives as set out in the MANCP.


The overall compliance of the Food Business Operators is generally satisfactory, and where it is not, effective, dissuasive and proportionate action can be taken by the VPHIS.

Sector Statement of overall

compliance Suitability of MANCP

Animal By-Products Combination of targeted and random inspections achieves satisfactory compliance.

Yes.

58

Statement on the overall performance

The strategic objectives set out in the MANCP are being progressed through co-ordinated and consistent control programmes. In the main the controls in place are effective and broadly reflect legislative requirements. Levels of co-operation and co-ordination both between and within Divisions has improved contributing to the overall achievement of the strategic objectives as set out in the MANCP.


Sector Area Controlled. Comment

Food of Plant Origin

Pesticide Residues in food.

Effectiveness and suitability of MANCP

Pesticide residues are effectively monitored and controlled.

Risk based official controls. Yes. Analysis of results. Acceptable. Suitability of performance indicators.

Programme targets met for 2013.


Area Controlled. Comment

Feed Business Operators and Feed


Good progress in achieving strategic objectives of the MANCP in respect to all stages of production, processing, storage, distribution and use of feed.

Good coordination between CA’s.

Risk based official controls The risk based targeting of official controls is in operation.



Hygiene Inspections. Contaminants of horticultural produce


Overall programme is effective. New legislative requirement and therefore initially would expect high level of non-compliances.

Risk based official controls. Risk based system is being developed. Controls are new in this area.

Analysis of results. Satisfactory. Suitability of performance indicators.

Satisfactory.



Suitability of performance indicators.

Programme targets met for 2013.

59





Continued progress made in achieving strategic objectives of the MANCP in respect of processing and storage of milk and milk products, with on-going programme reviews and revisions of standard operating procedures, including the introduction of a supervisory system for Staff Performing Official Food Safety Controls, operable from 2013. There was an underachievement in reaching the set down targets for official controls relating to food business operators producing and/or collecting raw milk. However, of the 203 milk production holdings inspected 60 % had non-compliances detected. While this is an improvement on 2012, it indicates that continued monitoring is necessary at primary production level. Implementation of the supervisory system is/will be impacted by a shortage of staff at supervisory level. Market access issues (3

rd Country audits

etc) and other investigations also impact on delivery of supervisory controls.

Risk based official controls. Yes

Analysis of results. With the exception of a small number of farm house producers, the Irish dairy industry continued in 2013 to maintain a high level of compliance.

Suitability of performance indicators.

The measurement of controls applied as a percentage of set down targets is working well as a performance indicator. However, ongoing review of targets is necessary.



All related areas Effectiveness and suitability of MANCP.

Staffing difficulties persisted in 2013. Thus some of the 2013 DAFM organics control programme was not completed, and overall the sector was satisfactorily controlled due to better risk analysis. Control/Monitoring remains effective.



Honey


Satisfactory; the programme is allowing effective monitoring and control in the honey sector.

Risk based official controls. Risk based controls are in operation.

Analysis of results. Analysis of results is effective in identifying areas where honey producers need to improve compliance.

60

Comment on the appropriateness and suitability of the MANCP - Did the programme of OC’s identify any necessary amendment to MANCP

No

61

Amendments to the national control plan Indicate any changes made to the MANCP during the year to which the report relates. The nature and reason for the amendments should be described.

MANCP to be updated in respect to resources used to implement the control programme.

62

ANNEX DAFM1 - VIAP Risk Assessment Form

63

VIAP Risk Assessment Form

Risk Assessment to Plan the Frequency of Audits VI Checks at Food

Establishments [Other than slaughter activities]. Name of Plant_______________________ Plant No______

Plant type Cutting MM+M Preps Meat Products Egg Products Milk Cold Stores

Approval (Tick)

RTE

Non-RTE

RTE = Ready to eat; MM = Minced Meat; M Preps = Meat Preparations

Risk Criteria Scoring Scheme Risk

Score

Type of Plant (RTE or Non RTE) RTE Score 12 Non RTE Score 3

Category 1 Findings (1 or more)* Yes: Score 6 No : Score 0

Category 2 Findings (3 or More) Yes: score 6 No: Score 0

Category 2 Findings (Less than 3) Yes Score 3

No Score 0

Category 3 Findings (3 or More) Yes Score 2 No Score 0

Category 3 Findings (less than 3) Yes Score 1 No Score 0

Legal Enforcement Notices (Other than those issued as a result of a VIAP)

Yes: Score 6 No Score 0

Overall Score

Score: 3 = I audit per year Score: 4 -6 = I Audit + 1 unannounced Inspection Score: 7-11 = 1 Audit + 2 unannounced Inspections Score: 12 = 2 Audits per year Score: 13-14 = 2 Audits + 1announced Inspection Score: 15-17 = 2 Audits+ 2 unannounced Inspections Score: 18 or greater = 2 Audits + 4 unannounced Inspections A significant non-compliance found during official controls (including those on imported

products) should prompt a consultation with the RSVI to discuss enforcement action and

a review of the risk assessment at that establishment. At the next visit the VI must carry

out a further risk assessment. If there is still significant non-compliance, a review of the

plant’s approval will be carried out by the RSVI in consultation with HQ

Frequency Level of VI Checks to be carried out at above named Plant for Year

ended 2013 : ___________________________ __

Note: Additional checks may be carried out over and above the prescribed frequency level at the direction of the RSVI or HQ.

Date Risk Assessment Performed _____________ Risk Assessor__________________

Agree with VI Risk Assessment

RSVI---------------------- Date---------------------------------

64

Notes

Each establishment is to be risk assessed by the VI responsible for the relevant plant after

the VIAP audit and this RA sets the frequency and type of follow up inspections and

close out verifications to be carried out in that plant for a year.

* The Plant is to be scored only once under audit findings at the highest scoring category

eg In the event of a Category 1 finding and less than 3 Category 2 findings the Plant

scores 6 and not 8 under findings.

65

ANNEX DAFM2 - SVI Risk Assessment Form

66

SVI Risk Assessment Form Risk Assessment to Plan the Minimum Frequency of Regional SVI Audits at Food

Establishments.

Name of Plant:____________________________________

Date Assessment Performed:________________________

Risk Assessor:____________________________________

Risk Criteria

Scoring Scheme

Risk Score

Level of overall compliance including compliance with Compliance Notice “A” [or equivalent] and CARs, which were issued during the previous year in relation

to structural defects, operational deficiencies, inadequate sanitation, inadequate sampling or unsatisfactory product .

Score 1 to 4¹

Was it necessary to issue a Compliance Notice “B” [or equivalent VC1] during

the previous year in relation to suspension of activities or to reduce throughput?

Score 1-4²

Was it necessary to issue a compliance Notice “A” during the previous year?

Yes: Score 2 No: Score 0

Are there effective QC and Own Checks programmes in place at the plant?

Score 1- 4

1

Is there an acceptable HACCP programme in place at the plant?

Score 1 –4

3

Nature of product (high, medium or low risk)³

Score 1 –4³

Does the VI require additional support (new recruit or other reasons)?

Score 1-4¹

Overall Score

Score

Frequency of Inspection

6-12

Level 1 for the plant type

13 - 18

Level 2 for the plant type

19 - 26 Level 3 for the plant type

A score in excess of 19 should prompt a formal review of the plant’s approval by the SVI

67

1 Score 1 = very good, 2 = satisfactory, 3= marginal , 4 = unsatisfactory.

² 1=No Notice. 2=VC1. 3=Serious reason for issuing notice such as breach of SRM protocols etc. 4= Very serious reason ie an immediate public health risk.

³ Nature of product is deemed to be a risk criterion. The following are examples of the different risk categories:

Low Risk Product (1) = Raw Medium Risk Product (2) = Comminuted Raw and Sliced Cured High

Risk (3) = Cooked non RTE (4) Very High Risk = RTE products.

Minimum Frequency levels of RSVI visits at Food establishments based on risk

assessment.

Level 1= annually. Level 2 = Every 6 Months. Level 3 = Every 4 Months.

68

ANNEX DAFM3 - 2013 - Summary of Legal Notices served

69

Establishments Total 15A Total 15B Voluntary

Closure

Slaughtering Plants (Incl. Farmed Game and Poultry) 18 1 2

Cutting Ests. Attached to Slaughter Ests. 4 0 0

Stand alone Cutting Ests. 3 1 0

Minced meat & meat preps Plants 5 0 2

Meat products Plants 8 2 0

Wild Game Handling Plants 0 0 0

Cold Stores. 1 3 0

Egg Product Plants 0 0 0

Sub Total 39 7 4

Total 39 11

70

ANNEX DAFM4 - Risk Assessment Protocols of VPHIS

71

2013 Risk Assessment - National Summary

Year No. of

Approved Activities

Planned VI Official

Controls on all Approved

Activities

RSVI Adjustment

Total Planned RSVI Official Controls on all Approved

Activities

Total Planned Official

Controls on all Approved

Activities

Total Planned RSVI Official Controls to Approved Premises

2013 297 2698 2698 337 3035 184

2012 300 2871 2875 335 3210 202

Difference/Reduction -3 -173 -177 2 -175 -18

% Difference/Reduction -1.00% -6.03% -6.16% 0.60% -5.45% -8.91%

72

ANNEX DAFM5 - VPHIS Training

73

VPHIS Training The Performance Management Development System of DAFM allows for personnel to identify and state their training needs. Arising from the needs identified by staff, allied to the needs arising from external audits, changes in /new legislation, a range of VPHIS Veterinary and Technical staff attended the following courses during 2013:

Staff Training & Development

VI Training - 2013

Course/Seminar No. of courses Total No. of Participants

1

Total No. of Staff Days

2

*BTSF 1 27 135

AFIT/VIAP Training 1 16 8

Conflict Mgmt & Resolution 1 3 3

CVRL Scientific Seminar 1 11 11

Effective Meetings 1 1 1

FETAC REFRESHER FIRST AID 1 5 10

HACCP COURSE 1 1 2

ICD SERIES 1 1 1

Induction 1.5 Day 1 1 1.5

Investigation Skills 1 14 14

Level 1 Management 1 5 10


Misc. Conference/Seminar 1 1 1

PeoplePoint Portal Training 1 4 2

Retirement Planning Course -2D 1 3 6

TIME MANAGEMENT 1 1 1

VPHIS SEMINAR: Animal Welfare 1 45 45

VPHIS SEMINAR-Common VI/TAO 1 43 43

VPHIS-USDA Seminar 1 19 19 1

Total No. of Meat Division Participants = Total no. of Meat Division attendees for a course/seminar.

2

To estimate “Total No. of Staff Days” per course/seminar, add up the “Staff Days for each course/seminar”.

“Staff Days for each course/seminar” = the time involved (to the nearest ½ day -

including time spent getting to and from the training) multiplied by the no. of Meat Division attendees.

*An update of Training Database is awaited.

74

TAO Training - 2013

Course/Seminar

No. of courses Total No. of

Participants1

Total No. of Staff Days2

Administrative Law 1 2 2

AIMS Training for Equines 1 4 4

Customer Quality Care 1 6 6

Computer Training 1 14 15

Conflict Mgmt & Resolution 1 2 2

Effective Meetings 1 2 2

FETAC REFRESHER FIRST AID 1 26 26

Health and Safety Course 1 6 6

HACCP COURSE Rendering Plant 1 1 2

Interview Training 1 1 1

Land Law and Probate 1 2 2



Manual Lifting 1 12 12

Minute Taking 1 2 2

PeoplePoint Portal Training 1 9 9

Retirement Planning Course -2D 1 1 3

Report Writing 1 8 8

VPHIS SEMINAR: Animal Welfare 1 66 66

VPHIS SEMINAR-Common VI/TAO 1 129 129

75

ANNEX DAFM6 - Plant Health Control information.

Harmful Organism Reason for

Survey Survey period

Survey Location

Host Plants Target %

Completion Findings Outcome Comments

Ralstonia solanacearum Brown Rot

EU Survey Council Directive 98/57/EC

Sept to July National Solanaceae spp. Seed and Ware potatoes

100% 589 samples analysed - no positives found

Country freedom maintained

No positives since findings in 2007. In addition 104 samples were taken from imported potatoes.

Clavibacter michiganensis Ring Rot

EU Survey Council Directive 93/85/EEC

Sept to July National Solanaceae spp. Seed and Ware potatoes

100% 589 samples analysed - no positives found

Country freedom maintained

In addition 104 samples were taken from imported potatoes.

Globodera spp Potato Cyst Nematode

EU Survey Council Directive 2007/33/EC

Oct to August

National Fields intended for planting and ware survey

Solanaceae spp. and Narcissus

All ground intended for potato certification and 0.1% of ware ground

100% 802 samples analysed

7 samples of seed potatoes infested and 13 samples non-seed potatoes infested.

On the basis of survey, PCN is present on the Irish territory.

Meloidogyne spp. Root Knot Nematode

EU Survey November to March

National Potatoes 200 100% 37 samples - no positives found

Country freedom

Reduced samples is due to the change in labs from Teagasc to AFBI

Bemisia tabaci Tobacco whitefly

Protected Zone (PZ) Continuous National

Numerous, but high risk species are Euphorbia pulcherrima & Ocimum spp.

Imported plants and nurseries along with wholesale inspections

100%

1170 visual inspections, 8samples submitted to entomologist with 5 findings on imported material.

Appropriate measures taken, eradication of pest at Producer

Protected Zone maintained

Leptinotarsa decemlineata Colorado beetle

Protected Zone (PZ) Spring / Summer

National Wholesale and retail level as well as growing potato crops

Potatoes and leafy vegetables

Potato seed crops and Merchant/wholesaler premises

100% No insects found Protected Zone maintained.

Liriomyza bryoniae Leaf miner

Protected Zone (PZ) Continuous National

Numerous Flowers and Plants as this pest is very polyphagous

100%

1154 visual inspections. 7 samples submitted to entomologist with 4 findings on imported material.

Appropriate measures taken, eradication of pest at Producer

Protected Zone maintained

Erwinia amylovora Fireblight

Temporary Protected Zone

June to October

Registered Nurseries, Garden Centres, Orchards, Public Parks & Private Gardens

Amelanchier spp. Chaenomeles spp. Cotoneaster spp. Crataegus spp. Cydonia spp. Eriobotrya spp. Malus spp.

All registered nurseries visually inspected along with other locations where positives were found in previous

100% 1,591 samples analysed, 12 positives at 10 sites.

All positive plants and other nearby host plants were destroyed.

Our temporary Protected Zone was reviewed in March 2014. Due to the repeated Fireblight findings in Galway city, Galway city lost its PZ

Mespilus spp. Photinia davidiana Pyracantha spp. Pyrus spp. Sorbus spp.

years. 1600 samples for laboratory analysis

for Fireblight. The remainder of the country retained its PZ status.

Chalara fraxinea Ash dieback

To determine the prevalence and extent of the disease in Ireland

July / Oct

Registered Nurseries, Garden Centres, Public Parks & Private Gardens

Fraxinus spp. 1000 samples 150% 1,500 samples submitted between AFBI and Plant Health Laboratories

Organism found in 72 locations as follows: Hort. Nurseries 17 Garden Centres 4 Private Gardens 4 REPS/AEOS 21 Roadside Planting 25 Hedgerow 1

A survey will be carried out during the summer of 2014 to help determine how best to proceed with this organism.

Beet Necrotic Yellow Vein Virus

Protected Zone (PZ) Nov / Dec National – Field grown host plants

Beets 194 samples for laboratory analysis

100%

194 samples were submitted to Plant Health Laboratory. No findings of the organism.

Protected Zone maintained.

Phytophthora ramorum

EU emergency legislation Commission Decision 2002/757/EC as amended

Dec 1 2012 to Nov 30 2013 Continuous

Registered Nurseries, Garden Centres, Public Parks & Private Gardens

Wide range of woody plants with ever increasing host range.

All registered producers and locations with previous findings visually inspected twice per year.

100% 437 samples to laboratory with 21 positives

Appropriate measures taken at infection sites.

Rhynchophorus ferrugineus Red palm weevil


Continuous

Registered Nurseries, Garden centres, Public Parks & Private Gardens

Palmae spp. Visual inspections of host plants

100%

93 nurseries/garden centres and 3 public green sites inspected. No Findings of organism.

No findings Unlikely to be found or become established here.

Dryocosmus kuriphilus Oriental chestnut gall wasp

EU emergency legislation Commission Decision 2006/464/EC

Continuous Registered Nurseries, Garden centres, Public Parks & Private Gardens

Castanea spp. Visual inspections of host plants

100% 36 Nurseries Inspected. No findings

No Findings Unlikely to cause economic loss here.

Diabrotica virgifera virgifera Western Corn rootworm


June to October

Ports Airports and Motorway service stations and maize fields near these locations

Maize Place and collect traps from all these locations as selected annually

100% 116 traps recovered with no Findings

No findings of Diabrotica in Ireland to date

Diabrotica was delisted as a harmful organism under Directive 2000/29/EC. Ireland will continue to survey for the pest.

Pepino Mosaic Virus EU emergency legislation Commission Decision 2004/200/EC

May to November

Wholesalers retailers and Tomato Fruit Growers

Tomatoes Visual inspections of all tomato fruit growers and inspections at Wholesale retail level

100% MS no longer obliged to carry out a survey for Pepino Mosaic Virus

Anoplophora chinensis Citrus longhorn beetle


Ongoing 1 April ‘13 to 31 March ‘14

Registered Nurseries, garden Centres, Public Parks & Private Gardens

Wide Range of woody plants with ever increasing host range

All registered premises inspected.

100% 339 nurseries/garden centres and 63 public green areas inspected. No Findings

Potato spindle tuber viroid

EU emergency legislation Commission Decision 2007/401/EC

May to November

Wholesalers, retailers and tomato fruit Producers

Potatoes, Tomatoes, ornamental solanaceae and Brugmansia spp.

All tomato and ornamental producers inspected as well as tomato inspections at Wholesale retail level

100% No Findings

Guignardia citricarpa & Xanthomonas campestris Citrus black spots


May to Nov Wholesalers and retailers

All Citrus fruits, however the legislation requires additional requirements for citrus from Brazil

Wholesale and retail inspections

100% No Findings As these pests only harm citrus, they will have no impact here.

Ditylenchus dipsaci Stem and bulb eelworm

EU legislation Council Directive 2000/29/EC

March to April

Commercial daffodil crops

Narcissus and Allium Suspect material sent for analysis

100% 25 samples . No finding

Various EU legislation Council Directive 2008/90/EC

May to Oct Producers Fruit plant propagating material

All Producers 100% No adverse Findings

Various quarantine pests EU Council Directive 2000/29/EC

Continuous National As per Annexes of Directive

Various Appropriate actions take on any findings

General plant Health inspections for quarantine pests

Health Service Executive (HSE)

The food safety remit of the Health Service Executive is delivered through a service contract under the FSAI Act 1998 with the Food Safety Authority of Ireland. The HSE / FSAI service contract details the food safety work to be undertaken by a number of services within the HSE, including:

1. Environmental health services (EHS)

2. Food safety laboratory services (9 Official Laboratories)

3. Public health medical services

The official controls undertaken by the HSE include; inspections, audits, sampling & analysis, disease surveillance, outbreak investigation, rapid alert follow up and complaint investigation. The EHS of the HSE undertakes official controls in the following sectors:

Retail sector establishments (including retail and catering)

Manufacturers of food of non-animal origin

Certain other food manufacturers/processing establishments

Certain wholesale/distribution operations

Certain approved establishments

Imports of food of non-animal origin

During 2013, the EHS was responsible for the supervision of 43,419 establishments, most (28,214) of which were in the service sector (see Annex HSE1 for more information).

MANCP Section

Title Information


FSAI Guidance Note 1 (GN1) sets out proactive inspection frequencies for inspection of food businesses supervised by the Environmental Health Service (EHS) of the HSE. The most recent version of GN1 (Revision 2) introduced a new risk categorisation process, broadened the range of risk categories from 3 to 6 with revised planned inspection frequencies, provides for classification of non-compliances & inspection outcomes and includes a requirement for priority action lists to ensure that effective / timely enforcement action is taken where appropriate. GN1 (Rev 2) became fully operational in January 2012 (see Annex HSE1, table HSE3). GN1 (Rev. 2) outlines a process for prioritising other official controls ahead of planned inspections based on risk. The level of priority is determined by the severity and the likelihood of the risk occurring. Accordingly priority is given to each of the following: food outbreaks; food alerts; food complaints where there is a serious risk to consumers; food businesses where enforcement action is current or may be required following inspection; insufficient confidence in management and/or the food safety management systems to ensure food safety; where the inspection outcome is Grade 5 (Unsatisfactory Serious) or where there have been 2 or more consecutive Grade 4 (Unsatisfactory Significant) inspection outcomes; in the case of obstruction. Import controls – All food consignments imported which are subject to additional controls to receive the additional official controls required by legislation. EHS takes samples from food business establishments under their supervision to support inspection activity and verify compliance with legislation. Samples are submitted for analysis to one of the HSE’s six food microbiology laboratories (for microbiological analysis) or the three Public Analyst Laboratories (for chemical analysis). One of the Public Analyst’s Laboratories (Dublin) carries out both chemical and microbiological analysis. Any non-compliance is followed up by the EHS and corrective action taken, where required.

Outputs

In 2013 there were 21,524 full programmed inspections carried out (see Annex HSE1, Table HSE6)

The HSE is responsible for carrying out checks on food of non-animal origin at point of entry into Ireland. Checks carried out include random checks and mandatory checks required on foot of EU Emergency Decisions or “Safeguard Measure”. All food consignments subject to these additional controls received the required checks in 2013.

Since 2009 the HSE has been implementing a more consistent targeted approach to food sampling and analysis. This approach to sampling which reflects a move towards more targeted sampling at central manufacturing and distribution points, away from retail level sampling is considered a more effective use of sampling and testing resources and is in accordance with the recommendation from the FSAI’s Scientific Committee which reviewed the microbiological testing programme and published its report in 2010 (See Annex HSE1, Table HSE7)

There has been a move toward increased multi parameter testing particularly for chemical samples which means that while sample numbers have reduced this does not correspond to the same reduction in tests carried out.

Annex HSE1 (Tables HSE7 & HSE7a) shows the total number of samples tested in the last five years for microbiological and chemical/physical parameters. Since 2009 there has been a significant reduction, which reflects a move towards more targeted sampling at central manufacturing and distribution points, away from retail level sampling.


Overall compliance The summary data presented in Annex HSE1 (Table HSE8 and Table HSE8a)- indicates that 7,093 infringements were detected in 2013 by HSE inspectors. However, the number of enforcement actions, which relate to serious food safety risks / non-compliances, (see Annex HSE1, Table HSE9) indicates a high level of compliance overall.

9.2.2.1 & 9.2.2.2


See Annex HSE1, Table HSE1

What were the main types of non-compliance identified Infringements observed during inspection

See Annex HSE1, Table HSE8a

Infringements from chemical/microbiological sampling

See Annex HSE1, Tables HSE7 and HSE7a. Typical infringements for the chemical/physical testing of food relate to labelling or compositional requirements; these include for example foodstuffs containing food additives that are not included in the list of ingredients. Non-compliances are followed-up by EHOs, with action proportionate to the nature of the infringement. In cases where sampling indicates that foods presenting a danger to health have been placed on the market, the FSAI is informed. If the food has been exported, the FSAI can issue notices to the country concerned via the Rapid Alerts System for Food and Feed (RASFF).


Randomly distributed


All non-compliances and inspection outcomes must be assessed and classified accordingly. This is documented in FSAI Guidance Note 1 (Rev. 2). Inspections with outcomes Grade 4 (Unsatisfactory Significant) or Grade 5 (Unsatisfactory Serious) will be likely to result in a formal enforcement action being served on the food business. The formal enforcement actions taken in 2012 are in Annex HSE1, Tables HSE9 and HSE9a.


Data is not available centrally on this

9.4.1


Enforcement action was taken where appropriate. The formal enforcement actions taken in 2013 are in Annex HSE1- Tables HSE9 and HSE9a.


Guidance Note 1 (Rev2) places a strong emphasis on taking effective and timely enforcement action where appropriate. This approach is reflected in the increase in enforcement actions in 2013.

9.5

Statement of Overall compliance within the sector

Overall the level of compliance of Food Business Operators supervised by the HSE is generally satisfactory, and where it is not, effective, dissuasive and proportionate action can be / is taken by the EHS.


Did the programme of OC’s identify any necessary amendment to MANCP No

Appendix: HSE1

2010 2011 2012 2013

Number of Establishments 46355 47057 46011 43419

Number of Establishments Inspected 27904 27055 26032 30172

Number of full and surveillance programmed Inspections

41966 37973 36584 33971

Number of Infringements 13,490 10,132 12,142 7,093

Table HSE1: No. of establishments, establishments inspected, inspections and No. of establishments committing infringements 2010 to 2013

2010 2011 2012 2013

Primary Producers 27 23 21

Manufacturers & Packers 1,921 2,253 2,534

Distributors & Transporters 1,370 1,487 1,472


1,738 724 695

Retailers 10,732 11,166 10,978 10,972

Service Sector 30,567 31,404 30,311 28,214

Transporter 64

Importer/Exporter 73

Manufacturers 2,864

Not Assigned 42

Packers 92

Wholesalers/Distributors 1,098

Total 46,355 47,057 46,011 43,419

Table HSE2: No. of establishments (by food chain stage)

2010 2011 2012 2013

1 155 135

2 2,193 2,157

3 16,664 13,314

4 10,907 13,415

5 13,794 11,188

6 1,671 1,392

High 23,278 23,498

Low 16,818 17,734

Medium 5,937 5,925

No Rating

Total 46,033 47,157 45,384 41,601

Table HSE3: No. of establishments (by risk category)

2010 2011 2012 2013

Primary Producers 53 28 37 15

Manufacturers & Packers 1,715 1,753 2,047 2,019

Distributors & Transporters 834 762 819 774


982 812 689 308

Retailers 10,148 8,510 7,806 7,583

Service Sector 28,234 26,108 25,186 23,272

Total 41,966 37,973 36,584 33,971

Table HSE4: Inspections (by food chain stage)

2010 2011 2012 2013

1 582 441

2 4,982 4,489

3 23,911 20,104

4 9,222 10,279

5 5,250 4,630

6 328 240

High 37,363 33,777

Low 7,592 7,020

Medium 6,144 5,659

No Rating

Total 51,099 46,456 44,275 40,183

Table HSE5: Inspections (by risk category)

2013

Risk Category Full

Programmed Inspections

Other Inspections

Programmed Surveillance Inspections

1 192 72 77

2 2,123 500 1,471

3 10,030 2,410 5,980

4 5,996 1,455 2,113

5 3,079 679 622

6 104 65 68

Total 21,524 5,181 10,331

Table HSE6: Inspections (by type) 2013

Samples Non-

Compliant % with

contamination

2009 5,664 236 4.17%

2010 4,712 224 4.75%

2011 3,331 197 5.91%

2012 3,314 226 6.82%

2013 3,113 223 7.16%

Table HSE7: Samples (Chemical/ Physical)

Samples Non-

Compliant % with

contamination

2009 12,236 1,632 13.34%

2010 10,396 1,172 11.27%

2011 8,465 733 8.66%

2012 7,112 880 12.37%

2013 6,441 484 7.51%

Table HSE7a: Samples (Microbiological)

2010 2011 2012 2013


Manufacturers & Packers 333 287 483 282

Distributors & Transporters 160 91 160 89


371 250 435 94

Retailers 2,900 1,913 2,347 1,319

Service Sector 9,706 7,588 8,715 5,309

Total 13,490 10,132 12,142 7,093

Table HSE8: Infringements by Food Chain Stage

2010 2011 2012 2013

Infringement Number % Number % Number % Number %

Chemical / Physical Contamination

199 1.48% 347 3.42% 104 0.86% 61 0.86%

General Hygiene 5,719 42.39% 4,431 43.73% 5,148 42.40% 3,143 44.31%

Labelling & Presentation 1,237 9.17% 785 7.75% 2,232 18.38% 404 5.70%

Risk Assesment / HACCP 4,417 32.74% 3,294 32.51% 3,444 28.36% 2,339 32.98%

Training 1,752 12.99% 1,170 11.55% 1,105 9.10% 811 11.43%

Other (specify) 166 1.23% 105 1.04% 109 0.90% 335 4.72%

Total 13,490 100% 10,132 100% 12,142 100% 7,093 100%

Table HSE8a: Infringements details

Enforcement type 2010 2011 2012 2013

Closure Order 57 66 91 119

Improvement Notice 254 294 307 322

Improvement Order 4 7 3 5

Prohibition Order 12 11 15 20

Total 327 378 416 466

Table HSE9: Enforcements

Enforcement type 2010 2011 2012 2013

Service Sector 45 55 79 89

Retailers 9 7 9 19

Primary 1

Manufacturer Selling Direct 1 1

Manufacturer/Packer 1 2 3 5

Distributors/Transporters 1 6

Total 57 66 91 119

Table HSE9a: Closure Orders

Sea-Fisheries Protection Authority (SFPA)

The SFPA undertakes official controls in the following areas: • Approved Establishments • Other Food Businesses (Excluding Fin-Fish farms, Shellfish Production, Vessels) • Bivalve Shellfish Production • Vessels • Inspection of Fish at Landing or First Sale • Animal By-Product Official Controls During 2013, the Sea-Fisheries Protection Authority (www.sfpa.ie) was responsible for supervising 2,591 establishments, fishing vessels, ice plants and molluscan production areas. On aquaculture sites, fin fish routine inspections are carried out by DAFM veterinary staff with non-compliances investigated by the SFPA. SFPA is responsible for following-up on non-compliant results in samples taken as part of the national residues monitoring programme. No non compliances were detected in 2013. As of the 31 December 2013 there were 179 “Manufacturers & Packers” and 2,259 food business operators classed as primary producers under SFPA supervision. Of the approved establishments under SFPA supervision, high risk FBOs accounted for 74, with 55 categorised as medium risk and 87 as low risk. The SFPA committed the equivalent of 41 WTE staffing resources to food safety and official controls in 2013, a decline of 2% on the previous year.

http://www.sfpa.ie/

MANCP Section

Title Information


Number planned

Appropriate official control checks were required to be carried out by SFPOs (Sea Fisheries Protection Officer) at least once for each approved establishment in 2013

The recommended frequency for vessel inspections was once per vessel per annum with priority to be given to vessels >15m.

Factory and Freezer Vessels are required to be approved by the SFPA; therefore, the inspection frequencies and procedures for approved establishments also apply

Trip Hygiene Inspections (hygiene inspections that focus on fish caught during a given fishing trip) were targeted to be carried out on all vessels including factory and freezer vessels at the following frequency

o Vessels <15m, once per year o Vessels >15m, 4 per year (1 per active quarter)

Fish being landed at Irish ports were targeted for inspection at a minimum frequency of once per active quarter per vessel (pelagic vessels may be active for only 1 or 2 quarters of the year); for 2013, this was applicable to all vessels > 15m. For demersal vessels, it is recommended that 3 species are assessed per inspection

Other Food Businesses (Excluding Finfish farms, Shellfish Production, Vessels) were scheduled to be inspected by SFPOs once or twice per year, depending on the risk presented

Shellfish production areas were scheduled for monthly monitoring

Completed 4343 Inspections carried out in 2013 comprising of :

Primary Producers 1708

Manufacturers & Packers 2609

Distributors & Transporters 26 46% of this inspection effort was focused on high risk food business operators. Land based establishments accounted for 2207 inspections. The SFPA also carried out 180 consignment inspections and issued 2774 health certificates. The fishing port of Howth accounted for the largest number of certificates (2270). A total of 105 staff days in 2013 were committed to food fraud investigations. 1522 food (shellfish) samples were taken by Sea-Fisheries Protection Officers in 2013.


Overall compliance Overall compliance in this sector was generally acceptable

9.2.2.1 & 9.2.2.2


A detailed inspection report is written up following each inspection identifying any non-compliances found during the course of the inspection, where necessary enforcements were issued. During 2013, 13 enforcements were served by the SFPA as a result of non-compliances found in contravention of EU food legislation.


Non compliances included structural deficiencies, inadequate food safety management systems, and deficiencies in hygiene, non-compliant microbiological product results, inadequate documentation and traceability.


Non-compliances were randomly distributed


Non compliances found which resulted in enforcements being served were major and moderate, 80% and 20% respectively.


Where appropriate, non-compliant FBOs received verbal or written warnings for minor non-compliances. More serious contraventions were dealt with through more formal means such as the service of compliance notices to remedy issues. Where FBOs required further training, advice or technical assistance they were referred to Bord Iascaigh Mhara (the Seafisheries Board) or the FSAI’s advice line.

9.4.1


Describe, giving the number of the various types of enforcement action deployed such as verbal warning, written notice, fixed penalty notice, restriction, premises closure, seizure/detention of animals or product, prosecution Actions taken to deal with non-compliances

6 Compliance Notices served 1 FSAI Act Prohibition Orders put in place 3 FSAI Act Improvement Notices served 3 Fixed Penalty Notices (under SI 432 of 2010)


The SFPA on its own initiative and with the assistance of other agencies provides training to its staff to support their professional development and skills in the area of food safety and official controls. In 2013, 78 SFPA staff spent a total of 1807 training days spread across 16 different training courses or events (including five FSAI Training / Seminar events). The SFPA also committed 163 staff-days to other food safety related engagement activities. The FSAI carried out an audit of the SFPA to assess progress on the corrective actions introduced in response to the findings outlined in the FVO Mission Report DG(SANCO) 2011-6007, which was carried out to evaluate the official food safety control system in place governing the production and placing on the market of bivalve molluscs.

9.5


Overall compliance within the sector is good


Did the programme of OC’s identify any necessary amendment to MANCP No

ANNEX: SFPA1

2010 2011 2012 2013


Manufacturers & Packers 370 396 414 799

Distributors / Transporters 62 3 15 26

Total 2572 2330 2380 2533

Table SFPA1: Number of inspections, 2010 – 2013.

2010 2011 2012 2013

High 182 199 221 203

Medium 112 129 113 74

Low 95 83 95 142

Total 389 411 429 419

Table SFPA2: Number of inspections by risk category, 2010 – 2013.

2010 2011 2012 2013

Approved Establishment 402

Aquaculture Sites 0 0 0 0

Factory & Freezer Vessels 23 0 22

Fishing Vessels 489 363 206 140

Freezer & Factory Vessels 19 15 15 22

Ice Plants 10 8 6 2

Land Based Est 370 396 414 397

Molluscan Production Areas 1,599 1,545 1,724 1,522

Other FBOs 26 0 0 0

Registered FBOs on Land 36 3 15 26

Total 2,572 2,330 2,380 2,533

Table SFPA3: Number of Inspections by business type, 2010 – 2013.

Local Authorities (LA) The local authorities are responsible for official controls in the following areas:

Low throughput slaughterhouses

Food businesses engaged in the slaughter of low volumes of poultry

Small meat manufacturing plants (SMMP’s) producing small quantities of fresh meat, minced meat, meat preparations and/or meat products

Cold stores/distribution centres

Meat transport vehicles at, or associated with inspected establishments

Wholesaling butcher shops subject to Regulation (EC) No. 853/2004. During 2013, the local authorities were responsible for carrying out official controls in 484 establishments as follows:

209 Slaughterhouses

205 Small Meat Manufacturing Plant

32 Poultry Plants

16 Cold store (animal origin no exposure)

12 Vehicle Operating without a Base Cat. I (raw and cooked meat product)

5 Cold store (animal origin exposure)

5 Butcher shops (retailers)

A total of 5,021 inspections were carried out in these establishments over the course of the year. In most cases, the local authority has one County Veterinary Officer (CVO), supported by temporary veterinary inspectors (TVIs) engaged for meat inspections in slaughterhouses. In 2013 LAs committed 73 WTE staff (not include temporary veterinary inspectors engaged in meat inspection) to official controls and food safety activities under their service contracts with the FSAI.


Number planned

The local authorities use a standard operating procedure (SOP D25) to determine the required inspection frequency for each establishment based on risk assessment. The following considerations are taken into account in this SOP:

Public health risks

Animal health risks

Animal welfare aspects where applicable

Type of processes carried out in the establishment

Throughput of the establishment

FBO’s past record of compliance with food law and the reliability of the FBO’s own checks.

The type of processes undertaken in an establishment and the nature and intended uses of its products determine to a large extent the risk to public health from consumption of those products. These factors therefore primarily determine the level of risk associated with the establishment. After the initial risk assessment of an establishment a re-assessment is carried out on an annual basis.

It is recommended that inspections of establishments should be carried out within the following range of frequencies, where the frequency is proportionate to the risk categorisation, based on the professional judgement of the CVO:

Low Risk: Between once every three months and once per month

Medium Risk: Between once every two months and twice per month

High Risk: Between once per month and four times per month

Very High Risk: At discretion of the county veterinary officer (CVO).

Completed

In 2013 there were 5,021 hygiene inspections carried out by local authority veterinary inspectors. The majority (53%) of inspections were in slaughterhouses, which account for 43% of all establishments under local authority supervision. The number of inspections per type of establishment are as follows:

Slaughterhouses 2660

SMMPs 2076

Poultry Plants 166

Comment

In addition to the above, local authority veterinary inspectors carry out sampling of food and related items as part of official control programmes linked to the production of foods of animal origin. This annual ‘National Sampling Plan’ covers all local authorities, one of which (Cork County Council through its Veterinary Food Safety Laboratory) acts in a co-ordination role.

Local authorities also participate in the national residue monitoring programme organised by the Department of Agriculture, Food and the Marine.

In 2013, a total of 1,776 samples were taken by local authorities. The majority (1,638) were routine samples.


Overall compliance

Overall compliance in this sector was generally acceptable

9.2.2.1 & 9.2.2.2


During 2013 LAs took 12 formal actions as a result of non-compliances detected during inspections.


Non-compliances included:

FBO engaged in activity outside the scope for which establishment had been approved

Deficiencies in structural and hygiene requirements

Non compliances in relation to pest proofing, pest control and cleaning and sanitation of an establishment

Bovine animal slaughtered without veterinary ante mortem inspection


Non-compliances were randomly distributed.


Non compliances found which resulted in enforcements being served were major and moderate, 80% and 20% respectively.

9.2.2.3

What was/were the root cause/s of the non-compliances identified

No data available for this.

9.4.1


Actions taken to deal with non-compliances

LAs took 12 formal, legal actions against FBOs under their supervision in 2013

9.4.2

Actions to ensure effectiveness of Official Controls (by the CA)

In order to comply with Regulation (EC) No. 882/2004 all official controls must be carried out in accordance with documented procedures. The local authority veterinary inspectorate has an established standardisation working group which has developed a number of operating procedures which inspectors use while carrying out official controls. The working group meets on a regular basis to update/amend/develop operating procedures as required. Local authorities implemented an internal audit programme relating to official controls whereby one local authority is audited by another local authority (cross-county auditing).

9.5


Overall compliance within the sector is good.


Did the programme of OC’s identify any necessary amendment to MANCP

No

Annex: LAVS1

2010 2011 2012 2013

Slaughterhouses 219 217 211 209

Small Meat Manufacturing Plant 188 200 205

Stand Alone Meat Plants 175

Poultry Plants 37 32 30 32

Cold store (animal origin no exposure)

10 10 16

Vehicle Operating without a Base Cat. I (raw and cooked meat product)

7 5 12

Cold store (animal origin exposure)

5 5 5

Other 20

Butcher Shop 3 5

Total 451 459 464 484

Table LAVS1: No. of establishments (by food chain stage)

Risk

Category 2011 2012 2013

Slaughterhouses

High 20 20 20

Medium 133 133 135

Low 31 32 33

Small Meat Manufacturing Plant

High 59 69 73

Medium 60 67 71

Low 36 39 40

Poultry Plants

High 3 3 4

Medium 11 11 11

Low 4 5 5

Cold store (animal origin no exposure)

High 0 0 0

Medium 0 1 2

Low 8 9 14

Vehicle Operating without a Base Cat. I (raw and cooked meat product)

High 0 0 0

Medium 1 0 1

Low 4 4 8

Cold store (animal origin exposure)

High 1 1 1

Medium 0 1 1

Low 2 2 2

Butcher Shop

High 0 0 1

Medium 0 2 2

Low 0 0 1

Total 451 459 464 484

Table LAVS2: No. of establishments (by risk category)

2011 2012 2013

Manufacturers & Packers 5081 4611 4902

Distributors & Transporters 73 75 97

Retailers 0 3 22

Total 5154 4089 5021

Table LAVS3: No. of inspections (by food chain stage)

2011 2012 2013

High 1,341 1,274 1,513

Medium 2,617 2,323 2,463

Low 567 490 540

Total 4,525 4,087 4,516

Table LAVS3: No. of inspections (by risk category)

The Marine Institute (MI) The Marine Institute (MI) (www.marine.ie) is Ireland’s national agency responsible for marine research, technology development and innovation. Its role is “to undertake, to co-ordinate, to promote and to assist in marine research and development and to provide such services related to research and development that, in the opinion of the Institute, will promote economic development and create employment and protect the marine environment.” Under its service contract with the FSAI, the MI is responsible for a limited range of official controls relating primarily to the sampling and analysis of shellfish and finfish. It is the Official Agency charged with providing scientific advice to the Authority and its official agencies on marine biotoxins and related issues, and in relation to the microbiological and virological safety and quality of shellfish and shellfish growing waters, and on related matters.

In accordance with Article 32 of Regulation (EC) No. 882/2004, the MI is Ireland’s National Reference Laboratory for:

monitoring for Marine Biotoxins in Live Bivalve Molluscs

monitoring for Bacteriological and Viral Contamination in Live Bivalve Molluscs

monitoring of Certain Substances and Residues thereof insofar as they apply to finfish aquaculture

The MI participated in relevant CRL organised inter-comparisons, as required.

The MI has also been designated as the competent authority and NRL “for the purposes of EU Directive 2006/88/EC in addition to conducting fish health and marine environment monitoring. These activities do not come under the scope of the Service Contract with the FSAI.

The MI is accredited to standard ISO17025. The Schedule of Accreditation applicable to the MI can be found at www.inab.ie/directoryofaccreditedbodies/laboratoryaccreditationtesting/130T-2.pdf

In 2013, the MI had 27.4 WTE staff allocated to delivering official controls under the Service Contract.

http://www.inab.ie/directoryofaccreditedbodies/laboratoryaccreditationtesting/130T-2.pdf

MANCP Section

Title Information


Shellfish sampling

o Shellfish Chemistry

o Shellfish Residues (BIPs)

o Biotoxin Bioassay

o Biotoxin Chemistry

o Microbiology of Shellfish (E. coli analysis)

Finfish

o Residues

o Chemistry: Port

Phytoplankton Sampling

Completed

A detailed breakdown of the sampling completed by the MI is included in Annex MI1

Comment

The MI also tests shellfish for the presence of Norovirus.


Overall compliance

The Marine Institute carries out official control activity in a limited number of food business operators. The results of this activity are reported to other competent authorities, such as the SFPA, who may use it to assess compliance in the aforementioned food businesses.

9.2.2.1 & 9.2.2.2










Actions taken to ensure improved compliance by Food Business Operators (FBOs) during 2011

The Marine Institute is not involved in assessing compliance among FBOs

9.4.1


Describe, giving the number of the various types of enforcement action deployed such as verbal warning, written notice, fixed penalty notice, restriction, premises closure, seizure/detention of animals or product, prosecution Actions taken to deal with non-compliances



The MI completed 83 staff days of training under the Service Contract. This was spread between 67 different events of varying duration. A further 107 staff days were committed to prepare, participate and follow-up on audits. The MI staff participated in 32 internal audits, 1 FVO audit, and 1 Irish National Accreditation Board (INAB) audit.

9.5




Did the programme of OC’s identify any necessary amendment to MANCP

No

Annex: MI1 - Sampling & Analysis

Sampling & Analysis activity - Shellfish

Analysis Type No. of Samples

Taken No. of Samples

Analysed No Of Results

No. of Compliant Samples

No. of Non-compliant Samples

Routine

Shellfish Chemistry

98 98 2528 98 0

Biotoxin Chemistry

Lipophilic Toxins

3069 3069

DSP Group 2474

2775 294

AZP Group 2450

PTX Group 1912

YTX Group 1637

ASP 1631

PSP 292

Microbiology Shellfish

Microbiology Shellfish (E. coli analysis including sub

contract testing)

1559 (E.coli testing including

subcontact testing)

1559 1559 Classification controls based on

E.coli levels

Non Routine

Shellfish Chemistry

0 0 0 0 0

Biotoxin Chemistry

Lipophilic Toxins

358 358

DSP Group 318

AZP Group 320

PTX Group 209

YTX Group 200

ASP 73

PSP 138

Virology Shellfish

Norovirus 151 151 151

38 negative for the

presence of norovirus.

113 positive for the presence of

norovirus.

Sampling & Analysis - Finfish

Analysis Type

No. of Samples Taken

No. of Samples Analysed

No. of Tests No. of

Compliant Samples


Routine

Residues 137 137 (651

samples sub divided)

16 tests (1494 results)

137 0

Chemistry: Port

33 33 12 tests (741

results) 33 0

Non Routine

Residues 15 15 6 tests (37

results) 14 1

Chemistry: Port

0 0 0 0 0

Sampling & Analysis - Water

Analysis Type No. of

Samples Taken

No. of Tests No. of

Compliant Samples


Phytoplankton Routine 2916 2777 2732 45

Non Routine 111 111 111 0

The National Standards Authority of Ireland (NSAI) The National Standards Authority of Ireland (NSAI) is Ireland’s official standards body. It operates under the National Standards Authority of Ireland Act 1996 and provides a certification service to enable businesses to demonstrate that Irish goods and services conform to applicable standards. NSAI is also an official agency of the FSAI. The NSAI has a focused role in official controls of food, reporting the use of just 1.1 whole-time equivalent of inspector resource devoted to the service contract activities in 2013. NSAI inspects and certifies suppliers of natural mineral water (NMW), of which there were four in Ireland operating five boreholes. The NSAI operates a quality management system certified to ISO 17021. Each supplier is inspected as part of this programme, with 12, 11, 9 and 11 inspections in 2010, 2011, 2012 and 2013 respectively. In 2013, the NSAI recorded 15 infringements against the requirements of 2009/54/EC, 2003/40/EC and NSAI issued Conditions for Exploitation against the requirements of S.I. 225 of 2007. Eight samples were taken for microbiological analysis, with 1 infringement detected, and subsequently closed out. Eight samples were taken for chemical analysis, with no (0) infringements detected. No complaints were received. The NSAI also carried out 78 Food Contact Material (FCM) Inspections in 2013, and took 18 FCM samples (ceramics) under its service contract with the FSAI.

national control plan - fsai

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