The European Commission’s Health and Safety Unit has published findings from two evaluations looking at fish controls in Mexico and Belgium.
An audit by DG Sante in Mexico in November 2022 assessed the systems covering checks on fishery products exported to Europe.
The auditors found that although the official control system covers the entire production chain and is managed by an authority with the necessary powers and resources, its effectiveness is hampered by several weaknesses in critical areas.
Since January 2018, three Rapid Alert System for Food and Feed (RASFF) reports have been issued for tuna products from Mexico due to histamine, mercury and cold chain issues.
Ensuring safe exports
One of the problems is that the national legal framework does not cover all EU requirements. This means that practices are accepted because they comply with national regulations, but not EU rules.
Differences include limits for cadmium and lead and sampling requirements for histamine that differ from EU rules. Freezing and temperature requirements are also different.
The auditors found that officials did not have sufficient knowledge to perform several control tasks correctly or effectively. Deficiencies in maintaining the list of EU-approved establishments and laboratory indicators were also identified.
Inspectors and certifying officers from the State Commissions for the Protection of Sanitary Risks (COEPRIS) showed adequate knowledge of food safety, but not EU rules. The staff of the Federal Commission for the Protection of Sanitary Risks (COFEPRIS) were familiar with the EU rules, except for the latest amendments to the legislation. However, they did not demonstrate the skills and knowledge needed to evaluate the freezing process.
“These shortcomings undermine both the reliability of the official control along the production chain and the confidence that can be had in the truth of the assurances given in relation to the EU requirements contained in the official EU certificate. As a result, an incorrectly certified product was exported to the EU,” the audit report said.
In response to 11 recommendations, Mexican authorities proposed a range of actions, including training, updated manuals and documents, and working with operators to meet EU requirements.
The audit in Belgium in November and December 2022 found that the organization and operation of official controls were generally effective.
However, some elements undermine the reliability of the system. These include allowing several firms to manufacture with the approval of another operator and granting approval to factory ships without the operators being able to demonstrate compliance with all legal requirements as they are not required to have HACCP-based procedures in place even though they cook shrimp and produce ready-to-eat (RTE) foods.
Auditors said official sampling procedures and related actions taken after these inspections can allow food products to be placed on the market despite non-conforming results.
There have been five recent RASFF alerts on fish products from Belgium, with three in 2020 and two in 2021. These include incorrect expiry dates, dioxins and Listeria in prawns.
Auditors found that the enforcement system meant that less serious non-compliance was at the discretion of operators. They said this could have the effect of fixing possible multiple or minor problems and preventing them from reoccurring.
In auction halls, some unsanitary practices endanger food safety, such as placing containers of fish products directly on the floor, frequently moving them through pools of water, and stacking containers on top of each other, resulting in contamination of the product, during loading and transportation, according to the report.
Sampling procedures for microbiological criteria state that inspectors initially take one sample instead of the five required by the EU regulation. In addition, the follow-up procedures specify that if any subsequent test after an initial finding of non-conformity gives a compliant result, all measures imposed on the relevant lot shall be lifted and the products may be placed on the market.
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