MANCP Multi Annual National Control Plan
Annual Report 2014
1 Contents
Executive Summary of the MANCP Annual Report 2014 2
Chapter 1 Introduction 11
Chapter 2 Description and developments in the organisations involved 12
Chapter 3 Enforcement in the food chain 17
Chapter 4 Reports on areas of supervision in 2014 20 4.1 Introduction 20 4.2 Animal health – monitoring and control 21 4.3 Animal health – prevention 26 4.4 Animal welfare 31 4.5 Animal feed 37 4.6 Animal by-products 41 4.7 Meat chain 43 4.8 Meat products 47 4.9 Imports of veterinary consignments 50 4.10 Composite products 53 4.11 Fish, fish products and aquaculture 56 4.12 Dairy, eggs and egg products 60 4.13 Hotel/restaurant/catering and artisanal production 64 4.14 Know what you are buying 68 4.15 Contaminants, residues and GMOs in food 70 4.16 Microbiology 76 4.17 Nutrition and health/special food and drink 79 4.18 Plant health 84 4.19 Plant protection 87 4.20 Organic products 91 4.21 Geographical protection: PDO, PGI, TSG 93
Chapter 5 Audits 97
Chapter 6 NVWA Intelligence and Investigation Service (IOD) 102
1 Executive Summary of the MANCP Annual Report 2014
This Multi Annual National Control Plan (MANCP) Annual Report is the eighth annual report on the Netherlands’ organisation and implementation of official controls on animal health, animal welfare, food and feed safety and plant health. The first MANCP annual report was drawn up in 2007. The most recent MANCP, the plan for the 2012-2016 period, was drawn up in 2011. On the publication of this report, the Netherlands has fulfilled its obligation to publish an annual report pursuant to Article 44 of the Control Regulation (EC) No 882/2004.
1 Developments
NVWA improvement plan The objective of the improvement plan is to achieve the structural improvement of the NVWA’s supervision required to equip the Authority for its tasks in an adequate and future-resilient manner. The improvement plan consists of four parts: 1. Certification and Supervision This relates to a review of the organisation of the certification and supervision system. 2. Enhancement of the enforcement capacity This relates to the strengthening of a number of weak points resulting from insufficient capacity. 3. Improvement of the effectiveness of the organisation Structural improvements will be made to the quality and effectiveness of the service to enhance the NVWA as an organisation. 4. Financing The implementation of the improvement plan will be supported by structural additional contributions from both the Ministry of Economic Affairs and the Ministry of Health, Welfare and Sport, as well as from the business community.
Food Confidence Task Force This Task Force was set up in March 2013, in response to the horse meat fraud at the beginning of 2013 that had revealed the need to implement firm measures to prevent the recurrence of incidents of this nature. The Task Force’s objective was to agree on measures designed to increase consumer confidence in food. The Task Force completed its work at the end of January 2015, and was then abolished. The most important result was the introduction of stringent criteria governing private quality systems. These criteria now enable the NVWA to ‘accept’ quality systems and use them as a source of information when performing its public supervision. The stringency of the procurement terms and conditions has been increased and harmonised with international umbrella systems, such as the British Retail Consortium (BRC) and International Food Standard (IFS), for which purpose agreements have been reached within the Global Food Safety Initiative (GFSI). What is referred to as a ‘fraud module’ is being developed within this context. Wageningen University & Research centre (WUR), RIKILT and the Dutch business community are involved in the development of this module. Food establishment operators will adopt this module in their quality systems when imposing requirements on suppliers that will provide assurances for food integrity and traceability. Although progress has been made and results have been achieved, changes can only really be made when all businesses in the sector actually assume their responsibility for the safety and integrity of their products. Chain liability will then be essential. A number of international chains have already adopted chain liability and the Dutch sectors are expected to be prepared to follow this example. The greatest challenge lies in the change in the behaviour and culture of the relevant sectors.
Abolition of the product boards The product boards were abolished on 1 January 2015. The public supervision duties in the animal and vegetable sectors that were assigned to the product boards were taken over by the NVWA and the Netherlands Enterprise Agency (RVO). The NVWA is responsible for the physical controls, supervision and enforcement of the duties assumed by the Authority. The RVO is responsible for the administrative control and implementation.
2 2 Effectiveness of controls
The NVWA makes continual improvements to its risk-oriented enforcement strategy in all areas of its supervision. This is also an element of the NVWA’s improvement plan (see above). As the majority of the controls are managed by one central authority, new inspection strategies developed at the central location become available for all areas of supervision. Laboratory capacity for analyses has also been centralised, resulting in one laboratory for food safety, one laboratory for phytosanitary analyses and two laboratories for product safety. The introduction of administrative fines – for the Animals Act, in 2013 – has improved the effectiveness of controls, in particular in the event of non-compliance, and has greatly accelerated the enforcement process. Although insufficient qualitative indicators are currently available to compare the actual effectiveness of the controls with the targets, the first pilot trials with kebab in the hotel/restaurant/catering sector and hygienic slaughter in the meat sector have demonstrated that the use of indicators does yield quantifiable results. This procedure will be developed further.
3 Key data
No. of inspections 2010 2011 2012 2013 2014 Identification and registration (I&R) 3,708 2,961 2,515 2,521 2,316 Animal heath - prevention 8,641 10,858 7,231 7,340 6,951 Animal welfare during transport 13,378 14,129 11,993 10,240 9,359 Animal feed 981 1,156 2,031 1,564 1,127 Animal by-products 6,668 5,936 5,712 4,307 3,655 Meat 1,803 2,883 2,320 3,022 2,772 Meat products 1,866 3,039 2,016 1,874 2,075 Imports of live animals and animal products 61,596 59,159 59,022 60,938 Industrial production (composite products) 3,340 3,871 5,502 5,361 3,274 Milk and dairy products 1,006 991 993 784 930 Egg sector 1,407 1,064 872 1,028 830 Hotel/restaurant/catering and retail 44,563 44,972 29,578 30,220 36,403 Labelling 1,050 422 178 80 168 Claims for foods for particular nutritional uses 2,207 1,350 1,865 1,734 1,862 Residues and contaminants in food 2,500 3,787 2,090 3,860 7,529 Veterinary medicines 952 689 2,502 1,156 620 Microbiological samples 26,897 18,209 15,184 Plant protection products 2,691 1,652 1,143 1,296 868 Organic products 5,069 5,258 4,064 4,878 4,908 Total 195,439 180,419 178,164 159,245 161,769
Certifications (in hours) 2010 2011 2012 2013 2014 Meat 188,727 186,787 203,345 273,425 281,747 Fish 9,918 4,596 9,352 8,982 10,070
Plant health inspections No. of inspections 2012 2013 2014 Results for arable agriculture 38,756 34,752 36,696 Results for fruit and vegetables 101,050 124,379 117,768 Results for ornamental horticulture 177,052 181,854 184,068 Results for tree nurseries and green spaces 14,161 14,146 13,971 Total 331,019 355,131 352,503
3 4 Findings and analysis of non-compliance in 2014
Animal health – monitoring and control • At the beginning of 2014, polymerase chain reaction (PCR) tests carried out at two laying hen farms tested positive for low pathogenic avian influenza (LPAI): H5N1 and H5N2. In November 2014, high pathogenic avian influenza (HPAI) was encountered at five farms, namely three laying hen farms, one farm with ducks for slaughter and one broiler parent stock farm (H5N8 in all cases). All these farms were depopulated. Three farms were also preventively depopulated due to their contact with or location within a 1-km radius of an infected farm. • Outbreaks of American foulbrood afflicted four bee colonies. • The inspections of milk collection containers demonstrated a new infection with Q fever at one dairy goat farm. This farm had not previously been infected. • The tuberculosis control programme revealed that the majority of the suspected cases and the five confirmed cases of tuberculosis related to contact animals that originated from infected cattle farms in Ireland.
Animal health - prevention • The I&R of Equidae continues to be a source of concern, as fraud involving horse passports leads to food safety issues. • It has transpired that the guarantees within the QLL (quality system livestock logistics) are insufficient to provide the necessary assurances for the system. This resulted in the withdrawal of the authorisation of the system and the associated supervision modalities on 1 March 2014. New quality systems were submitted for assessment at the end of 2014.
Animal welfare • Compliance during animal transport remains a general point for concern. The percentage of non-compliances increased further from 16% in 2012 to 20% in 2013 and 24% in 2014. This is largely the result of undertaking more risk-specific inspections. • Adequate room for the animals to move and the permanent availability of adequate materials to pigs to enable them to exhibit their natural behaviour, such as exploration and play. • Compliance in the broiler sector is inadequate and the compliance level will need to be increased in the coming years. • The primary establishments’ compliance with the rules governing calf welfare is generally good. Non-compliance is, in particular, identified at dairy farms and primarily relates to the prohibition on tethering calves and non-compliance with the conditions attached to individual pens (sufficient width and perforated walls). • In 2014, the NVWA maintained the level of its efforts to tackle animal neglect. Inspections are carried out in response to reports and establishments warranting attention are subjected to proactive monitoring. An intensive inspection regime governs establishments where severe animal neglect is identified. In addition, more attention is now devoted to the provision of information to professionals entering farms.
Animal feed • The general compliance of animal feed establishments is high (> 90%). • The sector responds to incidents by assuming the responsibility for traceability and the prevention of further dispersion. • Issues that still require attention are general hygiene management, carry-over/cross-contamination, hazards, risk analysis and traceability. In addition, attention continues to need to be devoted to labelling and the correct use of claims.
Animal by-products • The general compliance with the basic conditions attached to authorisation and registration is reasonable to good, although specific types of establishment, such as trading and storage establishments, do exhibit scope for improvement. However, the situation is not as good with respect to the introduction and implementation of Hazard Analysis and Critical Control Points (HACCP) and in-house inspections at establishments. This is a continuing issue for attention. • A large proportion of the non-compliance relates to the traceability of the materials and products. Projects carried out on processed animal proteins and fats have revealed that the traceability of the materials is a problem. The business community strives to obscure the traceability of processed animal protein, in particular, for as far as is possible in connection with illegal exports of ruminant protein to countries outside the EU.
4 Meat • The horse meat affair resulted in the performance of compulsory traceability and labelling system inspections at all types of establishment. 115 infringements were observed during these inspections. This resulted in ten written warnings, thirteen verbal warnings and one fine report. • The most serious incident related to a cattle slaughterhouse where the raceabilityt of the meat was not in order, the origin of the meat could not be demonstrated clearly and, as a result, food safety could not be guaranteed. The EC authorisation of this establishment was suspended for two months.
Meat products Inspections of meat product establishments are carried out pursuant to a risk-oriented approach. Establishments are classified into risk categories on the basis of non-compliances identified in the recent past and the magnitude of the risks at the establishments. This risk-oriented inspection approach was continued in 2014. Measures were taken in accordance with the intervention policy both during the inspections and audits. The ratio of the number of interventions to the number of audits and inspections fell in 2014 to 16% (2013: 18%). It is striking to note that the number of interventions has declined whilst the number of establishments classified in the poorest risk categories has risen.
Imports of live animals and animal products • The supply of consignments of imported veterinary goods is stable, with fluctuations in supply of less than 5%. The number of refusals is mainly caused by problems with documentation and subjection of consignments to more stringent supervision. • In 2014, specific attention was devoted to passenger baggage from areas in which Ebola is prevalent. This did not result in any special findings.
Industrial production – composite products • A new method for the supervision of traceability was developed in 2013. This new method has led to an increase in the number of identified non-compliances from 6% in 2012 to 17% in 2013. In 2014, the percentage of traceability interventions was once again 17%, which indicated a stabilisation in the percentage of non-compliances. • In 2014, specific attention was devoted to the bulk transport of foods in liquid, granular or powder form. 30 establishments were visited during this project: measures were taken when it transpired that the relevant tanks were not used exclusively for food transport.
Fish and fish products • Official controls carried out in the fish and fish processing industryn ofte reveal the need for interventions. For this reason, the inspection capacity for these official controls was expanded in 2015. • Chemical analyses of histamines, pesticide residues and antibiotics in imported fish did not reveal any need for the imposition of measures. The presence and growth of Listeria monocytogenes in smoked fish remains an issue that requires attention. • Infringements of food safety requirements and the presence of Norovirus are being reported in the mollusc and crustacean sector. This situation resulted in the development of a robust analysis method for the presence of Norovirus in cooperation with the National Reference Laboratory (NRL) and EU Reference Laboratories (EURL). This work has now been completed. The Netherlands has submitted a proposal to the European Commission for the introduction of standards for Norovirus levels in molluscs and crustaceans that are consumed raw.
Dairy • In 2014, compliance at the majority of dairy establishments was of an adequate level. However, the microbiological quality of ice cream remains an issue which requires attention. • In 2014, the increasing interest in products prepared from goat’s and/or sheep’s milk gave cause to the extension of the supervision processors of goat and/or sheep dairy products to include specific attention to the possible blending of cow’s milk during the preparation of these products. The results at two of the 56 establishments that were inspected gave cause to the issue of a fine report.
Eggs and egg products • The supervision of the package of hygiene measures in the egg sector has revealed a general high degree of compliance with the prevailing instructions. • 47 reports of Salmonella infections were submitted to the Dutch controlling authority for eggs (Nederlandse Controle
5 Autoriteit Eieren, NCAE) in 2014. NCAE supervised the correct channelling of these eggs to the egg product producers. • Three reports of transgressions of the dioxin limit in eggs were submitted. Fine reports were issued in two instances because of the failure to issue the authority prompt notification of amounts above the maximum level.
Hotel/restaurant/catering and artisanal production • In 2014, 32% of the inspections resulted in the imposition of a measure. 7% of the inspections identified a serious infringement (6.9% in 2013) and 25% an infringement (26.7% in 2013). The majority of the infringements related to temperature control in combination with the correct handling of food, in particular in the storage and presentation phases, as well as during the cleaning and disinfection of food (hygiene) and vermin. • The formula approach has proved to be an efficient system of supervision in which establishments that operate under a formula and have implemented control systems exhibiting an adequate performance are visited less frequently by the NVWA. In 2014, this approach was expanded further on refraining from carrying out monitoring inspections at establishments operating under a formula exhibiting an appropriate performance.
Know what you are buying Although the NVWA had not scheduled a specific labelling project in 2014, food safety inspections carried out during the year did reveal non-compliances in the labels on foods. In 2014, measures were taken in a total of 113 labelling cases (92 warnings and 21 fine reports).
Contaminants, residues and genetically modified organisms (GMOs) • As 10% of the samples of food, in particular of peanuts, figs and nutmeg, tested positive for mycotoxins, this issue continues to require attention. • Heavy metals were found in 2 consignments of wild mushrooms. • A survey of acrylamide in a number of product categories listed in Commission Recommendation 2013/647/EU did not reveal any transgressions of the limits. • More than 5,200 samples were found to contain approximately 10,600 residues of 187 different pesticides. A large number of samples of fruit and vegetables from Asia did not comply with the standard. In addition, a considerable proportion of the products from the Dominican Republic (19%), Suriname (13%) and Egypt (11%) did not comply with the statutory requirement. • In 2014, eleven consignments of rice from China were examined for the presence of non-authorised genetically modified organisms (GMOs), one consignment of which tested positive. Following a Rapid Alert System for Food and Feed (RASFF) notification of non-authorised GMO papaya from Thailand, five consignments were sampled at Amsterdam Airport Schiphol at the beginning of 2014. All samples tested negative. Five samples of food supplements containing papaya tested positive for a non-authorised GMO. The regular monitoring of foodstuffs for failure to report the presence of an authorised GMO in a product revealed only three non-compliances.
Veterinary medicines • The detection of prohibited substances, such as clenbuterol in 2014, gives cause to the need to devote continued attention to the presence of these substances on the basis of monitoring or targeted sampling. In a number of cases discussions are continuing on the possibility that these substances could occur in nature. • Attention is being given to the restrained and prudent use of antibiotics. The intensity of controls for antibiotics residues will be maintained at the current level. These residues can be indicative of unauthorised or imprudent use. • Furazolidone, a prohibited substance, was detected in animals at a number of cattle farms in 2014. The trail of furazolidone lead back via the animal feed to an animal feed producer. A total of some 7,500 animals at seven cattle farms were removed and culled. The animal feed producer’s registration was suspended. A criminal investigation is in progress.
Microbiology • The number of RASFF and General Food Law (GFL) notifications with a microbiological cause continues to increase. The stricter application of the rules on notification throughout the chain has given rise to a sharp increase in the number of GFL notifications. • In 2014, great efforts were made in the monitoring of shiga-toxin-producing E. coli (STEC). A total of about 900 samples of foods were examined for the presence of STEC. These foods included vegetables and vegetable sprouts, cheese, herbs and spices and meat. It transpired that it is still difficult to isolate STEC after a positive PCR screening.
6 Nutrition and health, special food and drink • The objective of the compliance policy for special food and drinks is both to promote compliance by the parties that are inspected and to fulfil an agenda-setting function for the relevant stakeholders. • The NVWA has been monitoring progress in the reduction of the salt content of foods by sampling and analysing ten food product groups every year since 2011. In 2014, the NVWA sampled a total of 1,101 products from various product groups and determined the common salt contents. The analyses revealed that there were great discrepancies in salt content between products of the same product type. • The NVWA carried out an investigation of the degree of compliance with food legislation (medical claims, banned herbs/spices, novel foods and health claims) at web shops that trade in special food and drink during the period from June 2013 to the end of February 2014. In 13% of all instances, the minimum information required about the trader and the web shop was absent, not displayed correctly or incomplete.
Plant health • In 2014, the number of Dutch interceptions of quarantine pests during inspections of imports from third countries increased from the number in 2013. The number of identified imported goods documentation errors declined further in 2014 to almost half the level in 2011. • The number of live organisms that are found and the fact that wood packaging materials from Asia regularly lack the correct marks illustrate that wood packaging materials still pose the greatest threat to the green spaces in the Netherlands. For this reason, the Netherlands and China are working on a joint pilot trial project on the increased control of the use of correctly marked wood packaging materials.
Plant protection • The number of culpable infringements with ornamental plants grown under glass, flower bulb production and the use of drift reduction measures in open fields near surface water in various target groups is relatively high. • Obtaining and maintaining an insight into the trade flows of pesticides continues to be of importance to the Authority’s ability to intercept unauthorised products as early as possible in the chain (imports, transit, internet).
Organic products • Once again, the majority of the organic establishments complied with the statutory requirements in 2014. • Incidents with sunflower press cake as an organic animal feed were recorded in 2014, and the certification of a butcher and importer was suspended.
Geographical Indication: PDO, PGI and TSG Additional attention needs to be devoted to the use of the correct designation of cheese with a protected designation of origin (PDO), protected geographical indication (PGI) or traditional specialities guaranteed (TSG) status. This is applicable to Noord-Hollandse Gouda cheese, Noord-Hollandse Edam cheese and raw milk cheese (Boerenkaas). It has been decided that the stringency of the supervision will be increased. This is also applicable to the fat content in the dry matter of Boerenkaas and Boeren-Leidse met sleutels PDO. The attention devoted to Noord-Hollandse Gouda and Noord- Hollandse Edam will focus on the moisture content of these types of cheese.
5 Actions taken on non-compliance control measures* 2009 2010 2011 2012 2013 2014 Written warnings 6,621 10,258 8,266 11,279 13,468 12,020 Administrative fines and official reports 1,756 2,640 2,216 2951 3,322 3,680
* Total number of warnings, fines and official reports listed in Chapter 4.
In addition to imposing administrative fines, the NVWA also imposes administrative measures including cease and desist order under penalty, administrative enforcement order, placement under supervision, intention to close down, close down order, official seizure order, penalty payment and ship supplier order: Intention to close down: 87 Intention to shut down process: 87 Intention to prohibit trade in foods: 36 Measures in the veterinary area: 116 Administrative measure for sanitary monitoring: 29 Total number of administrative measures in 2014: 555 7 6 National audit systems
Pursuant to the Control Regulation (EC) No 882/2004, the NVWA’s Internal Audit Branch conducts internal and external audits to assess the effectiveness of official controls. These internal audits are conducted annually to verify the accreditation of the laboratories, the national reference centre, the fish inspection teams and the Border Inspection Posts. In 2014, additional audits were conducted of the identification and registration (I&R) control of sheep and goats, the hotel/restaurant/catering teams, the TRAde Control and Expert System (TRACES), the Risk Plaza and the export certification by the Netherlands Controlling Authority for Milk and Milk Products (Centraal Orgaan voor Kwaliteitsaangelegenheden in de Zuivel, COKZ). In 2014, the external audits addressed the Animal Sector Quality Inspection Foundation (KDS), COKZ and vegetable inspection services.
7 Budget/resources
The following table lists the available budget and staffing levels for the relevant control agencies. resources in 2014 budget (EUR 1000s) staff (FTE) resources in 2013 budget (EUR 1000s) staff (FTE) NVWA 306,000 2,281 NVWA 278,000 2,181 COKZ / NCAE 7,839 52 COKZ / NCAE 7,796 52 NAK 22,965 194.7 NAK 27,349 197.8 Naktuinbouw 25,251 252 Naktuinbouw 24,650 250 BKD 8,509 99 BKD 8,400 115 KCB 14,510 137 KCB 12,147 137 GD 54,766 428 GD 57,104 497 Skal 3,403 32.1 Skal 3,146 31
8 Actions taken to improve the official controls
Animal health A basic training course has been set up for animal disease specialists. A field exercise has also been organised for the members of the front teams. The front teams were confronted with a scenario in which an outbreak of African swine fever was accompanied by a rapid sequence of unannounced occurrences. Two refresher days were organised for the animal disease specialists, one of which focused on Q fever, African swine fever and the new handling suspected animal diseases and zoonoses scenario and the second on assessment, low pathogenic avian influenza, psittacosis and tuberculosis (TB). The NVWA’s Veterinary Incident and Crisis Centre (NVIC) received several groups of final year veterinary science students and informed them about relevant animal disease control issues and the notification obligation.
Animal welfare In 2014, a new supervision subject was developed within the context of the NVWA Improvement plan. This ‘new style’ supervision was introduced at all ungulate slaughterhouses during the course of the year. The new form of supervision entailed the introduction of new, abbreviated animal welfare checklists that replaced the regular checklists. These welfare controls are carried out at a frequency which is dependent on the risk profile of the relevant slaughterhouse. This profile is in turn dependent on factors including the size of the establishment and past infringements, where relevant. Ritual slaughtering without pre-stunning is also taken into account in the risk profile. The frequency ranges from 4 to 24 controls a year, increased by any re-inspections, where relevant. In addition, daily ‘operational’ checklists are completed daily at the larger slaughterhouses with permanent supervision.
8 Meat The Meat chain improvement plan was launched in 2014. Two teams, a design team and a uniformity team, were formed for the implementation of this plan. The design team drew up a risk-oriented supervision model for small and medium-sized farm animal slaughterhouses that encompassed the supervision of issues including animal welfare, hygienic slaughter and animal health aspects. The uniformity team tested this supervision model in practice and supervised its introduction. In 2014, all farm animal slaughterhouses with permanent supervision were brought under this supervision model. Specific attention was devoted to four large calf slaughterhouses, where intensive enforcement was required to improve hygiene to acceptable levels by controlling faecal contamination.
Microbiology The laboratory works constantly on keeping the available analysis methods (development and validation) up to date. In 2014, this work included the further optimisation of a PCR method for STEC. Work also began on the Whole Genome Sequencing of Salmonella Heidelberg strains with the objective of accelerating the tracing of the source of outbreaks.
9 Actions taken to improve the compliance of the business community
Animal welfare One of the important elements of Regulation (EC) No 1099/2009 relates to the development of guides to good practice by organisations of operators of establishments. These guides lay down operating and monitoring procedures to be followed when killing animals, thereby providing proper guidance on animal welfare for establishment operators. In 2013 and 2014, the business community developed a guide to good practice to protect the welfare of poultry at poultry slaughterhouses from the time they arrive at the slaughterhouse grounds until the time they are slaughtered (poultry slaughterhouse welfare guide). Following consultations with the NVWA this guide was implemented in September 2014. The guide will be evaluated after one year and will then be made final. Work on the guide to good practice for small ungulate slaughterhouses has also reached an advanced stage. The implementation of this guide is scheduled for 2015. In 2012, a broad representation from the business community, banks and government organisations signed the identification of animal neglect (signalering dierenverwaarlozing) covenant. Professionals entering farms, in cooperation with the confidential help desk for farm animal welfare (Vertrouwensloket Welzijn Landbouwhuisdieren), are now focused on prevention, timely identification and provision of assistance. When this fails to achieve the required result then the NVWA is called in. The confidential help desk for farm animal welfare has received about 45 notifications from professionals entering farms a year since the covenant was signed in 2012. In 2014, ten of these cases were passed on to the NVWA. This number is relatively low, in part in view of the number of neglect cases the NVWA identifies during its regular supervision and the total number of notifications from members of the public. The NVWA provides specific information to increase the awareness of professionals entering farms.
Meat products In 2014, the NVWA drew up a draft information brochure to clarify the NVWA’s interpretation of the statutory regulations governing mechanically separated meat (MSM) for the sector. In 2015, the NVWA will adopt the final content of this information brochure and publish the brochure on its website for the establishments that produce and process MSM.
Imported veterinary products Supd@x (the Supply Chain Data Exchange) was introduced for the supervision of veterinary consignments at the Port of Rotterdam in 2013. This simplifies exchanges of data between the public authorities’ various declaration and notification systems. Supd@x also arranges for the provision of status information on controls (by the NVWA and Customs) to the relevant public authorities and responsible business community. The introduction and completion of the original Supd@x veterinary business case has played a major role in optimising the supervision of the veterinary import chain. Supd@x veterinary also marks a first step towards the Single Window Trade & Transport (SWH&T) system in the Netherlands. Work has also been carried out on the development of the National Inspection Terminal (RIT). The objective is then to create a one-stop shop where a number of government agencies can inspect a consignment simultaneously at one location.
9 Composite products – Industrial production The controls of bulk food transports gave cause to the revision of the information brochure on bulk transports at the end of 2014. In the most important revision, not only food of vegetable origin but also food of animal origin may now be delivered to non-food establishments solely in ‘reserved for foodstuffs only’ tanks.
Fish products In 2014, the Dutch fish auctions implemented the hygiene code that was approved by the Minister of Health, Welfare and Sport in 2014.
Hotel/restaurant/catering The NVWA began to disclose its inspection reports on lunchrooms in 2014. All lunchrooms can be awarded a rating of green, orange or red. Establishments that are awarded a green rating on what is referred to as the Hotel/restaurant/ catering inspection sheet have a kitchen where food is processed safely and where the hygiene and vermin control are in order. A kitchen is awarded an orange rating when an inspection reveals one or more non-compliances. A lunchroom will not immediately be awarded an orange rating for minor non-compliances. The rating awarded to the lunchroom will remain or become green when the proprietor demonstrates, within a reasonable time, that the non-compliance has been rectified. A lunchroom is awarded a red rating when there are structural problems with hygiene, food safety or vermin. The establishment will then be subjected to more stringent NVWA supervision. A lunchroom that has not been inspected in the previous year is awarded a white rating. Proprietors can complete a ‘safe food declaration’ on the NVWA site to be awarded a green rating on the sheet. The lunchroom is then inspected to verify that the declaration was completed truthfully. The report on the lunchroom with the colour rating on the inspection sheet is published within a few weeks. Pursuant to this approach, lunchrooms can ‘’fly their colours’. Consumers can use the hotel/restaurant/catering inspection sheet (Horeca inspectiekaart) app on their iPhone or Android device to find out which lunchrooms have been awarded a favourable score for issues including hygiene. The inspection sheet was drawn up in close cooperation with the Dutch association for the restaurant, hotel and catering industry (Koninklijke Horeca Nederland, KHN). The app offers consumers a simple means of reviewing a lunchroom’s score for food safety before buying a sandwich. Consumers can also use the app to give notification of potentially unsafe food products so that the NVWA can take the appropriate action, where relevant.
Healthy food and special food and drink • In 2007, the Dutch Food Industry Federation (FNLI) set up the Task Force Salt in Food to promote the reduction of salt in industrially prepared foods. The Task Force drew up an action plan designed to achieve an ultimate salt reduction of 20-30% in a wide range of foods. • The Task Force Responsible Fatty Acid Composition – a collaborative arrangement between establishments in the industrially processed vegetable oils and fats sector – has been working on improving the composition of fatty acids in foods containing vegetable oils and fats since 2005. The industrial and artisanal bakery sectors are also represented in the Task Force.
10 NVWA Intelligence and Investigation Service (IOD)
The NVWA IOD works in all fields of relevance to the NVWA. The NVWA IOD is deployed in the event of serious or systematic infringements of the law in the NVWA’s enforcement domain. The NVWA IOD then focuses primarily on complex, chain-related, organised and international criminality. The core tasks of the NVWA IOD are: • collecting and refining intelligence; • carrying out analyses to improve insights into the nature and extent of compliance and non-compliance; • conducting investigations on the basis of a wide range of powers.
In 2014, the investigations addressed the following subjects: • meat scams, such as the false labelling of horse meat • manure fraud • illegal trade and internet trade in protected animals and/or plants • animal welfare transgressions violations during transport • fraud in the certification of attractions • trade in products not intended for human consumption
10 CHAPTER 1: Introduction
Pursuant to the European Official Control Regulation (Regulation (EC) No 882/2004), as from 1 January 2007 all Member States are required to draw up a Multi Annual National Control Plan (MANCP). An annual report on the implementation of and results from this plan is submitted to the European Commission. This report is the annual report for 2014.
The MANCP annual report reviews the official controls in the areas of food safety, animal health, animal welfare, animal feeds, phytosanitary issues and organic production. In the Netherlands, the following organisations are involved in producing this report: • Supervision under Regulation (EC) No 882/2004: -- The Netherlands Food and Consumer Product Safety Authority (NVWA) -- The Netherlands Controlling Authority for Milk and Milk Products (Centraal Orgaan voor Kwaliteitsaangelegenheden in de Zuivel, COKZ) -- the Dutch controlling authority for eggs (Nederlandse Controle Autoriteit Eieren, NCAE) -- GD Animal Health (GD) • Supervision within the scope of Directive 2000/29/EC (plant health) in the Netherlands is conducted by: -- The Netherlands Food and Consumer Product Safety Authority (NVWA) -- NAK, the Netherlands General Inspection Service for agricultural seeds and seed potatoes (Nederlandse Algemene Keuringsdienst voor zaaizaad en pootgoed van landbouwgewassen) -- NAKtuinbouw, the Netherlands Inspection Service for Horticulture (Stichting Nederlandse Algemene Kwaliteitsdienst Tuinbouw) -- the BKD, the Flower Bulb Inspection Service (Bloembollen Keuringsdienst) -- the KCB, the Quality Control Bureau (Kwaliteits-Controle-Bureau) • Supervision within the scope of Regulation (EC) No 834/2007 (organic production and products) in the Netherlands is conducted by: -- Skal Biocontrole (Stichting Skal biocontrole).
The NVWA is responsible for the coordination of the MANCP in the Netherlands. The first MANCP was submitted to the European Commission’s Food and Veterinary Office (FVO) in July 2007. A new version of the MANCP for the 2012-2016 period was drawn up and submitted at the end of 2011.
Chapter 2 addresses a number of major developments in the organisations involved in conducting controls.
Chapter 3 reviews the key figures for enforcement in the food chain.
Chapter 4 contains the reports for the various areas of supervision, covering a total of 20 different subjects.
The last two chapters report the conclusions from the internal and external audits conducted in 2014 (Chapter 5) and the activities of the Intelligence and Investigation Service (Chapter 6).
The MANCP annual reports are available on the NVWA website.
11 CHAPTER 2: DEVELOPMENTS IN THE ORGANISATIONS INVOLVED
General developments
Abolition of the product boards
The product boards were abolished on 1 January 2015. The public duties of the product boards, including the duties performed pursuant to the Control Regulation (EC) No 882/2004, have been taken over by the Ministry of Economic Affairs (EZ). The Food and Consumer Product Safety Authority (NVWA) and Netherlands Enterprise Agency (RVO) will perform the majority of these duties. The NVWA is responsible for the physical controls, supervision and enforcement of the duties that the Authority has assumed. The RVO is responsible for the requisite administrative control and implementation. The services of private organisations will be called on for the performance of implementation work whenever this is feasible within the statutory framework. The duties taken over by the NVWA in the animal sector include: • the regulations for and the implementation of the identification and registration of poultry • the registration of the use of antibiotics on calves, pigs and poultry • the monitoring and/or control of animal diseases and zoonoses including: -- Salmonella (poultry) -- Mycoplasma gallisepticum and Mycoplasma synoviae (poultry) -- Aujeszky’s disease (pigs) • animal feed and medicated animal feed • supervision of the welfare of broiler parent stock, turkeys for meat, mink and rabbits for meat The duties taken over by the NVWA in the vegetable sectors relate to cultivation regulations and pesticide regulations. Growers will shortly be required to submit applications for exemption or dispensation to the NVWA rather than to the product boards. The inspection services will continue to carry out the the controls on compliance with cultivation regulations.
Food Confidence Task Force
This Task Force, a temporary collaborative arrangement between policy directorates, implementation agencies, the organised business community and other businesses, was set up in March 2013, after the horse meat fraud at the beginning of that year had revealed the need to implement firm measures to prevent the recurrence of incidents of this nature. The Task Force’s objective was to agree on measures designed to increase consumer confidence in food. The Task Force completed its work at the end of January 2015, and was then abolished. The most important result was the introduction of stringent criteria governing private quality systems. These criteria now enable the NVWA to ‘accept’ quality systems and use them as a source of information when performing its public supervision. The stringency of the procurement terms and conditions has been increased and harmonised with international umbrella systems, such as the BRC and IFS, for which purpose agreements have been reached within the Global Food Safety Initiative (GFSI). What is referred to as a ‘fraud module’ is being developed within this context. Wageningen University & Research centre (WUR), RIKILT and the Dutch business community are involved in the development of this module. Food establishment operators will adopt this module in their quality systems when imposing requirements on suppliers that will provide assurances for food integrity and traceability. Although progress has been made and results have been achieved, change can only really be made when all businesses in the sector actually assume their responsibility for the safety and integrity of their products. Chain liability will then be essential. A number of international chains have already adopted chain liability and the Dutch sectors are expected to be prepared to follow this example. The greatest challenge lies in the change in the behaviour and culture of the relevant sectors.
12 Description of and developments in the control agencies
NVWA
In 2007, the decision was taken to merge all the agencies involved in inspection into one integrated inspection service at the then Ministry of Agriculture, Nature and Food Quality. In May 2010, and in preparation for this merger, the Phytosanitary Service (PD), the General Inspection Service (AID) and the Food and Consumer Product Safety Authority (VWA) brought their organisations together into a temporary work organisation of the new Food and Consumer Product Safety Authority. The merger was completed on 1 January 2012, and the name of the organisation was changed into the Netherlands Food and Consumer Product Safety Authority (NVWA). Since 2013, the merger has been given further shape under the management of the new Inspector-General (IG), Harry Paul. In 2014 the structure of the organisation was as follows:
Organisation chart management NVWA inspector-general Harry Paul deputy inspector-general Freek van Zoeren
program director Jan Meijer Operational Management Department * Support Department *
director director Management Advice Rien van Immerseel (interim) Ineke Thien
Information Management Personnel and Organisation Planning, Finance and Control Legal Affairs Communications Internal Audit Service Lisette Broersen Cees Ridder (interim) Gerrit Huijs (interim) André Andeweg Anita Douven Rob de Heus
NVWA Intelligence and Office for Risk Assessment Client Services Division Veterinary and Import Agriculture and Nature Consumer and Safety and Research Division Division Division Investigation Service
chief inspector / director National director chief inspector chief inspector director Plant Protection Organization Martin Boskamp (interim) Nicole Kroon Henk de Groot Roel Stevens director Pauline den Ambtman (interim) Antoon Opperhuizen Incident and Crisiscentre Policy and International Affairs Supervision and Development Investigation Development Client Services Fred de Klerk deputy chief inspector Planthealth Koen Wienk and Intelligence Liesbeth Kooijman Integrated Risk Assessment chief veterinary inspector (CVI) Corry Brooijmans Ria Westendorp Koen Kolodziej Hub Noteborn Supervision and Development Fishery and EU-subsidies Facilities and Offices National Reference Centre Investigation Tineke Krediet Pim Kaptein Edwin Lap Mariëtte Edema Sjaak Kant Jan Willem van der Ham deputy chief inspector
Supervision and Development Client Services Centre Import Inspection Hotel and Catering Industry Gerben Maij Carla Aponno-Kootstra Ron Vanderweyden (acting) John Vliegenthart Wim van der Sande
Inspection Agriculture Live Stock Inspection Laboratory, Feed and Food Safety Harry Kamphuis Henk Luijmes Frank van Poelwijk deputy chief inspector
* Operational management tasks of the Support Slaughterhouse Inspection Inspection Plant and Nature Product Safety Department are executed by the temporary John Nijs Jack Wijnands Fokko Dannen Operational Management Department.
National Plant Protection Organization Food Safety and Industrial Production Wim van Eck Martine Hoogesteger deputy director March 2015
In 2014, the NVWA had a budget of EUR 306 million (EUR 119 million from the Ministry of Economic Affairs, EUR 78 million from the Ministry of Health, Welfare and Sport and EUR 94 million from third parties). The organisation had a staff of 2281 FTEs. The staff of three divisions, Veterinary and Import (V&I), Agriculture and Nature (L&N) and Consumer and Safety (C&V), were largely responsible for the results reported in Chapter 4.
Although the product safety domain falls within the C&V Division, this information is not included in this annual report as it does not fall within the scope of Regulation (EC) No 882/2004. Product Safety is addressed by a team in the Supervision Development (TO) department that is focused exclusively on product safety issues and in the Supervision Implementation (TU) department with two field teams which operate nationally and two laboratories in Zwijndrecht and Groningen.
The Support Department is responsible for policy, the organisation and management of finances and information management, as well as management control (controlling and auditing) for the whole NVWA. This department also alerts, initiates and advises in the areas of strategy, communication, organisation, human resources and legal affairs.
13 The Support Department is subdivided into Management Advice, Communication, Information Management, Personnel and Organisation, Management and Legal Affairs, Planning, Finance and Control and, in conclusion, the Internal Audit Service (See Chapter 5 for this Service’s results).
The Office for Risk Assessment and Research (BuRO) is authorised by the VWA Independent Risk Assessment Act (WOR 2006) to provide independent advice to the Minister and to the IG on public and animal health risks. Its advice often relates to situations or actions, as well as products involving risks that could be mitigated by the implementation of measures. BuRO substantiates its advice by commissioning research by knowledge institutes such as the National Institute for Public Health and the Environment (Rijksinstituut voor Volksgezondheid en Milieu, RIVM), RIKILT, the Central Veterinary Institute (CVI) and universities. The Office for Risk Assessment and Research has a staff of more than 20. An Advisory Board (RVA) monitors the scientific quality of the advice and its substantiation. This guarantees the independence and objectivity of its risk assessments and overall advice. The NVWA makes its risk assessments and advice public. Risk assessment results are not included in this report as risk assessment does not fall within the scope of Regulation (EC) No 882/2004.
The NVWA Intelligence and Investigation Service has drawn up a report of the activities in 2014, which is enclosed in Chapter 6 of this annual report.
The Client Services division (KCDV) bundles specific tasks of the primary process (shared services). KCDV serves as the link between the ‘outside’ (businesses and citizens) and the ‘inside’ (divisions), whereby the division acts as an information broker. The core tasks of KCDV are client interaction (receiving and dealing with questions, signals, reports and enquiries via the website, phone, email, fax and letters), issuing certificates and other export documents, grant management, relationship management and management of establishment files, processing measures and inspections, data processing for the primary process, other administrative tasks for the primary process, documentary information provision, facilities management and related policy development, general and technical support at head office and service offices, and the Fisheries Monitoring Centre (FMC).
The NVWA has, in conclusion, in-house laboratory capacity for the analysis of samples collected during official controls and inspections. The following table lists the laboratories, the number of their staff and their location.
NVWA Laboratory number of staff NRLa location 1 for food safety 130 RIVMb Wageningen RIKILTc NVWAd
1 for plant health 50 NVWA Wageningen 2 for product safety: 20 NVWAe Groningen (1 for chemical and microbiological analyses and 20 Zwijndrecht 1 for physical, mechanical and electrical analyses) a NRL = National Reference Laboratory b NRL for microbiology (except Campylobacter) c NRL for heavy metals, marine biotoxins, dioxins, polycyclic aromatic hydrocarbons (PAHs), growth promoters, veterinary medicinal product residues, animal feed and genetically modified organisms d NRL for pesticides in human food and animal feed e NRL for food contact materials
NVWA improvement plan The objective of the improvement plan is to achieve the structural improvement of the Authority’s supervision required to equip the NVWA for its tasks in an adequate and future-resilient manner. The improvement plan consists of four parts: 1. Certification and Supervision This relates to a review of the organisation of the certification and supervision system. 2. Enhancement of the enforcement capacity This relates to the strengthening of a number of weak points resulting from insufficient capacity.
14 3. Improvement of the effectiveness of the organisation Structural improvements will be made to the quality and effectiveness of the service to enhance the NVWA as an organisation. 4. Financing The implementation of the improvement plan will be supported by structural additional contributions from both the Ministry of Economic Affairs and the Ministry of Health, Welfare and Sport and the business community.
COKZ/NCAE
The Netherlands Controlling Authority for Milk and Milk Products (Centraal Orgaan voor Kwaliteitsaangelegenheden in de Zuivel, COKZ) is the Dutch authority for the control of milk and milk products, as well as for eggs, egg products and poultry meat (trading standards). The control of eggs and poultry meat is carried out by a separate division of the COKZ, namely the Dutch controlling authority for eggs (Nederlandse Controle Autoriteit Eieren, NCAE). The COKZ has been appointed to supervise compliance with the EU hygiene regulations for dairy cows and the dairy sector. The COKZ is also, within the scope of the Animals Act, entrusted with the supervision of compliance with the requirements governing exports of infant formulae, the quality of Gouda, Edam and Dutch Mimolette cheese, and the protected designation of origin, protected geographical indication and traditional specialities guaranteed certification. NCAE supervises compliance with the requirements governing trade in eggs. These requirements are laid down in Regulation (EC) No 589/2008. In addition, NCAE supervises compliance with the requirements laid down in Regulation (EC) No 543/2008 that govern the marketing of poultry meat. NCAE is the designated supervisory authority for compliance with all EU hygiene regulations by all food establishment operators in the egg sector.
GD Animal Health (GD)
The GD is involved in the whole supply chain from farmer to consumer and is in possession of all the expertise necessary for investigating and controlling animal diseases. The organisation also certifies cattle farms. The GD has an advanced laboratory and automated administration systems at its disposal for the performance of the organisation’s duties. The organisation has a total of 428 FTEs. The GD’s staff includes specialists in pathology, histology, microbiology (bacteriology), virology, molecular biology, immunology, chemistry and toxicology. The GD is an organisation that is, in the first instance, committed to improving animal health and the safety of animal products. Veterinary specialists offer cattle farmers and veterinarians help and advice that extends beyond the control of infectious diseases to cover other aspects of livestock farming such as biosecurity and animal welfare. The GD has a veterinary diagnostic laboratory in Deventer that is one of the largest in Europe. This laboratory has been accredited by the Dutch Accreditation Council (Nederlandse Raad voor Accreditatie, RvA) under NEN-EN-ISO 17025 since 1993. GD Animal Health has also received ISO 9001 certification and Laboratory Accreditation Cooperation (ILAC) (ISO17043) certification. In addition, the GD organises and implements compulsory and voluntary eradication and prevention programmes for various diseases and offers help in improving food quality and food safety (for example, in the production of milk and meat products). The voluntary programmes include programmes for the control of diseases such as Infectious Bovine Rhinotracheitis (IBR), bovine virus diarrhoea (BVD), Maedi-Visna and various other infectious animal diseases. The GD is also responsible for monitoring mandatory reportable diseases including Newcastle disease (ND), avian influenza, brucellosis and leukosis. Information of relevance to the monitoring programmes is collected from sources including the laboratory and establishments during visits, processed in reports and provided to bodies including the authorities.
Skal
Skal, an independent organisation based in Zwolle, supervises organic production in the Netherlands. The organisation has 32 FTEs.
NAK
NAK, the Netherlands General Inspection Service for agricultural seeds and seed potatoes (Nederlandse Algemene Keuringsdienst voor zaaizaad en pootgoed van landbouwgewassen), has the statutory duty to inspect seeds and seed potatoes. NAK performs this inspection duty on the request of and under the supervision of the Minister of Economic Affairs. The service performs phytosanitary inspections under the responsibility of the NVWA. 15 Naktuinbouw
Naktuinbouw, the Netherlands Inspection Service for Horticulture (Stichting Nederlandse Algemene Kwaliteitsdienst Tuinbouw), promotes and monitors the quality of horticultural products, processes and supply chains, with the emphasis on propagating material, both at the national and international level. Naktuinbouw is an independent administrative agency that is supervised by the Ministry of Economic Affairs. Naktuinbouw’s mandatory inspection system has adopted the requirements of the European directives governing propagating material for floricultural, arboricultural and vegetable crops. These directives have been implemented in the Netherlands in the form of the Seeds and Planting Materials Act. Naktuinbouw operates impartially and in autonomy. Public duties relating to basic inspections assigned to other national or international quality and/or inspection services are not performed in autonomy and are performed exclusively on the basis of collaboration. Naktuinbouw is the sole organisation in the Netherlands competent to assess varieties of vegetable, arable crops and ornamental plants in terms of their distinctness, uniformity and stability (DUS testing) for registration and/or plant breeders’ rights. Naktuinbouw operates voluntary quality certification systems. These complement the statutory certifications or extend beyond the legal guidelines. These include, for example, the quality assessments of propagating material and examinations of varietal identity and varietal purity. The majority of the service’s clients are individual and groups of producers of propagating material. Naktuinbouw also focuses on quality improvement and certain specialisms, for establishments across the entire horticulture supply chain, both in the Netherlands and abroad.
Flower Bulb Inspection Service (Bloembollen Keuringsdienst, BKD)
The Ministry of Economic Affairs (EZ) has entrusted the BKD with the inspection of the quality of all flower bulb crops in the Netherlands, other than Freesia and Nerine, which have been assigned to NAKtuinbouw. The BKD inspects flower bulbs for both quality defects and quarantine pathogens. The service also carries out quality inspections, import and export inspections and laboratory examinations.
KCB
The Quality Control Bureau (Kwaliteits-Controle-Bureau, KCB) is an independent administrative agency that is supervised by the Ministry of Economic Affairs and exclusively performs public duties. The Bureau’s head office has a staff of about 35 people in the management and support departments, with further staff of some 115 active in the field. The Bureau’s control and inspection work is carried out from the offices in the various districts. The KCB, a foundation, has a board with members who are appointed by industry organisations in the fruit and vegetable sector, the ornamental horticulture sector and the Netherlands Food Retailers Association (Centraal Bureau voor Levensmiddelenhandel, CBL). The appointment of the chair of the board is approved by the Minister of Economic Affairs. The KCB’s most important duty is to conduct import and export inspections of fresh fruit and vegetables, cut flowers and potted plants. The Bureau also monitors the quality of fresh fruit and vegetables traded in the Netherlands. In addition, the KCB carries out a number of projects for the government, including the Tuta absoluta survey in tomato cultivation and False Codling Moth survey in the final crop of peppers. The phytosanitary export inspections of vegetable products and issue of phytosanitary export certificates are carried out by NVWA officers. The Dutch Accreditation Council (Nederlandse Raad voor Accreditatie, RvA) has accredited KCB for the performance of these inspections.
16 CHAPTER 3: key figures
Introduction
This chapter reviews the key enforcement figures.
Available resources of the relevant agencies
The following table lists the available budget and staffing levels for the relevant control agencies (see Chapter 2 for a description of the agencies).
resources in 2014 budget (EUR 1000s) staff (FTE) resources in 2013 budget (EUR 1000s) staff (FTE) NVWA 306,000 2,281 NVWA 278,000 2,181 COKZ / NCAE 7,839 52 COKZ / NCAE 7,796 52 NAK 22,965 194.7 NAK 27,349 197.8 Naktuinbouw 25,251 252 Naktuinbouw 24,650 250 BKD 8,509 99 BKD 8,400 115 KCB 14,510 137 KCB 12,147 137 GD 54,766 428 GD 57,104 497 Skal 3,403 32.1 Skal 3,146 31
Total number of inspections and certifications (in hours) by domain in 2014
The following tables list the total number of inspections and certification hours by domain (see Chapter 4 for specific descriptions of each of the domains)
number of inspections 2010 2011 2012 2013 2014 Identification and registration (I&R) 3,708 2,961 2,515 2,521 2,316 Animal heath - prevention 8,641 10,858 7,231 7,340 6,951 Animal welfare during transport 13,378 14,129 11,993 10,240 9,359 Animal feed 981 1,156 2,031 1,564 1,127 Animal by-products 6,668 5,936 5,712 4,307 3,655 Meat 1,803 2,883 2,320 3,022 2,772 Meat products 1,866 3,039 2,016 1,874 2,075 Imports of live animals and animal products 61,596 59,159 59,022 60,938 Industrial production (composite products) 3,340 3,871 5,502 5,361 3,274 Milk and dairy products 1,006 991 993 784 930 Egg sector 1,407 1,064 872 1,028 830 Hotel/restaurant/catering and retail 44,563 44,972 29,578 30,220 36,403 Labelling 1,050 422 178 80 168 Claims for foods for particular nutritional uses 2,207 1,350 1,865 1,734 1,862 Residues and contaminants in food 2,500 3,787 2,090 3,860 7,529 Veterinary medicines 952 689 2,502 1,156 620 Microbiological samples 26,897 18,209 15,184 Plant protection products 2,691 1,652 1,143 1,296 868 Organic products 5,069 5,258 4,064 4,878 4,908 Total 195,439 180,419 178,164 159,245 161,769
Certifications (in hours) 2010 2011 2012 2013 2014 Meat 188,727 186,787 203,345 273,425 281,747 Fish 9,918 4,596 9,352 8,982 10,070 Live animals (export) 71,570 59,514 72,709 108,028
17 plant health number of inspections 2012 2013 2014 Results for arable agriculture 38,756 34,752 36,696 Results for fruit and vegetables 101,050 124,379 117,768 Results for ornamental horticulture 177,052 181,854 184,068 Results for tree nurseries and green spaces 14,161 14,146 13,971 Total 331,019 355,131 352,503
General developments in enforcement in the food chain
The NVWA, as in past years, worked on the further development of a more risk-oriented enforcement strategy in 2014. fine decisions 2010 2011 2012 2013 2014 number of fine decisions (Commodities Act) 3,223 2,275 2,951 3,322 2,808 Total amount of fines (EUR 1000s) 3,289 2,850 4,013 4,084 6,183 Average fine 1,027 1,253 1,360 1,229 1278
Total number of fine decisions in 2014
Act number total fines paid average fines paid amount of fines paid Commodities Act 2,808 € 3,413,893 € 1,216 € 3,631,980 Tobacco Act 1,641 € 1,575,875 € 960 € 1,709,220 Licensing Act 0 € 0 € 0 € 0 Plant Protection Products and Biocides Act 361 € 489,806 € 1,357 € 483,218 Medical Preparations Act 2 € 11,091 € 5,546 € 11,145 Animal Health and Welfare Act 157 € 277,500 € 1,768 € 225,640 Animals Act 358 € 1,045,025 € 2,919 € 844,772 Totaal 5,327 € 6,813,190 € 1,278 € 6,909,975
In 2014, a total of 5,327 fine decisions were issued (previous year: 5,869), of which 2,808 within the context of the Commodities Act, 1,641 within the context of the Tobacco Act, none within the context of the Licensing Act (due to the transfer of the enforcement from the NVWA to the municipal services), 361 within the context of the Plant Protection Products and Biocides Act, 2 within the context of the Medical Preparations Act, 157 within the context of of the Animal Health and Welfare Act and 351 within the context of the Animals Act.
Key figures and performance indicators
The NVWA has adopted a number of indicators for the assessment of the services it provides. An annual survey is also carried out to assess the public awareness of the authority and the public confidence in food safety.
Complaints about NVWA actions This indicator measures the number of complaints received about the NVWA staff’s performance of their duties.
Complaints about NVWA actions 2009 2010 2011 2012 2013 2014 Inspections 54 18 48 47 Sample analyses 26 5 9 0 Certifications 112 22 20 29 Total 192 45 52* 81* 77 76 * total number of complaints (a breakdown was not feasible in 2011 or 2012).
Speed of handling requests for information and complaints The following table lists the movements in the number of requests for information, complaints and reports received by the NVWA’s Client Services Centre. The Client Services Centre can be contacted by phone or email 24 hours a day and 7 days a week. As the NVWA’s name awareness has increased among consumers, more consumers are familiar with the complaint notification procedure. The number of complaints relating to smoking in hotels, restaurants and catering
18 facilities and in public spaces is steadily decreasing, whilst the number of complaints on hygiene and food poisoning is increasing.
Complaints/requests received 2011 2012 2013 2014 Number of phone calls 29,883 66,084 52,155 55,561 Emails received 26,097 45,130 50,198 42,014 Number of reports 5,446 4,844 3,569 3,465 Number of complaints, of which: 6,236 9,316 11,161 11,600 • Animal welfare/neglect 1,844 1,703 2,100 2,556 • Smoking in hotels/restaurants/catering facilities 3,818 1,547 1,692 1,339 • Hygiene issues 668 765 1,326 1,315 • Food poisoning 641 801 1,010 1,157 • General Food Law issues 112 250 262 918 • Vermin 651 489 518 624 • Defective conditions/past the best before date 300 265 324 563 • RASFF issues 300 261 195 422 • Flavour and odour defects 468 439 423 415 • Foreign objects in food 309 379 400 412 Percentage of justified complaints 37% 64% 62% 65% Percentage dealt with within 6 weeks 97% 50% 60% 58%
Name awareness A distinction is drawn between spontaneous and prompted name awareness when assessing name awareness. The following table reveals that the NVWA’s name awareness falls somewhat short of the target.
name awareness actual 2011 actual 2012 actual 2013 actual 2014 Spontaneous 17% 20% 41,80% 42,00% Total 75% 80% 90,40% 89,00%
The total score for the name awareness, 89%, is due to the use of an internet panel rather than the telephone survey of earlier years. It was known in advance that the adoption of a new method would result in a break from the trend. For this reason, this new measurement (from 2013) should be regarded as a baseline measurement. The name awareness has fallen slightly by 1.4 percentage point from 2013.
19 Chapter 4: Reports on areas of supervision in 2014
4.1 Introduction
Chapter 4 contains the reports on the various domains in 2014. The report for each domain reviews the following: • applicable legislation and regulations • size of control file • results of controls • findings on compliance • incidents • key conclusions.
The following domains are discussed in the following order: 4.2 Animal health – monitoring and control 4.3 Animal health – prevention (live animals and live products) 4.4 Animal welfare 4.5 Animal feed 4.6 Animal by-products 4.7 Meat (slaughterhouses, cutting plants and cold stores) 4.8 Meat products 4.9 Imports of veterinary consignments 4.10 Composite products – Industrial production 4.11 Fish, fish products and aquaculture 4.12 Dairy, eggs and egg products 4.13 Hotel/restaurant/catering and artisanal production 4.14 Know what you are buying 4.15 Contaminants, residues and GMOs in food 4.16 Microbiology (pathogens, food-borne infections and zoonoses) 4.17 Nutrition and health/special food and drink 4.18 Plant health 4.19 Plant protection 4.20 Organic products 4.21 Geographical protection: PDO, PGI, TSG
20 4.2 Animal health – monitoring and control
Controlling authorities: NVWA, GD Animal Health, Livestock, Meat and Eggs Product Boards
Summary of the main legislation addressed by controls in 2014
EU legislation Directive 64/432/EEC Intra-Community trade in bovine animals and swine (TB, brucellosis, leukosis) Directive 82/894/EEC notification of animal diseases Directive 91/68/EEC Intra-Community trade in sheep and goats (Brucella melitensis) Directive 92/65/EEC Balai Directive on trade in live animals and live products Directive 92/66/EEC Newcastle Disease control measures general Community measures for the control of certain animal diseases and Directive 92/119/EEC specific measures relating to swine vesicular disease Directive 2000/75/EEC specific provisions for the control and eradication of blue tongue Directive 2001/89/EEC Community measures for the control of classical swine fever Directive 2003/85/EEC Community measures for the control of foot-and-mouth disease Directive 2005/94/EEC Community measures for the control of avian influenza rules for the prevention, control and eradication of certain transmissible Regulation (EC) No 999/2001 on food hygiene spongiform encephalopathies
National: • Animal Health and Welfare Act (GWWD)
Size of control file in 2014
type of establishment number in 2014 number in 2013 Cattle farms 51,089 50,990 Establishments with small ruminants 40,495 39,856 Pig farms including farms with animals kept on a non-commercial basisa 11,985 11,061 Poultry establishments 2,163 2,139 a Establishments with more than five pigs (the Unique Business Number (UBN) registration system does not distinguish between establishments with animals kept on a non-commercial basis and pig farms).
The number of establishments relates to the number of registered establishments including those with no animals (what are referred to as ‘0 establishments’). The databases used for this purpose were the animal records of the National Service for Implementation of Regulations (Dienst Regelingen) and GD Animal Health. The section on Animal health – prevention also lists establishments, although solely establishments that actually held animals in the past year.
Results from the supervision of Identification and registration (I&R) in 2014
As from this year, the information on I&R is included under Animal health – prevention
References to specific reports
Reports pursuant to Directive 64/432/EEC Reports pursuant to Directive 91/68/EEC Half-yearly AI monitoring/surveillance Reports on welfare in depopulation operations within the context of Regulation (EC) No 1099/2009
21 Supervision of animal health, results in 2014 type of case total cases demonstrateda positiveb negative no actionc African horse sickness (APP/AHS) 1 1 American foulbrood 5 4 1 Aujeszky’s disease 2 2 Avian influenza (LP/HP AI) 228 7 145 76 Bluetongue (BT) 31 11 20 Bovine spongiform encephalopathy 1 1 Brucellosis abortus (Bang’s disease) 62 58 4 Brucellosis canis 1 1 Brucellosis (Brucella melitensis) 12 12 Swine brucellosis 112 112 Chlamydia abortus 1 1 Chlamydia caviae 1 1 Echinococcus granulosus 2 1 1 Equine Herpes Virus (EHV) 1 1 Equine Infectious Anaemia (EIA) 1 1 Equine Viral Arteritis (EVA) 2 2 Escherichia coli 1 1 Herpes B 1 1 Classical swine fever (KVP / CSF) 9 9 Cowpox 2 1 1 Leptospirosis 26 2 6 18 Leukosis 34 33 1 Listeriosis 2 2 Lumpy Skin Disease (LSD) 3 3 Glanders 1 1 Middle East Respiratory Syndrome (MERS) 1 1 Anthrax 8 7 1 Foot-and-mouth disease (MKZ /FMD) 4 2 2 Newcastle Disease (NCD / ND) 14 9 5 Parvo 1 1 Psittacosis (animal) 45 29 15 1 Psittacosis (human) 45 14 19 12 Q fever (animal) 5 5 Q fever (bulk tank milk) 7 1 6 Q fever (human) 6 4 2 Rabies (bat) 29 3 16 10 Rabies (mammal) 29 18 11 Rhinopneumonia 1 1 Salmonellosis 103 98 5 Sarcosporidiosis 1 1 Scrapie (classical) 1 1 Swine vesicular disease 18 13 5 Trichinellosis 1 1 Tuberculosis 50 1 5 29 15 Tularaemia 4 3 1 Venezuelan Equine Encephalomyelitis 2 2 Vesicular Stomatitis 3 2 1 West Nile Virus (WNF) 6 4 2 Yersiniosis 5 3 2 a ‘Demonstrated’ is the term for Article 10 of Regulation (EC) No 999/2001: animal pathogens which are not subject to compulsory control but which must be reported by the veterinarian. b ‘Positive’ are the results for animal diseases subject to compulsory control c Additional research, the clinical picture, laboratory report and specific circumstances, etc., did not reveal the need for further action.
22 Animal health monitoring
In 2014, GD Animal Health’s monitoring of animal health encompassed testing programmes in the fields of: • Brucellosis abortion testing: The Netherlands has been officially brucellosis-free since 1 August 1999. The mandatory EU surveillance testing which had been carried out annually since then came to an end on 1 August 2004. The mandatory requirement to report cases of abortion (abortion testing) remains in place. • Brucella melitensis testing: The Netherlands is officially free of Brucella melitensis. The disease has never been identified in the Netherlands. A large number of sheep and goat blood samples are tested annually to demonstrate that Brucella melitensis is not present in the Netherlands. • Monitoring of wild boar: Wild boar are tested annually for CSF, FMD, SVD and Aujeszky’s disease. The number of samples depends on the area in which the animals are shot. All boar shot in Limburg are tested, a representative random sample is taken in the Veluwe area, and in other areas in the Netherlands – in what are referred to as the ‘0 option areas’ – all animals that are shot as the occasion arises are tested.
The Netherlands was assigned Article 10 status for Aujeszky’s disease pursuant to Directive 64/432/EEC on 1 January 2009. Until the end of 2014, the monitoring and control were carried out by the product boards under the responsibility of the Ministry of Economic Affairs: • Breeding establishments must have blood samples from twelve animals a month tested for Aujeszky’s disease • Other pig establishments must have three animals tested every four months • The tests must be carried out by laboratories designated for the purpose.
Avian Influenza Mandatory national serological monitoring of AI antibodies at poultry establishments as part of AI monitoring was introduced in 2005. The frequencies, minimum ages and numbers depend on the animal species, animal type and type of farm: • broilers, ducks raised for meat, birds reared for breeding, breeding birds, birds reared for laying and non-free range layers: annually; • turkeys reared for meat: every production cycle; • laying hens and other chickens (free range): quarterly. The GD tests for antibodies, and positive samples are sent to the CVI for confirmation. The monitoring programme is supplemented with an early warning programme in which, when LPAI is included on the differential diagnosis list but is not the most probable diagnosis, veterinarians can send swabs to the NRL to rule out AI. The GD also sends exclusion swabs from autopsies for screening for AI when the results of an autopsy suggest there is reason to do so. In 2014, the GD submitted 184 consignments of exclusion swabs for testing. Veterinary practices and other organisations submitted 164 consignments. One of the two outbreaks of LPAI was detected by monitoring and the other by exclusion swabs.
The results from these programmes are listed in the following table.
number of number not Monitoring in 2014 number of samples positive after confirmation establishments negativea Brucellosis abortion testing 5,939 11,989 39 0 Brucella melitensis 1,317 15,940 12 0 CSF, FMD, SVD in wild boar (serology) - 750 0 0 Aujeszky’s disease in wild boar - 750 0 0 CSF in wild boar (virological [PCR]) - 76 0 0 Aujeszky’s disease 5,596 95,574 0 0 H5/H7 8,327 (consignments), 388 (consign- 19 positive consignments AI monitoring serology 2,224 various samples per ments) 11 unique businesses consignment (establishments)b a The laboratory uses this term when the final result is not yet known. This means that the blood sample did not test negative. The relevant animal was then transferred, slaughtered and culture samples were incubated. The result from the culture is decisive: these were negative for all the cattle that were tested here. b Although a number of establishments tested serologically positive, no virus could be demonstrated.
23 Incidents
Some particulars relating to animal disease control in 2014 are reviewed below:
Avian Influenza At the beginning of 2014, two laying hen farms tested PCR positive for LPAI (H5N1and H5N2). In November 2014, HPAI virus was encountered at five farms, namely three laying hen farms, one farm with ducks for slaughter and one broiler parent stock farm (H5N8 in all cases). Three farms were also preventively culled due to their contact with or location within a 1 km radius of an infected farm.
American foulbrood Four outbreaks of American foulbrood occurred.
Q fever In 2014, tests on bulk tank milk from one dairy goat establishment revealed a new infection with Coxiella burnettii, the Q fever bacteria. This establishment had not previously been infected.
Rabies Following consultations with experts the bat testing policy was fundamentally revised on 1 January 2013, as a result of which solely bats that have been in high-risk contact with humans are tested. Bats caught by dogs or cats, for example, no longer come into consideration for testing.
Tuberculosis The vast majority of suspected cases and the five outbreaks of TB relate to contact animals from infected cattle farms in Ireland.
Salmonellosis In mid-2012, GD Animal Health reported that it had observed an increase in the number of Salmonella infections on veal calf farms. Although no increase was observed in the number of Salmonella cases among humans, the increase among veal calves gave cause to close monitoring of the situation. This monitoring continued in 2014, which is the reason for the high number of Salmonella cases in the summary. Where an infection was identified, the farmer was contacted and given advice on farm hygiene.
Training for the animal disease control organisation
In 2014 the following training programmes courses and exercises were organised and held for the animal disease control organisation: • Basic training was organised for fourteen new animal disease specialists. This two-day basic training course covered the tasks and roles involved as well as the required knowledge, skills and behaviour. All participants passed the concluding examination. • A field exercise was organised for the members of the front teams. The front teams were confronted with a scenario in which an outbreak of African swine fever was accompanied by a rapid sequence of unannounced occurrences. The teams were observed and the points from the evaluation were discussed with the them. Twelve teams were trained during a four-day period. • Two refresher days were organised for the animal disease specialists, one of which focused on Q fever, African swine fever and the new handling suspected animal diseases and zoonoses scenario and the second on assessment, low pathogenic avian influenza, psittacosis and TB. • An annual training day on in-house emergency response was organised for the hygiene and enforcement officers who are members of the front team. • New members for the front teams received the basic training course. A number of these new members then received follow-on training for the position of front team coordinator. • The NVIC received several groups of final year veterinary science students and informed them about relevant animal disease control issues and the notification obligation.
24 Risk assessments
In 2014, the following risk assessments (RA) carried out in response to outbreaks of animal diseases in other countries: animal disease country aantal RA ASF Estonia 1 ASF Lithuania 1 ASF Poland 1 Aujeszky Romania 1 BT Albania 1 BT Bosnia-Herzegovina 1 BT Bulgaria 1 BT Croatia 1 BT Hungary 1 BT Romania 1 BT Spain 1 BT Montenegro 1 CSF Latvia 1 HPAI Germany 2 HPAI Italy 1 HPAI Russia 1 MKZ Algeria 1 NCD Romania 1 SVD Italy 1
Conclusions for 2014
• LPAI: LPAI outbreaks have occurred every year in recent years. In 2014, two commercial poultry establishments were afflicted by LPAI. Both establishments were free range poultry establishments. A total of more than 53,000 birds were slaughtered at these establishments (further details are given in the reports pursuant to Regulation (EC) No 1099/2009). • HPAI: In 2014, HPAI serotype H5N8 was encountered at five poultry establishments. 245,600 birds were slaughtered. • BSE: There were no cases of BSE at all in 2014. This serves as further corroboration of the conclusion that the BSE measures introduced in the late 1990s remain effective. The World Organisation for Animal Health (OIE) has awarded the Netherlands the ‘free status’1. • Schmallenberg virus: Once again, no new positive cases of the Schmallenberg virus occurred in 2014. • Tuberculosis: in 2014, five bovines were found to have TB. All the animals had been imported into the Netherlands.
1 Since the agreement, in May 2013, of Resolution 20 at the 81st General Session of OIE Paris, when ‘negligible BSE risk status’ was awarded in accordance with Chapter 11.5 of the OIE (Organisation Mondiale de la Santé Animale) Terrestrial Code. 25 4.3 Animal health – prevention (live animals and live products)
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Directive 90/425/EEC trade in live animals and products Directive 64/432/EEC trade in cattle and pigs Directive 2009/156/EEC import and trade in equidae Directive 90/427/EEC zootechnical and genealogical conditions for equidae Directive 2009/158/EEC trade in poultry and hatching eggs Directive 91/68/EEC trade in sheep and goats Directive 92/65/EEC Balai Directive Directive 88/407/EEC bovine semen Directive 90/429/EEC porcine semen Directive 89/556/EEC bovine embryos Directive 92/102/EEC I&R of animals Directive 2006/88/EEC aquaculture animals and products thereof Directive 90/425/EEC Control Directive Regulation (EC) No 1760/2000 I&R of bovine animals Regulation (EC) No 21/2004 I&R of sheep and goats Regulation (EC) No 504/2008 I&R of equidae Regulation (EC) No 318/2007 bird quarantine Regulation (EC) No 1255/1997 control posts Regulation (EC) No 1739/2005 circus animals Regulation (EC) No 998/2003 non-commercial movement of pet animals
National: Animal Health and Welfare Act with detailing in the form of specific regulations including: • Regulation on the prevention, control and monitoring of infectious animal diseases and zoonoses and TSEs (Regeling preventie, bestrijding en monitoring van besmettelijke dierziekten en zoönosen en TSE’s) • Regulation on trade in live animals and live products (Regeling handel levende dieren en levende producten) • Regulation on equine semen (Regeling paardensperma) • Regulation on bovine semen (Regeling rundersperma) • Regulation on porcine semen (Regeling varkensssperma) • Regulation on the identification and registration of animals Regeling( identificatie en registratie van dieren) • Regulation on aquaculture (Regeling aquacultuur)
General
As was the case in the previous year, the emphasis was placed on enforcement to make a contribution to preventing the introduction and spread of animal diseases. The NVWA, as a veterinary authority, needs to provide assurances for the animals’ health and the sector’s compliance with the statutory requirements to EU Member States and other countries. During the past few years, great efforts have been made to improve quality and increase the stringency of supervision. The identification and registration (I&R) of animals is of importance to tracing animal diseases, providing guarantees for export certification and to food safety in general.
26 Results from regular prevention controls of approved and other establishments and controls on exports in intra- Community trade and trade with third countries in 2014
Size of control file and number of inspections in 2014
type of establishment number at 31/12/2014 number of inspections in 2014 Approved assembly centres (VC), 77 298 of which approved as: • pig assembly centre 20 • cattle assembly centre 64 • sheep/goat assembly centre 28
Washing areas (approved) 167 580 Washing areas (designated, poultry) 38 112 Washing areas (simple and authorisation holder) 137 101 Bovine semen collection centres (SCC) 8 14 Porcine semen collection centres 20 38 Equine semen collection centres 17 20 Sheep/goat assembly centre 1 1 Quarantine for porcine/bovine/ovine/caprine SCCs 22 37 Bovine semen storage centres 10 16 Equine semen storage centres 3 4 Bovine embryo production teams 7 2 Equine embryo teams 2 1 Bovine embryo storage centres 1 1 Approved institutions 92/65 19 19 Bird quarantine stations 1 1 Approved poultry establishments, 675 632 of which approved as: • Hatchery 42 • Hatching egg export station 7 • Poultry-rearing establishment 310 • Hatching egg establishment 39 • Breeding establishment 277 Control posts 4 7 Registered circuses 5 15 Approved livestock dealers 462 0 Registered dealers in other species 117 0 Approved aquaculture production establishments (fish farms) 48 14 Approved aquaculture production establishments (molluscs) 128 0 Registered Put and Take fish farms 53 4 Destination controls 5,034 Total number of establishment inspections 6,951 (exclusive of export certification), in visit frequency
Certifications (export certification, in hours): 108,028
enforcement relating to prevention at approved and other establishments during regular and number other controls in 2014 Written warning to assembly centres 5 Intention to impose CDO (cease and desist order) on assembly centres 11 Imposition of CDO on assembly centres 3 Forfeiture pursuant to CDO on assembly centres 1 Collection of administrative fine imposed on assembly centres 3 Written warning to slaughterhouses (washing area) 4 Intention to impose CDO on slaughterhouses (washing area) 7 Imposition of CDO on slaughterhouses (washing area) 1
27 Forfeiture pursuant to CDO on slaughterhouses (washing area) 1 Written warning to transporters (C&S - cleaning and sanitation - vehicle) 10 Intention to impose CDO on transporters (C&S) 3 Notification of imposition of administrative fine on transporters (C&S of vehicle) 4 Imposition of fine decision on transporters (C&S of vehicle) 11 Collection of administrative fine on transporters (C&S of vehicle) 25 Communication to exporter 1 Total 90
In 2014, a total of 90 measures were implemented in connection with prevention (national: Regulation on the prevention, control and monitoring of infectious animal diseases and zoonoses and TSEs [Regeling preventie, bestrijding en monitoring van besmettelijke dierziekten en zoönosen en TSE’s]) at approved and other establishments during regular inspections and during export certification pursuant to the EU trade directives (national: Regulation on trade in live animals and live products [Regeling handel levende dieren en levende producten])
Additional explanation: • In addition to inspections of approved washing areas (independent washing areas, assembly centres and large medium-sized red meat slaughterhouses), the NVWA also carried out inspections of simple washing areas of smaller red meat slaughterhouses with limited slaughtering capacity. The target number of washing area inspections at slaughterhouses was not achieved. It should then be noted that a compliance survey has been carried out at the medium-sized and smaller slaughterhouses within the context of the Meat chain improvement plan that was initiated in 2014, and that a risk-oriented supervision model has been introduced on the basis of the findings. The compliance survey revealed that the washing areas’ compliance fell short of expectations. However, enforcement has been improved in 2014. Authorisation holders (extinction scheme) may, after unloading at small or other slaughterhouses and subject to conditions, arrange for the cleaning and sanitation of the vehicles at another location. Vehicles, other than those in transit, that are brought into the Netherlands empty and have been used to transport birds or hatching eggs in third countries or originate from European Member States where an outbreak of High Pathogenic Avian Influenza has been confirmed are cleaned and sanitised again at a designated washing area. • Semen collection centres and quarantine stations (bovine and porcine) exhibit a high level of compliance. In 2014, the abolition of the product boards gave cause to the preparation of a new regulation on equine semen (Regeling paardensperma) which will enter into force in 2015, and which will include solely the equine semen collection centres that operate for the national market. Until 1 January 2015, these national centres operated under the supervision of the Livestock, Meat and Eggs Product Board (PVE). • In 2014, no capacity or budget was available for controls of the registers of approved or registered traders. • In 2014, the aquaculture production establishments (fish farms) were lassifiedc into risk categories. The results will be used to adopt the inspection frequencies for each establishment from 2015. Fish carcases were not always collected from the aquaculture production establishments within the statutory 14-day period. The number of carcases at the establishments is generally extremely low and the carcases are usually stored in frozen condition. However, for policy reasons there is no willingness to extend the 14-day collection period for frozen carcases to, for example, 4 weeks. No inspections of mollusc aquaculture production establishments were carried out within the scope of Directive 2006/88/EC. However, these establishments are visited and inspected within the scope of the hygiene regulations. The Consumer and Safety Division is responsible for carrying out and reporting on these inspections. • The destination controls encompass all random controls requested and carried out at the destination address on the import of live animals and products from another Member State or third country to verify that the consignment has been certified pursuant to the provisions of Article 3 of Directive 90/425/EEC. • The specific export certification intervention policy has now been in force for 2 years. This specific intervention policy relates to the requirements laid down in the EU trade directives (national: Regulation on trade in live animals and live products [Regeling handel levende dieren en levende producten]). The objective is to have a harmonised enforcement strategy available for established infringements relating to export certification, transit controls and complaints from abroad. The clarified enforcement strategy is gradually beginning to bear fruit and increasingly adequate action is being taken in the event of non-compliances, which is in turn bringing non-compliances to an end more rapidly than in the past. • It has transpired that horses are regularly being exported without the mandatory export certificate, in particular from
28 horse markets. The NVWA is devoting additional attention to this issue and immediately draws up an official report both on discovering an illegal export or an illegal import. • The QLL (quality system livestock logistics)2 and the associated more flexible supervision modalities were withdrawn on 1 March 2014. The guarantees offered by the QLL were insufficient to provide the necessary assurances for the system. On taking this step the supervision of the assembly centres and export certification has once again become exclusively repressive. However, the State Secretary promised the House of Representatives of the States General that scope will be offered for new systems. The requirements to be met by new guarantee systems were adopted in mid-2014. Four new guarantee systems were submitted at the end of 2014, although these do not yet meet the requirements to the extent needed for the initiation of a pilot trial.
I&R control supervision, results in 2014 type of establishment number in 2014 number of inspections in 2014 Result: Bovine establishments with bovines in 2014 35,427 1,220 not approved: 618
settlement: • communication: 431 • administrative law: 1 • official report: 85 • written warning: 90 • being processed: 11 Sheep and/or goat establishment with sheep 35,519 1,096 not approved: 683 and/or goats present in 2014 settlement: • communication: 303 • administrative law: 0 • official report: 74 • written warning: 283 • being processed: 23
Additional explanation: • The bovine, sheep and goat I&R controls are focused on compliance with the percentage prescribed in the EU (3%, and achieved) and on actively tracking down establishments not in compliance. The controls are in part random and in part structured. • An I&R of Equidae compliance survey was carried out in the last quarter of 2013, and in the first quarter of 2014. This has been evaluated. The report has yet to be finalised. Fraud with horse passports is an issue which continues to require attention. Since 2014, passports are not only stamped as invalid at slaughterhouses but are also perforated to prevent fraud. The non-uniform approach adopted to passports by some Member States complicated the recognition of fraud with foreign passports. In 2014, a number of fines and even imprisonment were imposed for fraud with horse passports whereby horses that were not suitable for human consumption nevertheless probably entered the food chain. • As from the end of 2014, it is now possible to mark pigs for slaughter that are transported from the farm directly to German slaughterhouses with a slap mark rather than with the slaughter tag in the ear. In practice, it has transpired that German slaughterhouses do not use slaughter tags to identify and register pigs for slaughter, but instead use slap marks. A slap mark is a mark tattooed in the skin with an applicator. The potential expansion of use of the slap mark applicator will be reviewed in 2015.
Results from transport prevention controls in 2014
The transport teams’ controls focus on welfare and prevention controls in transit, but also extend to unannounced controls at assembly centres and slaughterhouses. The bovine, sheep and goat I&R controls at livestock establishments
2 QLL was the private quality system for both the transport and the assembly sector. Participants in this system undertook to comply with the transport and prevention regulations. Three certification bodies verified the in-house control on compliance on behalf of QLL. The govern- ment offered participants a number of financial incentives (time and planning gains), administrative incentives and incentives of a regulatory nature. 29 also extend to controls of the mandatory presence and performance of simple washing areas. Any welfare issues identified during these controls are included in the enforcement. The report on these welfare issues is enclosed in Chapter 4.4 (Animal welfare). type of control number of controls 2014 result Transport controls on the road and on arrival at or departure 2,994 • not approved, C&S: 106 from establishments, of which • not approved, prevention : 62 • Cleaning and sterilisation (C&S) controls 728 • not approved, other: 647 • other prevention issues 1,430 • other (not prevention) 836 settlements, total: • communication: 47 • verbal warning: 105 • written warning: 486 • fine report: 104 • official report: 73
Controls relating to the assembly of animals 40 • not approved: 27
settlement: • communication: 11 • written warning: 9 • official report: 7
Simple washing areas at livestock establishments (sheep/goat) 428 • not approved: 27
settlement: • communication: 15 • written warning: 11 • official report: 1
Simple washing areas at livestock establishments (bovine) 417 • not approved: 17
settlement: • communication: 11 • written warning: 6
Additional explanation: • The transport controls on the road relate to controls of cattle wagons orf non-compliances in connection with arrival at or departure from establishments (such as assembly centres and slaughterhouses, but also primary livestock establishments), the (complete) unloading, the correct assembly on the trucks and the C&S registration, etc. The C&S of vehicles, including empty vehicles, is also controlled. Consequently, cattle wagons can also be diverted from the road for controls. • The controls relating to the assembly of even-toed ungulates are focused specifically on all non-compliances with the permitted options that the regulations offer for the assembly of even-toed ungulates from different origins.
Incidents
In 2014, there were no specific large-scale incidents relating to prevention.
Conclusions
• The I&R of Equidae remains a source of concern, as fraud involving horse passports results in food safety issues. At the beginning of 2015, this resulted in the amendment of the EU I&R regulations for horses. The amended regulations enter into force on 1 January 2016. • The guarantees within the QLL quality system are insufficient to provide the necessary assurances for the system. This resulted in the withdrawal of the authorisation of the system and the associated supervision modalities on 1 March 2014. The NVWA has tackled the consequences vigorously, in part by arranging for training for new veterinarians and by the extension of the inspection times at the assembly centres. New quality systems were submitted for assessment at the end of 2014. Their rationale will be reviewed in 2015.
30 4.4 Animal welfare
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 1/2005 protection of animals during transport and related operations Regulation (EC) No 1099/2009 protection of animals at the time of killing Directive 93/119/EEC protection of animals at the time of slaughter or killing Directive 98/58/EC protection of animals kept for farming purposes Directive 1999/74/EC minimum standards for the protection of laying hens Directive 2007/43/EC minimum rules for the protection of chickens kept for meat production Directive 2008/119/EC minimum standards for the protection of calves Directive 2008/120/EC minimum standards for the protection of pigs Regulation (EC) No 853/2004 hygiene rules for food of animal origin
National: • Animal Health and Welfare Act (until 1 July 2014) • Animal welfare policy rules (Beleidsregels dierwelzijn) 2009 • Killing of animals decree (Besluit doden van dieren) (until 1 July 2014) • Ritual slaughter decree (Besluit ritueel slachten) (until 1 July 2014) • Pigs decree (Varkensbesluit) (until 1 July 2014) • Broiler decree (Vleeskuikenbesluit) 2010 (until 1 July 2014) • Calves decree (Kalverenbesluit) (until 1 July 2014) • Laying hens decree 2003 (until 1 July 2014) • Welfare of production animals decree (until 1 July 2014) • Regulation on killing animals (Regeling doden van dieren) 2012 (until 1 July 2014) • Regulation on animal transport (Regeling dierenvervoer) 2007 (until 1 July 2014) • Regulation on broilers (Regeling vleeskuikens) (until 1 July 2014) • Animals Act, section of Chapter 2: animals (as from 1 July 2014) • Animal keepers decree (Besluit houders van dieren) (as from 1 July 2014) • Regulation on animal keepers (Regeling houders van dieren) (as from 1 July 2014) • Enforcement and other Animals Act matters decree (Besluit handhaving en overige zaken Wet dieren) (as from 1 July 2014) • Regulation on enforcement and other Animals Act matters Regeling( handhaving en overige zaken Wet dieren) (as from 1 July 2014)
Size of control file in 2014 type of establishment number Livestock transporters (short journeys) 1,372 Livestock transporters (long journeys) 223 Continuous supervision of large ungulate slaughterhouses (active) 22 Small/medium-sized ungulate slaughterhouses 161 Poultry slaughterhouses (active) 30 Pig production sites 5,110 Laying hen production sites 994 Broiler production sites 659 Calf production sites 1,710
31 Supervision of animal welfare, results in 2014 animal welfare during the transport of animals number Inspected animal transport journey logs 7,537 - of which with supplementary GPS control 642 Number resulting in an intervention 77 - of which resulting from supplementary GPS control 32
Number of reports received on findings for slaughterhouses and assembly centres 177 Number resulting in an intervention 140
Number of transport controls 1,822 Number non-compliant 430 Number resulting in an intervention 365
Number of foreign complaints received about animal feed 49 Number resulting in an intervention 35 measures taken in respect of animal transport number Written warnings 170 Administrative fines 108 CDO (cease and desist order) procedure 3 Notification to a foreign competent authority in connection with infringement committed by foreign transporter 40 Inclusion of non-compliance in transporter’s file following foreign complaint 19 Total 340 animal welfare at the time of stunning and killing at the slaughterhouse number Number of reports on findings received 53 Number resulting in an intervention 52 measures relating to animal welfare at the time of stunning and killing animals number Written warnings 43 Administrative fines 2 CDO (cease and desist order) procedure 8 Total 53
References to specific reports
• Annual reports to the European Commission as referred to in Article 27 of Regulation (EC) No 1/2005 on non- discriminatory inspections of animals, means of transport and accompanying documents. • Annual reports to the European Commission as referred to in Decision 2006/778/EC concerning inspections of production sites on which certain animals are kept for farming purposes.
Supervision of animal welfare during transport, results in 2014
• In 2014, the Animal Intervention Bureau (IBD) continued its work on facilitating an integrated approach to offenders. A total of 7,537 journey log controls resulted in 77 interventions. • In 2014, the GPS data, and often also the tachograph records, were requested for a sample of 15% of the long- distance transports. In addition, these data were often requested following applications from the workplace and the pre-screening findings. Due to a shortage of IBD staff, no GPS data were requested for a period of a number of months and priority was assigned to dealing with statutory matters prescribed at national or EU level. • The problems with the enforcement of foreign transporters remain unresolved. The logbooks and GPS data requested from foreign transporters were not always submitted and, moreover, it is to date infeasible to impose administrative fines on and collect administrative fines from foreign transporters in countries other than Belgium and Germany.
32 Welfare during transport (controls by transport teams) number of inspections number non-compliant % non-compliant During road transport 1,420 319 22.5 Slaughterhouse 168 31 18.5 Assembly centre 110 27 24.5 Primary establishment 124 53 43 Total 1,822 430 24
• Compliance during animal transport remains a general point for concern. The percentage of non-compliances increased further from 16% in 2012 to 20% in 2013 and 24% in 2014. This is largely due to the increased number of more risk-oriented inspections. Conducting inspections on a risk-oriented basis increases the efficiency of the supervision and the effectiveness of the inspections. • A total of 2,362 inspections were carried during road transports in 2013, followed by 1,822 inspections in 2014. Although the number of inspections would appear to have declined, the 2013 reports include controls of empty wagons that do not relate to animal welfare. When the number of inspections is corrected for the controls of empty wagons then the number of inspections carried out in 2013 was 1,872, which is comparable with the number in 2014. • In 2014, 1,420 transports of animals were inspected in roadside controls. Non-compliances were observed in 319 cases. This is equivalent to 22,5% of the total number of controls, a 5% increase in the number of non-compliances from the previous year (17%). • The percentages of non-compliances identified during the controls of assembly centres and slaughterhouses fell sharply from 2013, from 35% and 30% to 24.5 and 18.5% respectively in 2014. This may be due to the effect of the more stringent enforcement in 2013, which may have resulted in the percentages of non-compliances returning to the levels prior to 2013. • In 2014, and in analogy with 2013, a new Calves Import project was initiated during the year. The controls carried out on the basis of risk analyses that resulted in a selection by high-risk countries. This revealed a non-compliance percentage of 78% (2013: 38%). The plans for 2015 also include controls of specific high-risk transports. These controls will then not only devote attention to imported calves but also to other young animals, such as young billy goats. The continuing failure to reach agreement on standards for the load rate and headroom complicates the inspection and enforcement of these transport requirements. • In 2014, in continuation of 2013, additional attention was once again be evotedd to poultry transports. A project plan was drawn up for this purpose. The plan included a campaign week scheduled in the autumn of 2014, during which a number of controls were to take place throughout the entire poultry chain. However, as a result of the outbreak of low pathogenic avian influenza these controls were not carried out in 2014. • 295 of the 394 reports/complaints received from colleague inspectors or members of the public that were investigated were held to be unfounded. Many of these reports related to reports about calves removed after the completion of 90% of the gestation period. This will also receive the necessary attention in 2015. • The NVWA Intelligence and Investigation Service (IOD) is called in when non-compliance is tantamount to fraud. The IOD and the Public Prosecution Service’s Functional Public Prosecutor’s Office devote attention to crime with an international trade or other component. In 2014, the investigations included an investigation of the neglect of ponies carried out on Germany’s request. • The Netherlands, in cooperation with the Danish and German authorities, drew up a position paper on animal transport. This was discussed during an international conference on animal welfare held on 14 December 2014, and then submitted to the European Commission. The position paper advocates an amendment of the Regulation on the protection of animals during transport, in part to improve controllability and enforceability. The following issues are then of particular importance: -- more explicit standards for the load rate and headroom. -- expansion of the obligation to install GPS systems to include short transports and poultry transports.
Supervision of animal welfare at the time of stunning and killing at the slaughterhouse
• In 2013 and 2014, a great deal of attention was devoted to the implementation of the new Regulation (EC) No 1099/2009 on the protection of animals at the time of killing. This Regulation, which entered into force on 1 January 2013, is intended to provide for the harmonisation of stunning and/or killing methods used for animals reared or kept for the production of food, wool, skin, fur or other products, as well as for killing animals in the control of animal diseases. On its entry into force the Regulation changed the supervision of animals in slaughterhouses and placed the emphasis on the operator’s responsibility for compliance with the welfare legislation. The NVWA’s supervision focuses on the establishments’ control of the killing process. 33 • The implementation of certain aspects of the Regulation have proven to be particularly difficult, in particular the development and application of standard working methods that the slaughterhouses are required to draw up for all phases of the production cycle. In 2014, the NVWA began to enforce the presence of these standard working methods. • Another important element of the Regulation relates to the development of guides to good practice by organisations of establishment operators. These guides lay down operating and monitoring procedures to be followed when killing animals, thereby providing proper guidance on animal welfare for operators of establishments. The guides are valuable instruments for operators of establishment as they help them in their compliance with the provisions of the Regulation, for example with respect to the development and application of standard working methods. In 2013 and 2014, the business community developed a guide to good practice to protect the welfare of poultry at poultry slaughterhouses from the time they arrive at the slaughterhouse grounds until the time they are slaughtered (poultry slaughterhouse welfare guide). Following consultations with the NVWA this guide was implemented in September 2014. The guide will be evaluated after one year and will then be made final. Work on the guide to good practice for small ungulate slaughterhouses has also reached an advanced stage and the implementation of the guide is scheduled for 2015. • In September 2014, an FVO audit was conducted of the animal welfare controls on the killing of animals, including the killing outside slaughterhouses and the delivery of animals to slaughterhouses. This audit was completed with success. The majority of the recommendations relate to comments about the assurances for timely and correct measurements. Attention to this issue is given, for example, during the NVWA’s system inspections and the training of veterinarians. The assurances at the slaughterhouses are provided in the form of the ‘animal welfare officers’ and the procedures as laid down in the standard working methods. • In 2014, a new supervision subject was developed within the context of the NVWA Improvement plan. This ‘new style’ supervision was introduced at all ungulate slaughterhouses during the course of the year. This began at the small and medium-sized slaughterhouses in March 2014, and at the larger slaughterhouses from October 2014. The poultry slaughterhouses will follow in 2015. • The new form of supervision entailed the introduction of new, abbreviated animal welfare checklists that replaced the regular checklists. For this reason some of the inspection records for 2014 have been recorded on the old, regular lists and entered in the ‘old’ database (ISI) and some have been recorded in the new system (SPIN/OBIEE). • These welfare controls are carried out at a frequency which is dependent on the risk profile of the relevant slaughterhouse. This profile is in turn dependent on factors including the size of the establishment and past infringements, where relevant. Ritual slaughtering without pre-stunning is also taken into account in the risk profile. The frequency ranges from 4 to 24 controls a year, increased by any re-inspections, where relevant. In addition, daily ‘operational’ checklists are completed daily at the larger slaughterhouses with permanent supervision. • The first group of 73 slaughterhouses that began to work with the new lists between 18 March and 19 June formed a pilot trial group. The results from this pilot trial will be evaluated at the beginning of 2015. It is striking to note that one third of these slaughterhouses had their standard working methods in order. Most of the non-compliances reported with killing related to slaughtering without stunning. Enforcement was not as yet involved in this evaluation. • System inspections relating to killing animals were begun in 2014. These inspections serve as a good aid in controlling compliance with all the provisions of the Regulation and, at the same time, in training the official veterinarians in their work environment. It is estimated that about 20 system inspections were carried out at poultry slaughterhouses and 20 at ungulate slaughterhouses in 2014. ‘Killing’ system inspections are scheduled for all slaughterhouses from 2015 onwards.
Supervision of animal welfare in primary establishments
• Every year the NVWA carries out animal welfare inspections at primary establishments and reports on their compli- ance level. The NVWA carries out inspections for compliance with the standards laid down in the European directives on the protection of pigs, laying hens, broilers and calves, as well as the Dutch legislation on animal welfare.
34 welfare of animals kept for farming purposes number inspected production sites with pigs 515 production sites without infringements 333 Inspected production sites with laying hens 8 production sites without infringements 8 Inspected production sites with broilers 131 production sites without infringements 56 Inspected production sites with calves 395 production sites without infringements 362
• Pig sector: In 2014, compliance with the rules for the protection of pig welfare was reasonable. Most cases of non-compliance identified in 2014 related to floors, adequate room for the animals to move and the permanent availability of adequate materials to pigs for exploration and play. Non-compliances were also identified with respect to feed, water and other substances (in particular, the permanent availability of sufficient fresh water to pigs) and minimum lighting levels (provision of a light intensity of at least 40 lux for at least 8 hours a day). • Laying hen sector: In 2014, the number of inspections carried out was too small to be able to draw a reliable conclusion about compliance with the animal welfare rules for laying hens. • Broiler sector: In 2014, compliance with the rules for the protection of welfare of broilers was 34%. The non- compliances that were identified related both to the accommodation regulations and the care of broilers, as well as to the administrative obligations. Most non-compliances related to non-compliance with the rules on notification and documentation, provision of flock data, the use of best practice guides and the setting up and keeping available inside the house of a collection of documents in which the production systems are described in detail. In addition, non-compliances related to the rules on mortality, such as excessive mortality, recording daily mortality rates and reporting mortality to the slaughterhouse. Non-compliances concerning lighting, loose material and the availability of sufficient space for the birds (stocking density) are also observed. • Calf sector: In 2014, compliance with the rules for the protection of calf welfare was good. The figures are based on inspections in both the calf and dairy cow sectors. The calf welfare inspections on dairy farms revealed that the prohibition on tying calves and the requirement that individual pens should not have solid walls were, in particular, infringed on a number of occasions .
Animal neglect
In 2014, the NVWA received 2,555 reports on animal neglect and on abuse of farm animals. About 80% of these reports related to the neglect of horses, ponies, sheep, donkeys and bovines. The other reports relate to animals including poultry and pigs. The majority of the reports are made by concerned members of the public. In addition to the reports, the NVWA also monitored various establishments warranting proactive attention and cases of animal neglect were also found during regular inspections. An intensive inspection regime is carried out at establishments where severe animal neglect is identified. In cases of severe animal neglect, this will often be a combination of non-compliances with the regulations on the rendering and the identification and registration of animals. In addition to criminal prosecution, sanctions under administrative law are widely used to rectify the situation, take animals away3 or to work towards the closure of the establishment. However, as sanctions under administrative law are much more effective in bringing about structural solutions these are used whenever feasible. Other parties also visit livestock establishments, such as veterinarians, feed suppliers and milk factory personnel: these parties are also jointly referred to as ‘professionals entering farms’. Experience has revealed that these professionals entering farms are often aware of animal neglect at an establishment.
In 2012, a broad representation from the business community, banks and government organisations signed the identification of animal neglect (signalering dierenverwaarlozing) covenant. Professionals entering farms, in cooperation with the confidential help desk for farm animal welfare (Vertrouwensloket Welzijn Landbouwhuisdieren), are now focused on prevention, timely identification and the provision of assistance. When this fails to achieve the required result then the NVWA is called in.
3 This, an administrative law term, means that animals are removed from the establishment and taken to a designated location at the owner’s/ holder’s expense until such time as a definitive decision is taken with regard to the animals. 35 The confidential help desk for farm animal welfare has received about 45 notifications from professionals entering farms a year since the covenant was signed in 2012. In 2014, ten of these cases were passed on to the NVWA. This number is relatively low, in part in view of the number of neglect cases the NVWA identifies during its regular supervision and the total number of notifications from members of the public.
Supervision of the animal welfare of animals used for scientific purposes
The NVWA’s laboratory animals domain supervises the Experiments on Animals Act. This Act, which entered into force on 18 December 2014, implements European Directive 2010/63/EU. The laboratory animals domain carries out inspections at nearly 80 institutions that have been issued a permit to carry out experiments on animals, rear animals for scientific purposes and/or to supply animals for scientific purposes. Inspections are carried out on the basis of a risk analyses of permit holders. This risk analysis is in turn based on parameters specified by the EU. In 2014, the NVWA carried out 297 inspections within the context of the Experiments on Animals Act. Three measures (written warnings) were taken during these inspections.
Conclusions
• The continuation of the effective, risk-oriented enforcement approach remains a top priority. • Enforcement efforts relating to poultry transports and transports, including long-distance transports, of calves continue to require an undiminished amount of attention. In 2015, attention will also be devoted to the transport of other young animals, such as young billy goats. • The controls of GPS data from long journeys (> 8 hours, excluding poultry) remain of undiminished importance to the enforcement of the regulations governing the duration of journeys, stopping at control posts and on driving and rest periods. • Although a great deal of progress was achieved in the development and application of best practice guides and standard working methods, the implementation of Regulation (EU) No 1099/2009 concerning the protection of animals at the time of killing remains an issue requiring attention. • Compliance in the pig sector was reasonable in 2014. Most cases of non-compliance identified in 2014 related to floors, adequate room for the animals to move and the permanent availability of adequate materials to pigs for exploration and play. • In 2014, the number of inspections carried out was too small to be able to draw a reliable conclusion about compliance with the animal welfare rules for laying hens. • Compliance in the broiler sector is inadequate and the compliance level will need to be increased in the coming years. • Compliance with the regulations on calf welfare is generally good. Non-compliance was, in particular, identified at dairy farms and primarily relates to the prohibition on tethering calves and non-compliance with the conditions attached to individual pens (sufficient width and perforated walls). • As in previous years, in 2014 the NVWA was extremely active in tackling animal neglect. Inspections are carried out in response to reports and establishments warranting attention are monitored proactively. An intensive inspection regime is carried out at establishments where severe animal neglect is identified. • An agreement framework for reporting animal neglect had already been agreed with what are referred to as ‘professionals entering farms’ (persons visiting a farm in a professional capacity, such as consultants or inspectors) in 2012. This lays down agreements for reporting and preventing neglect of farm animals. The NVWA holds a continually increasing number of presentations designed to increase the awareness of professionals entering farms. • Establishments reported to confidential help desk for farm animal welfare can obtain specific support. This support process not only devotes attention to animal welfare but also gives attention to the farmer’s personal situation.
36 4.5 Animal feed
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 178/2002 general principles and requirements of food law Regulation (EC) No 183/2005 animal feed hygiene Regulation (EC) No 1831/2003 additives in animal feed Regulation (EC) No 1829/2003 authorised GMOs in animal feed and foodstuffs Regulation (EC) No 1830/2003 Regulation (EC) No 999/2001 TSE regulation Regulation (EC) No 1069/2009 animal by-products Directive 2002/32/EC undesirable substances in animal feed Regulation (EC) No 767/2009 trade and use of animal feed Directive 90/167/EC medicated feedingstuffs Regulation (EC) No 669/2009 import controls on high-risk products
National: • Animals Act
Size of control file in 2014
type of establishment number at 01-01-2014 Approved and registered production establishments 1,556 of which food establishment operators 798 Transporters (including vessels) 2,880 Traders 2,023 Approved animal protein establishments 46 Representatives of third countries 15
Results for animal feed in 2014
Inspections and samples number Inspections of approved/registered establishments 1,127 • approved and registered production establishments 496 • inspections of project residues 6 • inspections for Regulation (EC) No 999/2001 73 • inspections of assurances for the purity of fats 10 • inspections of Tracking & Tracing 111 • inspections of laboratory notification obligation 12 • Complaints/reports 313 • re-inspections 106 Inspections at primary establishments (total) 331 samples in 2014 (total) 2,604 National Plan Animal Feed (analyses) 5,420
Further explanation of the results at authorised and registered establishments
Compliance by animal feed establishments has been shown to be generally high (>90%). Aspects that still require attention are general hygiene management, carry-over/cross-contamination, hazards and risk analysis. In addition, attention must also be paid to labelling and the correct use of claims. Traceability, in particular of vegetable products, still offers room for improvement.
37 Projects
Two projects were carried out in 2014.
Assurances for the purity of fats A specific project carried out with the colleagues of animal by-products and foods focus on the control of fats and oils. The traceability of these products in the chain and their labelling are specific points requiring attention.
Food residues The food residues project focused on the investigation of residues at production food establishments and traders. Six establishments were controlled. The end products/packaging at four of the six production establishments were not labelled or bore labels that did not comply with the requirements. Two establishments did not have complete administrative records (traceability). Production establishments usually sell food residues to traders, livestock farmers (often directly), other processing establishments and co-fermentation establishments. This last group, in combination with livestock farms, poses a risk as is feasible that downgraded residues are nevertheless being fed to animals. However, this project did not reveal any direct indications that this risk is materialising. The project will be continued in 2015.
Homogeneity tests
The NVWA has commissioned RIKILT to carry out an examination involving measurements of carry-over at animal feed establishments. This was necessary as it has transpired that measurements of carry-over at establishments is complicated: the value of the carry-over on one production day can, for example, differ significantly from the value measured at another time in the same production line
Controls at primary establishments
The regular inspections of animal feeds at primary establishments were supplemented with the following specific project:
Use of copper and zinc on pig farms This project reviewed the pig farmers’ approach to the reduction of the standard for pig feed to 170 ppm copper in feed for pigs of up to 12 weeks and 25 ppm for older pigs. Both feed and water were sampled at pig farms. A large number of liquid copper/zinc preparations are available on the market for administration via drinking water. Manure samples were also examined as the copper/zinc contents of manure provide a good indication of the total quantity of copper and zinc that pigs receive via their feed and/or drinking water. Extremely high levels of copper were found at 12 of the 48 pig farms that were inspected, and elevated levels at a further four. Enforcement actions were taken against these establishments. A high level of zinc was found at one of the pig farms that were inspected. Enforcement action was taken against this establishment.
Import controls
Import controls encompass high-risk products within the context of Regulation (EC) No 669/2009 and medium-risk products. Material controls are carried out on the basis of the National Plan Animal Feed. DDT was found in two consignments of millet from India. It transpired that the consignments in question had already been blended in compound feed at a limited percentage. The 2015 National Plan Animal Feed devotes specific attention to products from Asia, in particular from India. Dichlorvos was found in one consignment of maize. The consignment was vented, after which a repeat analysis tested negative.
National Plan Animal Feed
The National Plan Animal Feed relates to an examination of undesirable substances and forbidden materials in animal feed on the basis of factors including trend analyses and incidents. The examination has revealed a number of striking findings:
38 Autumn crocus containing high concentrations of colchicine, a plant toxin, has been found in a number of consignments of hay from the Eifel and other regions. Colchicine results in toxic symptoms in horses The NVWA issued a RASFF notification on this issue.
Two separate consignments of millet from India contained amounts of DDT (0.48 and 1.2 mg/kg) and HCH (0.16 and 0.11 mg/kg) that were above the permitted maximum level. Carry-over of antibiotics, in particular doxycycline and trimethoprim/sulfamethoxazole, in the drinking water was encountered at a number of pig farms. Chloramphenicol, a prohibited antibiotic, was found at concentrations of between 0.3 and 16 µg/kg in some 66% of the samples of straw that were examined. These samples originated from various EU Member States and regions in the Netherlands. The NVWA, in cooperation with the trade association, has initiated a further examination of the presence of CAP in straw.
Animal and fish bone fragments were found in 15 of 602 samples of animal feed for farm animals. Bovine DNA was identified in three of the samples. It is not possible to exclude the possibility that this originated from dairy products. Ruminant DNA was also found in one consignment of feather meal. No explanation for its presence is currently available. However, this consignment has been processed in the manure and pet food industries.
Forty-eight samples were tested for residues of packaging materials. The 0.15% tolerance was exceeded in three of the samples. One of these samples was from a consignment that had been rejected in an internal control. A second sample contained an amount exactly equal to the tolerance. The establishment in question will optimise the production process. This will be reviewed during a subsequent inspection. The finding for the third sample resulted in the establishment’s replacement of a vibratory sieve.
A number of 50 samples of alfalfa (18%) once again contained high to very high levels of pyrrolizidine alkaloids. There are currently no statutory standards for pyrrolizidine alkaloids. The results will be reported to the European Commission.
In 2014, 41 seed mixes for wild birds were tested for the presence of Ambrosia spp. Ambrosia was found in 16 of the 41 mixes, with levels in three of the 15 mixes which were above the 50 mg/kg limit specified in Directive 2002/32/EC.
Incidents
Controls in the event of incidents, complaints or reports play a key role in the supervision activities carried out by the NVWA. The NVWA receives indications of non-compliant animal feed via the European Rapid Alert System for Food and Feed (RASFF), direct contacts with other colleague services in EU Member States, reports from consumers submitted with the NVWA notification line and from NVWA and industry controls. Non-compliances usually relate to non- compliance with the standards for undesirable substances, but also to incorrect labelling of animal feed. The NVWA investigated several incidents in 2014. This resulted in measures in the following cases: • Fires: in 2014, the NVWA acted as a consultant following a number of fires in which smoke could have contaminated the surrounding fields to a greater or lesser extent. Prompt analyses of crops from the fields concerned indicated that no crop standards had been exceeded as a result of these fires. Air measurements in combination with crop analyses have demonstrated that air measurements offer a good indication for the rapid issue of warnings about threats or potential threats to public health. • Furazolidone in compound feeds: An inspection at a calf farm revealed the presence of Furazolidone, a prohibited antibiotic, in the cattle feed. This inspection lead to a cattle feed trader / producer. The prohibited substance was also found in the cattle feed producer’s cattle feed. The registration of the cattle feed establishment was suspended. Action was also taken in the calf sector, on the withdrawal of calves from the trade channel. The NVWA IOD is currently carrying out a criminal investigation of the cause and consequences of the presence of the prohibited substance. • GMO (Bt63) rice in choline chloride 60% maize meal from China. It has transpired that GMO rice is used as a carrier for the choline chloride. Inspections of the imports will be intensified.
39 Conclusions
• Compliance by animal feed establishments is generally high (>90%). • The sector responds to incidents by assuming the responsibility for traceability and the prevention of further spreading. • Issues that still require attention are general hygiene management, carry-over/cross-contamination, hazards, risk analysis and traceability. In addition, attention must also be paid to labelling and the correct use of claims.
40 4.6 Animal by-products
Controlling authorities: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 1069/2009 animal by-products – basic regulation Regulation (EC) No 142/2011 animal by-products – implementation regulation Regulation (EC) No 999/2001 TSE regulation
National: • Animals Act • Animal products decree (Besluit dierlijke producten) • Regulation on animal by-products (Regeling dierlijke producten)
Size of control file in 2014
activities of authorised/registered operators number Primary production approx. 40,000 Section I: storage of animal by-products 392 Section II: storage of derived products (authorised) 116 Section III: incineration/combustion of animal by-products/derived products (authorised) 50 Section IV: processing establishments 24 Section V: oleochemical establishments 3 Section VI: biogas establishments 104 Section VII: composting establishments 43 Section VIII: pet food 45 Section IX: handling of animal by-products and derived products outside the food chain 106 Section X: registered users for specific purposes 296 Section XI: assembly centres 16 Section XII: manufacture of organic fertilisers/soil improvers 39 Section XIII: other registered operators 1,130
Supervision of animal by-products, results in 2014
inspections & measures number • inspections of authorised ABP establishments (including granting of authorisation and issue of permits) 948 • inspections of registered ABP establishments 89 • inspections of establishments of origin (industrial food establishments including slaughterhouses and food 981 retail) • Destination controls 724 • Supervision of TSE sampling at cat. 1 processing plants 26 • Other inspections concerning safeguarding of trade flows 204 • Primary sector inspections 325 • Inspections of ABP transports DBP on the road 103 • Complaints and reports 255 Samples/analyses • Microbiological 153 • Chemical 24 Measures • Re-inspections 177 • Written warnings 263 • Fine reports 159
41 Further explanation of the results for animal by-products
The general compliance with the basic conditions attached to authorisation and registration is reasonable to good, although specific types of establishment, such as trading and storage establishments, do exhibit scope for improvement. However, the situation is not as good with respect to the introduction and implementation of HACCP and in-house inspections at establishments. This is a continuing issue for attention. As in previous years, a large proportion of the non-compliance relates to the traceability of the materials and products. Projects carried out on processed animal proteins and fats have revealed that the traceability of the materials is a problem. The business community strives to obscure the traceability of processed animal protein, in particular, for as far as is possible in connection with illegal exports of ruminant protein to countries outside the EU.
Controls in 2014
• Supervision of authorised and registered establishments. This relates to the supervision of authorisation conditions and registration conditions, as well as audits of HACCP systems, system inspections of controls carried out by establishments, such as process management, system inspections of traceability and chemical and microbiological analyses of samples. • Supervision of authorised and registered food establishments where animal by-products are created. • Destination controls of consignments traded in Intra-Community trade for which TRACES notifications are mandatory and imported consignments that must be transported in channelled transports from Border Inspection Posts. • Supervision of the collection of samples for TSE analysis when delivering carcases to category 1 processing plants. • Supervision of trade in animal by-products and derived products. This relates, in particular, to inspections of identification, documentation and traceability. This project placed the specific emphasis on the trade in processed animal proteins and fats and oils. • Supervision in the primary sector (livestock establishments) focused on the carcase regulations governing notification, keeping available, refrigeration, covering, removal and the administrative requirements. • Supervision of transports of animal by-products and derived products. This was carried out by stopping vehicles on the road for inspection. • The settlement of national and international complaints and notifications relating to animal by-products and derived products.
Incidents
Controls in the event of incidents, complaints or reports play a key role in the supervision activities carried out by the NVWA. The NVWA receives indications of non-compliant animal by-products (ABP) and derived products that are traded for animal feed and animal feed via the European Rapid Alert System for Food and Feed (RASFF), direct contacts with other colleague services in EU Member States, reports from consumers submitted with the NVWA notification line and from NVWA and industry controls. The majority of reports concerned non-compliance with microbiological standards relating to Salmonella in processed animal proteins. Other reports related to omissions in TRACES, including destination controls, and incorrect commercial documentation for animal by-products and derived products. An unusual incident related to the potential infection of beef with anthrax. As a result, potentially infected animal protein from Germany could not be placed on the Dutch market.
Conclusions
• The traceability of animal by-products remains an important issue for attention within the supervision of animal by-products and derived products • The large financial gains for establishments gives cause to the need for additional capacity relating to illegal exports of processed animal protein • The trade in processed animal protein remains an important issue requiring attention in the supervision
42 4.7 Meat (slaughterhouses, cutting plants and cold stores)
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 852/2004 food hygiene Regulation (EC) No 853/2004 hygiene of animal products Regulation (EC) No 854/2004 controls on animal products Regulation (EC) No 2073/2005 microbiological criteria Regulation (EC) No 2074/2005 implementing measures for certain animal products Regulation (EC) No 2075/2005 controls for Trichinella in meat Regulation (EC) No 999/2001 BSE
Size of control file in 2014
type of establishment number Domestic ungulates slaughterhouses 196 Poultry slaughterhouses 30 Farmed game slaughterhouses 23 Wild game slaughterhouses 15 Cutting plants for all types of meat (standalone) 195 Cutting plants affiliated to slaughterhouses 264 Cold and frozen stores (standalone) 139
Results for meat in 2014
NVWA inspections number • System inspections for maintenance of authorisation 430 • HACCP system supervision audits and inspections 2,342 certifications (in hours) 281,747 samples/analyses • Microbiological 2,028 • Antibiotics analyses 3,015 • Trichina (pigs 152,403, wild boar 706, equids 1,132) 154,241 Measures • Total number of written warnings 194 • Total number of official reports and fine reports 98 • Official detention 5 • Cease and desist administrative order 1 • Suspension of EC authorisations by NVWA 2 • Withdrawal of EC authorisations by NVWA -
Reference to specific reports, such as national plans and similar A separate report is being issued on the National Plan Residues.
Improvements in enforcement
The Meat chain improvement plan was launched in 2014. Two teams, a design team and a uniformity team, were formed for the implementation of this plan. The design team drew up a risk-oriented supervision model for small and medium-sized farm animal slaughterhouses that encompassed the supervision of issues including animal welfare, hygienic slaughter and animal health aspects. The uniformity team tested this supervision model in practice and supervised its introduction. In 2014, all farm animal slaughterhouses with permanent supervision were brought under this supervision model. Specific attention was devoted to four large calf slaughterhouses, with intensive enforcement to reduce faecal contamination to an acceptable level. 43 In 2014, the further improvement in enforcement in the meat sector resulted in an evident increase in the number of fine reports. In 2013, administrative law enforcement was introduced via the Animals Act As from 1 July 2013, the NVWA has the option of imposing administrative law fines. In 2013, the NVWA issued a total of 326 written measures for 340 observed infringements, whilst in 2014 the NVWA issued a total of 290 written measures for 438 observed infringements. The NVWA prepared 96 fine reports In 2014, a significant increase from the 33 fine reports in 2013.
A great deal of attention has, within the context of the Meat chain improvement plan, been devoted to hygienic slaughter processes. 83 written measures were drawn up within this context. The hygiene of the slaughter process in calf slaughterhouses has received a particularly great deal of attention. A total of 115 interventions were made at four calf slaughterhouses. In these interventions the speed of the belt was reduced or the belt was stopped, a prohibition on trade was imposed, an obligation to remove contamination was imposed, a prohibition on the supply of animals was imposed or corrective interventions were made.
In addition, structural discussions are taking place with business associations to explain changes in supervision, but also to report identified structural deficiencies which businesses can correct themselves. In conclusion, poorly performing establishments are discussed at the monthly NVWA enforcement meetings with a view to performing targeted enforcement at these establishments.
The more risk-oriented supervision of standalone cutting plants and cold stores was initiated in 2013. The past three years’ compliance results in the areas of HACCP, basic hygiene, traceability and smoking behaviour have been used to classify the establishments in a supervision pyramid. The supervision of poorly performing establishments is then increased and of well performing establishments decreased. This supervision pyramid was introduced in 2014.
Compliance with authorisation requirements by slaughterhouses and establishments
The NVWA has grouped meat producers into three categories for the purposes of granting and maintaining authorisation: • category 1: score 96-100% • category 2: score 81-95% • category 3: score 0-80% The score relates to the number of non-compliances identified during a system inspection at the establishment. The score is inversely proportional to the number of non-compliances.
Re-inspections relating to non-compliances are carried out in all categories. Establishments classified in category 3 can come into consideration for the procedure for the withdrawal of the authorisation.
The results from the inspections carried out in 2014 were analysed and the establishments were then classified into the three categories. The results, expressed in percentages, are listed in the following table:
Categories of meat processing establishments category 1 category 2 category 3 Farm animal slaughterhouses with permanent supervision 80% 20% 0% Farm animal slaughterhouses without permanent supervision 92% 6% 1% Poultry slaughterhouses 70% 17% 13% Game processing establishments 85% 15% 0% Cutting plants (standalone) 93% 6% 1% Cold stores (standalone) 95% 4% 1%
The number of category 3 establishments declined in 2014. In 2013, eighteen establishments were classified in this category, whilst seven establishments were classified in this category in 2014. In 2014, the majority of the non- compliances that were identified related to the same basic conditions, such as the requirements governing floors, walls, ceilings, equipment, personal hygiene and hygienic slaughtering practices. However, fewer infringements were identified than in previous years. This is an indication that the structural condition of the buildings and the hygiene at these establishments is generally better than in previous years. However, this is not true of poultry slaughterhouses, although the number of establishments in this sector classified in category 3 has also declined from four to three.
44 A downward trend, in conclusion, can be observed in the total number of EC authorisations in the meat sector in 2014. The total number of EC authorisations was 1,761 on 1 January 2014, as compared to 1,739 on 31 December 2014. Consequently, the number of EC authorisations fell by 22 in 2014, largely relating to the cutting plants processing domestic ungulates and poultry.
HACCP system supervision audits
In 2014, 2,592 system audits and inspections were performed in connection with HACCP supervision in the meat and food safety domain. Any non-compliances identified during an audit gave cause to a subsequent re-inspection to determine whether the non-compliances had been rectified. In 2014, the system audits and inspections carried out relating to the HACCP principles revealed the following: • Farm animal slaughterhouses with permanent supervision: compliance with the HACCP principles is reasonable to good. It is striking to note that in relative terms the establishments’ monitoring procedures and procedures for the delivery of animals exhibit the most deficiencies (7% and 13% of the number of audits conducted respectively). Moreover, and in analogy with 2013, compliance with the basic conditions was poorer. One explanation for the large numbers of non-compliances with the basic conditions may be due to the fact that these are large establishments with many different production rooms. For this reason, there is a greater probability that non-compliances will be established at these establishments. • Poultry slaughterhouses: Compliance with the HACCP principles is reasonable to good. It is striking to note that non-compliances are most frequently exhibited by the monitoring procedures (in 6% of the total number of audits), updated documentation (in 6% of the total number of audits) and the procedures that guarantee that products of animal origin comply with specific requirements (in 19% of the total number of audits). The audits once again reveal that compliance with the basic conditions was poorer. One explanation for the large numbers of non-compliances with the basic conditions may be due to the fact that these are large establishments with many different production rooms. • Farm animal slaughterhouses without permanent supervision: Slaughterhouses with < 10 LU4 comply reasonably well with the HACCP principles, as these establishments make good use of hygiene codes. No serious infringements were observed. Slaughterhouses with > 10 LU comply reasonably well with the HACCP principles. The most frequent non-compliance relates to the failure to carry out verification procedures or the failure to carry out the verification procedures correctly (12% of the number of audits conducted). As in previous years, some of these establishments did not comply with the basic conditions consistently. In 2014, for this reason, specific attention was devoted to this category of establishments in the Meat chain improvement plan. • Cutting plants (standalone): Compliance with the HACCP principles is reasonable to good. It is striking to note that non-compliances are most frequently exhibited by the procedures that guarantee that products of animal origin meet specific requirements (in 19% of the total number of audits). The audits also reveal that this category of establishments do not always comply with the basic conditions. • Cold stores (standalone): Compliance with the HACCP principles is reasonable to good. Serious infringements were observed in the monitoring and verification procedures in 6% and 6% respectively of the total number of audits that were conducted. The traceability and labelling system inspection is of great importance in this category of establishments, (see below). • Game processing establishments: Compliance with the basic conditions is good and the large majority of the establishments comply with the HACCP principles. No serious infringements were observed.
Traceability and labelling system inspections
The 2013 horse meat affair resulted in the performance of compulsory traceability and labelling system inspections at all types of establishment. 115 infringements were observed during these inspections. This resulted in ten written warnings, thirteen verbal warnings, one fine report and three other interventions. These system inspections may give cause to a further examination in the form of an EDP audit5 to obtain an improved insight into the establishment’s administrative and financial flows.
4 LU = livestock unit (1 dairy cow is 1 LU) 5 EDP audit = electronic data processing audit 45 Fraud indicators
The NVWA began with the preparation of fraud indicators in 2014. This enables inspectors to report suspicions of fraud either with or without grounds. The NVWA IOD reviews the results and may decide to investigate the situation further.
Food Chain Information (FCI) reliability project
Official NVWA veterinarians who have doubts about the reliability of FCI can arrange for an investigation of the primary establishments. This resulted in visits to poultry, pig, sheep and cattle farms and to a duck and rabbit farm. The findings from the controls revealed that these doubts were regularly justified in the case of dairy and other cows and pigs. The most frequent reason for the doubts was the discovery of antibiotic residues during microbiological screening whilst no use of antibiotics had been stated in the FCI. In other cases, whilst no disease symptoms and/or administration of medicines are stated in the FCI, the AM and/or PM inspections give cause to presume the contrary. A fine report is then issued to the relevant livestock farmer.
Project on visual chain inspections for pigs and visual inspections for calves
In 2014, visual inspections were introduced as the standard procedure at all pig slaughterhouses. In addition, the implementation of what is referred to as ‘supply chain meat inspection’ at three pig slaughterhouses was assessed by means of audits and verifications at both slaughterhouse and farm level. The results are good. The conditions attached to the implementation of visual inspections at calf slaughterhouses were adopted in 2013. This procedure was implemented incrementally at four large calf slaughterhouses in 2014, simultaneously with the standardisation of the post-mortem inspection in these establishments. A great deal of progress was achieved at these establishments in 2014.
Incidents
The most serious incident related to a cattle slaughterhouse where the traceability of the meat was not in order, the origin of the meat could not be demonstrated clearly and, as a result, food safety could not be guaranteed. For this reason, the EC authorisation of this establishment was suspended for two months. This case resulted in the official detention of meat at a further three establishments because of the lack of clarity about its origin.
Many other incidents were dealt with via the Rapid Alert System.
Conclusions
• The overall effectiveness of the supervision is reasonable. However, the 2013 horse meat affair also required the necessary political attention and had an impact in 2014. An improvement plan to enhance supervision at the slaughterhouses was initiated in 2014. This had the necessary impact at the small and medium-sized slaughterhouses and at four calf slaughterhouses. The supervision of faecal contamination, in particular, was a spearhead. • In 2014, attention was once again devoted to improving enforcement . The introduction of the Animals Act has rendered the issue fine reports feasible. An increase in the number of fine reports is discernible: whilst 33 fine reports were issued in 2013, 96 fine reports were issued in 2014. • In 2014, a risk-oriented approach to system inspections was adopted whenever feasible: the inspections of poorly performing establishments were increased and of well performing establishments decreased. However, to improve the design structure and to provide for the use of the compliance data from the previous three years, the first phase of the implementation of the supervision pyramid focused on standalone cutting plants and cold stores.
46 4.8 Meat products
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 178/2002 general principles and requirements of food law Regulation (EC) No 852/2004 food hygiene Regulation (EC) No 853/2004 food hygiene of products of animal origin Regulation (EC) No 2073/2005 microbiological criteria for foodstuffs
Size of control file in 2014
control file in 2014 number Production establishments 595 Officially authorised 57 Cold and frozen stores (standalone)* 61 Meat wholesalers and importers 133 Total number of establishments 846 * This relates to cold and frozen stores that do not combine their operations with other activities (slaughtering, production of meat preparations and meat products). However, when an establishment’s main activity is the slaughtering or production of meat preparations and meat products then the establishment is classified in that category and not as a cold and frozen store.
Supervision of meat processing establishment, results in 2014
Inspections number HACCP system audits 117 HACCP system inspections 425 Regulation (EC) No 2073/2005 system inspection 348 Inspections of basic conditions 677 Tracing 134 Other inspections (complaints, digital re-inspections (RI), tough when needed (TWN) 374 Total audits/inspections 2,075
microbiological and chemical number Chemical samples 108
Interventions number Inspections resulting in written warnings 283 Administrative fine/official report inspections 45 Total number of measures resulting from inspections and samples 328
Improvements in enforcement
Over the past few years a great deal of attention has been devoted to improving enforcement at industrial meat processing establishments. The frequency of the audits has been brought into line with those at non-authorised establishments by reducing the frequency of the audits at production establishments from once every two years to once every three years.
Results at meat processing establishments
HACCP system inspections The risk-oriented supervision of meat processing establishments was continued in 2014. In 2011, the meat processing establishments had been classified into compliance categories – what is referred to as the ‘colour pyramid’. This
47 classification is based on the number and nature of the non-compliances observed at these establishments in the past. The number of interventions at an establishment determines the colour under which it is classified. In 2014, the supervision of the establishments was determined on the basis of their colour classification, whereby green establishments were assigned a relatively low visit frequency, orange establishments a slightly higher frequency and red establishments were to be inspected most frequently. When insufficient information is available about an establishment it is assigned the colour white.
Following the introduction of the colour classification for establishments the number of non-compliances identified during the inspections has increased in the years since 2011. In 2014, the percentage of non-compliances identified during inspections declined for the first year since 2011: the total of 2,075 audits and inspections carried out in 2014 gave cause to 328 interventions (16%). The non-compliance percentages in the last 4 years were as follows: year percentage of non-compliances in audits and inspections 2011 9% 2012 13% 2013 18% 2014 16%
At the end of 2014, the classification of the meat processing establishments into the colour categories was as follows:
Category 2013 2012 2014 Green 33% 38% 43% Orange 60% 56% 54% Red 1% 1% 1% White 6% 5% 2%
It is striking to note that although the percentage of non-compliances in audits and inspections has decreased slightly, the percentage of green establishments has decreased whilst the percentage of orange establishments has increased.
HACCP system audits
A total of 117 HACCP audits were conducted in the meat sector in 2014. Any non-compliances identified during an audit give cause to a re-inspection within a specified period to determine whether the non-compliances had been rectified. 54% of the total number of HACCP audits at authorised and registered establishments revealed non-compliances.
Incidents
In 2014, a great deal of capacity was once again allocated to dealing with incidents and reports of unsafe foods. One of the most important reports during the year was the report of meat infected with anthrax. A number of establishments were visited in connection with this report. The relevant meat was traced and was removed from the market whenever this was feasible.
Projects
Supervision of mechanically separated meat production establishments All mechanically separated meat establishments (some 20 establishments) were intensively controlled in 2014. In 2014, all mechanically separated meat establishments were subjected to an NVWA sampling programme in which the results of the samples were reviewed against the requirements of Regulation (EC) No 2073/2005 that are applicable to what is referred to as mechanically separated meat ‘category 3’. Alongside the hygiene, raw materials and processing in these establishments, the labelling of mechanically separated meat is also an issue that requires attention. The objective was to ensure that all mechanically separated meat producers were stating the name of the product properly and traceably on the product at the source. In 2014, the NVWA drew up a draft information brochure to clarify the NVWA’s interpretation of the statutory regulations governing mechanically separated meat for the sector. In 2015, the NVWA will adopt the final content of this information brochure and publish the brochure on its website for the establishments that produce and process mechanically separated meat In 2014, the NVWA also began to supervise the labelling of
48 mechanically separated meat in consumer products containing mechanically separated meat. The examination of the labelling of mechanically separated meat at the processing establishments will be completed in 2015.
Particular details
In 2014, authorised meat processing establishments that were consistently performing poorly were approached in accordance with the ‘Tough when needed’ method. The establishments that consistently perform poorly are then given the choice of either shutting down operations or implementing structural improvements. This is an intensive approach which can sometimes result in lengthy legal procedures but ultimately demonstrably bears fruit. Only a very small number of authorised establishments (< 1%) were confronted with this tough approach in 2014.
Conclusions
The risk-oriente d inspection approach was continued in 2014. The authorised production establishments have been classified into compliance categories on the basis of the non-compliances identified in recent years. Measures are taken in accordance with the intervention policy both during the inspections and audits. The ratio of the number of interventi- ons to the number of audits and inspections fell in 2014 as compared to 2013: 16% (2013: 18%). It is striking to note that although the number of interventions has declined the colour classification of the establishments has also deteriorated.
49 4.9 Imports of veterinary consignments
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Directive 91/496/EEC veterinary checks on animals from third countries Directive 97/78/EC veterinary checks on animal products from third countries animal health rules governing the production, processing, distribution and Directive 2002/99/EC introduction of products of animal origin for human consumption Decision 2004/292/EC introduction of TRACES document for the declaration of and veterinary checks on animals from third Regulation (EC) No 282/2004 countries Regulation (EC) No 136/2004 procedures for veterinary checks on products imported from third countries official controls on compliance with feed and food law, animal health and animal Regulation (EC) No 882/2004 welfare rules Regulation (EC) No 853/2004 specific hygiene rules for food of animal origin specific rules for the organisation of official controls on products of animal origin Regulation (EC) No 854/2004 intended for human consumption Decision 2007/275/EC lists of animals and products to be subject to controls at border inspection posts Decision 2011/163/EU residue monitoring plans of third countries
Size of control file in 2014: Inspection centres: 18 (belonging to one of the seven designated Border Inspection Posts [BIPs])
Supervision of imports, results in 2014
results number number of import consignments 60,938 of which consignments of live animals 7,602 Number of laboratory analyses 1,530 Measures: number of refusals 436
General The NVWA’s control process for the import and transit of live animals and products of animal origin from countries outside the EU is laid down in a quality system. This quality system has been accredited by the Dutch Accreditation Council (Raad voor Accreditatie) pursuant to ISO/IEC 17020. The NVWA and Customs work closely together on the basis of a covenant. The official veterinarians and assistants deployed at the Border Inspection Posts (BIPs) attend internal training and refresher days.
year number of consignments presented number of refusals 2011 61,596 31 2012 59,159 246 2013 59,022 393 2014 60,938 436 The number of consignments has fluctuated at around 60,000 since 2009.
Main objectives
The main objectives for the coming years are: • increase the effectiveness of supervision by the further introduction of risk-oriented supervision when this is allowed by the European regulations and increase the importers’ attention to food safety and animal health. • increase the efficiency on import by harmonising the supervision systematics for veterinary and vegetable products.
50 • organise the control process more efficiently by making use of electronic rtificatesce from third countries. Within this context, a pilot project was initiated at Amsterdam Airport Schiphol in which document controls are carried out on the basis of the certification information in TRACES and subsequent to the control the original certificate can be submitted later.
FVO audit
An FVO mission visited in October 2014 to review the use of TRACES. The FVO issued two recommendations relating to the structure of the competent authority and to the data entered in TRACES pursuant to the European regulations. The recommendations will be implemented in 2015.
Direction at the border, the ‘single window’ and ‘one-stop shop’
The NVWA’s main government partner at the border is Customs. EU developments and the national customs policy will change this cooperation with Customs in the coming years: More of the information of the enforcement authorities will be available for exchanges. The existing cooperation will be intensified. Supd@x (the Supply Chain Data Exchange) was introduced for the supervision of veterinary consignments at the Port of Rotterdam in 2013. This simplifies exchanges of data between the public authorities’ various declaration and notification systems. This also provides for the availability of status information on controls (by the Netherlands Food and Consumer Product Safety Authority and Customs) to the relevant authorities and responsible business community. The introduction and completion of the original Supd@x veterinary business case made a major contribution to the optimisation of the veterinary import chain. Supd@x veterinary is also an initial step towards the Single Window Trade & Transport (SWH&T) system in the Netherlands. Work also continued on the development of the National Inspection Terminal. The objective is then to create a one-stop shop where a number of government agencies can inspect a consignment simultaneously at one location.
Passenger checks
In 2014, the NVWA once again requested Customs to conduct passenger checks relating to animal products and pets brought into the Netherlands from abroad. The checks on passengers bringing products of animal origin into the Netherlands were frequently scaled up or down in close consultation between the NVWA and Customs on the basis of the results from risk analyses of the fluctuating animal disease situations in third countries. In 2014, for public health reasons, specific attention was also devoted to passenger baggage from areas in which Ebola is prevalent. This did not result in any special findings.
Microbiological monitoring
A microbiological monitoring plan is drawn up once a year on the basis of Regulation (EC) No 136/2004. This takes account of the risks posed by various product/country combinations in relation to specific microorganisms as based on previous findings and RASFF notifications. The positive trend towards fewer non-compliant findings that was identified in 2010 continued in 2011. In 2011, this gave cause to a review of the need or desirability of any amendments. This resulted in the decision to focus the 2012 monitoring programme exclusively on the control of specific Salmonella species. As the results gave no cause for the continuation of the monitoring for a further year it was decided, in 2012 and in response to developments, to focus the programme primarily on STEC6 in fresh and frozen beef. The results from this programme during the first part of 2013 and the outcomes of the EFSA consultations yielded in a guidance document that the European Commission will discuss with the Member States during the course of 2015. During 2013, Salmonella samples from poultry imports one again tested positive. This resulted in the re-inclusion of Salmonella in the monitoring programme for 2014. 265 samples from 53 consignments were examined, of which 14 samples from 5 consignments tested positive.
6 STEC = shiga-toxin producing E. coli 51 Increased number of controls in 2014
Controls pursuant to articles 20 and 24 of Directive 97/78/EC in the Trade Control and Expert System (TRACES) were stepped up as from February 2012. The number of consignments inspected in 2013 increased sharply as compared to 2012 (from 106 to 916). 685 consignments were inspected in 2014. It is striking to note that many of the establishments that enter the regime never exit again. It is questionable whether establishments assigned Article 20 status for a long period of time should actually be included on the list of establishments of the relevant country.
Conclusions
The supply of consignments of veterinary goods is stable, with fluctuations in supply of less than 5%. The number of refusals is largely due to problems with documentation and the consignments subject to more stringent supervision. The number of inspections pursuant to articles 20 and 24 was lower than in 2013.
52 4.10 Industrial production – Composite products
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 178/2002 general principles and requirements of food law Regulation (EC) No 852/2004 food hygiene Regulation (EC) No 2073/2005 microbiological criteria for foodstuffs
Size of control file in 2014 control file in 2014 number Food factories 1,703 Food importers 751 Food trading companies 2,611 Food office addresses 946 Food transport companies 323 Total number of establishments 6,334
Supervision of registered establishments, results in 2014 inspections number HACCP system audits 85 HACCP system inspections 638 Regulation (EC) No 2073/2005 system inspection 149 Inspections of basic conditions 977 Tracing 185 Other inspections (complaints, digital RI, TWN) 1,240 Total audits/inspections 3,274
Interventions number Inspections resulting in written warnings 362 Administrative fine/official report inspections 67 Samples resulting in written warnings - Samples resulting in administrative fine/official report inspections - Total number of measures ensuing from inspections and samples 429
Further explanation of the results at non-authorised establishments
HACCP system inspections The risk-oriented supervision of non-authorised production establishments was developed further in 2014 The establishments have been classified into compliance categories, into what is referred to as the ‘colour pyramid’. This classification is based on the number and nature of the non-compliances observed at these establishments in the past. The number of interventions at an establishment determines the colour under which it is classified. In 2014, the supervision of the establishments was determined on the basis of their colour classification, whereby green establishments were assigned a relatively low visit frequency, orange establishments a slightly higher frequency and the red establishments were to be inspected most frequently and stringently. When insufficient information is available about an establishment it is assigned the colour white.
Following the introduction of the colour classification for establishments the number of non-compliances identified during the audits and inspections has fluctuated at around the relatively high level of 20% in recent years. The number of interventions resulting from audits and inspections fell sharply to 13% in 2014. This reveals a break from the trend of the previous years. More information is enclosed below:
53 year percentage of non-compliances in audits and inspections 2011 22% 2012 21% 2013 20% 2014 13%
No explanation of the cause of this break from the trend is currently available. However, it is striking to note that the percentage of interventions resulting from audits and inspections of authorised production establishments has also declined, although to a less extent than for the composite products. At the end of 2014, the classification of the non-authorised establishments into categories (colours) was as follows:
Category 2014 2013 2012 Green 49% 50% 51% Orange 29% 35% 30% Red 1% 1% 1% White 21% 14% 18%
HACCP system audits In 2014, a total of 85 HACCP audits were conducted at establishments that produce composite foods (2013: 185). 54% of the total number of HACCP audits at authorised and registered establishments revealed non-compliances.
A new method for the supervision of traceability was developed in 2013. Inspections have been carried out in accordance with this new method since mid-2013. Following the introduction of the new method, the number of identified non-compliances increased from 6% in 2012 to 17% in 2013. In 2014, the percentage of traceability interventions remained at 17%. This is indicative of a stabilisation in the percentage of non-compliances.
Incidents
In 2014, a great deal of capacity was allocated to dealing with incidents and reports of unsafe foods. Many reports were received about establishments bring unsafe products on the market. Where these products were also supplied to or from other Member States the situation was notified via the Rapid Alert System Food and Feed (RASFF).
Projects
In 2014, specific attention was devoted to the bulk transport of foods in liquid, granular or powder form. Food of this nature may be transported solely in tanks bearing a label such as ‘reserved for foodstuffs only’ and these tanks may be used solely to transport food. Thirty establishments were visited during this project: measures were taken when it transpired that the relevant tanks were not used exclusively for food transport. This caused a great deal of unrest in the sector. This ultimately resulted in the amendment of the intervention policy governing the bulk transport of foods of this nature: a number of fines that had been imposed were also rescinded. The information brochure on bulk transports was also revised accordingly at the end of 2014. In the most important revision, not only food of vegetable origin but also food of animal origin may now be delivered to non-food establishments solely in ‘reserved for foodstuffs only’ tanks.
Particular details
In 2014, non-authorised food establishment operators that were consistently performing poorly were once again approached according to the ‘Tough when needed’ method. The establishments that consistently perform poorly are then given the choice of either shutting down operations or implementing structural improvements. This is an intensive approach which can sometimes result in lengthy legal procedures but ultimately demonstrably bears fruit.
54 Conclusions
• In 2014, the NVWA once again focused on improving enforcement by adopting a more risk-oriented approach and devoting more attention to the further development of the intervention policy. The ratio of the number of interventions to the number of audits and inspections fell sharply for the non-authorised establishments in 2014, from 20% in 2013 to 13% in 2014. • In general, a risk-oriented approach to system supervision was adopted whenever feasible in 2014: the inspections of poorly performing establishments were increased and of well performing establishments decreased. • A relatively large amount of NVWA capacity was allocated to dealing with incidents and reports. • It transpired that bulk transports of foods were not carried out completely in line with the policy laid down in the information brochure. Following consultations with the sector the policy was amended.
55 4.11 Fish, fish products and aquaculture
Controlling authorities: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 852/2004 food hygiene Regulation (EC) No 853/2004 hygiene during production of products of animal origin Regulation (EC) No 854/2004 supervision of products of animal origin Regulation (EC) No 2073/2005 microbiological criteria for foodstuffs Directive 2006/88/EC aquaculture
Size of control file in 2014 type of establishment number Establishments handling and processing fishery products 274 Factory vessels 155 Freezer vessels 14 Fish auctions 14 Cold and frozen stores 58 Dispatch centres 38 Purification centres 15 Fish farms 63 Mollusc and crustacean farms 143 Total 711 Total number of establishments with EC authorisation 568
Reference to specific reports, such as national plans and similar A separate report is being published on the National Plan Residues.
Supervision of fish products, results in 2014 inspections, samples and measures number • Inspections in 2014 (in hours) 19,863 • Certifications (in hours) 10,070 • Samples/chemical analyses 100 • Samples/microbiological analyses 1,950 Measures • Warnings 246 • Administrative fines 35 • Official reports 6 • Suspensions of registrations/authorisations 0 • Withdrawals of registrations/authorisations 0 Total 287
Further explanation of the results for fish products
• This target group is represented by a relatively large number of small and medium-sized fish processing establishments with a relatively simple production process. The sector also has about 20 large industrial establishments. • There are currently 399 EU approved fish processing establishments in het Netherlands (situation on 1 January 2015) at which the NVWA carries out food safety controls. A further five new establishments have entered the procedure for definitive approval. The Netherlands also has 155 EU approved fishing vessels, the majority of which are engaged in shrimp fishing, and 14 EU approved freezer vessels. 739 inspections and 116 audits were carried out in 2014. The
56 NVWA implemented its intervention policy on 218 occasions in the period from 1 January 2014 to 31 December 2014 inclusive.
Control subjects in 2014
• Basic conditions: the basic conditions relate to the establishment’s structural infrastructure and working methods and hygiene, as well as to keeping the temperature of the products at the correct temperature. • HACCP: HACCP relates to obtaining an appropriate insight into and an appropriate control of health risks associated with the establishment’s preparation and processing methods. • Tracing and reporting: establishments must be able to trace their products. They must be able to establish the origin and destination of each product. An establishment that is aware that a product is unsafe must remove the product from the market and notify the NVWA of the situation. Establishments cannot recall unsafe products in the absence of good traceability systems. • Microbiological criteria: microbiological analyses are carried out to verify that the product complies with these criteria and, consequently, is safe.
Interventions on the basis of control subjects
174 of the establishments in this target group comply with the statutory regulations. Interventions were necessary at 218 establishments and one establishment received specific attention due to its structural non-compliance with the regulations. Seven establishments were not visited in 2014.
HACCP system supervision
739 inspections and 116 audits were carried out within the context of the HACCP system supervision of the fisheries sector in 2014. Official controls at purification centres focused specifically on the validation of the purification process as part of Regulation (EC) No 853/2004.
Health criteria
In 2014, the regular inspections and audits were supplemented with the further monitoring of the following subjects in the form of the additional supervision of health criteria during the official controls:
Organoleptic examination Organoleptic examinations are carried out on random samples in the production, processing and distribution stages. One of the objectives of these controls is to determine compliance with the freshness standards pursuant to Community legislation. Non-compliance with the minimum freshness standards at the time of first landing was, in particular, identified in the prawns product group.
Parasites The organoleptic examinations include visual inspections of random samples taken at first landing for the presence of parasites. Pursuant to the prevailing legislation, species of fish that could contain parasites and will be consumed raw must be frozen for at least 24 hours before being offered to consumers. Audits of establishments that prepare and trade in fish consumed raw focus on issues including the implementation of the freezing process as part of the food safety system designed to guarantee that any parasites in these types of product are killed.
Results from freshness indicators In 2014, organoleptic examinations did not give any cause for doubts about the freshness of the products. One consignment was destroyed. For this reason no verification samples were taken to determine the level of total volatile basic nitrogen (TVB-N) and trimethylamine nitrogen (TMA-N) in 2014.
Histamine Random histamine controls on a risk-oriented basis are carried out to examine compliance with the histamine limits defined in Community legislation. Pursuant to this risk-oriented approach, the NVWA focuses its sampling and analysis of fish with a high histidine content on imports of this type of fish from third countries. The control of this risk at
57 regional establishments is focused on the operational food safety plan and the in-house verifications of this health criterion by the establishments.
Residues and contaminants Controls were carried out on the presence of residues and contaminants. The sampling was focused on products from third countries. Analyses were carried out to examine the presence of residues of malachite green and leucomalachite green or its substitutes, pesticides and antibiotics residues in farmed fish from tropical regions. Analyses are also carried out within the context of the National Plan Residues and the monitoring of fish and fish products from the various fishing areas. The monitoring results gave cause to the imposition of territorial restrictions on inland fisheries, largely on account of concentrations of dioxin above the limit for eel and mitten crab in zones in which a fishing ban has been imposed.
Microbiological controls The majority of the microbiological controls of fish and fish products other than molluscs, crustaceans and smoked fish are carried out in the retail channel. Non-compliances with the safety criteria give cause to specific inspections of the establishments responsible for their production. The sampling of molluscs and crustaceans at retail level is supplemented with official sampling at the purification centres, dispatch centres and production areas. In addition to the assessment of potential non-compliances with food safety criteria – and notwithstanding the absence of an explicit Community standard – attention is also devoted to the presence of Norovirus. As no Norovirus standards are specified in the European Regulation, no interventions were made following the identification of Norovirus in controls carried out in 2014. However, a proposal was submitted to the European Union Working Group on live bivalve molluscs on the specification of standards for live bivalve molluscs consumed raw.
In 2014, a total of 515 samples for chemical analysis and 600 samples for microbiological analysis were included in the year plan as part of the official control of the aforementioned subjects.
Food and Veterinary Office (FVO) The FVO assessed the official control of fish and fish products in the Netherlands in 2014. The results from this FVO audit have been published on the DG Santé website and can be accessed via the link Rapportage FVO vis en visproducten 2014
RASFF 2014 In 2014, 35 establishments in the group of EU approved fish processing establishments were involved in RASFF notifications. Priority is assigned to excessive levels of residues of environmental contaminants in fish and Listeria monocytogenes in smoked fish.
Conclusions
• The risk-oriented supervision, which was continued in 2014, makes an important contribution to the selection of establishments that are to be inspected and the frequency with which they will be inspected. • Official controls carried out in the fish and fish processing industryn ofte reveal the need for interventions. For this reason, the inspection capacity for these official controls was expanded in 2015. • Chemical analyses of histamines, pesticide residues and antibiotics in imported fish did not reveal any need for the imposition of measures • In 2014, the measures relating to sampling were focused largely on microbiological non-compliances with the food safety criteria for molluscs and crustaceans and fish products. • The presence and growth of Listeria monocytogenes in smoked fish remains an issue that requires attention. • RASFF notifications contribute to the investigation and prevention of oodf safety issues at international level. • Non-compliances with the food safety criteria for and the presence of Norovirus in molluscs and crustaceans are being observed. The NVWA is tackling this latter issue by cooperating with the National Reference Laboratory and EURL in the development of a robust analytical method to determine the presence of Norovirus. The Netherlands has submitted a proposal to the European Commission for the introduction of standards for Norovirus levels in molluscs and crustaceans that are consumed raw. • The fish processing sector includes a large number of small and medium-sized establishments, each with its in-house food safety plan. The appropriate implementation and maintenance of an in-house food safety plan is a complex issue for many establishments. This results in the risk that in the short and medium term establishments may not
58 comply with the requirements governing the production of safe food. Although there is no best practice guide for the fish processing sector and no hygiene code approved by the Minister, the expectations indicate that the development of a code of this nature could make a contribution to the improvement of the level of compliance. In 2014, the Dutch fish auctions implemented the Hygiene Code approved by the Minister of Health, Welfare and Sport in 2014. • In 2015, the NVWA will begin to publish its reports on the inspection of EU approved fish processing establishments, whereby in the first instance the authority will publish the reports on the inspection results collected during official controls of Dutch fish auctions.
59 4.12 Dairy, eggs and egg products
Controlling authorities: COKZ, NCAE and NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 178/2002 general principles of food law Regulation (EC) No 852/2004 food hygiene Regulation (EC) No 853/2004 hygiene during production of products of animal origin Regulation (EC) No 2073/2005 microbiological criteria for foodstuffs
Size of control file in 2014
type of establishment number agricultural establishments in the dairy sector • Dairy farms 18,665 • Goat dairy farms 495 • Sheep dairy farms 40 • Horse dairy farms 25 • Camel dairy farms 1 food manufacturers, importers, trading and storage establishments in the dairy sector • Industrial dairy producers 173 • Subsequent processors 116 • Storage locations 30 • Small-scale processors and farm dairy processors including door-to-door sales of dairy products 441 • Producers of special foods 9 Total 769
agricultural establishments in the poultry sector • Egg laying poultry establishments 1,001 food manufacturers, importers, trading and storage establishments in the poultry sector • Collectors 20 • Packing stations 97 • Egg product producers 27 • Egg product traders 20 Total 164
Supervision within the context of the package of hygiene measures in the dairy sector, results in 2014
COKZ inspections in the dairy sector number • Industrial dairy producers 173 • Subsequent processors 116 • Storage locations 30 • Additional audits and unannounced inspections of the aforementioned establishments in connection with 69 non-compliances • Small-scale dairy processors 441 • Additional audits and unannounced inspections of small scale dairy producers in connection with non-compliances 88 • Producers of special foods 9 • Additional audits and unannounced inspections of producers of special foods 4 Samples/analyses • Microbiological analyses at dairy establishments 1,797 • Microbiological analyses at producers of special foodstuffs 150 • Microbiological analyses at small-scale producers 3,419
60 Measures • Warnings 38 • Administrative fines 10 • Suspensions of registrations/authorisations - • Withdrawals of registrations/authorisations -
Further explanation of the results in the dairy sector
The COKZ, within the context of the EU Hygiene Package, carried out supervision throughout the entire dairy farming, preparation and processing chain.
Dairy farms In the dairy farm sector, the requirements of the EU Hygiene Package have been integrated in the quality assurance systems of the dairy farms supplying the dairy establishments. The control bodies – called in by the dairy companies – control the dairy farms’ compliance with these systems. Virtually all dairy farms are governed by these systems: this relates to bovine, goat, sheep, horse and camel dairy farms. The COKZ supervises the establishments that are not governed by a quality assurance system (76) directly. A total of 81 inspections were carried out at these establishments. An evaluation of the supervision programme at the dairy farms (‘supervision of control’) began in 2014. For the purposes of the evaluation of the supervision programme, 123 random and unannounced inspections were carried out at dairy farms governed by a quality assurance system. The unannounced inspections restricted the regular work within the context of ‘supervision of control’, as a result of which fewer system assessments and assessments of control bodies took place in 2014 than in 2013. In addition, fewer visits of assessors were attended in 2014. The revision of the supervision programme is not complete and will be continued in 2015. In 2014, and in addition to the aforementioned activities, the COKZ also supervised the implementation of the various systems designed to provide assurances for the health of dairy livestock. The results from this supervision give cause to the conclusion that the systems, in general, monitor and follow up on animal health to an adequate extent.
Dairy establishments Within this context, ‘dairy establishments’ refer to establishments engaged in the industrial and subsequent processing of cheese, the storage locations and the producers of special foods. In 2014, the majority of the dairy establishments exhibited an adequate level of compliance and the assessments did not give cause to an amendment of the measures policy. An additional verification assessment was carried out at a number of establishments that verified that adequate corrective measures had implemented. Nevertheless, compliance with the basic conditions relating to the cleanliness and maintenance of the various storage and processing areas remains an issue requiring attention. The official sampling and analysis programme reveals that, in general, the milk and dairy products comply with the microbiological criteria. When the standards were exceeded the applicable procedures are followed adequately. However, the microbiological quality of ice cream remains an issue that requires attention.
Small-scale processors and farm dairy processors One regular annual audit is conducted of farm dairy processors and small scale processors. An extra assessment was carried out at 19% of the establishments to verify that the identified non-compliances had been rectified. These verified that the establishments has implemented adequate corrective measures. It is worthy to note that attention will also be devoted to residues and contamination in 2015, to verify that establishments have followed up on the non-compliances identified in 2014 to an adequate extent. It can be concluded that the majority of the farm dairy products comply with the microbiological quality requirements, although raw milk cheese (Boerenkaas) and, to a lesser extent, ice cream are both products that require attention.
Projects
In 2014, the increasing interest in products prepared from goat and/or sheep milk gave cause to the extension of the supervision processors of goat and/or sheep dairy products to include specific attention to the possible blending of cow’s milk during the preparation of these products.
61 The results at two of the 56 establishments that were inspected gave cause to the issue of a fine report. The COKZ also examined the iodine content of farm dairy products. Iodine at concentrations above the standard was found in samples from six of the 19 establishments. In 2015, these establishments will be visited to investigate the cause of the amount above the maximum level.
Incidents
In 2014, a total of 46 dossiers were addressed relating to product non-compliances of a microbiological nature (31 dossiers) or to chemical/physical contamination (15 dossiers). The majority of the non-compliances were not of a nature that gave cause to blocking and/or recalling products. The establishments involved in the aforementioned dossiers were requested to carry out a cause analysis and implement corrective measures. Verification assessments carried out by the COKZ have revealed that establishments have followed this procedure to an adequate extent.
Supervision within the context of the package of hygiene measures in the egg sector, results in 2014
NCAE inspections in the egg sector Number • Egg laying poultry establishments 432 • Extra assessments of egg laying poultry establishments 4 • Collectors 14 • Extra assessments of collectors 0 • Packing stations 286 • Extra assessments of packing stations 3 • Egg product producers 62 • Extra assessments of egg product producers 11 • Egg product traders 18 • Extra assessments of egg product traders 0 Samples/analyses • Microbiological analyses at egg product producers 306 Measures • Warnings 12 • Administrative fines 2 • Suspensions of registrations/authorisations - • Withdrawals of registrations/authorisations -
Further explanation of the results in the egg sector
In 2014 NCAE, within the context of the EU Hygiene Package, carried out supervision at egg laying poultry establishments, collectors, packing stations, egg product traders and egg product producers.
Supervision of the egg sector The frequency of the supervision at the egg laying poultry establishments took account of the evaluations of the ‘supervision of control’. The supervision of the Hygiene Package in the egg sector has revealed a general high degree of compliance with the prevailing instructions. Nevertheless, the cleanliness and maintenance of the various storage and preparation areas at egg product producers remains an issue requiring attention.
Projects
In 2014, random samples were taken for analyses of dioxins, dioxin-like PCBs and PCBs in the eggs of free-range chickens. Eggs from 35 egg laying poultry establishments were analysed. The eggs from one establishment did not comply with the statutory maximum limit. The eggs were blocked and the establishment was requested to carry out a cause analysis and implement corrective measures.
62 Incidents
In 2014, NCAE received 47 reports of Salmonella infections. NCAE supervised the correct channelling of these eggs to the egg product producers. A total of three reports were received on dioxin contents above the maximum level, one of which related to a random sample. Fine reports were issued in two instances because of the failure to issue the authority prompt notification of an amount above the maximum level.
63 4.13 Hotel/restaurant/catering and artisanal production
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 178/2002 general principles and requirements of food law Regulation (EC) No 852/2004 food hygiene
National: • Commodities Act
Size of control file in 2014
type of establishment number Hotel/restaurant/catering approx. 45,000 Retail (supermarkets and similar) approx. 25,500 Craft producer (butcher, baker, greengrocer, poulterer, market trader) approx. 25,000 Institutions approx. 5,000 Total approx. 100,000
The size of the control file remains relatively stable. However, shifts are visible between some small subgroups. A trend can also be observed towards an expansion of or shift in the operations, either on the customers’ request or in an endeavour to survive by offering the customers more. This latter form of shift is particularly evident in the hotel/ restaurant/catering sector. This trend has developed further outside the urban areas, as is manifested by the disappearance of various specific establishments.
Supervision of hotel/restaurant/catering and artisanal production, results in 2014
Results number • Hotel/restaurant/catering 17,907 • Craft 4,279 • Institutions 142 • Retail 1,426 Total 23,754 re-inspections in 2014 12,649 • Digital re-inspection 4,342 • Chargeable re-inspections 8,307 Samples/analyses (microbiological) 7,155 Inspection measures: Hotel/restaurant/catering 9,056 • fine/official report 2,075 • written warning 6,981 Craft 1,788 • fine/official report 335 • written warning 1,453 Institutions 37 • fine/official report 0 • written warning 37 Retail 696 • fine/official report 147 • written warning 549
64 temporary shut-down of activities • Intention to close down 248 • Closure 27 • Shut-down of process 14 • Confiscation 1 • Periodic penalty payments 2
Further explanation of the hotel/restaurant/catering and artisanal production results With risk-oriented selection the number of establishments to be visited remained low. In 2014, the number fell further from the previous year (about 14% of the establishments were visited in 2014, as compared to about 20% in 2013). The available compliance information is subjective and has no implications for the sector’s actual compliance level. However, the information does indicate the presence of a stubborn group of establishments that have difficulty complying with the regulations. In 2014, the figures were once again indicative of a trend towards more re-inspections (from 24% in 2013 to 35% in 2014). This shift is due to the improvements in the risk selection of establishments, which has in turn resulted in more measures.
In 2014, 32% of the inspections resulted in the imposition of a measure. 7% of the inspections identified a serious infringement (6.9% in 2013) and 25% an infringement (26.7% in 2013). The majority of infringements relate to temperature control in combination with the correct handling of food (particularly in the storage and presentation phases), cleaning and disinfection (hygiene), and vermin. This trend has been visible for a number of years and has changed little with the use of classical inspections and preparation of measures.
The persistent offenders require continually increasing attention. For this reason, the tough approach was continued in 2014. This approach consists of the following steps: : 1. A basic inspection: the NVWA carries out an initial inspection and then decides whether the establishment will remain in the tough regime or whether it is performing well enough to return to regular supervision. 2. Inspections focused on improvement: when the establishment remains in the regime the NVWA alternates inspections with meetings until the location improves. In the absence of improvements the establishment is temporarily closed. The shutting down of processes was introduced in 2014. 3. Monitoring closure: when the NVWA temporarily closes a location the Authority carries out a daily control to verify that the location remains closed. The NVWA can impose a fine when a trader does not comply with the temporary or partial closure order. 4. Follow-up: the establishment must continue to prove that its compliance is at the appropriate level for a period of at least six months.
The duration of this regime (steps 1 to 3 inclusive) can vary from a few days (in the event of a serious risk to public health) to a few months. In 2014, the group of persistent offenders consisted of 417 establishments. Although the number increased again in 2014, the number of establishments in the follow-up stage has also risen sharply during the year (from 79 in 2013 to 137 in 2014). However, the number of establishments that deteriorated after an earlier improvement continues to give cause for concern. The size of this group increased in 2014, from 114 in 2013 to 152 in 2014. The number of intentions to close down establishments increased sharply in 2014, from 183 in 2013 to 248 in 2014. The number of closures increased again in 2014, from 13 in 2013 to 27 in 2014, with a sharp increase in the number of immediate closures to 12 in 2014 (2013: 2). The number of shut-downs of processes fell from 22 in 2013 to 14 in 2014. The group of persistent offenders is, in general, becoming more visible, both due to the specific selection and to tackling problems directly by issuing immediate closure orders when there is a very real threat to public health.
Formula approach
The formula approach is characterised by the use of random samples to arrive at a conclusion on compliance throughout the entire formula. The above control file consists of about 15,000 branches that form part of a formula, an establishment with multiple locations. efficient and effective method was continued in 2014. On the basis of random sampling, the NVWA groups the establishments into:
65 • ‘green’ establishments: more than 90 percent of the locations comply with the food safety requirements • ‘orange’ establishments: fewer than 90 percent of the locations comply with the food safety requirements; • individual locations posing structural risks (persistent offenders). The NVWA devotes regular attention to establishments in the orange category by including more locations in a subsequent random sampling. The NVWA takes immediate appropriate measures at locations with serious non- compliances. A location that does not resolve the problems may be designated as a persistent offender, after which the location will either need to achieve rapid improvements or risk the issue of a permanent or temporary closure order. Establishments in the green category come into consideration for appropriately reduced supervision, although structural contacts will be maintained with the head office.
This formula approach method has been adopted for well-known national formulas (chains) of supermarkets, bakeries, butchers, caterers, petrol stations, hotels and restaurants. At the end of 2014, the situation was as follows: sector number of formula establishments number of enforcement inspections number of measures Bakeries 6 63 12 Catering 10 115 8 Hotel/restaurant/catering 52 436 88 Butchers 1 0 0 Supermarkets 23 502 94 Petrol stations 7 64 7 Total 99 1,180 209 The results from the inspections are published on the NVWA website. A total of 99 formula establishments were assessed in this manner in 2014, with 1,180 inspections during the year. In 2014, the monitoring was restricted to contacts with the head offices. More than 17% of the inspections (209) resulted in the preparation if a measure (fine report). The number of inspections fell by 588 from the number in 2013, as no monitoring inspections took place and 298 fewer random inspections were carried out.
The supermarkets achieved a great leap forward in improvement: 17 formulas were classified in the green category in 2014, in contrast to the 12 formulas in 2013. The classifications of the other groups remained reasonably constant, although movements were seen within individual formulas. Unfortunately, formulas occasionally fall back: the NVWA’s inspections then provide sufficient incentives for improvements.
Ten locations of formula establishments (five supermarkets and five hotel/restaurant/catering locations) were of a quality that was so poor that they were included in the strategy for persistent offenders. In 2013, the number of these locations was twelve.
In 2014, the NVWA minimised the supervision of establishments classified in the green category to contacts with the head office. The earlier approach based on the conclusion of covenants with establishments has been minimised throughout the NVWA.
Vermin
Vermin has been a spearhead in every inspection carried out since the beginning of 2013. The Flora and Fauna Act has been introduced into the supervision system. The use of glue traps without a dispensation is prohibited. This has been addressed since 2013, when a collaborative arrangement as set up with the then National Service for Implementation of Regulations (now the Netherlands Enterprise Agency [RVO]) to ensure that the correct action is taken by the relevant vermin management establishment. In addition, explicit procedures were implemented for applications for dispensation and for the supervision of the correct administration of this dispensation. Applications for a number of dispensations were submitted in 2014. One vermin management establishment was found to have intentionally infringed the regulations. The NVWA then, in cooperation with the RVO, took action by imposing a cease and desist order of an indefinite duration.
66 Horizontal supervision
In 2014, the horizontal supervision in this domain focused on the expansion of the number of self-inspection systems accepted by the NVWA. At the end of 2014, the ‘counter’ stood at seven systems. A continually increasing number of locations appreciate the benefits they are offered and take part. About 2000 establishments now take part and a similar number are working on the improvements required to achieve the necessary level.
Movements in supervision
An approach was adopted several years ago in which greater emphasis would be placed on influencing behaviour as a means of promoting compliance instead of the classical inspections and the imposition of measures. This approach was to be adopted when this was worthwhile and other instruments would achieve a greater effect. The compliance risk management strategy cycle was adopted for this purpose.
The number of persistent offenders is increasing to an extent such that it has become apparent that diligence can impede speed. The steps taken in 2013 were continued in 2014, with specific attention to the legal options. A review was also made of the extent to which contracting third parties could support the achievement of the necessary improvements. This was formulated explicitly by implementing an improvement to the decision text. The effects of all the improvements will first become noticeable in 2015.
Work on the publication of inspection results began in 2012. As a supplement to the existing methods, a Safe Food Declaration and an associated inspection method were developed in 2013. The actual live publication of the inspection results will begin on 7 July, both on the website and via a newly developed hotel/restaurant/catering app (horeca app). The roll-out of the data is initially limited to a pilot trial group of lunchrooms.
Conclusions
• The continuation of the risk selection approach has resulted in a further reduction in the frequency of visits. • In 2014, slightly fewer inspections and re-inspections were carried out than in 2013. However, a relatively greater number of re-inspections were carried out. This increase is due to the larger number of measures that is in turn to be expected with improved risk selection. • No significant changes were observed in the compliance of the hotel/restaurant/catering, artisanal or retail sectors. In contrast to 2013, no fine reports were prepared for establishments in the institution category, a relatively small category. • The unchanged level of compliance has promoted the devotion of attention to specific developments of appropriate instruments that will achieve greater effects than the compliance risk management strategy. • The formula approach has proven to be an efficient system of supervision in which establishments that operate as a formula and have implemented control systems with an adequate performance receive fewer visits from the NVWA. In 2014, this approach was expanded further for the green formulas on refraining from carrying out monitoring inspections these establishments. • Horizontal supervision is interpreted in terms of the acceptance of self-inspection systems. Seven systems had been accepted by the end of 2014. • The approach to persistent offenders remains necessary. The number of establishments subjected to this approach once again increased in 2014.
67 4.14 Know what you are buying
Controlling authorities: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Directive 89/395/EEC labelling, packaging and advertising of foodstuffs. Regulation (EC) No 110/2008 labelling of the geographical indication of spirit drinks Directive 79/1005/EC indication of quantities Regulation (EC) No 1169/2011 provision of food information for consumers Regulation (EC) No 1333/2008 food additives Regulation (EC) No 1151/2012 quality schemes for agricultural products and foodstuffs flavourings and certain food ingredients with flavouring properties for use in and Regulation (EC) No 1334/2008 on foods
National: Most of the legislation on labelling and allergens is set out in the labelling of foodstuffs (Commodities Act) decree (Warenwetbesluit Etikettering van levensmiddelen) . However, the Commodities Act contains 40 other instances of additional labelling regulations. A transitional phase is applicable to the labelling regulations in 2014: the labelling of foodstuffs (Commodities Act) decree (Warenwetbesluit Etikettering van levensmiddelen) is applicable until mid-December 2014. The prevailing regulation in the Food Labelling Regulation will enter into force on 14 December 2014.
Size of control file in 2014 type of establishment number Food factories (authorised and registered) 2,300 Importers, wholesalers, food storage 4,800 Hotel/restaurant/catering, retailers (bakeries, butchers etc.), supermarkets, institutional kitchens approx. 100,000
Supervision of ‘Know what you are buying’, results in 2014 inspections/tests in 2014 number % non-compliance Inspection of the addition of water and labelling of meat preparations 60 5 Opson IV 108 1
The NVWA’s efforts in this area were limited due to budget cuts. A number of minor supervision projects were scheduled for 2014. In addition to these supervision projects, time was also reserved for the development of knowledge and transfer of information relating to a number of regulations.
Development of knowledge and transfer of information Regulation (EC) No 1169/2011
The new Labelling Regulation (Regulation on the provision of food information to consumers) entered into force at the end of 2011. There are still many unanswered questions and ambiguities relating to this regulation. In 2014, the NVWA – both within the Authority and in cooperation with the Ministry of Health, Welfare and Sport – regularly devoted time to the interpretation of this new Regulation. A number of NVWA staff also followed the Better Training Safer Food (BTSF) food safety course that covered issues including this Regulation. In 2014, the NVWA devoted most of the time to the acquisition of knowledge about the Regulation: the transfer of this knowledge will take place in 2015.
Inspection of the addition of water and labelling of meat preparations
60 samples were analysed within the scope of this project to examine the accuracy of the meat content displayed on the label. It transpired that the meat content displayed on the label of three of the samples was not correct. Fine reports were prepared for these non-compliances.
68 Additives: provision of information to inspectors about Regulation (EC) No 1333/2008
This activity had been scheduled for 2013, but was not organised due to lack of capacity. It also proved impossible to update the inspectors on the additives Regulation in 2014. However, a number of inspectors did follow the BTSF food additives course in 2014.
Labelling of mechanically separated meat
A specific project on ‘mechanically separated meat’ was organised in 2014. Both the producers of mechanically separated meat and processors of mechanically separated meat were visited for the purposes of this project. One of the objectives of this project was to assess the labelling of mechanically separated meat in both business-to-business (B2B) deliveries consignments of consumer products containing mechanically separated meat. As this project continues into 2015, results on the labelling of mechanically separated meat are not currently available. However, the Netherlands has now adopted the standpoint that the labels of products containing mechanically separated meat should include MSM as a separate ingredient. Until recently, mechanically separated meat type 3 (low pressure) could still be referred to as ‘meat’. As from 1 January 2016, the NVWA will take enforcement actions against the incorrect labelling of mechanically separated meat.
Supervision of meat trimmings in the meat chain: are the correct types of animals stated?
The Netherlands takes part in the annual Interpol-Europol Operation Opson. ‘Opson’ is the classical Greek word for food. The objective of this operation is to create awareness of the hazards posed by fake food and food that does not comply with the relevant legislation, protect consumers and set up collaborative arrangements for the investigation of food fraud. In 2014, a total of 108 samples of meat trimmings were collected within the scope of Operation Opson Project IV and subjected to DNA analysis to determine the type of animal. One of the samples collected during this inspection which purportedly consisted of beef was found to contain solely horse meat. As the producer had not brought the relevant consignment onto the market, no intervention was required.
General
Labelling Although the NVWA had not scheduled any specific labelling projects in 2014, non-compliances in the labelling of foods were nevertheless identified during the Authority’s food safety inspections. In 2014, measures were taken in a total of 113 labelling cases (92 warnings and 21 fine reports).
69 4.15 Contaminants, residues and GMOs in food
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation setting maximum levels for certain contaminants (nitrate, mycotoxins, Regulation (EC) No 1881/2006 lead, cadmium, mercury, tin, 3-MCPD, dioxins and PCBs, PAHs, melamine and erucic acid) in foodstuffs Regulation (EC) No 1151/2009 mineral oil in sunflower oil originating in or consigned from Ukraine Regulation (EC) No 669/2009, latest update (EU) No increased level of official controls on imports of certain feed and food of 1295/2014 non-animal origin Commission Implementing Regulation (EU) No special conditions governing the import of certain feed and food from 884/2014 certain third countries due to contamination risk by aflatoxins Commission Recommendation 2013/647/EU investigations into the levels of acrylamide in food Commission Recommendation 2012/154/EU monitoring of the presence of ergot alkaloids in food Commission Recommendation 2013/165/EU presence of T-2 and HT-2 toxin in cereals and cereal products Regulation (EC) No 396/2005 maximum residue levels of pesticides Regulation (EC) No 1829/2003 authorised GMOs in animal feed and foodstuffs Regulation (EC) No 1830/2003 emergency measures regarding unauthorised genetically modified rice in Commission Implementing Decision 2013/287/EU rice products originating from China Regulation (EC) No 470/2009 residues of veterinary medicinal products in foodstuffs Regulation (EC) No 37/2010 MRLs for residues of veterinary medicinal products Directive 96/22/EC prohibition on the use of growth promoters Directive 96/23/EC monitoring residues in live animals and products of animal origin Regulation (EC) No 669/2009 controls of high-risk non-veterinary products at the border Regulation (EC) No 1152/2009 emergency measure concerning aflatoxins in products from third countries
National: • Commodities Act • Pesticide residues (Commodities Act) regulation (Warenwetregeling Residuen van bestrijdingsmiddelen) • Contaminants in food (Commodities Act) regulation (Warenwetregeling Verontreinigingen in levensmiddelen) • Preparation and handling of food (Commodities Act) decree (Warenwetbesluit Bereiding en behandeling van levensmiddelen) • Regulation prohibiting trade in animals and products treated with certain substances (Regeling verbod handel met bepaalde stoffen behandelde dieren en producten)
Size of control file in 2014
type of establishment number Importers, wholesalers, manufacturers, supermarket chains, retail stores approx. 150,000 Primary establishments (farms with grazing livestock) approx. 35,000 Primary establishments (farms with indoor livestock) approx. 5,550 Veterinarians approx. 4,200
70 Supervision of contaminants, residues and GMOs, results in 2014
Results number NVWA inspections/samples in 2014 • pesticide residues -- on the basis of the National Control Plan 3,538 -- representative for the market 2,376 -- on the basis of a risk profile 1,162 -- on the basis of Regulation (EC) No 669/2009 1,645 • GMO-foodstuffs 221 • GMO-Chinese rice 11 • mycotoxins 3,759
Non-compliant samples on the basis of pesticide residues • on the basis of the National Control Plan 212 -- representative for the market 95 -- on the basis of a risk profile 117 • on the basis of Regulation (EC) No 669/2009 153
Reference to specific reports, such as national plans and similar Report of Pesticide Residues Monitoring Results of the Netherlands for 2014
Contaminants The following table lists a summary of all the products/samples that were examined.
2014: samples tested and percentage of non-compliances with Regulation (EC) No 1881/2006 product total % non-compliant Grain (and grain products including cake) 528 0 Dried tropical fruits 486 2.1 Nuts and seeds (and nut and seed products, including peanut sauce) 1,994 4.0 Wine, beer and fruit juice 154 0 Baby food 136 0.7 Herbs and spices 285 3.2 Coffee and tea (including liquorice and Dutch liquorice drop( ) 135 0 Cocoa (and cocoa products) 41 0 Total 3,759 2.7
Mycotoxins
As the severity of fungal attacks can vary from one harvesting season to the next, annual attention needs to be devoted to the enforcement of the EU regulations and draft standards governing mycotoxins (as laid down in many Commission Recommendations). All products for which standards or draft standards were available were sampled during the course of the year. In addition to specific controls of imports from third countries and at production establishments, attention was also devoted to products from other EU Member States.
Striking non-compliances
Nutmeg Seven of the 64 sampled consignments of nutmeg contained aflatoxin at levels of above the 5 µg/kg limit and in one instance of no less than 160 μg/kg aflatoxin B1. The resultant import refusal of 10.9% of the consignments was slightly lower than the 13% in 2013.
Paprika Six of the 35 sampled consignments of paprika powder contained aflatoxin B1 and a further 30 ochratoxin A, although only one sample contained ochratoxin A at a level above the limit, namely 63 μg/kg. This was far above the limit and for this reason import was refused for this consignment.
71 Dried tropical fruits Six of the 61 sampled consignments of figs contained ochratoxin A at levels above the national limit of 10 µg/kg) and two samples contained aflatoxin B1 at levels of above the maximum limit of 6 µg/kg laid down in Regulation (EC) No 1881/2006.
Peanuts 72 of the 591 consignments controlled on import contained aflatoxin. 59 of these consignments (10%) contained aflatoxin B1 at levels above the 2 µg/kg limit and the import of the consignments was refused. This level was slightly higher than the level of 8.7% in 2013.
As is customary, these results were reported to Brussels via the Rapid Alert for Food and Feed System.
Other contaminants
Heavy metals The GFL notifications of mercury in wild mushrooms in 2014 gave cause to a survey of heavy metals in wild mushrooms in the same year. About 50 samples of wild mushrooms were analysed for mercury, arsenic, cadmium and lead. Maximum levels were exceeded in two samples: a sample of shiitake had a cadmium content above the limit and a sample of Boletus edulis (‘penny bun’) had a mercury content above the limit.
Acrylamide A survey of acrylamide in a number of product categories listed in Commission Recommendation 2013/647/EU was carried out in 2014. Analyses were also carried out on samples of a number of characteristic Dutch products, such as spice biscuits (kruidnoten), gingerbread nuts (pepernoten) and fried chips. The contents found in the analyses were below the indicative maximum acrylamide levels stated in Commission Recommendation 2013/647/EU.
Pesticide residues
Analyses of pesticide residues reveal that the percentages of non-compliance of products grown in the EU are still low, in part as a result of the entry into force of the harmonised MRLs7 throughout the EU in 2008. However, the percentage of non-compliances of products from outside Europe remains relatively high. The programme reveals that: • More than 5,200 samples contained approximately 10,500 residues of 187 different pesticides. The EU has determined which agents must in any case be included in the national control programme. In 2014, 97% of the various residues that were found belonged to the mandatory list. • Many samples of fruit and vegetables from Asia did not comply with the standard. A considerable proportion of the products from the Dominican Republic (19%), Suriname (13%) and Egypt (11%) also failed to comply with the statutory standard. The following tables list the product/country combinations with the greatest MRL non-compliances. • In 2014, the Netherlands submitted 17 notifications to the Rapid Alert forood F and Feed (RASFF) system on the basis of NVWA inspections and a further 23 notifications on the basis of notifications from the business community within the context of the General Food Law Regulation. The number on the basis of NVWA inspections is comparable with the number in 2013. The number of RASFF notifications due to notifications from the business community increased sharply, although no clear explanation is as yet available. • Both the non-compliances with and the RASFF notifications of residues of highly toxic, old-fashioned pesticides from third world countries (such as endosulfan, chlorfenapyr and hexaconazole) were striking. • Fewer controls of Dutch products were carried out in 2014, although controls were increased of imported products from countries outside the EU, with particular attention to Thailand, the Dominican Republic, India, Egypt, Hong Kong, China and Argentina.
7 MRL = maximum residue level 72 Important products analysed in the national control plan with high non-compliance percentages, with country of origin product pesticides % > MRL country of origin Cactus fruit iprodion, carbendazim 42.9 Vietnam Cucumber-like fruit with an edible peel chorothalonil 35.0 Suriname Passion fruit various 25.0 Colombia Pomegranate various 24.3 India, Peru Lime methidathion, carbofuran 15.6 Brazil Cherry dimethoate 14.3 Various Aubergine various 13.0 various
Major products with high non-compliance percentages found after import controls within the context of Regulation (EC) No 669/2009 product pesticides % > MRL country of origin Chinese broccoli chlorfenapyr, pyridaben, propiconazole 57.1 China Strawberries methomyl, oxamyl 21.7 Egypt Tea fipronil, acetamiprid, pyridaben 18.9 China Aubergine dinotefuran 18.5 Cambodia Basil various 16.7 Vietnam, Morocco Peppers permethrin, chlorfenapyr 14.3 Dominican Republic, Vietnam
Genetically modified organisms (GMOs)
The European emergency measure that requires all consignments of rice products from China to be inspected for non-authorised GMO was introduced in early 2012, and was still in force throughout 2014. A total of eleven consignments of rice (or rice products) were sampled and analysed. All costs incurred by the NVWA are charged to the relevant establishment. One consignment tested positive for non-authorised GMOs and was returned to China. An RASFF notification relating to non-authorised papaya from Thailand resulted in five consignments being sampled at Amsterdam Airport Schiphol at the beginning of 2014. All samples tested negative. Five samples of food supplements containing papaya tested positive for a non-authorised GMO. These products probably originated from China. The regular monitoring of foodstuffs for failure to report the presence of an authorised GMO in a product revealed only three non-compliances.
Incidents
Perchlorate was found in some fruit and vegetables in 2013, and chlorate was an important issue in the discussions with the fruit and vegetable sector in 2014. The source of the chlorate is not always clear: however, the contents found in the samples readily exceeded the standard EU limit of 0.01 mg/kg. The EU is currently working on a temporary limit value. The Netherlands has already adopted the proposed limits to avoid the unnecessary destruction of products and disruptions of the market .
Supervision of veterinary medicinal products and veterinary practice, results in 2014
Inspections of veterinary medicinal products (VMP): number VMP inspections, basic (livestock farms) 524 VMP inspections at trading establishments 34 VMP inspections under the National Plan Residues 62 Measures Official reports 25 Fine reports 1 Warnings 55
73 Inspections of veterinary practices number General inspections 57 Specific inspections (calf veterinarians) 10 Measures Official reports 0 Trial report 1 Fine report 5 Warnings 13 inspections of prohibited substances (inclusive of National Plan Residues) number Samples/analyses Veterinary medicinal products and animal matrices Samples 23,552 Analyses 33,469 VMP inspections under the National Plan Residues and prohibited substances 105 (62 and 43 respectively) Measures Official reports 9 Fine report 37 Warnings 6
References to specific reports
• Report of Pesticide Residues Monitoring Results of the Netherlands for 2014 • Report of the National Plan Residues in live animals and animal products of the Netherlands 2014 • Annual Report 2014 of the Netherlands on Control Measures according to Article 17 of Directive 91/414/EEC.
Residues of veterinary medicinal products
The report on the analysis of residues of veterinary medicinal products reveals that the non-compliance percentages are low and of a similar magnitude to the averages published by EFSA in its summary report on the Residue Monitoring Plans (RMP) of all Member States.
• For group A substances (unauthorised substances), incidental cases of antithyroid agents (thiouracil) and steroid hormones (boldenone, nortestosterone) were found. However, there is still uncertainty as to the extent to which these substances can also be formed naturally in the animal. Techniques to distinguish between endogenous and exogenous origins are not yet available or suitable for use with the concentrations that are normally found. • In 2014, the presence of beta-agonists (A5) was demonstrated in two cases. These related to salbutamol and clenbuterol. In the first case, the results from additional samples were not indicative of illegal use. However, with clenbuterol there were strong indications of illegal use. A criminal investigation is in progress. • In the prohibited antibiotics group (A6), the use of nitrofurans on cattle was once again identified in 2014. This finding did not originate from the monitoring of nitrofurans within the context of the National Plan Residues, but from risk-oriented sampling. The cause for this sampling was a consignment of contaminated animal feed. This finding had a great impact: a total of some 7,500 animals at seven establishments were removed and culled. Contaminated animal feed had also been processed at a large number of pig establishments and, as a result, diluted. However, the animals tested negative. • One of the suspect establishments had delivered animals to the slaughterhouse. Furazolidone residues were found in meat still present at the slaughterhouse. The NVWA then immediately traced the route this contaminated meat or meat mixed with contaminated meat had taken through the supply chain. 24 tonnes of meat or meat product had been exported and 45 tonnes was in the Netherlands. Some of this had already been consumed: the remainder was removed from the market. Persons who had consumed the meat in question had ingested only very small amounts Estimates by the NVWA Office for Risk Assessment and Research (BuRO) indicated that public health had not been at risk. • Nitrofurans and, in particular, furaltadone, are regularly found in pigeons supplied for slaughter. The Netherlands is working on a specific enforcement policy designed to reduce the presence of this substance in pigeons for slaughter. This policy will be implemented in 2015.
74 • Antibiotics residues of group B substances were found on occasion. This finding is also in line with the results in previous years. A shift from tetracyclines to aminoglycosides was observed in 2013. However, in 2014 the non- compliances related solely to tetracyclines: 3x with pigs, 1x with sheep & goats and 12x with poultry. The results for poultry then give cause to the question as to the extent the non-compliances could have resulted from the failure to observe the full waiting period. These results are in part the reason for the continued high priority assigned to antibiotics residues in the Dutch National Plan. The Animals Act, which entered into force on 1 January 2013, made non-compliance with the MRL for these residues in animals offered for slaughter a punishable offence. This has made more sanctioning measures available and increased the effectiveness of enforcement. This had already resulted in the imposition of a larger number of sanctions in 2013, a trend which continued in 2014. • The use of antibiotics in food-producing animals in the Netherlands has decreased significantly during the past five years. In 2014, however, the use of antibiotics now revealed a trend towards stabilisation at the level of the previous year. For this reason new policy will need to be developed to achieve a further reduction. This shall need to focus on sustainable changes in the sectors or establishments in or at which the use of antibiotics remains at unacceptably high levels. The number of antibiotic MRL non-compliances remains constant. The causes of this have not yet been identified.
Conclusions for veterinary medicinal products
• The detection of prohibited substances such as clenbuterol in 2014 gives cause to the need to devote continued attention to the presence of these substances on the basis of monitoring or specific sampling. In a number of cases the possibility that these substances could occur in nature is the subject of continually increasing discussion; • The discussions about microorganism resistance to antibiotics and society’s continuing attention to the need for the prudent use of antibiotics give cause to the need to maintain the intensity of controls for antibiotics residues at the current level. These residues can be indicative of unauthorised or imprudent use. The number of antibiotic MRL non-compliances remains constant.
75 4.16 Microbiology (pathogens, food-borne infections and zoonoses)
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Directive 2003/99/EC zoonoses and zoonotic agents Regulation (EC) No 2073/2005 microbiological criteria for foodstuffs coordinated control plan for antimicrobial resistance monitoring in Commission Implementing Decision 2013/653/EU zoonotic agents in 2014 monitoring and reporting of antimicrobial resistance in zoonotic and Commission Implementing Decision 2013/652/EU commensal bacteria
Size of control file See chapters 4.2, 4.8, 4.10 and 4.13.
Supervision of microbiology, results in 2014
microbiology results number of samples Monitoring of pathogens, primary phase (farm/slaughterhouse; animal): including farm animals, MRSA, 2,476 ESBL, sampling for AMR CVI Monitoring and surveillance of second phase pathogens (import, industry, wholesale): projects including smoked fish, live bivalves, meat preparations (eaten raw), gelatine, MSM, sprouts, fresh and dried herbs and 4,876 spices, soft fruit, imported chicken meat, etc. Monitoring and surveillance of pathogens in the retail phase: eggs, meat, meat preparations, meat products, 6,271 fish, fish products, raw milk cheese, sushi, cut vegetables, live bivalves, ready-to-bake bread etc. Monitoring and surveillance of pathogens in animal feed: animal meal 45 Monitoring and surveillance of pathogens in hotel/restaurant/catering: non-chilled products, confectionery, 197 kebab, raw food salads, etc. Complaints and reports, source tracing (bacteriology, virology) 1,328 Total samples 15,184
Antibiotics resistance (sensitivity of pathogens, indicators from products) 3,091 Active surveillance of ESBL isolates – CVI/RIVM 515 Total isolates* 3.606* * These are not separate samples but tests for bacterial isolates from regular sample testing
Reference to specific reports • EU zoonosis reports in 2013 • NETHMAP MARAN reports in 2013 • Registration of food-borne infections and poisoning in 2013
Projects
1. Reactive risk reduction/source tracing: food-borne infections and zoonoses and support for the necessary infrastructure (Helpdesk, OSIRIS8); maintenance of database with typing results, coordination of recalls Results from examinations of outbreaks The figures for food-borne infections in 2014 had not been processed in time for inclusion in this annual report. In 2013, more – but smaller – outbreaks of food-borne infections or poisoning were registered than in 2012. There were 290 outbreaks, 14 more than in the previous years. These outbreaks affected at least 1,460 persons, a considerably lower number than in 2012 (2,607 persons). This difference from the previous year is largely due to the 2012 outbreak of Salmonella Thompson caused by infected salmon, a single outbreak that on its own accounted for the illness of 1,149
8 OSIRIS is an on-line registration system for food-borne infections and outbreaks 76 persons. In 2013, the NVWA also registered a further 265 individual cases of food-borne infections or poisoning. The NVWA and Municipal Health Services both carry out, on the basis of their individual disciplines, investigations of the causes of food-borne infections or poisoning to determine in the source of infection and the pathogen that was involved. As the results from these investigations supplement each other, as from this year the reports from both registrations are combined and discussed in the annual report. The information had previously been reviewed separately. As in previous years, Campylobacter and Norovirus were the most frequent pathogens identified in food-borne outbreaks. Although both caused approximately the same number of outbreaks, Norovirus affected the most persons. Salmonella was responsible for a significantly lower number of outbreaks and a significantly lower number of patients than in previous years. Both authorities registered the outbreak reported to them. The NVWA examines the food and the location at which it is prepared. The Municipal Health Services interview the persons who were exposed to the infected food. This new, integrated approach provides a clearer insight into the incidence of outbreaks of food-borne infections or poisoning in the Netherlands and trends in the outbreaks over the years. The data referred to in the reports underestimate the actual number of food-borne infections or poisoning, as not all persons who are taken ill visit their general physician or contact the NVWA. On the basis of an extrapolation it is estimated that every year some 680,000 persons in the Netherlands are taken ill due to the consumption of infected food.
2. Monitoring of pathogens in farm animals, animal feed, animals for slaughter, products of animal origin (‘farm to fork’) A master plan for the periodic surveillance of farm animals was adopted in 2013. This plan can be used to track trends in the prevalence of zoonotic agents in populations of farm animals. The results are submitted to the EFSA in the annual EU zoonosis report. In addition, possible relationships can be identified between different types of zoonotic agents carried by farm animals and, for example, persons living or working on livestock farms. This relates to a five-year cycle in which a different animal chain is studied each year. The chains monitored for various relevant pathogens are the pig, poultry, cattle, veal calf and small ruminant chains. Work began on pigs in 2013, with an extension into 2014. Samples of faeces were taken from pig farms and analysed for the presence of Salmonella, Campylobacter, STEC, ESBL producing bacteria and Clostridium difficile. Samples of human faeces were also taken from farmers, workers and family members for analyses of ESBL producing bacteria and Clostridium. The results were correlated with the livestock results. The results from these samples did not reveal any relationship between the strains and genes of humans and pigs. In addition to the work carried out on reporting the results for pigs in 2014, work was also carried out on the preparations for the chain of the project to be studied in 2015, namely laying hens.
3. Antibiotics resistance: resistance determinations in products of animal origin for trend determination The NVWA, in cooperation with the CVI and RIVM, has been monitoring various isolates for antibiotics resistance for many years. This includes the following: • Salmonella: (approx. 2,500 isolates from humans, approx. 1,500 isolates from farm animals and approx. 1,000 from other foodstuffs) • Campylobacter jejuni: (approx. 100 isolates per year from broiler manure, approx. 250 isolates per year from poultry products) • Indicator E. coli: (approx. 270 isolates per year per animal species (broilers, dairy cows, fattening pigs and veal calves), approx. 200 isolates from laying hens and approx. 600 isolates per year from raw chicken, pork, beef and veal • Enterococcus faecium, faecalis: (approx. 120-250 isolates per animal species (depending on the species) once every three years from animal manure and approx. 350 isolates from raw meat, once every three years per animal species) • ESBL/AmpC and carbapenemase screening in E. coli: in all manure samples (approx. 1,500 per year) and meat samples. • The data are reported annually in the Netherlands in the NETHMAP-MARAN report, which reports the use of and resistance to antibiotics in animals together with human data. The results for the last two years appear to indicate a trend towards a slight decline in resistance in the veterinary sector. At European level, the results are reported annually via the EU zoonosis reports.
4. Viruses: reactive risk reduction/source tracing, surveillance and methodology development In 2014, virus analyses (for Norovirus and Hepatitis A virus [HAV]) were carried out within the context of a number of monitoring projects (for example, in lettuce, fruit, herbs and molluscs and crustaceans). The results for molluscs and crustaceans, in particular, gave cause for concern. In 2014, viruses were found in approximately 16% of the samples, a finding that gave cause to the Netherlands making an active contribution to the discussions about this item on the
77 European agenda. The NVWA also made a major contribution to the European tracing study of the hepatitis A virus outbreak associated with berries.
5. Development and validation of microbiological analysis methods The laboratory is continually engaged on keeping the available analysis methods (development and validation) up to date. In 2014, this included the further optimisation of a PCR method for STEC. Work also began on the Whole Genome Sequencing of Salmonella Heidelberg strains with the objective of accelerating the tracing of the source of outbreaks.
6. Processing of complaints and notifications: provision of information, complaints, General Food Law (GFL) notifications and Rapid Alert System Food and Feed (RASFF) notifications concerning biological agents The number of RASFF and GFL notifications with a microbiological cause continues to increase. The stricter application of the rules on notification throughout the chain has, in particular, resulted in a sharp increase in the number of GFL notifications. In 2014, the NVWA revised the notification guide and then communicated the introduction of the revised guide actively to the branches and establishments. As tracing remains a difficult issue for establishments, intensive monitoring of the data that is supplied continues to be necessary.
7. Monitoring and enforcement programmes: in the context of the national criteria referred to in Article 4 of the food handling and preparation (Commodities Act) decree (Warenwetbesluit Bereiding en behandeling van levensmiddelen) in connection with Regulation (EC) No 2073/2005 and Article 14 of Regulation (EC) No 178/2002. In particular: • monitoring of food safety criteria in products already placed on the market • STEC analyses of various products regarded as high-risk products. • The aforementioned projects are reported to EFSA and published in the annual EU zoonosis reports. • In 2014, a great deal of work was carried out on the STEC problem: the web dossier was put into order, the supervision and intervention policy was adopted and the associated expert declarations were drawn up. At a European level, a contribution was made to the preparation of a guidance document. This approach was, in conclusion, communicated both inside and outside the Authority. A total of approximately 900 samples of foods were examined for the presence of STEC. These foods included vegetables and vegetable shoots, cheese, herbs and spices and meat. It transpired that it is still difficult to isolate STEC after a positive PCR screening. Further development of the analytical method is desirable.
8. Sharing knowledge and advice with other divisions and domains The microbiological expertise available at the NVWA is concentrated in the microbiology domain. In 2014, this expertise was deployed for other domains and divisions, including on the following subjects: • STEC, both in imports and exports • FVO mission crisis preparations • issuing best before dates for cut meat products in supermarkets • approach to the Listeria problem at fish establishments • back-office for the implementation of Regulation (EU) No 2073/2005 • answering questions from the House of Representatives of the States General on a wide range of topics
78 4.17 Nutrition and health/special food and drink
Controlling authority: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Directive 90/496/EEC nutrition labelling of foodstuffs Directive 2000/13/EC labelling, presentation and advertising of foodstuffs Regulation (EC) No 258/97 novel foods and novel food ingredients Directive 89/398/EEC foodstuffs intended for particular nutritional uses Directive 2001/15/EC specific nutritional purposes Directive 1999/21/EC dietary foods for special medical purposes Directive 2006/141/EC infant formulae Directive 96/5/EC baby foods Directive 96/8/EC energy-restricted diets for weight reduction Directive 2002/46/EC food supplements Regulation (EC) No 1924/2006 nutrition and health claims Regulation (EC) No 1925/2006 addition of vitamins and minerals Directive 2001/83/EC medicinal products for human use Regulation (EC) No 1881/2006 maximum levels for certain contaminants in foodstuffs Regulation (EC) No 1333/2008 food additives substances that may be added for specific nutritional purposes in foods for particular Regulation (EC) No 953/2009 nutritional uses Regulation (EC) No 1169/2011 provision of food information to consumers (entering into force in December 2014) food intended for infants and young children, food for special medical purposes, and Regulation (EC) No 609/2013 total diet replacement for weight control
Specific national legislation is also applicable, the most important of which is the Commodities Act (Warenwet) and the herbal preparations (Commodities Act) decree (Warenwetbesluit Kruidenpreparaten). This domain also has many interfaces with the legislation and regulations governing all food, including the food information (Commodities Act) decree (Warenwetbesluit informatie levensmiddelen), labelling of foodstuffs (Commodities Act) decree (Warenwetbesluit Etikettering van levensmiddelen), contamination in foodstuffs (Commodities Act) decree (Warenwetregeling Verontreinigingen in levensmiddelen) and Regulation (EC) No 852/2004 on food hygiene.
Characteristic of this domain is that the legal status of many products is not clear in advance: for example, certain products could qualify as a medical device, a medicinal product or a food supplement.
Size of control file in 2014
type of establishment number Food factory (non-authorised) approx. 1,400 Importers, wholesalers, food storage (non-authorised) approx. 4,500 Hotel/restaurant/catering, retailers, supermarkets, institutional kitchens approx. 100,000
Supervision of nutrition and health/special food and drink, results in 2014
results of inspections in 2014 number Inspections at establishments 1,431 Specific label controls 431 Samples 579 measures ensuing from inspections and samples Warnings 341 Administrative fines 73
79 Further explanation of the results
Inspections at establishments Inspections at establishments are focused on the following: • labelling in general • advertising of infant formulae • novel foods • prohibited herbs/spices The total number of the inspections also includes: 218 complaints and 176 inspections within the context of ‘remote certification’ and 91 inspections within the context of the project relating to the control of web shops with a seal of approval which trade in products that fall within the scope of special food and drink. Labelling controls include general label controls as well as inspections within the context of the labelling control of infant formulae project, labelling control of follow-on formulae and ‘toddler’s milk’ and the labelling control of breakfast cereal.
Specific label controls
The specific label controls are focused on the following: • claims (medical claims, nutritional and health claims); • other labelling requirements.
Samples The samples relate to supplements, herbal preparations and products that may contain suspected pharmaceutical substances. Samples of 284 products were analysed for PAHs, 238 products for heavy metals, 20 products destined for RIVM in the context of pharmaceutical substances enforcement, and 37 products for a banned spice.
Measures Findings (non-compliances) relating to a specific Act or to a number of Acts can occasionally be brought together under one measure. It is also feasible for, for example, a fine report (FR) and a written warning (WW) relating to findings during an inspection and/or samples of a specific establishment are brought together in one FR. 26 measures (22 FR and four WW) of the total of 414 measures related to samples (nine FR in connection with heavy metals, thirteen FR with PAHs, two FR on prohibited pharmaceutical substances and two FR in connection with analyses. The other 388 measures were imposed in connection with inspections. This is inclusive of measures and complaints relating to the advertising of infant formulae and measures relating to other complaints.
These 388 measures encompass a total of 504 findings (one inspection may reveal a number of non-compliances). The 504 findings were: • 204 infringements of Regulation (EC) No 1924/2006 on nutrition and health claims made on foods • 103 infringements of Directive 2001/83/EEC • 90 infringements of Regulation (EC) No 852/2004 on hygiene • 34 infringements of the labelling of foodstuffs (Commodities Act) decree (Warenwetregeling Zuigelingenvoeding), 2007; 27 infringements of the labelling of foodstuffs (Commodities Act) decree Warenwetbesluit( Etikettering van levensmiddelen) • 15 infringements of the products for special foods (Commodities Act) decree (Warenwetbesluit Producten voor bijzondere voeding) • 12 infringements of the nutritional information on food (Commodities Act) decree (Warenwetbesluit Voedingswaarde- informatie levensmiddelen) • 8 infringements of Regulation (EC) No 258/97 on novel foods and novel food ingredients • 7 infringements of Regulation (EC) No 178/2002 • 8 infringements of other legislation
Complaints In 2014, 218 inspections were carried out in response to a complaint. These resulted in 66 measures (6 FR and 60 WW). As a result, 31% of the complaints were held to be justified (2013: 43%). An inventory was made of the legislation applicable to each complaint (whereby more than one Act may be applicable to a complaint). This inventory revealed that advertising relating to the use of medical claims ranked highest as ground for complaint (see the following table).
80 legislation % Directive 2001/83/EC 26 Regulation (EC) No 1924/2006 22 Labelling of foodstuffs (Commodities Act) decree (Warenwetbesluit Etikettering van levensmiddelen) 9 Commodities Act (Warenwet) 7 Other legislation 36
Advertising of infant formulae Advertising infant formulae is an infringement of the Infant formulae (Commodities Act) regulation (Warenwetregeling zuigelingenvoeding) 2007, which is based on European Directive 2006/141/EC. Eight complaints were registered in 2014, of which two were held to be justified. The infringement of the prohibition on advertising infant formulae resulted in a total of seven measures (four WW and three FR). The following table lists the information for 2014. For the purposes of comparison, 25 complaints were submitted in 2013, which resulted in five measures. A total of 13 measures were taken in 2013. party responsible for the advertising complaint measure number Manufacturer yes none 1 Manufacturer no WW 1 Manufacturer at trade fair no FR 2 Supermarket n/a none 4 Supermarket yes WW 1 Supermarket no WW 1 Website yes none 1 Website yes WW 1 Website of manufacturer no FR 1 Total 4 WW and 3 FR 13
Samples (national legislation) In 2014, 17 of the total of the 284 samples of food supplements and herbal preparations contained benzo[a]pyrene at levels above the standard.
Samples (European legislation) In 2014, nine of the total of the 238 samples of food supplements and herbal preparations contained mercury at levels above the standard.
Samples for analyses of suspect or potentially suspect pharmaceutical substances Samples of four products marketed via two web shops and one sex shop were found to contain prohibited pharmaceutical and other substances (DMAA and sildenafil).
Reduction of salt content and intake of trans-fatty and saturated fatty acids.
The Ministry of Health, Welfare and Sport published the National Memorandum on Health Policy, Gezondheid dichtbij 3, in May 2011 This memorandum includes a description of health policy in the field of nutrition in relation to health. Reducing the salt content of food and lowering intake of trans and saturated fats are important aspects of this policy. The Ministry of Health, Welfare and Sport has decided not to implement legislation to compel this reduction, but rather to implement other instruments. These instruments are, firstly, the provision of information and encouragement for consumers via Nutrition Centre projects and, secondly, reaching agreements with industry on the achievement of the targets: • To encourage the reduction of salt in industrially prepared foods, the Dutch Food Industry Federation (FNLI) set up the Task Force Salt in Food in 2007. The Task Force drew up an action plan designed to achieve an ultimate salt reduction of 20-30% in a wide range of foods. • The Task Force Responsible Fatty Acid Composition – a collaborative arrangement between establishments in the industrially processed vegetable oils and fats sector – has been working on improving the composition of fatty acids in foods containing vegetable oils and fats since 2005. The industrial and artisanal bakery sectors are also represented in the Task Force.
81 Within the context of the Public Health Supervisory Service the NVWA monitors the improvement in the composition of foods to review whether the self-regulation arrangements between the Ministry of Health, Welfare and Sport and the industrial sector are effective. In 2014, the following projects were carried out within this context: • Since 2011, the NVWA annually samples and analyses 10 food product groups to monitor progress in the reduction of salt. In 2014, the NVWA sampled a total of 1,101 products from various product groups and determined the common salt contents. The analyses revealed that there were great discrepancies in salt content between products of the same product type. The median table salt content of the entire dataset (1049 products) has decreased from 1.20% in 2011 to 1.12% in 2014, a decrease of 6.7%. A comparison of 470 products (A and B brands and own label) samples in 2011 and 2014 that are otherwise identical reveals a demonstrable and significant decline in their salt content. The decline in the median salt content in 2014 (1.18%) from 2011 (1.10%) was 6.8%. The greatest decline in the median salt content was achieved in single vegetables and legumes (41.5%), ready to eat meals (20.1%), Gouda 48+ cheese (16.5%) and bread governed by the maximum salt content prescribed by the bread and meal (Commodities Act) decree (Warenwetbesluit Brood en meel) (11.9%). The median salt content of products in the soup, canned foods (other) and cheese (other) product groups has risen by 5.2%, 8.9% and 15.5% respectively since 2011. In 2014, the table salt content of products in the frozen snacks, sauces and meat products groups had not changed significantly from the levels in 2011. • 224 products in the ‘small’ savoury snacks category (puff pastry products, crisps, prawn crackers, nuts, savoury biscuits and savoury crackers) divided between 17 product types were sampled in 2012 and 2013, and the fatty acid composition was analysed. The report on the findings was published in 2014. The analyses revealed that there are large variations in the fat content between a number of types of savoury snack products (per 100 g of product). Making products in these product categories with lower fat contents is feasible. The levels of saturated fatty acids also vary greatly, both between the various types of savoury snacks and within a single group of products.
Enforcement of nutrition and health claims on the labelling of and advertising for food
• The labelling on follow-on formulae (for suckling infants younger than 12 months), ‘toddler’s milk’ (for children between the ages of 1 and 3) and pre-school milk (for children from the age of 3) products was inspected for compliance with requirements including the requirements laid down in the Infant formulae (Commodities Act) regulation (Warenwetregeling zuigelingenvoeding) 2007, products for special foods (Commodities Act) decree (Warenwetbesluit Producten voor bijzondere voeding) and Regulation (EC) No 1924/2006. The majority of the contents of the Infant formulae (Commodities Act) regulation (Warenwetregeling zuigelingenvoeding) 2007 refer to European Directive 2006/141/EC. • Inspections or re-inspections were carried out on a total of 69 products, namely 41 on follow-on formulae, 25 on ‘toddler’s milk’ and two on pre-school milk, originating from 18 manufacturers/retailers. • When the combination of the label on a product and the information in the feeding schedule did not make clear whether the product was destined for use as a follow-on formula or as ‘toddler’s milk’ then the product was assessed against the regulations governing follow-on formulae. This related to 18 of the total of 41 follow-on formulae. • The products of two of the manufacturers complied with the stipulated requirements. • A total of 159 measures (98 written warnings and 61 fine reports) wereaken t in connection with the labels of 55 products made by the other 16 manufacturers and in connection with the associated websites. • Most of the non-compliances that were identified (58%) related to the incorrect use of nutrition and health claims on the labels. Other non-compliances related to other labelling issues such as statements, designations, the nutritional value, statements and designations that were not in the Dutch language, the incorrect use of nutrition and health claims on the website and the failure to give notification of products for special foods to the NVWA whilst this is a mandatory requirement
Enforcement of and monitoring of legislation at web shops with a seal of approval
• The NVWA carried out an investigation of the degree of compliance with food legislation (medical claims, banned herbs/spices, novel foods and health claims) at web shops that trade in special food and drink during the period from June 2013 to the end of February 2014. To this end, 180 web shops were identified that are listed on a consumer advice website (ConsuWijzer) and which trade in special foods and beverages. • In 13% of all cases, the minimum information required about the trader and the web shop was absent, not displayed correctly or incomplete. The most frequent omissions related to the failure to display a Chamber of Commerce number and/or VAT number.
82 • The most frequent non-compliance (enforcement) related to the infringement of Directive 2001/83/EC (about 1 in 5). • About half of all the websites were in non-compliance with the requirements laid down in Regulation (EC) No 1924/2006 on nutrition and health claims (monitoring). • Over half of the 180 web shops were not known to the NVWA. In addition, the inspector expects that about 1/3 of these also import products. • During this series of inspections it often transpired that web shops did not have or no longer had a seal of approval or were no longer trading in special foods and beverages at the time of the NVWA’s inspection, whilst they were nevertheless displayed on the seal of approval website. Web shops were often found to be offline or linked through to another website that did not trade in food. • In the autumn of 2014, additional attention was devoted to the correct ntrye of the web shops in the NVWA database. • In 2014, work began on a study of a more product-oriented form of investigation. The results will be announced in 2015.
Conclusion
It can and must be easier for consumers to opt for healthier products. A healthy dietary pattern is of importance to good health. In 2014, analyses were carried out to monitor the salt content of 10 food product groups and review the fat content and fatty acid composition of savoury snacks. The results from this monitoring provide for assessment of progress with the product composition improvement agreement (Akkoord Verbetering Productsamenstelling).
It is striking to note that from the supervision perspective the special foods and beverages domain is very broad, ranging from products such as drip feeds to herbal preparations. In 2014, the supervision was largely focused on the enforcement of labelling and nutrition and health claims. The objective of the compliance policy is both to promote compliance by the parties that are inspected and to fulfil an agenda-setting function for the relevant stakeholders. In addition, specific attention was devoted to the supervision of web shops and new supervision methods were developed. E-commerce, an area that will receive a great deal of attention in the future, may also pose major risks. During 2014, continual attention was also devoted to the analysis of harmful and prohibited substances in food, including in food supplements and herbal preparations.
83 4.18 Plant health
Controlling authorities: NVWA, KCB, NAK, Naktuinbouw and BKD.
Summary of the main legislation addressed by controls in 2014
EU legislation on protective measures against the introduction into the Community of organisms Directive 2000/29/EC harmful to plants or plant products and against their spread within the Community Directive 2007/33/EC on the control of potato cyst nematodes Directives 2006/63/EC and 98/57/EC on the control of Ralstonia solanacearum (Smith) Yabuuchi et al. Directives 2006/56/EC and 93/85/EC on the control of potato ring rot Directive 68/464/EEC on control of potato wart disease
National: • Plant Disease Act
Size of control file in 2014 type of establishment number Arable 11,946 Ornamental horticulture – flower bulbs 1,520 Ornamental horticulture – floristry 3,585 Ornamental horticulture – tree nurseries 3,794 Vegetables 4,155 Fruit 2,344
Supervision of arable agriculture, results in 2014
The situation in arable agriculture is characterised by the continual effort needed to control a small number of significant quarantine pests in potato and seed potato cultivation. This primarily relates to potato cyst nematode (PCM), Meloidogyne chitwoodi/fallax, brown rot, ring rot and potato wart disease. The detailed EU regulations on the control of these diseases were once again implemented in 2014. results for arable agriculture number of inspections rejection due to quarantine pests 2012 2013 2014 2012 2013 2014 inspections imports 1,606 1,474 806 0 0 0 potato wart disease 131 432 311 0 1 0 national seed potato crop 16,281 16,089 15,076 14 21 49 export inspections 20,738 16,757 20,503 17 21 25
In 2014, the most important findings in the arable agriculture sector were: • The situation with respect to imports of ware potatoes remained unchanged from previous years. • Integral tests of seed potatoes identified no brown rot for the th5 consecutive year. • No ring rot was encountered in 2014. This indicates that the preventive approach adopted by the seed potato chain and authorities is bearing fruit. • In 2014, the number of fields in which M. chitwoodi/fallax was found – 38 and 2 cases respectively – was higher than ever before. • The area declared infected with PCM has remained virtually constant since 2011. In 2014, potato spindle tuber viroid (PSTVd) was encountered in propagation material for potatoes. This resulted in the initiation of a large-scale examination which was carried out in and with the propagation sector. The findings gave cause to the enhancement of the prevention and sampling programme for this viroid in the propagation sector.
84 Supervision of fruit and vegetables, results in 2014
Results for fruit and vegetables number of inspections rejection due to quarantine pests 2012 2013 2014 2012 2013 2014 inspections import inspections 63,781 68,921 72,500 108 191 145 Inspections, national survey n/a 3,114 4,152 n/a 78 59 Plant passport 2,579 3,258 3,513 98 45 45 Export inspections 34,690 49,086 37,603 522 487 376
The fruit and vegetable sector encompasses production in open fields and in greenhouses, with production chains from seed production to the cultivation of end products, with imports, trading and exports in every link in the chain. In 2014, the most important findings were: • In 2014, the number of interceptions of quarantine pests during inspections of imports declined to 145 (2013: 191). These related primarily to Phyllosticta citricarpa (Citrus Black Spot) and non-European Tephritidae. • In 2014, eight growers reported an infection of Clavibacter michiganensis. • The number of rejections of exports fell from the number in 2013, largely due to fewer administrative errors.
Supervision of ornamental horticulture, results in 2014
Floristry The floristry sector encompasses the wide range of ornamental horticulture products, and includes the production of both propagating material and end products. The highly internationalised production chains have close connections between the links in the chain. In 2014, the most important findings were: • In 2014, the 154 interceptions of harmful organisms in imports were significantly lower than in previous years, in particular due to the decrease in the number of cases in which Spodoptera littoralis was found to half the previous level. • 573 observations were carried out at ornamental horticulture establishments within the context of phyto monitoring. Quarantine pests were found in eleven cases. • The number of rejections of exports due to harmful organisms fell sharply from the numbers in previous years. This was also the case with rejections for administrative reasons. The more stringent controls would appear to be bearing fruit. results for ornamental horticulture number of inspections rejection due to quarantine pests 2012 2013 2014 2012 2013 2014 Inspections floristry import 97,877 94,219 104,500 231 234 154 flower bulb import 478 436 439 0 2 0 floristry, national survey 526 897 573 9 33 11 floristry, plant passport 12,222 11,607 11,451 2 0 3 flower bulb, plant passport 24,635 23,877 24,419 40 64 134 floristry export 33,982 43,060 35,578 7,378 7,923 4,702 flower bulb export 7,332 7,758 7,108 213 150 264
Flower bulbs The outdoor field cultivation of flower bulbs gives cause to specific dispersion risks. Alongside their general disease and pest problems, each of the various species of flower bulbs also has its specific disease and pest problems. At the same time, Dutch flower bulbs are marketed all over the world. This combination of factors poses a major challenge to the sector organisations and to the BKD (the Flower Bulb Inspection Service [Bloembollen Keuringsdienst]) and the NVWA. In 2014, the most important findings were: • In 2014, the number of infections with Ditylenchus dipsaci found in the passport inspections was much higher than in previous years, due to the mild winter. The current approach, in combination with restrictions on the application of soil disinfection, was evaluated at the end of 2014, and a proposal was drawn up for a more preventive approach as from 2015. • The trend towards a decline in the number of rejections in export inspections exhibited in previous years did not continue in 2014. The number of rejections due to mould increased from the number in 2013, and the number of
85 rejections due to nematodes was about double the level in previous years. Conversely, the number of rejections due to soil decreased. • For exports to third countries, the initial steps have been taken towards a chain-oriented approach in the lily sector that is based on virus-free propagating material. The first two viruses that are being addressed are Arabis Mosaic Virus (ArMV) and Strawberry Latent Ringspot Virus (SLRSV) for China.
Supervision of tree nurseries and green spaces, results in 2014 The tree nursery sector is closely associated with woods, gardens and parks, as well as with public or private urban parks or what are referred to as ‘green spaces’. The tree nursery sector and the green spaces are confronted with same diseases and pests and, as a result, are at mutual risk of infection. In 2014, the most important developments in the green spaces and the tree nursery sector were: • The first find of Xylella fastidiosa, in Italy, and at the end of 2013, resulted in the implementation of European emergency measures that include the obligation to carry out surveys. In the first survey, conducted in 2014, Xylella fastidiosa was found in coffee plants imported from Central America. • There have been no new Citrus long-horned beetle outbreaks in the past year. However, areas in which outbreaks occurred in the past years are continuing to be monitored to verify that the Citrus long-horned beetle has indeed been eradicated. No Citrus long-horned beetle have been found in these monitoring inspections. tree nurseries and green spaces number rejection due to quarantine pests 2012 2013 2014 2012 2013 2014 Inspections Tree nurseries, national survey 553 142 224 n/a 0 1 Tree nurseries, plan passport 11,089 10,488 10,353 72 54 37 Wood packing materials inspection programme 1,575 2,751 2,832 21 10 35 Green spaces, national surveys 944 765 562 75* 74* 101* * relates to Erwinia amylovora in buffer zones outside nurseries
• The number of live organisms that are found and the fact that wood packaging materials from Asia regularly lack the correct marks illustrate that wood packaging materials still pose the greatest threat to the green spaces in the Netherlands. For this reason, the Netherlands and China are working on a joint pilot trial project for the increased control of the use of correctly marked wood packaging materials. • New risk flows of wood products have emerged in 2014, as a result of which supplementary measures will be required.
Conclusions
• The number of Dutch interceptions of quarantine pests during inspections of imports from third countries increased in 2014 from 2013. • The number of identified imported goods documentation errors declined further in 2014 to almost half the level in 2011. The effects of the intensification of the document control pursuant to a recommendation issued by the Food and Veterinary Office (FVO) have also continued in 2014. • In 2014, the number of notifications the Netherlands received from third countries was comparable with the numbers in previous years, with a striking number of 21 notifications for seed material and fewer notifications for flower bulbs. • In 2014, the Netherlands received 74 notifications from EU Member States about consignments in intra-Community transport. Of these, 63 related to the finding of an EU quarantine pest; whilst the others related to the lack of, or an incomplete, plant passport. • In 2014, there were three changes in the pest status of organisms regulated in the EU since 2013. -F- rom transient to absent: Thaumatotibia leucotreta -F- rom absent to transient: Ralstonia solanacearum race 1 (Curcuma) -F- rom absent to transient: Thrips setosis (N.B.: does not have the quarantine status)
86 4.19 Plant protection
Controlling authorities: NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 1107/2009 placing of plant protection products on the market Directive 128/2009/EU sustainable use of pesticides Regulation (EC) No 1198/2006 statistics on plant protection products Directive 42/2006/EC machines for the application of plant protection products Regulation (EC) No 396/2005 plant protection product residues
National: • Plant protection products and biocides act (Wet Gewasbescherming en biociden) • Plant protection products and biocides decree (Besluit gewasbescherming en biociden) • Plant protection products and biocides regulation (Regeling gewasbescherming en biociden) • Environmental management activities decree (Activiteitenbesluit Milieubeheer)
Size of control file in 2014 (Source CBS9) types of establishments/products number (approx.) hectare (approx.) • Authorisation holders N/A N/A • Importers N/A N/A • Wholesalers 278a N/A users of plant protection products • Ornamental crops, greenhouses 2,350 4,138 • Vegetable cultivation, outdoor 4,330 79.000b • Trees and perennials 3,075 17,000. • Arable farming 11,950 517,000 • Fruit cultivation, outdoor 2,345 19,163 • Flower bulbs 1,515 23,590 • Vegetables, greenhouses 1,220 4,833 a Source CDG10 list. 241 CDG establishments and 37 VKL ([food quality contract work) establishments b Vegetable cultivation (83832) – vegetable greenhouse cultivation (4833)
The contents of the table shown above are the same as in the previous year, with the exception of the new ‘importers’ row. In recent years, the supervision of imports has become of increasing importance to the prevention of trade in and the use of illegal products. The ‘manufacturers’ type of establishment has been changed into ‘authorisation holders’. This relates to the quality control of products brought on the market, a responsibility which is borne by the authorisation holders. Target groups that are subject to controls carried out solely on the basis of reports and personal observations (such as public green spaces, livestock farming and private use) are not included. Public green spaces do not constitute a priority target group for the NVWA. The Human Environment and Transport Inspectorate (Inspectie Leefomgeving & Transport, IL&T) bears this responsibility. The inspectors include the contract work establishments in the relevant target groups.
Increases in scale and the economic circumstances are resulting in a gradual decline in the number of establishments, although the total area remains stable.
9 CBS = Statistics Netherlands 10 CDG = Certification for the distribution of plant protection products 87 Supervision of the trade in and use of plant protection products, results
A multi-annual enforcement programme has been developed for the control of the trade in and use of plant protection products. This includes an analysis of the Plant Protection Products and Biocides Act target groups. The target groups are reviewed regularly on the basis of the non-compliance risks. Various target groups are monitored on a project basis and controls are intensified where necessary by way of targeted control plans. The target groups were classified as follows in 2014:
High risk Medium risk Low risk Ornamental crops under glass Nursery Arable Flower bulb production Field-scale vegetables Fruit production Greenhouse vegetables Wholesalers Authorisation holders
Land in areas with a large volume of surface water or in water catchment or groundwater protection areas poses a higher environmental risk than in other areas. For this reason, these are assigned a higher priority. Target groups are also assigned a higher priority when the risks are greater due to the more intensive use of chemical plant protection products and an increased probability of the identification of non-compliance, such as ornamental crops in greenhouses.
The NVWA makes use of two forms of controls when monitoring users of plant protection products: 1. Application controls. These involve surveillance in the field at the point when a grower sprays his crop. The inspector focuses primarily on the use of plant protection products authorised for use in the Netherlands and use within 14 metres of surface water. This control is focused on compliance with the legal usage requirements and the special rules (emission abatement measures) applicable to spraying near surface water. 2. Establishment controls designed to ensure that growers are using exclusively authorised products and are using them in accordance with the legal requirements. In addition to a thorough inspection of the establishment and its records, the inspector may also take a plant sample for laboratory testing for residues of unauthorised products. This enables the NVWA to demonstrate whether a grower has used an unauthorised plant protection product and whether he has complied with the rules stated on the label. In addition, the records are checked for proof of professional competence. For controls of open and protected crops, the NVWA works with other bodies responsible for enforcing the Plant Protection Products and Biocides Act, in particular the Water Boards and the Human Environment and Transport Inspectorate (ILT, formerly the VROM Inspectorate) and the SZW Inspectorate 11 (formerly the Labour Inspectorate). In 2011, the NVWA also concluded a covenant with Customs on the monitoring of imports of plant protection products. results in 2014 number of establishment controls administrative and criminal law settlements warnings • Authorisation holders 36 1 5 • Importers 50 4 • Wholesalers 2 - 1 users of plant protection products: 344 83 30 • Ornamental crops, greenhouses 173 47 7 • Vegetable cultivation, outdoor 4 -- • Trees and perennials 7 - 2 • Arable farming 29 3 1 • Fruit cultivation, outdoor 16 1 1 • Flower bulbs 95 31 15 • Vegetables, greenhouses 11 - 2 • Public spaces 9 1 2
• Application inspections 290 63 13 • Reports/incidents/complaints 176 21 21
Total in 2014 868 172 70
11 SZW = Ministry of Social Affairs and Employment 88 The numbers are determined on the basis of the inspections completed in 2014. As some of these are still under investigation, the final number of settlements may vary slightly from the data in the table. 126 of the 868 inspections were begun before 2014. The table does not include 164 inspections that were begun in 2014 but have yet to be completed.
The results cannot generally be regarded as representative for the Dutch situation as the NVWA adopts a risk-oriented approach to inspections whenever feasible or, in other words, the NVWA’s controls focus on establishments at which the Authority has assessed that the probability of non-compliances will be greater. This analysis is often based on information and indications, a specific measurement or a general compliance measurement in a certain target group. Consequently, compliance measurements provide an indication for compliance in a certain sector since a representative random sample is taken.
The wholesaler target group requires an additional explanation. The wholesaler target group is classified as high risk as the target group’s position in the chain and the degree of compliance among wholesalers has an impact on the compliance level of all target groups. Within this context, it should be noted that the correct use of a product depends on the provision of the correct information to the users . As from 1 January 2010, all establishments trading in professional plant protection products must be affiliated with the foundation for the certification of the distribution of plant protection products (Stichting CDG). Pursuant to this affiliation, the CDG supervises the target group’s compliance with the regulations.
The inspections that were classified under ‘importers’ were inspections focused on imports of plant protection products. The NVWA, in cooperation with Customs, inspected 14 parcels and 65 containers that could have contained plant protection products during the course of 2014. These inspections resulted in the preparation of a fine report or an official report in seven cases. About 100 tonnes of non-authorised crop protection products were seized. The results gave cause to the continuation of the efforts in 2015. The current European attention being devoted to illegal and counterfeit products gives cause to the expectation that the efforts will need to be increased in the future.
As was the case in 2013, the inspections of ornamental crops under glass, such as of the cultivation of cut roses and the use imidacloprid, once again required a great deal of the NVWA’s attention in 2014. 130 inspections revealed culpable acts in 20 cases.
In addition to the specific establishment and application controls, the NVWA also carries out one or more compliance measurements in certain target groups each year. These offer a more or less representative insight into compliance in a target group. In 2014, the NVWA carried out a measurement in the flower bulb production target group. The 146 inspections established culpable acts in 51 cases that gave cause to the imposition of a fine. These usually related to the use of products that were not authorised for the cultivation. Indications have also emerged of the use of formalin.
Once the instructions for the use of metam sodium had been made more stringent. the reports were analysed and the reports with the highest risk were selected for inspection. Culpable acts were established in one case .
The discussions about the bee toxicity of neonicotinoids gave cause the devotion of specific attention to their use in 2014. The inspections of the use on flowering crops (prohibited) did not reveal any non-compliances. However, eleven reports of sudden sudden bee death were received in 2014. These have been investigated: in one case the bee death was caused by the use of imidacloprid. A number of additional inspections were carried out to review the greenhouse horticulture establishments’ compliance with their purification obligation. One inspection revealed a non-compliance.
The Rapid Alert System (RAS) was set up on the initiative of the OECD. This system enables consignments of illegal or suspected illegal PPPs to be tracked from the point of entry into the EU to the destination within the Member States. This system has been operational since October 2012. In 2014, the Netherlands submitted 26 RAS notifications of suspected illegal PPPs and/or active substances from third countries that had been imported into the Netherlands and were destined for one of the EU Member States.
89 Conclusions
• The controls and measurements that were carried out established that enforcement of the following aspects requires more attention: -- the use of non-authorised products in a number of specific ornamental crops grown in greenhouses; -- the use of illegal products, in particular the use of non-authorised herbicides in flower bulb cultivation; -- the failure to implement or the incorrect implementation of drift reduction measures in open fields near surface water, particularly in fruit production, field-scale vegetable production and arable agriculture -- carelessness resulting in the failure to clean the spray tank in the appropriate manner; -- the supply of and trade in products not authorised in the Netherlands; -- the bringing on the market of plant protection products with what are referred to as ‘parallel authorisations’ which do not comply with the legal requirements • The number of culpable infringements with ornamental plants in greenhouses, flower bulb production and the use of drift reduction measures in open fields near surface water in various target groups is relatively high. • Obtaining and maintaining an insight into the trade flows of pesticides continues to be of importance to the Authority’s ability to intercept unauthorised products as early as possible in the chain (imports, transit, internet).
90 4.20 Organic products
Controlling authorities: Skal Biocontrole
Summary of the main legislation addressed by controls in 2014
EU legislation Regulation (EC) No 834/2007, 889/2008 organic production and labelling of organic products Regulation (EC) No 1235/2008 provisions for import of organic products
Size of control file in 2014 type of establishment number Agricultural establishments 1,600 Food manufacturers, importers, 2138 trading and storage establishments Total 3,738
Supervision of organic products, results in 2014
Inspections Number Permit inspections 423 Expansion 98 Annual inspections 3,599 Re-inspections 171 Depth & chain & fraud 12 Unannounced snap inspections 605
Further explanation of the results for organic products
In 2014, all 3,738 organic establishments were inspected in either permit inspection for new establishments or an annual inspection for existing establishments. 302 establishments deregistered. The Skal inspections once again revealed that the large majority of the organic establishments complied with the statutory regulations in 2014. The certificates of these establishments were prolonged or renewed and newly-registered establishments received their first certificate. The NVWA regards compliance with the regulations as a favourable indication of the reliability of the Dutch organic product. However, not all establishments complied with the stipulated requirements. During their 1,501 visits to establishments the inspectors identified a total of 750 major non-compliances and 42 critical non-compliances. The number of critical non-compliances was lower than in 2013. ‘Critical’ does not imply a non-compliance of a severity that puts the food safety of the relevant product in jeopardy: it indicates that the relevant product or process no longer complies with the organic requirements. The 42 critical non-compliances were identified at 38 establishments, including their sub- locations. 24 critical non-compliances related to a repeated major non-compliance.
Projects
1. Supervision of the organic meat sector In 2014, Skal devoted additional attention to the organic meat sector in the form of announced and unannounced inspections. The certified operators that were subjected to an additional inspection all retained their organic certificate. The inspections revealed that the organic meat sector can develop itself further to improve traceability. Although organic certification requires extremely good administrative records, a number of meat processors fail to comply with this requirement. The mandatory re-inspections revealed that these non-compliances had been rectified: the operators had made adequate improvements to their administrative records.
91 2. Extra inspections of organic spelt Skal responded to the market’s indications of a shortage of organic spelt by conducting extra inspections. In 2014, Skal held extra inspections at fifteen establishments that process spelt. Skal’s inspections of the delivery documents established that the spelt was of organic origin. Samples were also collected at the establishments and analysed for the presence of non-authorised chemical plant protection products. None were found. The results from these samples give no cause to doubt the organic status of organic spelt.
3. Random samples of imported organic fruit and vegetables Skal collected 48 random samples of fresh fruit and vegetables at 20 wholesalers, importers and retail outlets in August 2014. Residues from a non-authorised plant protection product were found in one of the 48 products. Although a portion of the consignment could be returned to the supplier, the remainder had already been consumed and, consequently, could not be removed from the market. Future deliveries from the establishment concerned will need to be tested before they can be traded as organic. Skal will supervise compliance with this requirement.
4. Attention notices In 2014, Skal drew the attention of 60 conventional establishments to het need for them to subject themselves to Skal’s supervision due to their being engaged in organic operations (2013: 57). Some of these attention notices were issued following reports from attentive consumers.
Incidents
• In 2014, Skal issued a certificate to one butcher and suspended the certificate of one importer. Skal withdrew the certificate for the plot of a vegetable grower who had used non-authorised plant protection products. • Meat processing establishment: following hearings in 2014, the Skal disciplinary tribunal imposed a maximum fine of €15,000 on a meat processor for marketing conventional meat as organic meat (infringement from 2012). • Organic cattle feed (sunflower press cake): a consignment of contaminated cattle feed from Ukraine was brought on the market in a number of countries, including the Netherlands, by a Dutch importer. Inspections by Skal and the NVWA revealed that the 4000 tonnes of sunflower cake was contaminated with metalaxyl (fungicide) and thiamethoxam (insecticide) residues. A further inspection carried out by the NVWA revealed that no traces of the plant protection products remained in the animal products (milk, eggs and meat). Skal then also decided that the animals that had been fed with the contaminated feed would retain their organic status. The animal products also retained their organic status. The examination of the source of the contamination will continue into 2015.
Conclusions
The Skal inspections once again revealed that the large majority of the organic establishments complied with the statutory regulations in 2014. When this was not the case, Skal took enforcement action. The combination of the good compliance and enforcement reinforces the reliability of the Dutch organic product. The growth of the organic sector is resulting in higher numbers of inspections for Skal. In 2014, Skal ultimately issued more than 1,000 information packages, conducted about 5,000 inspections and collected almost 200 samples.
92 4.21 Geographical protection: PDO, PGI and TSG
Controlling authorities: COKZ, KCB and the NVWA
Summary of the main legislation addressed by controls in 2014
EU legislation protected designation of origin (PDO), Regulation (EC) No 1151/2012 and protected geographical indication (PGI), Implementing Regulations (EC) No 509/2006 and 510/2006 and traditional specialities guaranteed (TSG) for agricultural products and foodstuffs
Size of control file in 2014
type of establishment number Producers, importers and trading and storage establishments of cheese with a protected designation Factory processors of PDO and/or PGI cheese a 13 Processors of raw milk cheese (TSG) and/or Boeren-Leidse met sleutels (PDO) cheese 213 Subsequent processors of PDO, PGI and/or TSG cheese 58 Total 284 a Relates to Gouda Holland, Edam Holland and Noord-Hollandse Gouda. No Noord-Hollandse Edammer is produced.
Supervision of PDO, PGI and TSG, results in 2014
COKZ inspections of cheese with a protected designation in 2014 number Factory processors of PDO and/or PGI cheese 293 Processors of raw milk cheese (TSG) and/or Boeren-Leidse met sleutels (PDO) cheese 510 Subsequent processors of PDO, PGI and/or TSG cheese 58 Total 861 Factory processors of PDO and/or PGI cheese 293
samples/analyses of cheese with a protected designation Factory processors of PDO and/or PGI cheese -- microbiological analyses 293 -- phosphatase activity 149 -- compositional analyses 3,918 Processors of raw milk cheese (TSG) and/or Boeren-Leidse met sleutels (PDO) cheese -- compositional analyses 510 -- phosphatase a 53 Subsequent processors of PDO, PGI and/or TSG cheese -- microbiological analyses 17 -- additives (cheese rind treatment) 18 a At establishments with equipment to heat milk to above 40 °C (31 establishments).
Further explanation of the PDO, PGI and TSG results in 2014
Factory processors of PDO and/or PGI cheese The regulation on animal by-products (Animals Act) (Regeling dierlijke producten (Wet dieren) prescribes that cheese sold as Goudse kaas (Gouda), Edammer kaas (Edam) or Commissiekaas (Dutch Mimolette) shall be produced in a manner that complies with the characteristics laid down in the regulation. These types of cheese do not enjoy PDO or PGI status under EU law as such. However, a large proportion of Goudse kaas and, increasingly, Edammer kaas is now marketed under the respective EU protected geographical indications (PGI) Gouda Holland and Edam Holland. In addition, Goudse kaas is produced in the Province of Noord-Holland which is marketed under the EU protected designation of origin (PDO) Noord-Hollandse Gouda. No PDO protected Dutch cheese of the types Noord Hollandse Edammer, Kanterkaas, Kanternagelkaas or Kanterkomijnekaas were produced in 2014.
93 PDO Noord-Hollandse Gouda and Noord-Hollandse Edammer The product specifications for PDO Noord-Hollandse Gouda and Noord-Hollandse Edammer were adopted in 1997. There are two initial processors and four subsequent processors of Noord-Hollandse Gouda. Two controls of each of the two initial processors of Noord-Hollandse Gouda were carried out to assess compliance with the process requirements: it was verified that solely milk designated as originating from Noord-Holland was used in the processing of Noord-Hollandse Gouda. Those involved were called to account for non-compliances that were identified and measures were implemented to rectify the shortcomings. No non-compliances relating to Noord-Hollandse Gouda were submitted to the disciplinary tribunal.
PGI Gouda Holland and Edam Holland The Gouda Holland and Edam Holland product specifications were approved by the European Commission on 2 December 2010, and entered into force on 24 December 2010. The State Secretary for Economic Affairs, Agriculture and Innovation approved the control regulations on 25 January 2011.
Initial processors In 2014, thirteen initial processors were engaged in the production of PGI Gouda Holland or Edam Holland. The basic frequency of control visits to initial processors of PGI cheese has been set at nine per quarter. During these controls, samples are taken for analyses relating to the composition of the milk, microbiology, cheese milk pasteurisation, nitrate and brine. What is referred to as a ‘partial inspection I’ is carried out on the samples for composition analysis. An inspection is carried out four times a year to verify the correct use of rennet and starter culture, the correct use of the PGI cheese brand and the origin of the milk, etc. When an establishment has implemented a quality system which has been approved by the COKZ then the basic frequency of nine control visits and collection of a maximum of 150 samples for composition analyses can both be reduced to one-third. One establishment has indicated that it does not wish to make use of this opportunity for the time being. COKZ carries out 100% of the controls at this establishment. Quarterly reviews of the other initial processors of PGI cheese are carried out within the context of the regulation to verify that they still comply with the requirements laid down in the regulation. This was not the case at all establishments throughout the year. The results from the in-house controls at a number of the establishments were such that the COKZ found itself compelled to assume the full responsibility for this review during one or more quarters of the year. Non-compliances relating to the moisture content, fat content in the dry matter, maximum salt content in the dry matter, phosphatase activity and excessive heating of the cheese milk were submitted to the disciplinary tribunal. The results for the other aspects examined in the controls complied with the standards.
Subsequent processors In 2014, inspections were carried out at 58 subsequent processors to review compliance with the requirements for the subsequent processing of PGI cheese that are applicable to them. This cheese is inspected at an age of approximately 28 days (partial inspection II) on the subsequent processors’ premises. This relates to the shape, appearance, rind, milk ingredients, odour/flavour, cheese label and ripening temperature. The non-compliances that were identified did not result in sanctions. The relevant establishments were requested to implement corrective measures to prevent a recurrence. On its delivery the cheese is re-tested pursuant to the partial inspection III programme. This partial inspection programme consists of the partial inspection II programme supplemented with controls to verify the correct use of the Gouda Holland or Edam Holland designation. Samples collected at subsequent processors are also analysed for natamycin. The results from these analyses did not give cause to the implementation of measures.
Results from partial inspections I, II and III Some of the non-compliances identified during the partial inspections I, II or III, or identified in some other manner, related to the incorrect and misleading designation of the cheese. Seven of these non-compliances were of a severity that resulted in the decision to submit the case to the disciplinary tribunal. Comments were also made about the appearance, flavour and/or consistency of the cheese, as well as about the ripening temperature and compliance with the minimum ripening period. However, these non-compliances and comments were not of a nature such that they resulted in the imposition of written warnings or fine reports. The relevant establishments were requested to implement corrective measures to prevent a recurrence.
94 Kanterkaas The product specifications for cheese designated as Kanterkaas, Kanternagelkaas or Kanterkomijnekaas were adopted in 2000. The relevant specifications were published in 1999. No cheese processors were engaged in the production of these types of cheese in 2014.
Boeren-Leidse met sleutels (PDO) The product specifications for Boeren-Leidse met sleutels were adopted in 1997. This type of cheese is a semi-hard raw milk cheese, or Boerenkaas, produced in accordance with the special recipe for this type in the Netherlands in an area defined in the specifications. Thirteen initial processors are engaged in the production of Boeren-Leidse met sleutels. About fifteen subsequent processors are engaged in the production ofBoeren-Leidse met sleutels. Seven of the thirteen initial processors were visited and reviewed within the context of the PDO inspection programme. Reviews were carried out at the other six establishments within the context of the raw milk cheese (Boerenkaas) TSG inspection programme , which is largely identical to the PDO inspection programme. Both programmes encompass analyses including the fat content in the dry matter, the moisture content and the raw milk nature of the cheese. The relevant establishments were charged with non-compliances with these aspects and the relevant fine regulation was implemented. The stringency of the regulation governing non-compliances with the fat content in the dry matter was increased on 1 October 2014.
Boerenkaas (TSG) The product specifications for Boerenkaas were adopted in 2007. This is cheese that is made on the farm from raw milk largely supplied by the farm’s dairy cows. More than 200 processors of Boerenkaas in the Netherlands and just under 40 subsequent processors of Boerenkaas are active in the Netherlands The latter group is primarily engaged in the storage of the cheese during the ripening process. The COKZ formulated the TSG Boerenkaas control regulations 2007 for the performance of the relevant controls. The regulations were approved by the then Minister of Agriculture, Nature and Food Quality in 2008. These control regulations were used to lay down the TSG Boerenkaas control programme 2008. The majority of the Boerenkaas that was inspected complied with the relevant composition and quality requirements. Any non-compliances that were identified related largely to the phosphatase activity (an analysis carried out to determine whether the milk used to make the cheese has been heated), fat content in the dry matter and the moisture content. In most cases, the non-compliances were settled with a warning. A number of non-compliances were of a severity that resulted in the decision to submit the case to the competent disciplinary tribunal. The relatively high percentage of non-compliances with the specification for the fat content in the dry matter required additional attention. It was decided to increase the stringency of the relevant fine regulation as from 1 October 2014.
The COKZ regularly drew some of the establishments’ attention to their incorrect and occasionally misleading designations of the cheese on labels that are either unintentionally or intentionally applied to the product, in particular to what is referred to as ‘cheese from the farm’ (kaas van de boerderij) that does not comply with the Boerenkaas specifications but nevertheless is occasionally designated asBoerenkaas . In view of this situation, it was decided that as from 1 January 2015 establishments will be charged with non-compliances relating to theBoerenkaas designation or name and that these cases will be will be submitted to the COKZ disciplinary tribunal.
Supplementary information:
Five PDOs, three PGIs and two TSGs (see table) from the Netherlands are registered in the database of origin & registration12
12 http://ec.europa.eu/agriculture/quality/schemes/index_en.htm 95 name type registered since
Basterdsuiker/Basterdsuicker/Basterdsuijcker/ Basterdsuijker/Basterd/Bastardsuiker/ TSG 07/11/2013 Bastardsuicker/ Bastardsuijcker/Bastardsuijker/Bastard/Bastert/Bastertsuiker
Gouda Holland PGI 03/12/2010 Edam Holland PGI 03/12/2010 Boerenkaas TSG 16/02/2007 Westlandse druif PGI 07/11/2013 Kanterkaas; Kanternagelkaas; Kanterkomijnekaas PDO 08/09/2000 Boeren-Leidse met sleutels PDO 13/06/1997 Opperdoezer Ronde PDO 21/06/1996 Noord-Hollandse Gouda PDO 21/06/1996 Noord-Hollandse Edammer PDO 21/06/1996
The COKZ carries out the controls on registered dairy products, the KCB on fruit and vegetables and the NVWA on other products and in the retail chain. The NVWA and KCB began their controls in 2015.
Conclusions
The use of the correct designation for cheese with PDO, PGI or TSG protection status requires additional attention. This is applicable to Gouda Holland cheese, Edam Holland cheese and raw milk cheese (Boerenkaas). It has been decided that the stringency of the supervision will be increased. This is also applicable to the fat content in the dry matter of Boerenkaas and Boeren-Leidse met sleutels PDO. The attention devoted to Gouda Holland cheese and Edam Holland cheese will focus on the moisture content of these types of cheese.
96 Chapter 5: Audits
Introduction
This chapter reviews the audits conducted within the context of Regulation (EC) No 882/2004 in 2014. The Chapter begins with the internal audits conducted by the NVWA and the moves on to the audits the NVWA conducted during the course of the year at external organisations that perform certain tasks under the responsibility of the NVWA.
Internal audits at NVWA in 2014 Various NVWA laboratory and inspection activities have been accredited by the Dutch Accreditation Council (Raad van Accreditatie, RvA) on the basis of international quality standards. In addition to the annual external audits conducted by the RvA, the NVWA also conducted a number of internal audits in 2014. The most important conclusion from these audits is that the NVWA’s quality system is appropriate, effective and is ISO 17025 or ISO 17020 compliant. These internal audits relate to the following divisions: • Feed and Food Safety Laboratory The laboratory performs laboratory research on products of animal origin and food and is RvA accredited and registered under the code L-104. • National Reference Centre (NRC) The NRC is the knowledge centre in the division dealing with phytosanitary organisms and diagnostics, vectors and invasive plants. The laboratory’s research is RvA accredited and registered under the code L-522. • Supervision of fish The Fish teams supervise compliance with the regulations at landing and export of fishery products. This task is RvA accredited and registered under the code I-134. • Border Inspection Posts (BIP) One of the tasks of the Import Execution Supervision department is to supervise compliance of imports of live animals and products of animal origin at Border Inspection Posts (BIP). This task is RvA accredited and registered under the code I-134.
In 2014, the following internal audits were also conducted within the context of Regulation (EC) No 882/2004. The main conclusions are: • 2014-103 L&N I&R controls of sheep and goats (follow-up) In 2014, an internal audit was conducted on the identification and registration (I&R) controls of sheep and goats. This audit focused on the improvement measures implemented following the non-compliances identified in a previous audit in 2013. It was established that the number of non-compliances has decreased and that work on the improvement measures is continuing. • 2014-01 C&V HAIR internal audit hotel/restaurant/catering team In October and November 2014, a conformity audit was conducted in the Food Safety (consumer market and institutions) domain. To this end, the auditors attended a number of inspections by a hotel/restaurant/catering team. This audit identified a number of issues that need to be improved, such as the correct registration of inspection data and the inspectors’ knowledge of the quality documents. • 2014-01 V&I import TRACES In the summer of 2014, an internal audit was conducted at the various NVWA divisions involved in the TRACES process. The audit focused on verifying that all the required information is registered in TRACES correctly and in time. From the findings from the audit it can be concluded that the information is registered correctly in TRACES and, with one or two exceptions, (no contact with provider) in time. The inspectors receive sufficient support and training. • 2013-50 IAD RiskPlaza The RiskPlaza system has been set up for the food sector to support establishments in the provision of assurances for the food safety of ingredients. The NVWA and the then Product Board Arable Products signed the Horizontal Supervision (HT) covenant on 4 June 2012. The two parties concluded the HT covenant in an endeavour to elevate the use of the RiskPlaza database and the RiskPlaza audit+ to an increased level of compliance with the applicable regulations. This simultaneously reduces the verification burden on the participating establishments as the NVWA no longer carries out inspections relating to the ‘control of hazards in raw materials’ issue. The chief inspector of the
97 Consumer and Safety Division requested the Internal Audit Service to conduct an audit of the management and performance of the RiskPlaza. The general conclusion of the Internal Audit Service’s audit was that the performance of the RiskPlaza database and RiskPlaza audit+ is adequate for the provision of assurances for the food safety of ingredients. The Internal Audit Service issued a number of recommendations for improvements of the system. The management of the Consumer and Safety Division has stated that it will implement the recommendations and discuss them with the owner of the RiskPlaza. • 2014-60 IAD COKZ Following the Russian inspections of the dairy sector in the autumn of 2014 the Internal Audit Service, on the request of the Deputy Inspector-General, conducted an audit of the supervisory activities of the Netherlands Controlling Authority for Milk and Milk Products (Centraal Orgaan voor Kwaliteitsaangelegenheden in de Zuivel, COKZ). The audit related to a quick scan of the COKZ’s issue of health and other export certificates for Dutch dairy products to the Customs Union of Belarus, Kazakhstan and the Russian Federation. It was concluded from the results of the quick scan that the COKZ’s performance of its duties relating to veterinary export certificates for dairy products to the Customs Union is adequate. It was also concluded that the COKZ’s supervision of the authorised establishments is sufficiently powerful and that the NVWA’s performance of its supervisory duties relating to export certificates for dairy products is inadequate. The Inspector-General has announced a number of measures to intensify the NVWA’s supervision of the COKZ. In 2015, the Internal Audit Service will also conduct a follow-up audit of the implementation of the measures that have been announced and their performance. • 2014-69 IAD Audit of the docking of horses tails The Internal Audit Service has initiated an audit of the NVWA’s treatment of internal and external reports relating to the docking of horses tails that is prohibited by law in the Netherlands. It has been established that a specific report from 2012 (which gave cause to the audit by the Internal Audit Service) had not been registered correctly in the report system. The organisation of the report process was improved in 2013, and all reports are now closed with a written communication (on location). It has also been established that a number of reports have given cause to an enforcement investigation relating to the docking of horses tails. • 2014-72 IAD BIP Rotterdam The NVWA’s Internal Audit Service conducted an audit of the documentary, identity and physical checks of veterinary products at the BIP Rotterdam. The objective of this audit was to assess the design, implementation and performance of the documentary, identity and physical checks and to submit recommendations on potential improvements. The audit also examined the measures that have been implemented following the report from the Dutch Safety Council (Onderzoeksraad voor de Veiligheid, OvV) (March 2014) and the FVO reports of March 2011 and June 2013. The general conclusion is that the BIP organisation has exhibited an active response to the comments made in the reports from the Dutch Safety Council and FVO. The control and management measures for the correct implementation of the veterinary import controls are adequate. The ‘consignments that got through’ pose a residual risk, although it is expected that the management measures will limit this residual risk.
Audits of external bodies conducted by the NVWA in 2014
The NVWA conducted the following external audits in 2014:
Veterinary & Import Division • Animal Sector Quality Inspection Foundation (Kwaliteitskeuring Dierlijke Sector) The Animal Sector Quality Inspection Foundation (Kwaliteitskeuring Dierlijke Sector, KDS) is an accredited private organisation that carries out post-mortem (PM) inspections of red meat on behalf of and under the auspices of the NVWA. For this purpose, the covenant on the organisation of (post-mortem) red meat Inspections (Convenant Organisatie roodvleeskeuring post-mortem) was drawn up in the Netherlands along with the associated regulatory arrangements. The NVWA audits PM inspections of red meat once a year. The audit focuses on the official assistants’ performance of their inspection activities and other inspection competences as defined in the VWA-KDS Contract, the associated annexes and the KDS Quality Manual. The audit also includes the internal audits performed by the KDS and by the Dutch Accreditation Council (Raad voor Accreditatie).
98 The audit conducted by the NVWA revealed that the KDS has implemented a number of important formal improvements since the NVWA’s 2013 audit, including the adoption of the agreements by inspection location (slaughterhouse protocols) in consultation with the NVWA 2013, the more intensive reporting of issues requiring attention at inspection locations and the completion of the revised training. The KDS has implemented a robust evaluation and internal audit system. This records bottlenecks and provides an insight into improvement actions and results. The work at the larger inspection locations with permanent NVWA supervision is also in accordance with the agreements.
The NVWA recommends that the KDS intensify its monitoring of the inspection activities at the smaller inspection locations without permanent NVWA supervision. Although this has not resulted in demonstrably incorrect inspection decisions at any location, in some instances the KDS inspection assistants fail to observe the agreements reached by the NVWA and the slaughterhouse to an adequate extent. In view of the option available to pig slaughterhouses to apply for visual inspections from 1 July 2014, the NVWA recommends that the KDS increase its supervision of the KDS inspection assistants to ensure that they respond to the appropriate indications by carrying out additional – full – inspections.
Consumer and Safety Division • The Netherlands Controlling Authority for Milk and Milk Products (Centraal Orgaan Kwaliteitsaangelegenheden in de Zuivel, COKZ) The COKZ supervises the dairy sector’s compliance with food safety legislation. The collection of the various acts that are applicable is referred to as the ‘Hygiene Package’. The COKZ conducts this supervision pursuant to a mandate granted by the Inspector-General of the Netherlands Food and Consumer Product Safety Authority (NVWA). The COKZ also, in its role as an unremunerated public official of the NVWA, supervises compliance with the animal by-product legislation and regulations.
The COKZ draws up an annual work plan listing the type and quantity of each task to be performed. The NVWA’s approval of this work plan is required. The COKZ gives account for the work that it actually carries out each year in an annual report and a Management Control System (MCS). The NVWA , on the request of the chief inspector of the Consumer and Safety Division (C&V), conducts an annual audit to assess the quantity and quality of the work carried out by the COKZ. The scope of the audit encompassed 2013, and was limited, as at the time the COKZ was holding consultations with the NVWA on a number of structural changes to its supervision. For this reason, the audit was limited to a qualitative and quantitative analysis of the performance of the supervision and did not address the structure of the supervision.
The NVWA’s audit revealed that, in general, the COKZ gave sufficient qualitative account of its planned and actual activities in 2013. Exceptions to the above were the actual number of samples the COKZ collected at establishments that was below budget but was not accompanied by a clear explanation and the actual extra audits and unannounced inspections relating to animal by-products legislation that were fewer than the stated number. Improvements are evident in the supervision. The COKZ inspectors have improved their documentation of the supervision of dairy establishments, processors of special foods and farm dairy processors. The COKZ inspectors make good efforts, but lack the knowledge of some elements of the legislation to always act in a uniform manner, provide appropriate substantiation for identified non-compliances and make the correct interventions. The COKZ has observed a number of recommendations issued in previous NVWA audits and is consulting with the NVWA on some of these. As a result, and although the depth of the inspections and the efforts made by the COKZ inspectors had improved at the time of the audits, the implementation of the supervision – in particular, the knowledge of the legislation and the uniform implementation of the supervision and interventions – still exhibits room for improvement.
The NVWA’s recommendation on the qualitative account given for the activities recommends that more transparent account be given of the the organisation of the supervision – and, as a result, its quality – in the MCS annual reports. This then relates, in particular, to the creation of a distinction between the various types of inspections and various types of establishments. In addition, it is also recommended that the COKZ informs the NVWA immediately, with substantiation, of quantitative and qualitative variances from the work plan.
99 In conclusion, the NVWA audit team recommends that the COKZ increase its focus providing the COKZ inspectors the knowledge of the legislation they need to act in a more uniform manner, provide improved substantiation for non-compliances and intervene in a consistent and appropriate manner.
Agriculture and Nature Division • Phytosanitary inspection services The Ministry of Economic Affairs delegated the phytosanitary import inspections to the four inspection authorities BKD, KCB, NAK and Naktuinbouw in the Multiannual Phytosanitary Inspection Agreement. In 2014, the NVWA conducted supervision audits of these inspections and attended the inspections on a regular basis. During the period under review, the NVWA attended 37 inspection visits focused on rejection (imports) or indemnification (exports) and four other activities (field inspections within the context of the issue of plant passports, surveys and sampling, etc.). This related to activities carried out by 28 officers. It was concluded that the parties involved exhibited a reasonable to good performance and that the inspections and associated actions are carried out at least in compliance with the agreed reference level. The organisation of the quality management systems of the inspection authorities and their procedures for carrying out phytosanitary import and export inspections are, in general, well organised. However, scope for improvement was identified in various areas of the operations at all the parties. These included the quality of the certified phytosanitary certificates, the sequence of inspections, the inspection conditions, and the identity and document checks. • Phytosanitary inspection services diagnosis laboratory External laboratories that carry out official phytosanitary inspections have received the necessary authorisation from the NVWA NRC (National Reference Centre). This relates to inspections of what are referred to as ‘official samples’ to test for specific organisms referred to in Directive 2000/29/EC. Some of these operations are audited annually by the NVWA within the context of the Phytosanitary Inspection Agreement. The laboratories have also received accreditation for, or for some, of the authorised operations. The Dutch Accreditation Council (Raad voor Accreditatie, RvA) also conducts annual audits. The reports of these audits are taken into account in the NVWA’s assessment.
The NAK has been authorised for 27 operations. In 2014, the audit focused on visual, nematological and bacteriological operations with the IF technique. Naktuinbouw has been authorised for 42 operations. In 2014, an audit of Naktuinbouw was conducted which consisted of two separate one-day sub-audits that reviewed the quality management system and the virology, molecular biology and mycology aspects. The bacteriology aspect was assessed in a document audit. The positive opinion of the Dutch Accreditation Council (Raad voor Accreditatie, RvA) was adopted for the second and third line assurances element of the requirements on the quality management system. The BKD does not carry out laboratory tests on EU quarantine pests. However, the BKD has been authorised to carry out three operations on third country quarantine pests. The 2012 report of the Dutch Accreditation Council (Raad voor Accreditatie, RvA) revealed that these three operations are carried out in accordance with the prescribed requirements.
It was concluded that the assurances included in the quality management systems of the BKD, NAK and Naktuinbouw have been implemented and perform to an adequate extent to provide for arriving at the correct diagnoses for the audited organism/plant combinations. The operations that were attended were performed in accordance with the requirements. The combined supervision activities of the NVWA and the Dutch Accreditation Council (Raad voor Accreditatie, RvA) do not give cause to doubt the results of the phytosanitary laboratory tests issued by the inspection authorities.
BLGG has been authorised by NVWA-NRC to test anonymised soil samples within the context of what is referred to as the ‘control directive’, Directive 2007/33/EC on potato cyst nematodes. The 2013 report of the Dutch Accreditation Council (Raad voor Accreditatie, RvA) revealed that the phytosanitary operations are carried out in accordance with the prescribed requirements.
• Resistance tests for potato cyst nematode and potato wart disease Research institutions can make the results of their resistance tests available to the NVWA, to enable the NVWA produce name lists of resistant potato varieties (within the context of the EU control directives 2007/33/EC [for potato cyst nematode] and 69/464/EEC [for potato wart disease]). These test results are used only when it has been
100 confirmed that the test was carried out in accordance with the specified implementation protocols. The NVWA assesses this by auditing the research institutes. Within this context the NVWA audited three private laboratories that perform resistance tests for potato cyst nematode and potato wart disease. It was concluded that all three have implemented effective quality management systems and that the tests meet the conditions laid down in the implementation protocols.
101 Chapter 6: NVWA Intelligence and Investigation Service (NVWA IOD)
The tasks of the Special Investigation Service (BOD) of the Ministry of Economic Affairs and the Ministry of Health, Welfare and Sport are brought under the NVWA Intelligence and Investigation Service (NVWA IOD). The IOD is active in all NVWA domains. The NVWA IOD is deployed in the event of serious or systematic infringements of the law in the NVWA’s enforcement domain. The NVWA-IOD then focuses primarily on complex, chain-related, organised and international criminality. The core tasks of the NVWA IOD are: • collecting and refining intelligence • carrying out analyses to improve insights into the nature and extent of compliance and non-compliance • conducting investigations on the basis of a wide range of powers
In 2014, the investigations addressed the following subjects: • meat scams, such as the false labelling of horse meat • manure fraud • illegal trade and internet trade in protected animals and/or plants • animal welfare transgressions violations during transport • fraud in the certification of attractions • trade in products not intended for human consumption
Cooperation with other investigation organisations is assured by means including the Special Investigation Services Platform Cooperation and the National Intelligence Agenda. In areas relating to environmental enforcement, the NVWA IOD cooperates intensively with the police and the Intelligence and Investigation Service of the Human Environment and Transport Inspectorate (ILT IOD).
Investigations and requests for mutual assistance
In 2014, the NVWA IOD completed 24 investigations, of which nine were what are referred to as ‘Rapid Intervention Services (RIS)’ and – with the exception of four investigations that were broken off – submitted them to the Public Prosecutor’s Office for further investigation. The NVWA IOD also handled seven other requests for mutual assistance on various subjects. Of these investigations, eighteen concerning food fraud were completed. These included illegal slaughtering, the use of illegal veterinary medicinal products, fishing quota fraud, trading in unsuitable consignments of meat or dairy products, or fraud involving the origin, type or designation of foodstuffs. Other themes included animal feed, product safety, animal welfare and phytosanitary issues.
Other tasks
The NWA IOD cooperates with the supervision divisions of the NVWA and other enforcement services such as the National Police Force. As the many domains in which NVWA carries out enforcement are extremely knowledge-intensive, the NVWA IOD devotes some of its capacity to the performance of analyses to increase the insights into fraud. These insights are published, as was recently the case with the analysis of fraud in the meat sector.
The NWA IOD, Public Prosecution Service’s Functional Public Prosecutor’s Office and other special investigation services have also drawn up a phenomenon analysis of the risks of fraud with government grants. In 2014, in conclusion, the NVWA IOD published an article on combating food fraud in the Netherlands (De bestrijding van voedselfraude in Nederland) in the Justitiële Verkenningen journal. This article provides an insight into the NVWA IOD’s food fraud cases and analyses them in terms of aspects including opportunity and motive.
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