EUROPEAN COMMISSIONDIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY
Health and food audits and analysis
DG(SANTE) 2020-6927
FINAL REPORT OF AN AUDIT
CARRIED OUT IN
MALTA
FROM 24 FEBRUARY 2020 TO 04 MARCH 2020
IN ORDER TO
EVALUATE THE CONTROL SYSTEM IN PLACE GOVERNING THE PRODUCTION AND PLACING ON THE MARKET OF BOVINE MEAT, INCLUDING TRACEABILITY
Ref. Ares(2020)4166430 - 07/08/2020
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Executive Summary
This audit was carried out from 24 February to 4 March 2020 by Directorate-General for Health and Food Safety of the European Commission in order to assess the official controls related to the production of bovine meat, including traceability. In addition, the audit collected information on the ante-mortem and post-mortem arrangements in place regarding the poultry sector.
The audit established that competent authorities at all levels are seriously understaffed, which has an evident impact on the effectiveness of official controls. The posts of Chief Veterinary Officer and of four out of five Heads of Unit are vacant, whilst at the lower level, the tasks of several vacant posts are covered and shared by available staff from different services, but without providing appropriate training for these tasks.
As a consequence, the frequency of inspections of food producing establishments established by the competent authority, based on the risk assessment of their activities, cannot be respected, and relevant non-compliances with regulatory requirements in all areas remain undetected for a long period of time. These non-compliances include issues regarding the traceability of red meat and poultry meat, the state and the verification of cleanliness of establishments, and microbiological testing of carcases at slaughterhouse level.
The system for approval of food producing establishments also showed important shortcomings; all approval files reviewed by the audit team were largely incomplete, demonstrating that the competent authority does not keep the approval conditions under regular review, contrary to what is required by Article 148(5) of Regulation (EU) 2017/625 of the European Parliament and of the Council.
In contrast, the traceability of live cattle was satisfactory, due to the regular update of the National Livestock Database by the competent authority.
The findings regarding ante-mortem and post-mortem inspections at slaughterhouse level were generally well documented, and consistent; however, the evaluation of (incomplete) Food Chain Information was poor at the poultry slaughterhouse. There is an efficient system in place for emergency slaughter at farms of animals unfit for transport, which has dramatically reduced the number of animals deemed unfit for transport arriving at slaughterhouses.
No particular issues were identified in respect of animal welfare at slaughterhouse, but regulatory requirements regarding animal welfare during transport, especially those related to the suitability of vehicles, are not verified by official controls. Religious slaughter of farmed animals is systematically carried out with prior stunning.
The report contains recommendations to the central competent authority to address the shortcomings identified and to further enhance the control system.
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Table of contents
1 Introduction ....................................................................................................................................1
2 Objectives and scope......................................................................................................................1
3 Legal Basis .....................................................................................................................................2
4 Background ....................................................................................................................................2
5 Findings and Conclusions ..............................................................................................................2
5.1 Legislation and implementing measures .................................................................................2
5.2 Competent Authorities.............................................................................................................3
5.2.1 Structure and organisation ............................................................................................3
5.3 Approval of establishments .....................................................................................................7
5.4 Organisation and implementation of official controls .............................................................9
5.4.1 Official controls on cattle identification and movements of animals ...........................9
5.4.2 Official tasks at establishment level (slaughterhouses) ..............................................12
5.4.3 Official controls of Food Operators' obligations ........................................................14
5.4.4 Animal welfare at transport and the time of slaughter or killing................................15
5.4.5 General and specific hygiene requirements................................................................16
5.4.6 HACCP.......................................................................................................................17
5.4.7 Microbiological criteria ..............................................................................................17
5.4.8 Traceability, labelling and health marking .................................................................18
5.5 Rapid Alert System for Food and Feed (RASFF) .................................................................20
6 Overall Conclusions .....................................................................................................................20
7 Closing Meeting ...........................................................................................................................21
8 Recommendations ........................................................................................................................22
ANNEX 1 - Legal references
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ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT
Abbreviation Explanation
AHU Animal Health Unit
AHWD Animal Health and Welfare Department
AWU Animal Welfare Unit
CA(s) Competent Authority(ies)
CCA Central Competent Authority
CVO Chief Veterinary Officer
DG Health and Food Safety
Directorate-General for Health and Food Safety of the European Commission
EHD Environment Health Directorate of the Ministry of Health
EU European Union
FBO(s) Food Business Operator(s)
FCI Food Chain Information
HACCP Hazard Analysis and Critical Control Points
NLD National Livestock Database
OV(s) Official Veterinarian(s)
RASFF Rapid Alert System for Food and Feed
VRD Veterinary Regulation Directorate
VSO(s) Veterinary Support Officer(s)
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1 INTRODUCTION
The audit took place from 24 February to 4 March 2020. The audit team comprised one auditor from Directorate-General for Health and Food Safety of the European Commission (DG Health and Food Safety) and was accompanied throughout the audit by representatives of the Central Competent Authority (CCA), the Veterinary Regulation Directorate (VRD). In addition, the audit team met staff of VRD involved in the control systems during the relevant parts of the audit.
An opening meeting was held on 24 February with the CCA in Marsa. At this meeting, the audit team confirmed the objectives of, and itinerary for, the audit, and additional information required for the satisfactory completion of the audit was requested.
2 OBJECTIVES AND SCOPE
The main objective of the audit was to evaluate the operation of official controls and the enforcement of the applicable European Union (EU) requirements over and along the production chain of bovine meat. In particular, the audit focused on the official controls exerted over culled cows (at the end of their production life).
In terms of scope, the audit covered bovine slaughter, and in particular:
the organisation and competencies of the competent authorities (CAs), including oversight and enforcement, at all relevant levels, in particular the controls over production and traceability of bovine animals at the end of their production life, and certain aspects of animal welfare especially the evaluation of fitness for transport and slaughter;
the CAs' performance in terms of the design and on-the-ground implementation of the official control systems covering the production, processing and distribution chains of beef, and products derived therefrom.
In addition, the audit collected information on the ante-mortem and post-mortem arrangements in place in Malta regarding the poultry sector.
The table below lists the sites visited and the meetings held in order to achieve the above-mentioned objective:
COMPETENT AUTHORITY
Central VRD 2 At opening and closing meetingsCentral Environmental Health Directorate (EHD)
1 At closing meeting
Other VRD and EHD staff During visits to food business operatorsCentral Bovine Database 1
2
FOOD BUSINESS ESTABLISHMENTS
Bovine slaughterhouses 2 Only one in operationCutting plants 2 One integrated in a slaughterhouse and one stand alonePoultry slaughterhouse 1Dairy Farms 1 Dairy cattle farmButcher shop 1
3 LEGAL BASIS
The audit was carried out under the general provisions of EU legislation and, in particular Articles 116, 117 and 119 of Regulation (EU) 2017/625 of the European Parliament and of the Council (the “Official Controls Regulation – OCR”).
EU legislation (1) relevant to the audit is listed in the Annex to this report.
4 BACKGROUND
The audit took place as part of a series of audits planned in the Member States initiated in 2019 after media allegations of slaughter, in several Member States including Germany, of cows unfit for slaughter for human consumption and/or of breaches in the animal welfare rules during transport and slaughter. This initiated series of audits will continue.
Those media reports and a recent Commission audit in another Member State have pointed to gaps in the official control systems that could potentially facilitate the slaughtering of such cows.
Against this background, and in the context of the enactment of the OCR, Commission Delegated Regulation (EU) 2019/624 and Commission Implementing Regulation (EU) 2019/627, DG Health and Food Safety initiated this audit series with the aim of assessing the performance of the CAs in this area of official controls.
5 FINDINGS AND CONCLUSIONS
5.1 LEGISLATION AND IMPLEMENTING MEASURES
Legal requirements
Article 291(1) of the Treaty on the Functioning of the European Union and Articles 1(3)(d) and (4) of Regulation (EC) No 853/2004 of the European Parliament and of the Council.
Article 5(1)(g) and (h) and Article 18(1) of Regulation (EU) 2017/625.
(1) EU legal texts quoted in this document refer to the last amended version.
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Findings
1. The CCA stated that no derogations, pursuant to Article 10(3) of Regulation (EC) No 853/2004, in the form of national legislation adapting the requirements laid down in Annex III of Regulation (EC) No 853/2004 are in place.
2. The CCA had granted one of the two approved slaughterhouses a flexibility measure in the form of decreased frequency of the testing of carcases for verification of process hygiene, as provided for in Article 5(3) of Commission Regulation (EC) No 2073/2005 (see paragraphs 19, 31 and 77).
3. No implementing measures are currently yet envisaged by the CCA that would effect changes in responsibilities with regard to ante-mortem and post-mortem inspections between official veterinarians (OVs) and official auxiliaries, following the adoption in 2019 of the EU provisions implementing the requirements of the OCR.
Conclusions on legislation and implementing measures
4. No national legal measures are in place that provide for deviations from the existing EU legal framework.
5.2 COMPETENT AUTHORITIES
Legal requirements
Articles 4, 5 and 6 of Regulation (EU) 2017/625.
Article 13 of Regulation (EU) 2019/624.
Findings
5.2.1 Structure and organisation
5. The relevant CAs and the organisation of the control systems are described in the country profile for Malta, available at the following link: https://ec.europa.eu/food/audits-analysis/country_profiles/details.cfm?co_id=MT. However, responsibilities at higher levels changed in January 2020.
6. In summary, the CA comprises a three-level structured system, which has recently changed due to a re-organisation at the level of Ministries: the responsible Ministry is no longer the Ministry for Environment, Sustainable Development and Climate Change, but is currently the new Ministry of Agriculture, Fisheries and Animals Rights (MAFA).
7. The former Veterinary and Phytosanitary Regulation Department, which was responsible for policies’ development, is now re-named as the Animal Health and Welfare Department (AHWD). It no longer has responsibility for plant protection, which has been attributed to another Department. Consequently, a small number of staff from the
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AHWD (mainly administrative staff) have moved to that Department. The AHWD includes:
a. the Animal Welfare, Promotion and Service Directorate, mainly responsible for controls over pet animals;
b. the VRD, which has maintained its name and is the CCA, of which the Director is also the Chief Veterinary Officer (CVO). The VRD is responsible for the implementation of food safety legislation at level of primary production, processing, transport and trade of food of animal origin, with the exception of the retail and catering sectors. Within the VRD the following Units are relevant for the scope of the audit:
i. Safety of Food Chain Unit (SFCU), responsible for official controls, among others, in red meat establishments (slaughterhouses and cutting plants),
ii. Animal Health Unit (AHU), also responsible for managing the Animal Register National Livestock Database (NLD),
iii. Animal Welfare Unit (AWU),iv. Policy and Enforcement Unit,v. Trade Unit, including border controls;
c. at establishment level, OVs and official auxiliaries (named Veterinary Support Officers – VSOs) supervise the food business operators (FBOs).
8. Some high grade OVs (e.g. named “officers in grade 5”) carry out routine tasks such as ante-mortem and post-mortem inspections in a State-owned multispecies slaughterhouse and in one rabbit slaughterhouse, in addition to their management duties (see paragraph 14).
9. Butcher shops, including those located in supermarkets, are inspected by the official staff pertaining to the EHD under the Ministry for Health.
10. As described in the country profile for Malta, the coordination between the activities of the different authorities involved in health and food safety is ensured by monthly meetings of the Food Safety Commission, where the VRD and the EHD are also represented.
11. Some coordination activities and exchange of information between the different units of the VRD (e.g. when non-conformities originating at holding level in relation to animal welfare are detected during visits to perform animal health tests) have been implemented and documented: in such cases the OV of the AHU informs the colleagues of the AWU at VRD level for the appropriate action to be taken.
12. Similar exchange of information has been envisaged in cases where non-conformities in relation to animal welfare or animal identification are detected at slaughterhouse level. The OV at one of the two approved slaughterhouses stated that, due to the heavy workload caused by shortage of staff, he/she had currently no time to implement such a
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procedure. Currently, in such cases, OVs at both multispecies slaughterhouses only issue the responsible farmer with a verbal warning.
13. OVs may also be involved in private professional activities, but they have to declare any potential conflict of interest and must receive a specific approval from their hierarchy.
14. All levels of the CA are affected by staff shortages, as several officials are either on unpaid leave or maternity leave, whilst all but one of the Heads of the VRD Units posts are vacant, as well as the post of CVO. As a result, several officials cover and share the tasks from the colleagues above mentioned between different Units and services, while completing their workload, without having been provided with specific training for those tasks.
15. Field services of the EHD are also understaffed, which impacts on the number and on the extent of their inspections over retailers’ activities.
16. The CCA stated that the last two competitions for recruiting OVs resulted in only one suitable candidate being selected; this person is in the process of being recruited and will take up the position in April 2020. Six Maltese veterinarians will be graduating from a University in Europe, and the CCA is expecting that at least some of these new graduates may be interested in participating in the forthcoming competitions for the recruitment of new staff. The CCA explained that the reasons for such low interest might either be because of the level of salary that is offered to junior OVs, or the requirement of knowledge of the Maltese language in order to qualify for the post. It is planned to modify this latter requirement for candidates originating from abroad, in order to make the competitions more attractive; newly recruited staff not fluent in the Maltese language will be granted one year to attend intensive language courses and undergo consequent proficiency tests.
17. OVs have personal computers and direct access to the NLD for the purpose of official controls.
18. The shortage of staff impacts on the effectiveness of official controls performed: the frequency of official controls in approved establishments, set by the CA on the basis of the specific criteria laid down by Article 9(1) of OCR, is not followed. The audits carried out by central level do not cover all requirements, and some administrative tasks (e.g. updating approval and inspection files) are not completed. A similar issue was brought to the attention of the audit team by representatives of the EHD: due to staff shortage, inspections in retail shops like butchers are performed at a much lower frequency than planned, and does not always cover all items present in the inspection checklists.
19. Specific training for junior OVs was not always delivered; in one slaughterhouse, the recently recruited OV was not aware of (and did not verify) the requirements concerning microbiological testing of cattle carcases (see paragraphs 31 and 77); this same OV’s knowledge of the criteria for the assessment of animal welfare at slaughter was also not sufficient (see paragraph 69). Some OVs have participated in different sessions of the
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Commission’s Better Training for Safer Food initiative. The audit team had been provided with documentation on the training for some official staff that was planned and carried out in 2019.
20. Training was not provided to official staff that had moved to another position and were carrying out new tasks. For instance, an OV was recently moved from the Trade Unit (dealing with border controls) to the SFCU at poultry slaughterhouses (see paragraph 53) with no training having been provided on the specific elements of these new responsibilities.
21. The VRD has a post dealing with policy and internal audit: however, this post (shared with the Policy and Enforcement Unit) is currently not operational as the relevant official is on unpaid leave. The programme for internal audits for 2018-2020 has not been implemented: the follow-up audit on animal identification and the registration system, scheduled for 2018, was not carried out.
22. No mechanisms for the supervision of OVs are in place to give the CA a reasonable level of assurance that controls are carried out uniformly, correctly and consistently, and to allow it to take corrective actions if needed. Supervision tools currently in place include an interview with the staff to agree on their annual self-assessment and to evaluate their working records. As a consequence, no support for OVs is provided as no particular lack of knowledge is identified.
23. There is a procedure (Guidelines on Enforcement Actions, dated July 2018) in place that should ensure that, when non-compliances are identified, their origin is determined and appropriate graded/proportionate measures are taken to remedy and to prevent their recurrence. The first grade of enforcement measures is a verbal warning, followed by a written Corrective Action Request (CAR), and then by two warning letters, an inspection with report, and an administrative fine. If the FBO is still not compliant with the regulatory requirements, the final level of the enforcement is to take the FBO to court. The CCA stated that in 2018 four warning letters were issued to farmers in relation to the enforcement of provisions on animal identification (one farmer was targeted with a second warning letter) and one case ended before the courts. This latter case also included prosecution for breaches of requirements related to animal welfare.
24. Some CARs have been documented for non-compliances related to hygiene of foodstuffs of animal origin. However, not all deficiencies detected by the audit team during the visits to the establishments (notably, those related to contamination of carcases, traceability of meat and sampling of carcases) were identified by the OVs and/or by the audits from the upper level of the CA. As a consequence, not all regulatory requirements have been effectively enforced.
Conclusions on competent authorities
25. Some cooperation/coordination and exchange of information is arranged within the CA, but not completely integrated in specified procedures, with an impact on the
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performance of controls/enforcement.
26. Staff shortages have an important negative impact, at all levels of the CAs, on the overall delivery of the official control system, in particular on frequency of inspections on FBOs.
27. Not all officials performing the controls have sufficient knowledge/experience to perform them adequately, and no specific training arrangements are in place when staff is given new responsibilities or has to cover tasks from other colleagues or vacant posts. Given the number of incidents where staff were found to lack appropriate training to enable them undertake their duties competently, there is clear evidence of non-compliance with Art 5(4) (a) of the OCR.
28. Supervision of the OVs and VSOs performance is carried out by evaluation of self- assessments and by some checks on the working documentation. The staff’s management verification carried out on the ground is rare or inexistent: consequently, a reasonable level of assurance that controls are carried out uniformly, correctly and consistently, allowing the CA to take corrective actions if needed, cannot be ensured.
29. CA’s enforcement of regulatory requirements is in place, allowing the CA to apply proportionate and dissuasive sanctions when the FBO does not remedy and prevent the recurrence of the identified non-compliances. However, not all regulatory requirements have been effectively enforced.
5.3 APPROVAL OF ESTABLISHMENTS
Legal requirements
Article 6(3) of Regulation (EC) No 852/2004 of the European Parliament and of the Council.
Articles 10(2), 138(2)(j) and 148 of Regulation (EU) 2017/625.
Findings
30. A new updated procedure for the approval of food producing establishments by the CA is in place since 20 January 2020, superseding the previous procedure that was issued in 2017. It includes provisions for the issuing of a three months conditional approval (with the possibility of renewal for further three months, if necessary) when all structural and equipment requirements are complied with and the FBO’s programmes for pre-requisites and Hazard Analysis and Critical Control Points (HACCP) have been drafted. The conditional period is used to verify the implementation of these latter programmes by the FBO, and to assess their validity in controlling food hazards. An approval shall be granted once the CA is satisfied that the pre-requisite and HACCP-based programmes are effectively implemented and validated.
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31. The audit team reviewed the approval files of the visited establishments, when available (in few cases no documentation was included in the files), and compared the available information with the results of the physical inspection of the premises:
a. In one slaughterhouse (and in the CCA office) the approval file did not include any document. The same situation was found at the time of the 2007, 2009 and 2013 DG Health and Food Safety audits. The FBO later provided a letter issued by the CA on 20 December 2019, stating that the operator was “hereby being approved to run an abattoir”; a copy of such document was not included in the approval file kept in the CCA office, and both the FBO and the CA were unable to demonstrate that this letter was issued following an application. The slaughterhouse had undergone extensive refurbishments and changes in equipment (including the building of a new facility for emergency slaughter) since the last DG Health and Food Safety audit in 2013, which had identified relevant structural and hygienic non-conformities. However, the absence of a blueprint on file makes impossible to identify which parts have been refurbished and which areas and equipment are covered by the approval. Moreover, being a multispecies slaughterhouse, no maximum capacity or slaughter line speed have been set for the different animal species slaughtered in order to ensure appropriate hygienic slaughter practices.
b. The cutting premises that were built later within the vicinity of the slaughterhouse described above were first conditionally approved and definitely approved in 2016: documentation related to the inspections that were carried out during the approval process was available on file. However, the blue print was not on file, making the evaluation of structures, equipment, and flow of carcases-final products-personnel difficult to evaluate. The approval did not indicate maximum capacities for cutting, nor did it set any restriction for middlemen who were still allowed to enter the premises with their own equipment and operate on the carcases.
c. The cutting premises that were built later in the vicinity of the second slaughterhouse visited, were first conditionally approved and definitely approved in 2017: however, also in this case, no blueprint of the premises and equipment, nor maximum capacity allowed for cutting were documented. The attached slaughterhouse had been granted a flexibility measure in May 2017 related to the frequency of carcases testing for aerobic bacteria, Salmonella and Enterobacteriaceae counts. The FBO had been allowed to carry out such tests fortnightly on cattle and swine carcases, but not on small ruminants carcases. However, Article 5(3) of Regulation (EC) No 2073/2005 only allows FBOs to benefit from such flexibility when they are able to demonstrate implementation of effective HACCP-based procedures supported by good results from several sampling sessions. Neither the two OVs, who were in charge of official tasks at the premises since 2017, nor the senior OV responsible for their supervision had enforced these preconditions. In fact, the FBO had never tested carcases against the microbiological criteria set in the Regulation: such non-compliance was only detected on 22 November 2019 during an audit carried out by the CCA (the first
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within a three years period). To date, the requirement is not yet enforced; the FBO could only demonstrate having received a quotation from an accredited laboratory for a suitable testing scheme.
d. The last establishment visited was definitively approved as a cold store, and has been conditionally approved since December 2019 for re-packing activities and for producing meat cuts, meat preparations and minced meat. The audit team revised the file and the documents available, and compared them with the findings of the physical visit of the premises and of the activities carried out at the time of the audit. The establishment was still under construction in one section that included changing rooms for staff, areas dedicated to washing of working shoes, social rooms, and some corridors and stairs leading to processing areas. Moreover, the pre-requisites programme had not yet been drafted, the programme based on HACCP principles was largely incomplete and did not include several products already processed on site.
32. The published list of the approved establishments was up-to-date, including a specific mention when the approval granted was only a conditional one.
Conclusions on approval of establishments
33. The procedure in place for conditional approval/approval of food producing establishments was not always followed by the CA when conditionally approving the premises; in the case seen, a conditional approval was granted although not all structures had been completed, and with pre-requisites and HACCP-based procedures largely incomplete.
34. The approval of establishments is not kept under review by the CA, contrary to what is required by Article 148(5) of Regulation (EU) 2017/625, since the CA does not always have the relevant information to assess if changes have been introduced after the initial approval was granted.
5.4 ORGANISATION AND IMPLEMENTATION OF OFFICIAL CONTROLS
5.4.1 Official controls on cattle identification and movements of animals
Legal requirements
Articles 3, 5, 6, 7, and 9(a) of Regulation (EC) No 1760/2000 of the European Parliament and of the Council.
On farm/dealer control
35. All farmers keeping farmed food producing animals are registered with the Animal Register Section – NLD with a unique code.
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36. Malta has no cattle dealers in the terms defined by Council Directive 64/432/EEC. Middlemen (“pitkal” in Maltese) are persons that purchase cattle from farmers, but leave them at the holding until they are ready to bring them to slaughter. At the time of the last DG Health and Food Safety audit in 2013, they were also allowed to enter the slaughter premises to attend the slaughter of their animals. This was no longer the case at the time of the current audit; however, middlemen still can enter the cutting premises attached to the slaughterhouse to cut the carcases they own.
37. OVs and VSOs carry out annual routine testing for bovine brucellosis and biannual tests for bovine tuberculosis in all dairy holdings and in the majority of the fattening farms (these latter are of smaller size). During such visits, the OVs and VSOs carry out the census of the animals and any discrepancy is communicated to the NLD for correction; thus, the CCA stated that no “ghost” animals are registered in the NLD. Moreover, the correct identification of animals, meaning the presence of official eartags on both ears, is verified: the farmer must document that any non-compliance has been followed-up with the documented request for replacement eartags to the CA.
38. The OVs of the AHU, with the help of VSOs, carry out official inspections and testing ; currently the Unit has three OVs and six VSOs. Moreover, staff of the AWU, which has two OVs and two VSOs (one part-time engaged in the work of the Unit), also verifies the identity of cattle. This Unit verifies a minimum of 10% of dairy holdings annually, by means of a specific checklist. Additional inspections are planned if necessary. Any relevant discrepancy detected following such inspections leads to the issue of verbal warning, CAR, warning letters (four were issued in 2019), followed by a second warning letter in cases where the farmer does not implement corrective measures within the prescribed deadlines; one such case occurred in 2019. Final enforcement measures consist of the application of fines and in court prosecution (one case in 2019).
39. Arrival of incorrectly identified cattle at the slaughterhouse is mentioned in the records of ante-mortem inspection; cattle with one eartag are allowed to be slaughtered. The OV at one slaughterhouse visited stated that he was planning to notify such irregularities to the AHU, for further action, but this had not yet been implemented due to heavy workload. The OV of the other visited slaughterhouse stated that responsible keepers are verbally warned, when such cases should occur.
40. Arrivals at slaughterhouse of cattle unfit for travel have dramatically reduced since the efficient system for emergency slaughter at holding has been put in place; only three cattle arrived in poor welfare conditions in the last three years in one slaughterhouse, and two in 2019 at the second premises. In such cases, no action (e.g. issue of warnings to the keepers, or notification to the relevant AWU for further enforcement) has been documented by the OV.
41. Verification of records of veterinary medicinal products used at farm level is carried out during official visits, including checks that withdrawal periods are respected.
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Central Bovine database
42. The database is based on the physical location of the animals, and does not register the transfers of property; consequently, middlemen notify, on behalf of the farmer/keeper, any animals they have bought when moving the cattle from the holding to the slaughterhouse. The FBO running the slaughterhouse receives, a few days before, a booking for slaughter of cattle from the middleman and closes the movement of the animal in the NLD at the time of its arrival. Following the slaughtering of such animals, their death is finally notified to the NLD. In case any discrepancy is noted at the time of booking (e.g. animal located in a holding different from is the one notified) the middleman is invited to verify the data and correct the situation, otherwise the animal is refused for slaughter.
43. The NLD has been recognised as fully operational by Commission Decision 2004/588/EC: thus, the CA no longer issues passports for cattle destined for national trade. Only OVs and FBOs running slaughterhouses have direct access to the NLD, whilst the farmers have to apply to the CA staff for all related operations (notifications of births, deaths, movements, order of eartags and of replacement eartags) and are still obliged to keep an holding register in the paper format established by the CCA.
44. 90 dairy holdings and 142 medium/small fattening cattle holdings are registered in the NLD, which totals 14,196 registered bovine animals (data at the time of this current audit). The NLD had registered 4,655 births and 2,900 requests for replacement eartags in 2019.
45. When verifying some requests for replacement eartags in hard copies and in the NLD, the audit team noted that some orders were present only in hard copies and, some were only electronically registered in the NLD, whilst, when both formats were present, a few had differing dates. Some replacement orders were dated from a few days before the announced animal health testing.
46. Movements of cattle between holdings are accompanied by a movement document issued by an OV and countersigned by the selling farmer; the movement is then closed in the database when the receiving farmer countersigns the same document and brings it to the OV for registration in the NLD. Forms for movements of cattle from farm to the slaughterhouse are completed directly by farmers.
47. The NLD is currently still in a transition step from the old module called “InterTrace” to a more sophisticated version “InterTrace Plus” which has been in operation since 2018; some data is still stored or accessible in the old version. Official staff using the new version had not received any specific training, however, should the need arise, staff can contact the system administrator in order to receive the necessary support. As the staff met were not aware of the possible plausibility tests being carried out by the NLD, the audit team requested the list of available plausibility checks; however, this list has not yet been received.
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5.4.2 Official tasks at establishment level (slaughterhouses)
Legal requirements
Article 18 of Regulation (EU) 2017/625.
Articles 3, 4, 5, 6, 7 and 8 of Regulation (EU) 2019/624.
Articles 10 to 19, 29, 30, 33, 34 and 43 of Regulation (EU) 2019/627.
Ante-mortem inspection
Findings
48. In the two operating slaughterhouses, the OV has the sole responsibility for carrying out ante-mortem inspection on red meat farmed animals. VSOs only carry out preparation of offal for inspection, sampling for official purposes and administrative tasks.
49. As already mentioned in paragraph 43, FBOs, as part of their own procedures for receiving animals, have previously verified, through the “pre-booking”, the ownership and previous location of the animals in the NLD and the presence of the Food Chain Information (FCI). Mismatches must be corrected before the animals are dispatched from their holding of origin. The “pre-booking” list is then presented to the OV who, at the time of the ante-mortem inspection, can identify unclean animals to be slaughtered last as well as health and welfare issues. At the end of the ante-mortem inspection, the OV countersigns the FCI document and may note his remarks (e.g. presence of a single eartag, cleanliness classification, health and welfare problems, etc.). Finally, the killing list is established and slaughter can commence.
50. The audit team verified the ante-mortem records against the findings of post-mortem inspections, covering a three years period, and noted that such records were consistent.
51. No provisions are in place to carry out ante-mortem inspection at the holding of provenance (Article 5 of Regulation (EU) 2019/624).
52. The audit team visited a poultry slaughterhouse to collect information on procedures implemented for ante-mortem inspection. The four approved poultry slaughterhouses carry out their operations daily at the same time: due to staff shortages, ante-mortem inspections are solely performed by a roving OV; four VSOs (one per slaughterhouse) and one senior VSO also provide support in inspection activities (mainly for post-mortem inspections and administrative tasks). The ante-mortem inspection includes an evaluation of the FCI documents accompanying the animals. The audit team noted that certain mandatory information were not indicated on such documents (e.g. number of animals included in the load, their age, indication that no medical treatments had been administered, etc.); these non-compliances were not identified, and thus not investigated, by the OV, who could not justify this conduct.
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Post-mortem inspection
53. Post-mortem inspection is only carried out by an OV. The procedure still includes the cuts and palpations, as it was required by Regulation (EC) No 854/2004 of the European Parliament and of the Council (repealed by the OCR, with effect from 14 December 2019). Moreover, the VSOs collect official blood samples from all slaughtered cattle for testing for bovine brucellosis.
54. No specific controls for Cisticercus bovis (by incisions of external and internal masseters) were in place in the operating slaughterhouse visited, as required by Article 19(1)(a) of Commission Implementing Regulation (EU) 2019/627: heads were removed from the slaughter line after removal of the tongue (presented to the OV with the other offal) and handled in a separate room for harvesting of the cheek meat. This harvesting took place without closing the stunning hole with a stopper, to avoid possible contamination with brain tissue. Bronchial lymph nodes were incised by the OV.
55. Some carcases of animals that have undergone emergency slaughter, as well as any other carcases so requiring, may be held in the retention chiller to await the results of tests or their appearance after chilling in order to assess their suitability for human consumption. The audit team saw examples of this in the OV records, as well as accurate records linked to specific animals on the reasons for discarding offal and other parts of the carcases.
56. The audit team noted that visible faecal contamination of carcases (especially hindquarters) due to poor hygienic practices occurring at the start of the de-hiding procedures are not dealt with on the slaughter line. Neither the OV, nor the FBO staff (who are also governmental staff representing the Operational area of the MAFA) had such findings in their records, although random check on cleanliness of carcases were regularly documented. Similar behaviour was noted in the cutting room attached to the slaughterhouse, where evident visible faecal contamination of some carcases was not identified and noted in the reception sheet either by the OV, the VSO or by the staff in charge of cutting. As a result, no CARs were issued, nor were the staff responsible for de-hiding retrained in order to improve hygiene standards.
57. Condemned carcases are sent for disposal accompanied by a certificate that is signed by the OV, whilst bulk condemned offal are given a weight estimate and are collected by the transporter for further disposal. Weight of the load on a weighbridge is carried out upon reception at the disposal establishment.
58. No specific procedures are in place to provide feedback to the farmer on ante-mortem and post-mortem inspection results, with the exception of findings related to identification and welfare. In this case, verbal warning is the common tool used.
59. In the poultry slaughterhouses, post-mortem inspections are carried out by the VSOs, by observing the activities of FBO staff at the end of the slaughter line. The roving OV stated that, when so required, he can be called back for a professional judgement on
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carcasses and offal.
Emergency slaughter
60. As mentioned in paragraph 40, a 24/7 on call service has been in place since 2012 for emergency slaughter at holding of any farmed animal deemed unfit for transport. A team composed of one OV, two butchers (governmental personnel working in the State-owned slaughterhouses) and two trucks (one is refrigerated and equipped with an elevator to hoist the animal during bleeding and evisceration, and the other is dedicated to transport animal-by-products resulting from the slaughter) has carried out 124 interventions on cattle in 2019 (94 in Malta island and 30 in Gozo island), 129 in 2018 (81 in Malta, 48 in Gozo) and 145 in 2017. The animals undergo ante-mortem inspection by the OV, bleeding and evisceration on-site, whilst further de-hiding and post-mortem inspection are carried out at the slaughterhouse. In cases where the intervention is taking place during the weekend, any further processing of the carcase, including post-mortem inspection, is delayed until the following Monday. Carcases are then health marked and may either be sold on the market or recovered by the farmer. The service only foresees a minimal fee to be paid by the farmer for the post-mortem inspection by an OV and for slaughterhouse services. Twenty four of such carcases were classified as unfit for human consumption in 2018 and 40 in 2017. Animals that undergo emergency slaughter are specially identified in the hard copies and computerised records of post-mortem inspection at slaughterhouse level.
61. The model certificate in accordance with Annex V to Commission Implementing Regulation (EU) 2019/628 was used to document the outcomes of ante-mortem inspection at holding.
Other official controls at slaughterhouse level
62. Routine tasks of VSOs at slaughterhouse level include blood sampling of all cattle on the slaughter line for detection of possible positive cases of bovine brucellosis, post-slaughter verification of cattle documentation and notification of slaughter to the NLD.
5.4.3 Official controls of Food Operators' obligations
Food Chain Information (FCI) and animal identification
Legal requirements
Article 3 of Regulation (EC) No 853/2004 in conjunction with its Annex II Sections I and III and Articles 9 and 10 of Regulation (EU) 2019/627.
Findings
63. Presence and consistency of information provided with the FCI is first verified by the FBO and then by the OV. However, issues on identification (presence of only one eartag) were not always noted by the OV on the documents. When such a case is identified, in general, the farmer must provide documented evidence that he had ordered
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a replacement tag for the animal concerned; many copies of such documents were seen by the audit team, but not all cases had been confirmed by farmers’ documented evidence.
64. As described in paragraph 52, the FCI accompanying broilers to slaughter was incomplete: information on age, mortality rate in the flock of origin, records of prescribed (or absence of) medication and the number of animals to be slaughtered were missing on all documents seen by the audit team. The responsible person did not initial amendments/corrections of data on some documents. The FBO, OV and VSOs did not consider these as non-compliances.
5.4.4 Animal welfare at transport and the time of slaughter or killing
Legal requirements
Article 18(2)(d)(vi) of Regulation (EU) 2017/625.
Council Regulation (EC) No 1099/2009.
Article 3(c) of Council Regulation (EC) No 1/2005.
Articles 38 and 44 of Regulation (EU) 2019/627.
Findings
65. Evaluation of fitness for transport of cattle received for slaughter is left to the professional judgement of the OV. Very few cachectic animals or cattle unable to stand had been identified at arrival at slaughterhouse, as such animals are generally dealt with by the emergency slaughter service.
66. During the visit to one of the two red meat slaughterhouses visited, the audit team noted that three cattle from Gozo (having therefore undergone travel by road and ferry of circa three hours) had been transported in a vehicle not suitable for transport of live animals. This vehicle, a truck not belonging to the farmer, was normally used for the transport of bulk feedingstuff, and was equipped for unloading its load by elevating its trailer; the animals had to jump over the unloading ramp, because the levels of the ramp and of the truck floor did not meet for more than 50 cm. As an additional comment to this finding, the CA stated that:
a. journeys normally do not exceed the 50 km and that, in general, farmers transport their animals using their own trucks
b. inspections, in accordance with Article 21 of the OCR, on means of transport, are not planned and carried out.
67. Both visited slaughterhouses had appropriate lairages, with animals arriving the day of slaughter and provided with water. The FBO stated that, in the unlikely case an animal had to stay overnight within the fence of the premises, the keeper is responsible for provision of water, feed and bedding. However, no such cases had been documented in
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the two slaughterhouses visited.
68. Both slaughterhouses had procedures for religious slaughter: all cattle undergo prior stunning with captive penetrative bolt (spare equipment was present and within proximity) and were then killed by severing the whole throat. Good records on the maintenance of stunning equipment were seen in one slaughterhouse. The audit team noted that stun-to-stick intervals were appropriate to ensure a satisfactory animal welfare.
69. In the second slaughterhouse visited, no slaughter activities were being carried out at the time of the audit, but the audit team’s discussion with the OV highlighted its insufficient knowledge of animal welfare indicators in relation to slaughter activities (e.g. 15 seconds considered by the OV as a satisfactory stun-to-stick interval, not taking into account that, as general practice, the time needed to stun the animal, to unload it from the stunning box and to hoist it before sticking is usually between 45 and 60 seconds).
5.4.5 General and specific hygiene requirements
Legal requirements
Article 4 of Regulation (EC) No 852/2004.
Article 3 of Regulation (EC) No 853/2004.
Articles 35 and 46 of Regulation (EU) 2019/627.
Findings
70. The establishments visited had satisfactory structures and equipment. In particular, one slaughterhouse and cutting plant had been refurbished and equipped to acceptable standards, even though still in need of some continuous maintenance. Although the checks on the approval files (when available, see paragraph 31) did not mention any limits or capacity permitted for the activities carried out, the line speed and the capacity of chillers were adequate.
71. Presence of middlemen in the cutting plant is still allowed, and they were also permitted to cut their own carcases. Some rusty equipment (e.g. saw) was present.
72. No specific checks on carcass hygiene had been documented by the FBOs and OVs in the slaughterhouses and cutting plants visited. Several carcases with faecal contamination had been accepted for cutting; as neither the OV, nor the FBO reacted in order to correct the deficiency, the audit team requested the trimming of the affected areas, which was swiftly carried out by the available personnel.
73. In the newly conditionally approved meat processing establishment, the audit team noted the presence of dirty crates in cleaned working areas, damaged wooden pallets in the cold store, and the presence of expired ingredients for marinating meat. On the first floor of this establishment, where changing rooms, toilets and boot washing facilities were
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located, building works were still to be completed.
74. In the poultry slaughterhouse visited wash basins and chilling units were not ducted; condensation water was splashing onto unprotected poultry carcases in the chiller.
5.4.6 HACCP
Legal requirements
Article 5 of Regulation (EC) No 852/2004.
Findings
75. The audit team has checked the pre-requisites programmes and HACCP-based procedures, which have been previously verified by the CA during their routine official controls, in all establishments visited. CA supervisory reports did not highlight specific non-conformities. However, the audit team identified the following deficiencies:
a. at one slaughterhouse, the HACCP programme did not include a clean animal policy, whilst trends drafted on the basis of results of carcases’ testing did not match with the analytical results. No corrective actions had been documented following the appearance of three clusters of Salmonella on carcases in 2019. The CA representatives stated that, although the FBO had not drafted nor implemented a clean animal policy, a separation of dirty animals to be slaughtered at the end of the working shift is carried out by the OV at the time of the ante-mortem inspection;
b. a recently conditionally approved meat processing establishment has been producing a wide range of meat cuts and meat preparations since December 2019. Although relevant and presumably long-standing non-compliances were detected during the visit by the audit team (see paragraphs 31.d, 73, 77 and 78), the CA had conditionally approved the FBO after several inspections. In addition, the pre-requisite programme was largely insufficient and poorly detailed. The HACCP programme did not include most of the required features (HACCP team composition, flow diagrams, recipes of different products, etc.). As a consequence, the production was carried out without any identification of potential risks and therefore without any planned corrective action being prepared in case of such risks becoming a reality. The representatives of the CA stated that a verification of the presence, implementation and validation of such programmes was planned during the conditional approval period. However, since the conditional approval was granted in December 2019, no such verifications have been carried out.
76. The CA’s control checklists include a point for verification of FBO’s procedures based on the HACCP principles. However, as this point is not detailed enough, the official verification often overlooks relevant deficiencies in such procedures and some mandatory requirements (see paragraph 75).
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5.4.7 Microbiological criteria
Legal requirements
Article 35 of Regulation (EU) 2019/627.
Articles 3 and 4, and Annex I to Regulation (EC) No 2073/2005.
Findings
77. In one slaughterhouse visited, the CA had granted in 2017 the flexibility option with regard to the testing frequency of carcases for Enterobacteriaceae, aerobic count and Salmonella spp. pursuant to Article 5(3) of Regulation (EC) No 2073/2005. However, neither the OV in charge of the establishment, nor its supervisor had identified that the FBO was not testing the carcases during that time, as required by Articles 3 and 4 of Regulation (EC) No 2073/2005. This non-compliance was only identified during the CCA audit in November 2019, but at the time of the current DG Health and Food Safety audit, the FBO could only provide evidence of a quotation by a private accredited laboratory for a testing scheme.
78. The audit team examined the trends of microbiological results established by the FBO running the second slaughterhouse visited: cross checks of the trends with the reports of results received from the laboratory revealed that they did not match. The FBO’s staff gave no explanation for this discrepancy. Moreover, the CA had not requested, nor the FBO had implemented, corrective actions following three clusters of positive results for Salmonella spp. detected on cattle carcases in 2019.
79. The dirtiness of several carcasses noted by the audit team at the time of the visit remained unnoticed by the FBO and OV in charge (see paragraph 72).
5.4.8 Traceability, labelling and health marking
Legal requirements
Article 18 of Regulation (EC) No 178/2002 of the European Parliament and of the Council.
Article 5 of, and Annex II – Sections I and IV to, Regulation (EC) No 853/2004 of the European Parliament and of the Council.
Articles 8 and 10 of, and Annex X to, Regulation (EC) No 1169/2002 of the European Parliament and of the Council.
Article 13 of Regulation (EC) No 1760/2000 of the European Parliament and of the Council.
Findings
80. All cattle carcases were correctly health marked, although the mark was not always legible. Equipment for marking was kept locked away, under the control of the OV and was given to FBO staff only for the duration of time required for performing health
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marking.
81. Checklists used by official staff included a generic item with regard to traceability. No issues were detected by the CA in inspection/audit reports that were checked by the audit team. However, the following relevant critical non-compliances were identified by the audit team during the visits to the different establishments:
a. In the cutting plant, the reconciliation of quantities did not allow the OV/VSO to identify the quantities of meat produced. From the documents reviewed by the audit team, the weight of the carcases was integrally reported in the quantities of cuts produced, whilst in reality the yield of cutting is around 65-70%. In some cases, bones were dispatched together with the cut meat, in other cases they were disposed as animal by-products by the cutting plant;
b. In the meat processing establishment visited, a large amount of fresh and frozen cuts (of pork, beef, and poultry) were packed without traceability or labelling; the date of freezing was also omitted. Several pieces of meat products, originating from other national establishments and seen in the cold store did not bear any labels or identification marks. In contrast with the requirements laid down in Article 13 of Regulation (EC) No 1760/2000 of the European Parliament and of the Council., the commercial documents accompanying beef carcases from a Member State did not supply the correct information regarding the traceability of live cattle (eartags belonging to two different Member States were indicated as origin identification of the cattle, but the country of birth was declared as the Member State where the cattle had been slaughtered);
c. In the poultry slaughterhouse visited, contrary to the requirements laid down in Section IV of Annex II to Regulation (EC) No 853/2004, a large amount of fresh and frozen cuts was packed without traceability or labelling; the date of freezing was also omitted. [please quote relevant legal provision(s)]
Conclusions on organisation and implementation of official controls
82. The NLD is a useful tool for the verification of animal identification, animal movements and various events like births, deaths, etc.; it is regularly updated at the time of official controls at holdings level and represents a reliable picture of the national cattle population.
83. Official controls at slaughterhouse level are based on reliable documentation on ante-mortem findings following routine and emergency slaughter, even though the return of information to the holding of origin did not always meet all EU requirements.
84. Official controls, as documented in the records of post-mortem inspections, were exhaustive, with the exception of verification of cleanliness of carcases, for which both FBOs and OVs did not request effective corrective actions and did not ensure proper follow-up.
85. An efficient system for providing official services in case of emergency slaughter at
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the holding of origin of animals unfit for transport has dramatically reduced the arrival of such animals at slaughterhouses, thus resulting in great improvement of the welfare of such animals during transport and at the time of killing.
86. Official controls on FCI at ante-mortem inspections were generally satisfactory in cattle slaughterhouses, but weak performance in the evaluation of incomplete FCI was noted at the poultry slaughterhouse.
87. Official controls on animal welfare at slaughterhouse were satisfactory. However, regulatory requirements regarding animal welfare during transport are not always met, especially those related to the suitability of vehicles, as laid down in Article 3(c) of Regulation (EC) No 1/2005. Religious slaughter of farmed animals is systematically carried out with prior stunning.
88. The weaknesses, sometimes significant, noted in the performance of official controls undermine the capacity of the CA to verify the FBOs’ compliance with the relevant general and specific hygiene requirements, especially in relation to pre-requisite and HACCP-based programmes, meat traceability and microbiological criteria.
5.5 RAPID ALERT SYSTEM FOR FOOD AND FEED (RASFF)
Legal requirements
Article 50 of Regulation (EC) No 178/2002 of the European Parliament and of the Council and Commission Implementing Regulation (EU) 2019/1715.
Findings
89. Due also to the fact that Malta is a net importer of foodstuffs, no iRASFF (2) notifications have been issued for Maltese products in the past few years. The last RASFF alert was notified in 2009 regarding the presence of Salmonella spp. in pork and beef sausages.
Conclusions on RASFF
90. No recent RASFF alerts involving Maltese producers have been notified.
6 OVERALL CONCLUSIONS
The competent authorities at all levels are seriously understaffed, which has an evident impact on the effectiveness of official controls. The posts of CVO and of four out of five Heads of Unit are vacant, whilst at the lower level, the tasks of several vacant posts are
(2) “iRASFF” means the electronic system implementing the RASFF and Administrative Assistance and Cooperation (AAC) procedures described in Article 50 of Regulation (EC) No 178/2002 and Articles 102 to 108 of Regulation (EU) 2017/625 respectively.
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covered and shared by available staff from different services, but without providing appropriate training for their new tasks.
As a consequence, the frequency of inspections of food producing establishments, based on the risk assessment of their activities, cannot be respected, and relevant non-compliances with regard to regulatory requirements in all areas remain undetected for a long period of time. These non-compliances include issues regarding the traceability of red meat and poultry meat, the state and the verification of cleanliness in establishments, and microbiological testing of carcases at slaughterhouse level.
The system for approval of food producing establishments also showed important shortcomings; all approval files seen by the audit team were largely incomplete, demonstrating that the competent authority does not keep the approval conditions under regular review, contrary to what is required by Article 148(5) of Regulation (EU) 2017/625.
In contrast, the traceability of live cattle was satisfactory, due to the regular update of the NLD by the CA.
The findings regarding ante-mortem and post-mortem inspections at slaughterhouse level were generally well documented and consistent; however, the evaluation of (incomplete) FCI was poor at the poultry slaughterhouse. There is an efficient system in place for emergency slaughter at farms of animals unfit for transport, which has dramatically reduced the number of animals, deemed unfit for transport, arriving at slaughterhouses.
No particular issues were identified in respect of animal welfare at slaughterhouse, but regulatory requirements regarding animal welfare during transport, especially those related to the suitability of vehicles, are not verified by official controls. Religious slaughter of farmed animals is systematically carried out with prior stunning.
7 CLOSING MEETING
A closing meeting was held in Valletta on 4 March with the CCA. At this meeting, the audit team presented the main findings and preliminary conclusions of the audit and advised the CCA of the relevant time limits for the production of the report and their response.
The representatives of CCA acknowledged the findings and conclusions presented by the audit team.
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8 RECOMMENDATIONS
The CCA should provide Commission services with an action plan, including a timetable for its completion, within twenty-five working days of receipt of the translated draft report, intended to address the shortcomings identified and, in particular, the following recommendations:
No. Recommendation
1. The CCA should ensure that it has, or has access to, a sufficient number of suitably qualified and experienced staff so that official controls and other official activities can be performed efficiently and effectively, as required by Article 5(1)(e) of Regulation (EU) 2017/625.
Recommendation based on conclusion No 26.
Associated findings Nos 14, 15, 16, 18, 21 and 52.
2. The CCA should ensure that staff performing official controls and other official activities receive, for their areas of competence, appropriate training enabling them to undertake their duties competently and to perform official controls and other official activities in a consistent manner, as required by Article 5(4) of Regulation (EU) 2017/625.
Recommendation based on conclusion No 27.
Associated findings Nos 19, 20 and 69.
3. The CCA should ensure that adequate control verification procedures are in place and consistently applied, in order to verify that official controls take place in accordance with all regulatory requirements, and to guarantee the quality, the consistency, the effectiveness and the appropriateness of official controls and other official activities, as required by Article 5(1)(a) and (b) and Article 12(2) of Regulation (EU) 2017/625.
Recommendation based on conclusion No 28.
Associated findings Nos 21, 22 and 24.
4. The CCA should ensure that official controls on all food business operators are carried out regularly and that the appropriate frequency of inspections is established on a risk basis, as required by Article 9(1) of Regulation (EU) 2017/625, and that this frequency is respected.
Recommendation based on conclusion No 26.
Associated finding No 18.
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No. Recommendation
5. The CCA should ensure that procedures for food business operators to follow when applying for the approval of their establishments are respected and that approvals of such establishments are kept regularly under review when carrying out official controls, as required by Article 148(1) and (5) of Regulation (EU) 2017/625.
Recommendation based on conclusions Nos 33 and 34.
Associated finding No 31.
6. The CCA should verify that food business operators running slaughterhouses, cutting and meat processing plants apply the general and specific hygiene requirements, as laid down in Regulations (EC) No 852/2004 and No 853/2004, and should enforce these requirements when they are not met.
Recommendation based on conclusions Nos 83, 84 and 88.
Associated findings Nos 24, 56, 58, 71, 72, 73, 74, 75 and 76.
7. The CCA should ensure that traceability of red and poultry meat, meat preparations and meat products is ensured, as required by Article 18 of Regulation (EC) No 178/2002, and that labelling of such products is done in accordance with the requirements of Articles 8 and 10 of, and Annex X to, Regulation (EC) No 1169/2011.
Recommendation based on conclusion No 88.
Associated findings Nos 24 and 81.
8. The CCA should to the extent necessary to ascertain, in accordance with Article 10(1) of Regulation (EU) 2017/625, that food business operators comply with Articles 3 and 4 of Regulation (EC) No 2073/2005 and that their products comply with the relevant microbiological criteria set in Annex I to the same Regulation.
Recommendation based on conclusion No 88.
Associated findings Nos 24, 77 and 78.
9. The CCA should ensure, in accordance with Article 138(1)(b) of Regulation (EU) 2017/625,that the food business operators take the measures laid down in Article 7(4) of Regulation (EC) No 2073/2005, when the results of testing of their products against the criteria set out in Annex I to, the same Regulation are unsatisfactory.
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No. Recommendation
Recommendation based on conclusion No 88.
Associated findings Nos 24, 75(a) and 78.
10. The CCA should check, in accordance with Article 9 of Regulation (EU) 2019/627, that Food Chain Information accompanying farmed animals to the slaughterhouse contains all required information, as laid down in Section III of Annex II to Regulation (EC) No 853/2004.
Recommendation based on conclusion No 86.
Associated findings Nos 52, 63 and 64.
11. The CCA should ensure, in accordance with Article 38 and 44(4) of Regulation (EU) 2019/627, that regulatory requirements regarding animal welfare during transport are met, especially those related to the suitability of vehicles, as laid down in Article 3(c) of Regulation (EC) No 1/2005.
Recommendation based on conclusion No 87.
Associated findings Nos 40 and 66.
The competent authority's response to the recommendations can be found at:
http://ec.europa.eu/food/audits-analysis/rep_details_en.cfm?rep_inspection_ref=2020-6927
ANNEX 1 – LEGAL REFERENCES
Legal Reference Official Journal TitleReg. 178/2002 OJ L 31, 1.2.2002, p.
1-24 Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety
Reg. 852/2004 OJ L 139, 30.4.2004, p. 1, Corrected and re-published in OJ L 226, 25.6.2004, p. 3
Regulation (EC) No 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs
Reg. 853/2004 OJ L 139, 30.4.2004, p. 55, Corrected and re-published in OJ L 226, 25.6.2004, p. 22
Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin
Reg. 931/2011 OJ L 242, 20.9.2011, p. 2-3
Commission Implementing Regulation (EU) No 931/2011 of 19 September 2011 on the traceability requirements set by Regulation (EC) No 178/2002 of the European Parliament and of the Council for food of animal origin
Reg. 1760/2000 OJ L 204, 11.8.2000, p. 1-10
Regulation (EC) No 1760/2000 of the European Parliament and of the Council of 17 July 2000 establishing a system for the identification and registration of bovine animals and regarding the labelling of beef and beef products and repealing Council Regulation (EC) No 820/97
Reg. 1825/2000 OJ L 216, 26.8.2000, p. 8-12
Commission Regulation (EC) No 1825/2000 of 25 August 2000 laying down detailed rules for the application of Regulation (EC) No 1760/2000 of the European Parliament and of the Council as regards the labelling of beef and beef products
Reg. 1082/2003 OJ L 156, 25.6.2003, p. 9-12
Commission Regulation (EC) No 1082/2003 of 23 June 2003 laying down detailed rules for the implementation of Regulation (EC) No 1760/2000 of the European Parliament and of the Council as regards the minimum level of controls to be carried out in the framework of the system for the identification and registration of bovine animals
Reg. 911/2004 OJ L 163, 30.4.2004, p. 65-70
Commission Regulation (EC) No 911/2004 of 29 April 2004 implementing Regulation (EC) No 1760/2000 of the European Parliament and of the Council as regards eartags, passports and holding registers
Reg. 1169/2011 OJ L 304, 22.11.2011, p. 18-63
Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004
Reg. 2073/2005 OJ L 338, 22.12.2005, p. 1-26
Commission Regulation (EC) No 2073/2005 of 15 November 2005 on microbiological criteria for foodstuffs
Reg. 2074/2005 OJ L 338, 22.12.2005, p. 27-59
Commission Regulation (EC) No 2074/2005 of 5 December 2005 laying down implementing measures for certain products under Regulation (EC) No 853/2004 of the European Parliament and of the Council and for the organisation of official controls under Regulation (EC) No 854/2004 of the European Parliament and of the Council and Regulation (EC) No 882/2004 of the European Parliament and of the Council, derogating from Regulation (EC) No 852/2004 of the European Parliament and of the Council and amending Regulations (EC) No 853/2004 and (EC) No 854/2004
Dir. 98/83/EC OJ L 330, 5.12.1998, p. 32-54
Council Directive 98/83/EC of 3 November 1998 on the quality of water intended for human consumption
Reg. 1099/2009 OJ L 303, 18.11.2009, p. 1-30
Council Regulation (EC) No 1099/2009 of 24 September 2009 on the protection of animals at the time of killing
Reg. 1/2005 OJ L 3, 5.1.2005, p. 1-44
Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection of animals during transport and related operations and amending Directives 64/432/EEC and 93/119/EC and Regulation (EC) No 1255/97
Reg. 2017/625 OJ L 95, 7.4.2017, p. 1–142
Regulation (EU) 2017/625 of the European Parliament and of the Council of 15 March 2017 on official controls and other official activities performed to ensure the application of food and feed law, rules on animal health and welfare, plant health and plant protection products, amending Regulations (EC) No 999/2001, (EC) No 396/2005, (EC) No 1069/2009, (EC) No 1107/2009, (EU) No 1151/2012, (EU) No 652/2014, (EU) 2016/429 and (EU) 2016/2031 of the European Parliament and of the Council, Council Regulations (EC) No 1/2005 and (EC) No 1099/2009 and Council Directives 98/58/EC, 1999/74/EC, 2007/43/EC, 2008/119/EC and 2008/120/EC, and repealing Regulations (EC) No 854/2004 and (EC) No 882/2004 of the European Parliament and of the Council, Council Directives 89/608/EEC, 89/662/EEC, 90/425/EEC, 91/496/EEC, 96/23/EC, 96/93/EC and 97/78/EC and Council Decision 92/438/EEC (Official Controls Regulation)Text with EEA relevance.
Reg. 2019/624 OJ L 131, 17.5.2019, p. 1–17
Commission Delegated Regulation (EU) 2019/624 of 8 February 2019 concerning specific rules for the performance of official controls on the production of meat and for production and relaying areas of live bivalve molluscs in accordance with Regulation (EU) 2017/625 of the European Parliament and of the Council
Reg. 2019/627 OJ L 131, 17.5.2019, p. 51–100
Commission Implementing Regulation (EU) 2019/627 of 15 March 2019 laying down uniform practical arrangements for the performance of official controls on products of animal origin intended for human consumption in accordance with Regulation (EU) 2017/625 of the European Parliament and of the Council and amending Commission Regulation (EC) No 2074/2005 as regards official controls
