1.Process of Information Exchange of Ireland
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Transcript of 1.Process of Information Exchange of Ireland
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7/30/2019 1.Process of Information Exchange of Ireland
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2005
Food incidents
Process for Information Exchange
Bangkok
October 2007
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The World on Your PlateThe World on Your Plate
AnAn IrishIrish Chicken KievChicken Kiev
Herb ButterHerb Butter ::
Salted butterSalted butter
garlic pureegarlic puree
garlic saltgarlic salt
lemonlemon
parsleyparsley
pepperpepper
waterwater
Chicken BreastChicken Breast:Chicken
Batter:Batter: FlourWater
Bread CrumbBread Crumb:: Bread crumbRape-seed oil
-- IrelandIreland-- China, USA, SpainChina, USA, Spain-- China, USA, SpainChina, USA, Spain-- USAUSA-- France, UKFrance, UK
-- IndonesiaIndonesia
-- IrelandIreland
-- Ireland, BelgiumIreland, Belgium
UK, Thailand etc.UK, Thailand etc.-- Belgium, FranceBelgium, France-- IrelandIreland
-- Ireland, UKIreland, UK
-- EU, AustraliaEU, Australia
Eastern EuropeEastern Europe
Chicken Kiev
A Russian inspired recipe made inIreland with ingredients from aroundthe world
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Fresh Food
MaybeMaybe--ButJ
etlagged!
ButJetlag
ged!
5,000 km from FARM5,000 km from FARM
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16October2003
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Articles of Relevance
Article 2: Definition of Food
Definition over-rides national definitions
Article 3: Definition of Food Business, Food BusinessOperator, placing on the market, risk and traceability
Articles 11 and 12: Import/Export
Article 14: Food Safety Requirements (Unsafe Food)
Article 16: Presentation of food (MisleadingLabels/Claims etc)
Article 17: General Responsibilities
Article 18: Traceability Article 19: Responsibilities Withdrawal and Notification
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European Commission Guidance
http://europa.eu.int/comm/food/food/foodlaw/guidance/guidance_rev_7_en.pdf
http://europa.eu.int/comm/food/food/foodlaw/guidance/guidance_rev_7_en.pdfhttp://europa.eu.int/comm/food/food/foodlaw/guidance/guidance_rev_7_en.pdf -
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Article 18 : Traceability
1. The traceability of food, feed, food-producing animals, andany other substance intended to be, or expected to be,incorporated into a food or feed shall be established at allstages of production, processing and distribution
2. Food and feed business operators shall be able to identifyany person from whom they have been supplied with a food,a feed, a food-producing animal, or any substance intended
to be, or expected to be, incorporated into a food or feed. Tothis end, such operators shall have in place systems andprocedures which allow for this information to be madeavailable to the competent authorities on demand
3. Food and feed business operators shall have in placesystems and procedures to identify the other businesses towhich their products have been supplied. This information
shall be made available to the competent authorities ondemand
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From Farm to Fork
(the food chain)
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One Step Forward One Step
Backwards
Regulation (EC) No 178/2002Regulation (EC) No 178/2002
Farmer
Processor
Retailer
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Internal traceability (process traceability) is not required inlaw but it is expected that most food businesses willneed to put some form of this in place to reduce theirliability
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Food incidents managed in 2006
76 food incidents were investigated
15 notifications of recall from Industry were received
71 miscellaneous incidents were opened
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Product Recalls
Entero
bacter
sakazaki
i
carcinogen
choking
hazard
exce
ssivesh
elflife
salmone
lla
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Guidance Note 10:
Product Recall andTraceability
Developed by the FSAIand industry and is abest practice document
Also designed to minimisecompany liability in theevent of food safety incidents
Covers all food sectors
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Article 19 : Notification and Recall
Responsibilities for food: food business operators1. If a food business operator considers or has reason tobelieve that a food which it has imported, produced,
processed, manufactured or distributed is not in compliancewith the food safety requirements, it shall immediately initiateprocedures to withdraw the food in question from the marketwhere the food has left the immediate control of that initial
food business operator and inform the competent authoritiesthereof. Where the product may have reached the consumer,the operator shall effectively and accurately inform theconsumers of the reason for its withdrawal, and if necessary,
recall from consumers products already supplied to themwhen other measures are not sufficient to achieve a high levelof health protection.
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Article 19: Retailers
A food business operator responsible for retail or distributionactivities which do not affect the packaging, labelling, safety
or integrity of the food shall, within the limits of its respectiveactivities, initiate procedures to withdraw from the marketproducts not in compliance with the food-safety requirementsand shall participate in contributing to the safety of the food
by passing on relevant information necessarynecessary to trace a food,cooperating in the action taken by producers, processors,manufacturers and/or the competent authorities.
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Definitions
Withdrawal
Removing a food product from anywhere in the food
chain up to the point of sale to the consumer
Recall
Removing a food product from the food chain
including products which have been sold toconsumers by requesting them to return or disposeof the product
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European Guidance on Article 19
Food Business must ..
withdraw unsafe food and notify competent authorities
recall unsafe products if reached final consumer andnotify competent authorities
co-operate with withdrawals/recalls initiated by otherfood businesses or the authorities
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European Guidance on Article 19
Withdrawal means any measure aimed atpreventing the distribution, display or offer of aproduct dangerous to the consumer.
When to withdraw..I f a food in question is considered by theoperator as not being in compliance with the foodsafety requirements i.e. Injurious to health orunfit for human consumption as laid out in Article14 (read full text of guidance document)
When to withdraw and notify the authorities.
as above and. the food has left the immediatecontrol of the food business (i.e. it has beenshipped to another business unit of the samecompany or to another food business whichincludes a contracted transporter or warehouse)
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European Guidance on Article 19
Notification of competent authorities when food has left the immediate control of
the food business
NOT when food is NOT placed on the market(i.e. not in the hands of another food businessor the consumer)
Co-operation retail businesses (retail and catering) must co-operate with withdrawals by other businesseseven if their operation does not affect thesafety of the food (e.g. a wholesaler of pre-
packaged ambient foods)
retail businesses are also obliged to withdrawproduct within their sphere of influence and
notify the manufacturer of the food to completewithdrawal in other food businesses
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Stages of a product Recall Procedure
1. Development of a product recall policy
2. Development of a product recall plan
3. Testing of a product recall plan4. Notification and initiation of a product recall
5. Management of a product recall
6. Closing a product recall
7. Review of a product recall and amendment of theproduct recall plan
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Recall Plan Support Material
Sample documents
Role & responsibility chart
Contact list layout
Product recall decision tree
Trade notification
Product recall notice
Press release
Example of a bad & good recall notice
Contact details for the FSAI and the Regulatory
Authorities Relevant legislation
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SOP No.43: Managing Food Incidents
To identify, characterise and manage foodincidents
Scope
Food incidents whereby physical, chemical andmicrobiological hazards are (or thought to be)
associated with food which are identified as posing arisk to consumer health
Responsibility: Chief Specialists, Directors andassociated staff
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SOP No.43: Managing Food Incidents
Definitions:
Food; Hazard; Risk; Incident Manager; IncidentTeam; Food Incident; Rapid Alert Team and RASFFNotification
Related Records:
Food Incident Report Form SOP 40: Rapid Alerts
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SOP No.43: Managing Food Incidents
When a potential incident is reported to the FSAI asmuch detail as possible should be noted and theinformation passed to the Rapid Alert team
Reporter details including out of hours number if possible Type of food including brand name
Pack size
Durability
Lot/batch numbers
Origin / distribution of food
Nature of complaint / hazard
Establishment involved Details of any associated illness
Action already taken
Results of analysis
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SOP No.43: Managing Food Incidents
Food Incident Log created using the agreed template byRapid Alert team member recording as much detail aspossible
Information is assessed by the Chief Specialist EH inconsultation with other staff as appropriate
Provision for delegation in the absence of the Chief
Specialist Risk assessment carried out in consultation with subject
matter experts and key details recorded in the incidentlog
If no further action required the incident log iscompleted, the form signed and dated by the ChiefSpecialist or delegate
Where further action is required the Chief Specialist EHor delegate will act as Incident Manager
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SOP No.43: Managing Food Incidents
Press or Public Relations Officer advised of the incident.An Incident Team is appointed on the basis of expertise.A member of the Rapid Alert Team will always be
appointed to the team.
Possible communication needs will be discussed with thePress & PR Officer at this stage
Information Manager will be advised of the incident andthe Incident Manager will discuss possible consumerqueries and concerns
Information Manager in co-operation with the Incident
Manager may hold a briefing session for advice-line staffand prepare a series of possible Q&As
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SOP No.43: Managing Food Incidents
A food incident number will be assigned sequentuallyand a log saved to the electronic folder numbered andtitled accordingly
An all staff email will be issued advising staff of theincident details and management unless decidedotherwise by the Incident Manager and reasons noted
Where it is determined that the incident forms the basisof a RASFF notification then SOP 40 is to be followed
As the incident progresses relevant staff will continue tobe updated by the Incident Team & Manager
Incident food log is updated as necessary on the basisof information gathered during the investigations.Decisions on action to be noted along with interimevaluations and ongoing risk assessments which may
need to be revised as information becomes available
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SOP No.43: Managing Food Incidents
Incident manager & Team consider the necessary actionson product withdrawal and recall in consultation withexperts as necessary
Once the incident is declared over electronic and hardcopy files will be updated, finalised and signed off ascomplete by the Incident Manager
Files to be archived electronically and manually
Briefing session to be held including the Incidentmanager & Team and where appropriate the Press & PROfficer, Information Officer and other staff involved
To identify any procedural changes required and inform
policy on management of similar incidents in future Summary note of briefing to be included at the end of
the sequential log on the food incident log
An all staff email will be issued advising of the closing of
the incident where all staff were notified originally
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Food Incident Report Form
Section 1 Initial Report
Incident Number and subject
Notification of the Food Incident Date & Time reported
Reported to
Notified byif RASFF number / title
Details of Incident
Product identification
Details of Investigation
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Food Incident Report Form
Section 2 Assessment of Incident
Risk categorisation
Information on risk already available Consult with other staff members / external experts
Assessment
If no further action required sign-off
If case transferred
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Food Incident Report Form
Section 3 Incident Management
Incident Manager
Incident Team members
Section4 Communication
All staff email
Staff from external agencies notified Consultation with Press & PR Officer
Sequential Log
Section 5 Resolution Report / Summary Comments
Closing Off Food Incident
Food Incident Manager Sign-Off
All staff email
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Summary:
New General Food Law Regulation 178/2002 sets outspecific legal requirements on traceability, withdrawaland notification to authorities
Clearly places an onus in food business operators to:
Comply with food law
Not place food on the market which is unsafe
Maintain traceability information and systems Initiate action on withdrawals and recalls
Provide information to the public
Notify and cooperate with Competent Authorities New Provisions took effect from 1 January 2005
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Summary:
EU Guidance Document on Interpretation ofTraceability, Recall and Notifications
Guidance Note 10: Product Recall and Traceability
Guide to Good Practice not Compliance
Code of Practice 5: Food Incidents and Alerts
Deals with notification requirements of Article 19
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