The European Commission’s health and safety unit has published findings from assessments looking at controls on food of non-animal origin (FNAO) in Morocco and Portugal.

A DG Sante audit in Morocco, in March and April 2023, looked at microbiological contamination in food such as strawberries, leafy crops like lettuce, tomatoes, herbs and spices.

A 2015 audit found the safety of FNAO was mainly guaranteed by inspections and certifications of private standards. Also, the effectiveness of official controls was undermined by limited laboratory capacity for microbiological testing.

Moroccan situation
The latest audit also found microbiological food safety at primary production depends on good agricultural practices, inspections by buyers and private certification systems.

Officials could not provide data on the number of farms that are producing or supplying for export to the EU but did share post-farm gate information.

There are no official controls to verify measures taken on farm to prevent microbial contamination during growing and harvest but documentary checks take place afterwards. The absence of controls at these stages could present a problem in outbreak situations, said auditors.

Authorities have not considered the risk of environmental Listeria contamination at operators handling products intended to be eaten raw, as requested by EU legislation. Inspectors also demonstrated limited knowledge and expertise of how to verify food firms’ management of Listeria monocytogenes risk.

Moroccan officials said a new rule for ready-to-eat food businesses to take Listeria samples in processing areas and on equipment as part of their sampling plans should apply from the end of 2023.

The lab network is good but there is no official laboratory with accredited methods to detect Shiga toxin-producing E. coli (STEC) and foodborne viruses. A National Reference Laboratory for foodborne pathogens is planned for the future and accreditation should be achieved in 2024.

“The lack of accredited methods for these foodborne pathogens, in conjunction with the absence of national reference labs supporting the official laboratories, could have an impact on the reliable laboratory investigation of FNAO,” said auditors.

Portugal findings
A DG Sante audit in February and March 2023 in Portugal covered FNAO, including seeds intended for sprouting and sprouts.

There is a risk-based system for onsite controls but there are gaps in identifying high-risk growers and in the registration of processors. It is also not geared towards crops at primary production level which pose the greatest microbiological risks. This means products with potentially high food safety risks may not be subject to official controls, said auditors.

The audit team found training did not enable all inspectors to assess correctly some aspects of the operators’ own-check quality assurance systems regarding the time and place of Listeria monocytogenes sampling and HACCP.

During the second half of 2023, training will be reinforced on Listeria testing, cross-contamination, and critical control points. Several sessions on HACCP have already been carried out involving the General Directorate of Food and Veterinary Affairs (DGAV) and the Portuguese Meat Industry Association (APIC).

At the time of the visit, three sprout-producing operators were approved. However, one had ceased activities and another was suspended after detection of STEC in sprouts. A root cause investigation found problems with the water supply. A third was suspended after an inspection observed by the audit team. This was lifted after non-conformities were corrected.

At processing sites, auditors noticed produce dropped on the floor was put back on the transport belt, and workers did not change gloves after touching the floor. Condensation on ceilings over exposed produce was not always detected and dealt with efficiently.

Suitable lab capability is in place but authorities had yet to designate a National Reference Laboratory for foodborne viruses, which is against EU rules. This was addressed with INSA being named as the NRL in June 2023.

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