Controls on the ready-to-eat food sector in Belgium mostly ensure compliance with European unio rules, but some issues are not detected or treated seriously enough.

DG Sante, the unit that leads the European Commission’s policies on health and food safety, found the systems are generally effective in identifying hygiene non-compliances.

A recent report of an audit in June 2019 included visits to three meat products sites, two of which also do meat preparation intended to be eaten raw; one fishery for cold smoked fish; a dairy plant producing soft cheeses from pasteurized milk; a salad and sandwich producer that supplies to retailers; and a catering factory producing ready-to-eat (RTE) meals but also approved for meat and fishery products.

A total of 377 foodborne outbreaks were registered in Belgium in 2016 with almost 2,000 people ill; 304 in 2017 with 1,400 ill; and 429 in 2018 with almost 2,300 ill and one death. One outbreak was traced to RTE food. In 2018, a large Salmonella outbreak involving several schools was linked to a caterer supplying them. The implicated food source of the outbreak was not identified.

Between January 2016 and December 2018, there were 61 RASFF alerts involving food from Belgium due to pathogens, with 28 were linked to RTE food. The audit team noted 17 alerts were because of Listeria monocytogenes, nine in meat products and four in fishery items and five due to Salmonella in meat products. During this period, there were 73 incidents related to RTE items mainly meat products and preparations, and dairy and fishery products at national level.

During 2016 to 2018, 65,092 samples of RTE food were tested for microbial contamination and 426 were non-compliant. Results indicate a good compliance level in the sector, according to DG Sante.

Operate without approval
National measures on managing the withdrawal or suspension and refusal or approval of establishments contain elements contrary to EU requirements since they may allow sites to operate and put products on the market without a valid approval under certain circumstances.

Belgian authorities said in the short term the procedure will be adapted to prevent a business placing products on the market without a valid approval. In the long run, a modification of the law is planned, according to officials.

EU Reference Laboratory (EURL) guidelines on environmental sampling relevant to RTE foods are not taken into account during official controls.

Procedures for controls and inspectors’ incorrect understanding of certain rules impacted detection of non-compliances, according to the audit report. Some problems, which may impact safety of RTE products, are considered as minor, and automatically rated as such on checklists available to control personnel. This means they are not followed up in a way which ensures swift corrective action by the food business.

Belgian officials said official control checklists will be revised and a specific checklist for the follow-up of major non-conformities will be created.

The audit team noted some weaknesses in the knowledge of inspectors on Hazard Analysis and Critical Control Point (HACCP) requirements, judging the seriousness of certain non-compliances and specialist technical knowledge such as milk pasteurization. In several factories visited, condensation on the ceilings and rusty elements of chilling units above exposed products were considered by the inspectors as minor maintenance issues.

A plant producing dairy products from unpasteurized milk has the same basic inspection frequency of once per year or once per two years if production is on the farm as a dairy using pasteurized milk, regardless of size. However, in 2018, officials collected 1,363 samples from cheeses made from pasteurized milk, compared with 2,791 from non-pasteurized cheeses.

The basic inspection frequency for a producer of prepared fishery products is double, at eight times annually, than a factory making products with higher risks such as processed fishery products like cold smoked fish for which frequency is four times a year. There is no program with more official samples taken from products with higher risks such as cold smoked fish in the fishery products sector.

Understanding the rules
Several uniform checklists, applying scores to weigh seriousness of non-compliances detected for each area to be inspected and for each type of establishment are used during official visits.

The audit team noted low scores allocated for certain non-compliances such as lack of corrective and preventive measures in case of non-compliant test results or inadequate protection of exposed products from contamination, impact on effectiveness of controls.

They found checklists allow alternative sampling and testing procedures, such as pooling of samples, without requiring the business to demonstrate that the procedures provide at least equivalent guarantees. This is contrary to EU regulation.

In most establishments visited subject to RASFF alerts or compulsory notifications, after incidents, the businesses continued taking one sample unit for microbiological analysis. This is not in line with EU regulation or Belgian procedure that requires at least three batches to be tested with five sample units after RASFF alert or compulsory notification.

Actions by authorities to ensure firms have measures to address the root cause and to prevent re-occurrence of non-compliances are not effective, according to DG Sante.

In two sites visited, the audit team noted confusion by the business and inspectors on the applicable compliance limits for Listeria monocytogenes, caused delays in the notification to the authority of two to three weeks. This meant delays in issuing the RASFF alert and, in one case, failure to recall contaminated products, which by then had reached the end of their shelf life.

In two establishments, although Salmonella in meat or Listeria monocytogenes in milk was detected during the firm’s own-check testing in raw materials, they were still used to produce the final products, without adequate demonstration that the process would eliminate the hazards.