Belgium’s system to prevent microbiological risks before and during harvest of certain foods has been criticized by the EU’s health and safety body. Officials in Belgium disagree.

A DG Sante audit found Belgium’s program is not designed to identify businesses that don’t have measures to stop the risk of contamination at these stages of production of food of non-animal origin (FNAO), which include fruits and vegetables.

The audit took place in late October 2020 but the coronavirus pandemic meant findings are based on a remote review of documentation and video interviews with officials. It was the second audit of official controls on FNAO in Belgium. A 2015 report made one recommendation but in the latest assessment DG Sante found the adopted measures were not sufficient.

Before and during harvest issues
The audit team found the official control system is unable to identify and rectify shortcomings prior to and during harvesting of FNAO and checks for primary producers focus on after harvest.

The Federal Agency for the Safety of the Food Chain (FASFC) in Belgium didn’t agree with DG Sante’s opinion that there are no controls before and during harvest. However, the agency added it will see if some items can be improved.

“The FASFC, at present, still judges that no in depth official control is needed at the production stages prior and during harvest, due to the high level of certified self-checking systems and downstream official and own controls. FASFC believes the statement that there are no controls prior and during harvest is untrue,” according to the agency.

Auditors noted FNAO inspectors were not aware of EU guidance to check how companies do environmental sampling to detect Listeria monocytogenes, so this cannot be verified effectively by official controls.

The Belgium officials said staff will be made aware of the documents but they are under revision so a timeline for an e-learning tool with emphasis on Listeria will depend on when the new versions are published.

The audit found producer registration does not include the type of crop grown, which prevents identification of primary producers that have high risk crops like soft berries and leafy vegetables.

Different risk levels for different products are not taken into account. Leafy green vegetables, soft berries, frozen berries and frozen vegetables are in the same category as potatoes and other vegetables intended to be eaten after cooking. For the risk based plan in the same product group, factors such as farm size and production volume are also not included.

Information gaps
DG Sante said the risk-based official control system for FNAO is weakened because the information about primary producers is insufficient to take into account higher risks of microbial contamination of certain produce.

Also, inspections on food hygiene do not include specific measures to prevent microbiological risks during the pre-harvest and harvest stages of production.

The system of own-controls certified by a third party certification body could mitigate the risk of the lack of official controls before and during harvest. For primary producers, such systems are voluntary and only about 50 percent of 21,500 have them.

Controls like the presence and use of handwashing facilities and toilets and protection of fields from animal access and pests are not foreseen by the system and not implemented by inspectors even for crops deemed high risk. FASFC said it was “impossible” to prevent the access of animals to open fields and “not realistic” to protect them from bird droppings.

Official controls are carried out by qualified staff with help from IT tools and checklists plus detected non-compliances are followed up. A microbiological monitoring plan is in place and the laboratory capability and capacity was another positive.