Two audits by the European Commission’s health and safety unit have looked at the safety of food of non-animal origin in Italy and France.

A recent report on a remote DG Sante audit, in September 2021 in Italy, found the system cannot verify that food is produced under conditions that meet EU hygiene rules designed to prevent pathogen contamination. Legislation around sprouts was not correctly applied by food businesses and not enforced systematically by authorities. Eleven recommendations were made.

Italy is one of the main producers of fruit and vegetables in the EU and a major producer of seeds for sprouting.

The Ministry of Health initially informed the audit team that primary production before and during harvest was not its responsibility. This resulted in official controls on microbial risks not being performed.

Inspectors met by the audit team showed gaps in knowledge on food hygiene requirements at farm level to prevent microbiological contamination in open field production. The two regions visited also reported staff shortages.

Primary production problems
An inspection is not a mandatory requirement for primary producers and processors to be registered and is not carried out prior to registration. Registration of primary producers of seeds for sprouting is not compulsory throughout Italy.

Inspections do not cover aspects relevant to microbiological risks related to growing stages and harvesting, such as the presence and suitability of toilets and handwashing facilities in fields.

In one of two sprout-producing sites evaluated by auditors, approval was given even though a serious non-compliance involving the absence of an import certificate was not corrected at the time or during any controls in the next seven years. This factory uses seeds cultivated in another country and labeled as “seeds for human consumption, not for sprouting.”

Generic checklists for sprout-producing factories also prevent inspectors from carrying out consistent official controls.

In one region, companies were taking environmental samples for detecting Listeria monocytogenes after cleaning when the rules state this should be done before cleaning.

A multi-country outbreak of Listeria linked to blanched frozen vegetables between 2015 and 2018 did not trigger targeted actions by authorities. The audit team noted the type of product and process does not significantly affect the class of risk for an establishment, so frozen vegetables and berries could have the same inspection frequency as potatoes.

As a follow-up to RASFF notifications, there is a lack of on-the-spot controls of microbiological risks at primary production, before or during harvest. This means the root cause of contamination is often not known.

French findings
A remote audit in France in November and December 2021 also found issues at primary production level and DG Sante officials made four recommendations.

France is the third biggest producer in the EU for cultivated fresh vegetables including melons and strawberries.

The audit team noted weaknesses on staff knowledge of microbiology.

For primary production, the registration system does not provide information on producers of seeds for sprouting, so risks cannot be taken into account when determining the frequency of controls, which prevents adequate risk-based official controls.

Authorities were not able to provide information about the numbers of French producers of seeds for sprouting. This means official controls on microbiological risks cannot be prioritized.

At processing plants, inspectors focus on the analytical results of final products. They do not verify if companies have a system of environmental swabs at production stage, to prevent contamination of food with Listeria monocytogenes, as required by EU legislation.