Two audits by the European Commission’s health and safety unit have looked at checks on the food of non-animal origin (FNAO) in Hungary and Bulgaria.

A DG Sante audit, in May and June 2022 in Hungary, found a shortage of staff and experience was weakening the system of official controls. The focus was on primary production, frozen products, pre-cut fruit and vegetables, sprouts, and seeds intended for sprouting.

Development of a guide on GAP for fruit and vegetable production, including information on how to prevent microbiological contamination for primary producers, is still underway, as it was during the previous audit in 2019. Progress was noted in the official control system on FNAO and three of six recommendations made in 2019 had been addressed by the 2022 assessment.

The audit team was told that in 2019, 2020, and 2021, 183 of 240 planned inspections at primary production were carried out for leafy green vegetables and soft fruits, resulting in one non-compliance. The difference between planned and performed checks was because of shortages in resources and the COVID-19 pandemic, according to officials.

Issues throughout the supply chain
Over the same three years, 157 of 164 inspections were done in freezing and establishments involved in pre-cutting of FNAO, resulting in 20 non-compliances related to areas such as cleaning and incorrect or non-existing procedures for environmental sampling for Listeria monocytogenes and 36 non-compliant official samples.

In processing plants, there were 167 official inspections out of 183 planned visits and 20 non-compliances were detected for issues such as hygiene, hazard analysis and critical control points, maintenance, pest control, health certificates for workers, sample analysis plans, and risk classification of products.

In primary production, non-compliances are rarely detected, and enforcement of requirements is affected. The effectiveness of official controls is limited by giving more relevance to testing rather than good practices during production, said auditors.

At the time of the audit, in most counties, if the analytical result is satisfactory, no corrective actions by the business were required as the inspection was deemed to be compliant. Because of this approach, detected non-compliances were not documented or rectified. However, new procedures are being put in place so sampling will only have a monitoring function and for each non-conformity, a corrective action plan will be required.

From 2019 to 2021, out of 1,030 official samples, 57 were positive for Listeria monocytogenes. In a survey at the retail level on frozen vegetables, out of 288 official samples, 104 were positive, showing the capability of the system to detect Listeria but also the discrepancy between official controls and food companies’ own checks. The findings didn’t trigger any action by authorities.

Whole genome sequencing of Listeria isolates in retail samples of frozen vegetables in 2018, 2020 and 2022 did not find a match to a strain that caused a multi-country outbreak from 2015 to 2018 with 54 cases and 10 deaths.

Bulgarian audit
A DG Sante audit, in May 2022 Bulgaria, found a mixed picture at different points in the supply chain. Some shortcomings were also noted during the last audit on the same subject in 2015.

At primary production, the criteria for targeting official controls are not suitable for identifying higher-risk crops or farms. Combined with the authority not having adequate data on the number of operators or the nature of their production, this hampers the effectiveness of the control system in targeting higher-risk products, said auditors.

National staff told the audit team that microbiological risks would be irrelevant before harvest in soft fruit and leafy vegetables because they undergo treatments like rinsing at collectors and processors. Auditors said there is scientific evidence that describes the risks as well as an EU guidance document on microbial risks at primary production. EFSA’s opinions on the microbiological risk ranking of different crops had not been taken into account when planning controls.

Auditors said the control system for sprout-producing sites is not capable of identifying non-compliances or effectively enforcing EU requirements. For processors, the system is satisfactory but has some weaknesses when monitoring Listeria monocytogenes.

Bulgarian officials said the training would be given to inspectors and it will include a guide on hygiene from the European Association of Sprouted Seed Producers. Guidelines and a checklist to perform official controls at sprout production sites will also be developed.

Some facilities of the National Centre of Food Safety in Sofia were outdated, including the laboratories for norovirus and hepatitis A. Because of a lack of funding, not all consumables required for analysis were available in sufficient quantities. There were also no accredited methods for the detection of norovirus and hepatitis A but accreditation is planned for 2023.

Auditors also found the composing and pooling of samples were not verified, which could lead to false negative results.

The audit team followed up on a 2021 RASFF notification about hepatitis A in raspberries with raw material from Bulgaria and Poland. Appropriate investigations were done at the processor and another batch with the same raw material tested negative. However, investigations did not cover primary producers of the raspberries and authorities could not identify the root cause.