Two audits by the European Commission’s health and safety department looked at milk and milk products in Poland and the Netherlands.
A remote audit by DG Santa, in March 2021 in Poland, showed that the system is well designed, but the lack of training and internal audit weakens its effectiveness.
Dairy products with traditional characteristics are sold nationally and produced in non-approved facilities, which is contrary to EU legislation. Procedures for approving, registering and listing facilities that are part of the dairy supply chain are also not fully compliant with EU rules, the auditors said.
Summary of issues found The audit team noted gaps in understanding or knowledge for some inspectors interviewed in areas such as assessment of microbiological criteria for Listeria monocytogenes in dairy products and procedures based on hazard analysis and critical control points (HACCP). They stated that this negatively affects the level of expertise of official control personnel in the sector.
Official testing of dairy products for microbial criteria in 2018 and 2019 revealed Listeria monocytogenes in 32 batches out of 1,973 sampled and Salmonella in two batches out of 695 tested. Sampling for process hygiene criteria revealed coagulase-positive staphylococcus in 33 of 1,146 batches and E. coli in 22 batches of 757 tested.
The steps taken in cases of dairy product alerts were not entirely satisfactory and did not comply with guidance, officials said.
The audit team assessed the actions of the competent authorities in relation to two RASFF alerts in 2019 for the detection of Salmonella in milk powder and Listeria monocytogenes in cheese. In the example with salmonella, unsatisfactory hygiene of the production line process was identified as the cause. The authorities suspended work on this line and it was later closed, but did not take samples of other batches that may have been made on the same line, in accordance with the guidelines.
In the case of Listeria, authorities only noticed the non-compliance after 20 days. This delay is related to the agency’s lack of understanding of the requirements and actions to be taken for positive samples below the 100 colony forming units per gram limit.
“Corrective actions were limited to the food businesses and districts involved and no evidence was available that the information gathered was used to improve relevant aspects of the control system and to prevent a possible recurrence elsewhere,” the report said.
Polish authorities said the recommendations would be addressed through training, reminding officials of specific rules and revised checklists.
Featured audit in the Netherlands. Another virtual assessment in the Netherlands in October 2021 identified problems with the food business approval system.
The Dutch Food and Consumer Product Safety Authority (NVWA) and the Dutch Inspection Authority for Dairy Products and Eggs (COKZ) are understaffed, which affects the effectiveness of official controls.
Staff involved in official controls in the dairy sector said that the workload sometimes resulted in delayed inspections – mainly related to monitoring, reporting and enforcement.
Training, laboratory capabilities and collaboration between different agencies were cited as positives.
The audit team said inspectors generally used the lowest score for non-compliance despite some requiring a warning and follow-up. They also found delays, sometimes up to three months from the day of the inspection, in the delivery of reports and written warnings, which affected the timely elimination of non-compliance.
In 2020, the project tested 46 samples of soft and mature cheese made from raw milk for shiga toxin-producing E. coli (STEC). It was found in two samples from the rind of mature cheeses. Another study looked at raw milk for direct delivery to consumers. In 2020, out of 100 samples of raw cow’s milk, five were positive for a high number of coagulase-positive staphylococci, four for STEC and the only sample of raw goat’s milk was positive for STEC.
The audit team followed up on five RASFF notifications for Listeria monocytogenes, Salmonella and E. coli in cheese and one for undeclared allergens in cheese, reported in 2020 and 2021. All investigations and follow-up were deemed effective.
In response, Dutch officials said the gaps in the approval were for so-called farm milk processors. This is a group of more than 500 farmers who process part or all of their raw milk production into regional products, often in a traditional way. They represent only 4 percent of the total milk flow in the Netherlands, while the other 96 percent are not affected.
COKZ will review the approval procedure and adapt it by September 2022. The agency will also develop an assurance system to ensure timely assessment for those with conditional approval. COKZ will also ensure that the re-inspection is carried out within three months of the initial visit and that deficiencies are communicated at the end of the inspection.
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