The European Commission has finally published theRapid Alert System on Food and Feed (RASFF) annual report for the year 2019. (1) Food, feed and MOCA safety alerts in the EU, an in-depth discussion with brief notes to follow.
RASFF, Annual Report 2019
In 2019, 4,118 notifications(original notifications) were registered in the RASFF system, followed by 10,388 update(follow-up) notifications. There is an increase in original notifications, +10% over 2018, and an all-time record of interactions within the system (14,803).
Notifications without validation by the Commission-and therefore not forwarded to other member states-were 297 (+31%). Since they mostly pertain to foods with pesticide residues above the MRLs(Maximum Residues Levels) set in Reg. EC 396/05, Brussels’ assessments of the absence of risk to public health (justified by the application of RASFF Working Instruction 2.2) would merit further study.
It adds up to more than 1,600 non-compliance reports without health significance (400 more than in 2018, 1,000 more than in 2017), registered in theAdministrative Assistance and Cooperation ( AAC) system.
Sources of notifications
Border controls on products entering the EU market are confirmed to be the first source of notifications in the RASFF system, 40 percent of the total. Although down from 2013-2015, when they exceeded 50 percent. This is followed by official controls carried out in the domestic market, with 30 percent of notifications. And reports from enterprises, in the area of self-monitoring (20 percent).
It emerges the monitoring of food products sold online, recorded from 2017, now expresses 5% of cases. In contrast, notifications triggered by consumer reports (<5%) or poisonings (3%) are stable compared to 2018.
Salmonella, listeria and STEC on the podium
Pathogenic bacteria dominate the ranking of alert notifications on European products with 575 notifications, up 17 percent from 2018, mostly on food of animal origin:
– salmonella maintains the numerical lead, with poultry topping the list of contaminated foods. Poland is the European champion, with 181 out of 371 reports,
– listeria, on the other hand, is the leading cause of serious toxins. One is reminded of the Spanish outbreak in the summer of 2019, which was poorly managed by Brussels. And repeated incidents are reported on French cheeses, emerging risks on fresh smoked fish and meat-based ready-to-eat foods,
– STEC (
Shiga-toxin producing Escherichia coli
) caused 32 alerts, on non-heat-treated meat products and cheese,
– norovirus, finally, with 17 notifications.
Allergens and foreign bodies
Physical contamination of food products in the EU continues to be of concern because of the serious, even life-threatening, danger associated with allergic reactions:
–Allergen alert , +30% . 194 notifications. Lactose, gluten-containing grains, and soy are the allergens most often omitted or misstated on labels. Prevalent risks on cereals and baked goods, ready meals and snacks, but also less suspicious products (ready-made soups, broths, condiments, sauces, chocolate, coffee and tea). Reports particularly from the Netherlands, Belgium, England and Italy.
– Foreign bodies. 137 notifications. Pieces of metal and glass, plastic fragments in 70% of reports. Unexpected insects, mouse droppings, and other foreign bodies the remaining 30%.
Mycotoxins
Mycotoxins remain a serious food safety and public health problem in the European Union. (3,4,5) There are 534 total notifications on non-EU foods. Less than one-tenth of those recorded on EU products where, however, as recently reported in the case of T2 and HT2 toxins on pasta, controls appear poor.
The scenario, which is feared to be reductive to the actual spread of risk, indicates the prevalence of aflatoxins (80 percent of cases) in hazelnuts and oilseeds. With 104 alert on Turkey’s hazelnuts only). Ochratoxin A has been detected in raisins and dried figs, mainly of Turkish origin (39 notifications).
Non-EU products, salmonella and pesticide residues.
399 notifications concern the presence of pathogenic bacteria in food of non-EU origin. Outside Europe, salmonella also retains the top spot, found mainly on sesame seeds (184 notifications, including 99 from Sudan), herbs and spices (88 notifications) and black pepper from Brazil (65 notifications).
Pesticide residues mark 253 notifications on non-EU imported products, mostly fruits and vegetables. Chlorpiryfos-which will only in the coming months be subjected to an analytical zero tolerance level in the EU on food and feed-dominates the rankings and concerns. 188 out of 253 notified consignments were rejected at the border. Turkey is the top sourcing country for foodstuffs with pesticide residues that are not allowed, i.e., above tolerated thresholds.
Notifications from Italy
Italy ranks fourth in the number of notifications to the RASFF system in 2019 (377), after Germany (534), the United Kingdom (387) and the Netherlands (378). Some data:
– Spain is the top country of origin of notified products (69), followed by China (38), Turkey (36), France (30), Poland (17) and the US (13). There were 60 reports executed by the Ministry of Health following notification by supply chain operators,
– pathogenic bacteria are the leading cause of reports (67). This is followed by mycotoxins (51), heavy metals (48), migration from MOCAs (42), additives and flavorings that are not allowed or are beyond the allowed limits (32), and parasites (30),
– Fish and fish products are the product category with the highest reports (99). This was followed by peanuts, oilseeds and related products (46), MOCA (42), shellfish (29), fruits and vegetables (27), chicken meat (22), and cereals and bakery products (16).
Notifications from non-EU countries
Only 11 out of 4,118 notifications in 2029 came from health authorities in third countries. In relation to both products of EU origin distributed there and local products potentially exported to Europe. In these cases, the notification is not made directly from the third country to the RASFF system, but comes to it through a member state, subject to validation by the Commission.
These include the two cases of French goat and sheep cheeses contaminated with Lysteria Monocytogenes, following investigation and analysis by Canadian and Australian authorities. In both cases, France recalled the remaining products from the market.
Brief notes
The 12.12.19 report of EFSA (European Food Safety Authority) and ECDC (European Centre for Disease Prevention and Control) on zoonoses – The European Union One Health Zoonoses Report – offers a reassuring picture of the level of food safety that EU member states have managed to achieve in the two decades since the reform of the European Food Law.
The reg. EU 2017/625, in updating the general principles to be followed in official public inspections, will contribute to the improvement of the results obtained. However, one cannot escape observing the lack of accountability of some member states with respect to certain risks. Two out of all, salmonella and listeria in Poland and Spain. They also amaze:
– The lack of notifications related to
Campylobacter
, the prevalence of which had also emerged in the EFSA-ECDC report,
– the lack of attention to mycotoxins, in spite of the serious risks they pose to the general population and minors in particular. (3) For the sake of reg. EU 2019/1793 on strengthened border controls for higher-risk plant products.
For further study, please refer to theebook ‘Food Safety, Mandatory Rules and Voluntary Standards,’ at https://www.greatitalianfoodtrade.it/libri/sicurezza-alimentare-regole-cogenti-e-norme-volontarie-il-nuovo-libro-di-dario-dongo.
RASFF, 40 years of alertness in Europe
The Rapid Alert System on Food and Feed Safety was established in 1979 to promote cooperation among the authorities of the member states of the then European Economic Community and also theEuropean Free Trade Association (EFTA). Switzerland, Liechtenstein, Norway and Iceland), which now form the European Economic Area (EEA).
The General Food Law (reg. EC 178/02) marked a big step forward, with the establishment of EFSA(European Food Safety Authority), which was entrusted with risk analysis that previously fell to the European Commission. Reg. EC 1935/04 then extended the scope of notifications to MOCAs (Food Contact Materials and Objects). (6)
RASFF and AAC
The RASFF System collects safety risk alerts related to food, feed and MOCAs placed on the internal market or entering the EU borders. The notifying state-through its point of contact with the European Food Safety Risk Management Network-describes:
– risk identified,
– product and data that enable its traceability,
– measures taken.
The control point of the European Commission, having verified the relevance of the news, classifies the risk and forwards the notification to the participating states (EEA). Interactions and follow-ups follow.
The RASFF’s IT platform, iRAFSS, is being integrated with that of theAdministrative Assistance and Cooperation ( AAC) system, where non-compliance notifications without health significance are shared. (7) This integration is useful for monitoring on product nonconformities in the Internal Market, offering useful clues on irregularities that could transcend into food safety risks.
RASFF notifications, the 4 categories
Notifications fall into 4 categories:
1) alert. The notification concerns products on the market with a serious safety risk that requires or may require rapid action by other member states,
2) Information. The notification does not require the sudden adoption of measures by other member states. It can be of two types, information for attention (product present on the market of the notifying country only or not yet placed on the market or no longer on the market) and follow-up information.
3) rejection at the border. The notification concerns consignments of food, feed or MOCA that have been prevented from entering the EU market because they pose a specific risk to human, animal or plant health, or the environment.
4) news. The report has informal source or otherwise is not complete (e.g., unidentified product, information not fully verified). These can be, for instance, news provided by the media or international organizations or foreign competent authorities, deemed worthy of attention by the European Risk Analysis and Management Network.
Dario Dongo and Giulia Orsi
Notes
(1) European Commission, DG SANTE(Directorate General for Health and Food Safety). RASFF annual report 2019, 9.10.2020, at https://op.europa.eu/it/publication-detail/-/publication/2c5c7729-0c31-11eb-bc07-01aa75ed71a1
(2) Non-compliance notifications mostly involved ‘diet foods, supplements and fortified foods‘ (187 cases), fruits and vegetables (174), and meat and meat products (137). The main violation reported in the AAC system concerns mislabeling, that is, violation of labeling rules. Next, prohibited treatments and/or processes, substitution/dilution/addition/removal of substances, documentation violations
(3) On mycotoxins see previous articles https://www.greatitalianfoodtrade.it/sicurezza/micotossine-il-male-invisibile-l-abc, https://www.greatitalianfoodtrade.it/sicurezza/micotossine-intervista-a-carlo-brera-esperto-iss
(4) OSTRY, V., MALIR, F., TOMAN, J., GROSSE, Y. Mycotoxins as human carcinogens – the IARC Monographs classification. Mycotoxin Res, 2017, 33, 65-73. DOI: 10.1007/s12550-016-0265-7, pp. 66-67 https://www.researchgate.net/publication/310837252_Mycotoxins_as_human_carcinogens-the_IARC_Monographs_classification
(5) OSTRY, V., MALIR, F., TOMAN, J., GROSSE, Y. Mycotoxins as human carcinogens – the IARC Monographs classification. Mycotoxin Res, 2017, 33, 65-73. DOI: 10.1007/s12550-016-0265-7, p. 67
(6) Dario Dongo. Food contact materials, reform-slug slips again. GIFT (Great Italian Food Trade). 17.2.20, https://www.greatitalianfoodtrade.it/imballaggi/materiali-a-contatto-con-gli-alimenti-la-riforma-lumaca-slitta-ancora
(7) Reg. EU 2019/1715. Actual integration of iRASFF and AAC platforms is expected by late 2020, Covid-19 permitting
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Graduated in Law at the University of Bologna, now enrolled in the master of law of agri-food markets at the University of Turin. She is a practicing lawyer.
