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Testing and regulation 1881/2006


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#1 agnes

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Posted 08 October 2020 - 08:43 AM

Hello All,

 

I need guidance with regulation and required testing for maximum levels for certain contaminants in foodstuffs.

My understanding/ due diligence was that at least once a year we send dry spices and herbs for pesticide, heavy metals, mycotoxins etc. testing to make sure we comply with Regulation 1881/2006.

My supplier refuses to test dry spice for PAH as according to them” regulation 1881/2006” doesn’t nowhere specifically states that it has to be tested at all. So, looking at their logic why bother to test for anything (HM, mycotoxins etc.).

I have read twice this regulation and it does not state nowhere that we need to test it or have I missed something. Can anyone help?

The same supplier (lucky me!) refuses to test for basic micro like e.coli and salmonella too. They claim product (herbs, spices) is not ready to eat therefore they won’t be testing it but still want to sell it to the market.  I know they need to make sure that product they place on the market can not harm people but they explanation was raw chicken is sold even though can carry bacteria and without further processing is not safe for consumption.  Any thoughts on that?

 

Any comments are appreciated.

Thanks

Agnusen

 


Agnes

#2 pHruit

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Posted 08 October 2020 - 03:27 PM

The wonderful thing about much of EU food regulation is that it isn't prescriptive, and so it rarely says "though shalt do x".
The more challenging thing about much of EU food regulation is that it isn't prescriptive, and so it rarely says "though shalt do x".

Regulation (EC) 1881/2006 does indeed not say that testing shall occur, or define a frequency at which it should occur, but your supplier's position raises an obvious question, and it is one that is fitting given the overall ethos of the approach taken in much of the EU food regulation - the onus is on the food business operator to show that they're making safe compliant product (as opposed to an approach of saying "do x and we will then consider the product safe for regulatory purposes"). I'd assume you've already asked as much, but if not then the query I'd be putting to your supplier is: if they aren't doing any sort of analysis, how do they know if their product actually complies with the contaminants limits that apply for the EU market?

 

The micro one is perhaps more subtle, but I still disagree with your supplier ;)

The argument about the raw chicken is reasonable until one looks at it more closely. For example, it should be noted that:
1) A subsequent mandatory cooking step does not give carte-blanche for unlimited microbiological growth to be present in a raw material. Consider e.g. the potential for toxin formation in some cases, but also the chicken example itself seems moderately pertinent, given the recent significant FSA interest in Campylobacter on raw chicken...

2) I can't really imagine anyone eating raw chicken (notwithstanding the occasional case of people thinking that chicken cooked "rare" is an undiscovered delicacy...), whereas it is fairly foreseeable that consumers may use spices/herbs in applications that do not have a subsequent cook step. The spice/herb may still be a "raw material", but there is little way to know that consumers won't use it in a way that they and others would seem reasonable, whilst not actually cooking it. I did notice a bit of discussion on this in the HPA's Guidelines for Assessing the Microbiological Safety of Ready-to-Eat Foods Placed on the Market: https://assets.publi..._the_market.pdf

3) Irrespective of what happens with the herbs/spices at the consumer level, if a food business is using them as a raw material then they might reasonably want to understand the micro levels of their raw materials as it may have an impact on their own handling/processing requirements.

 

Honestly your supplier sounds like they'd be best avoided if possible...



#3 agnes

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Posted 09 October 2020 - 07:19 AM

Hello pHruit, thank you very much for your input.

Yes i am  planning to stay away from this supplier and  i have informed my directors too about their attitude toward their clients too.

 

Thanks again


Agnes




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