NATIONAL DEPARTMENT OF AGRICULTURE DEPARTMENT AGRICULTURE DIRECTORATE FOOD

NATIONAL DEPARTMENT OF AGRICULTURE DEPARTMENT: AGRICULTURE DIRECTORATE FOOD SAFETY & QUALITY ASSURANCE SA OFFICIAL EXPORT FOOD SAFETY CONTROL SYSTEM FOR REGULATED AGRICULTURAL PRODUCTS OF PLANT ORIGIN

CONTENTS Ø Why food safety control systems Ø Current situation Ø Current mandates Ø EU Food safety requirements Ø Proposed food safety system Ø Registration Ø Traceability Ø Official control & fees Ø Proposed changes to export standards & requirements DEPARTMENT: AGRICULTURE

Why must export Food Safety Control Systems be in place? DEPARTMENT: AGRICULTURE

EUROPEAN UNION – Proposed Ø EC Regulatory requirement - 1 January 2004 Ø Require: • GAP, GMP, GDP • Hygiene • HACCP principles From FARM to FORK - safe Ø To be audited by EU Commission DEPARTMENT: AGRICULTURE

COUNTRIES OF THE EU Ø Austria Ø Belgium Ø Denmark Ø Finland Ø France Ø Germany Ø Greece Ø Ireland Ø Italy Ø Luxembourg Ø Netherlands Ø Portugal Ø Spain Ø Sweden Ø UK New accession countries from 1 May 2004 ØCyprus ØCzech Republic ØEstonia ØHungary ØLatvia ØLithuania ØMalta, ØPoland ØSlovakia ØSlovenia DEPARTMENT: AGRICULTURE

CURRENT SITUATION Ø APS Act Ø Limited to: – residue monitoring programme (chemical) – aflatoxin on groundnuts – physical hazards DEPARTMENT: AGRICULTURE

CURRENT MANDATES 1. NDA • National level • Export certification mandate • Responsible for food safety and quality assurance wrt export • Amendment in 1998 to provide for – Management Control Systems – including Food Safety DEPARTMENT: AGRICULTURE

CURRENT MANDATES 2. Department of Health • Foodstuffs, Cosmetics and Disinfectants Act (R 908/2003) • Health Act (R 918/1999) • Three levels – National - policy – Provincial and local authorities - operational • No export certification mandate • Constitutional responsibility DEPARTMENT: AGRICULTURE

CURRENT MANDATES 3. PPECB Ø Assignee in terms of APS Act Ø Delegated export certification mandate Ø PPECB Act – regulate cold chain DEPARTMENT: AGRICULTURE

EU FOOD SAFETY REQUIREMENTS Ø Implementation of— • GAP • Hygiene practices • Food Safety programmes Ø No commercial certification of GAP or HACCP required Ø HACCP principles required for off farm pack houses – compliance certificate DEPARTMENT: AGRICULTURE

LEGISLATION HISTORY Ø Draft was distributed during July 2002 for comments Ø Industry meetings were held Ø Comments were addressed Ø Industry concerns: • Cost • Recognition of private systems • Duplication between Agriculture and Health DEPARTMENT: AGRICULTURE

SCOPE OF FS LEGISLATION Ø Regulated Agricultural Products of Plant Origin Ø Terms of the APS Act Ø Exported to EU DEPARTMENT: AGRICULTURE

REGULATED PLANT PRODUCTS • All fresh fruit and vegetables • All canned fruit and vegetables • All frozen fruit and vegetables • Dried fruit • Groundnuts and grain • Rooibos and Honeybush DEPARTMENT: AGRICULTURE

PROPOSED LEGISLATION Ø “Standard Regarding Food Hygiene and Food Safety of Regulated Agricultural Food Products of Plant Origin Intended for Export” Ø Legislation - Outcome based Ø Relates only to food safety Ø Provides for • Hygiene requirements at all stages & where necessary a food safety programme • Guides to good practices may be developed • Application of HACCP principles • Record keeping & recalls Ø Reference local legislation and include GAP requirements DEPARTMENT: AGRICULTURE

PROPOSED LEGISLATION CONT. Ø Farm to fork principle Ø EU specific - mandatory by 1 Jan 2004 Ø Nationally applied on product country basis • Reason: – Certification not required – If food safety problem occurs - country’s export for specific product will be prohibited to EU, not individuals DEPARTMENT: AGRICULTURE

PROPOSED OFFICIAL FOOD SAFETY CONTROL SYSTEMS Ø Systems level • Primary production up to harvesting - GAP compliance • Handling/processing/packing - GMP + Food safety programme compliance (if hazard exist) • Distribution – GDP + Food safety programme compliance (if hazard exist) DEPARTMENT: AGRICULTURE

PROPOSED OFFICIAL FOOD SAFETY CONTROL SYSTEMS Ø Product/packaging/marking • Covered in current export standards and requirements • Export prohibited unless it comply • Samples taken on auditing basis on risk • Need to extend testing to importing country requirements eg. micro, heavy metals, mycotoxins DEPARTMENT: AGRICULTURE

PROPOSED DRAFT LEGISLATION § § § Definitions Scope General obligation Hygiene requirements Food safety programmes Guides to good practices and guides to application of HACCP Registration of food business for specific destinations Withdrawal of products/traceability Official control and fees Appeals Offence and penalties DEPARTMENT: AGRICULTURE

GENERAL OBLIGATION Food business operators shall ensure that all stages of handling for which they are responsible, from and including primary production up to and including the export of food products are carried out in a hygienic way in accordance with the prescribed requirements of this Standard. FBO’s – producers, packhouses, transporters, cold stores, i. e. everyone in supply chain DEPARTMENT: AGRICULTURE

HYGIENE REQUIREMENTS (GAP) 1. Primary production level Primary production shall be carried out in accordance to good practices and managed in such a way that hazards are monitored and where necessary eliminated or reduced to an acceptable level. This includes where appropriate a) adopting practices and measures – hygienic b) adopting measures to control environmental hazards c) controlling contaminants, pests & diseases DEPARTMENT: AGRICULTURE

Methods to control hazards – guides Ø Don’t produce where environment – threat to safety of food products Ø Adopt appropriate methods for production, harvesting, handling, storage & transportation – industry specific Ø Avoid contamination with biological, chemical, physical hazards Ø Use water of suitable quality Ø Correct use and storage of chemicals and fertilizers Ø Adopt measures to ensure acceptable personal hygiene Ø Maintenance and cleaning of equipment, vehicles Ø Proper disposal of waste Ø Establish record keeping system DEPARTMENT: AGRICULTURE

HYGIENE REQUIREMENTS (GMP/GDP) 2. Food business operators other than primary production (other than farm level) Must adhere to General Hygiene Requirements for Food Premises and the Transport of Food, No. 918 of 30 July 1999 (as amended) in terms of the Health Act, 1977 (Act No. 63 of 1977) DEPARTMENT: AGRICULTURE

FOOD SAFETY PROGRAMMES Ø Primary production and primary products (excluding those products listed as a risk or required by the importing country) – Food safety programme not required. Ø Processing and processed products (include primary products listed as a risk or required by the importing country) – Food safety programme is required. DEPARTMENT: AGRICULTURE

FOOD SAFETY PROGRAMMES Ø Hazard analysis Ø If one or more hazards identified develop Food Safety Programme (HACCP) Ø Regulations relating to the application of the Hazard Analysis and Critical Control Point System (HACCP system), No. R. 908 of 27 June 2003 in terms of the Foodstuffs, Cosmetics and Disinfectants Act, 1972 (Act No. 54 of 1972) DEPARTMENT: AGRICULTURE

HACCP PRINCIPLES ØIdentify a potential hazard ØIdentification of the critical control points ØEstablishing of critical limits ØMonitoring procedures ØCorrective actions ØVerification ØRecordkeeping DEPARTMENT: AGRICULTURE

GUIDES Ø Business sectors may compile the following guides: • Food Hygiene • Food Safety Ø Consider Codex Codes of Practices Ø Include all role players (e. g. emerging sector, government) DEPARTMENT: AGRICULTURE

CHECKLISTS Ø PPECB & NDA – develop checklists Ø Used by PPECB Inspectors & EHP’s Ø Indication to producers, packers, manufacturers, exporters to what compliance is needed Ø Envisaged to be ready by end Nov 2003 DEPARTMENT: AGRICULTURE

REGISTRATION Ø New database – based on location Ø Register with NDA/PPECB by 21 Nov 2003 Ø Use current PUC, PHC and factory code Ø Form available from www. nda. agric. za/docs/plantquality/default. htm DEPARTMENT: AGRICULTURE

TRACEABILITY Adequate procedures and records to withdraw food products from the market where such food products presents a serious risk to health of consumers. DEPARTMENT: AGRICULTURE

OFFICIAL CONTROL AND FEES Ø Implementation date – 1 JAN 2004 Ø GAP + HYGIENE • Inspected by PPECB/EHP • Audited by NDA Ø HACCP • Inspected by PPECB/EHP • Recognise SANAS CB/IAF affiliated certification • Audited by NDA Ø Inclusion of EHP’s – strengthen local situation DEPARTMENT: AGRICULTURE

OFFICIAL CONTROL AND FEES Ø Audited on risk and at least every 18 months. Ø Recognise private systems like certified and SANAS accredited Eurep. GAP/BRC/HACCP by reducing frequency of audits Ø PPECB – cost, impact assessment, negotiate with industry – no duplication of inspections Ø No third party commercial certification DEPARTMENT: AGRICULTURE

APPEALS Ø An appeal procedure is in place Ø An appeal board shall decide on such an appeal - NDA DEPARTMENT: AGRICULTURE

PROPOSED CHANGES TO EXPORT STANDARDS AND REQUIREMENTS DEPARTMENT: AGRICULTURE

Physical hazards No consignment of table grapes classified as "Extra Class", " Class 1" or "Class 2" shall contain: Ø (a) any foreign matter in excess of the tolerance as set out in Table 1; Ø (b) any organisms which may be a source of danger to the human health in excess of the tolerance as set out in Table 2. DEPARTMENT: AGRICULTURE

Biological and chemical hazards Ø No consignment of table grapes classified as "Extra Class", "Class 1" and "Class 2" shall contain -biological or chemical contaminants in quantities or at levels that exceed the maximum limits prescribed in terms of the Foodstuffs, Cosmetics and Disinfectants Act, 1972 (Act No. 54 of 1972 Ø Importing country stricter limit – comply DEPARTMENT: AGRICULTURE

TRACEABILITY REQUIREMENTS Ø Producers, pack houses and exporters shall: Ø (a) establish the traceability of food at all stages of production, packing, handling and distribution; Ø (b) be able to identify any person or supplier from whom they have been supplied with a food product, or any substance intended to, or expected to be used in the production or processing of food products ; Ø (c) have in place systems and procedures to identify other businesses to which their products have been supplied; DEPARTMENT: AGRICULTURE

TRACEABILITY CONTINUED Ø (d) ensure that adequate procedures are in place to withdraw food products from the market where such food products present a serious risk to the health of consumers; Ø (e) immediately withdraw food products which were identified as food products that present a serious risk to the health of consumers; Ø (f) immediately inform the Executive Officer of such withdrawal; and Ø (g) immediately make available, on request, any information or documentation mentioned in (a), (b), (c), (d), (e) or (f). DEPARTMENT: AGRICULTURE

CONTACT DETAILS PERSONS v Cyril Julius (012) 319 6023 v Elsa van Rensburg (012) 319 6029 v David Malan (012) 319 6049 NB WEB PAGES: v www. nda. agric. za/docs/plantquality/default. htm v www. codexalimentarius. net v http: //europa. eu. int/comm/food/index_en. html DEPARTMENT: AGRICULTURE