First, the General
Food Law was published. Following principles were established:
The legislation
on feed additives also had to be revised thoroughly.
The principle of the positive list is maintained.
All additives on this positive list are divided into
5 categories. For each additive a procedure for approval
has to be sublitted. In case of zootechnical additives
(coccidiostatica included), the legislator states
explicitly that there has to be a “Brand Specific
Approval” (BSA). The state of the art for the
coccodiostatica : a transitional period is ongoing.
The regulation
on Feed Hygiene, will come into force on January1st
of 2006. All actors worldwide in the feed/food chain,
will at least be obliged to be registered. All actors
of the feed/food chain will have to implement a self-control
system which has the HACCP-principles built in (except
for the primary production). In addition, certain
minimum conditions concerning the obliged notification
and the traceability, have to be fulfilled. The necessity
for financial guarantees is still under examination.
The private
sector accelerated investing in a pro-active feed
chain approach from the year 2000 on. In several member
countries (the Netherlands, the UK, Belgium, Germany,…)
projects were started, with the intention to write
out and implement a quality system for control on
food safety in the whole feed chain. Most of these
projects were guided by the feed industry under severe
pressure of the retailers. All actors of the feed
chain ( feed ingredient producers, traders, premix
manufacturers, feed manufacturers, transport,…).
Each EU-member country anticipated on the political
and social bottlenecks. The standards (codes of good
practices) were elaborated and introduced for accreditation
per individual member country at the level of the
national accreditation boards. Independent certification
bodies could certify the individual companies and
therefore sustain the credibility of the quality system
.
These individual,
national initiatives resulted in the fact that the
importers all over the world were confronted with
different quality systems applied by the different
countries. The lack of communication was apparent
. Furthermore, even the countries with a quality system,
approved by an accreditation body, had problems with
the export of their certified commodities/services.
Several member
countries took the initiative to strive for bilateral
agreements between quality systems. These latter were
compared through well developed comparison tables
and were put through a benchmarking procedure. That
way, the biggest bottlenecks for the incoming and
outgoing fluxes with the neighbouring countries were
eliminated. Still, the suppliers from countries spread
all over the world kept complaining about the several
quality-requirements : they were still confronted
with different quality systems and -demands.
Four countries,
Belgium, Germany, the Netherlands and the UK, already
involved in bilateral agreements, decided to establish
an international platform with the main purpose of
harmonising the quality systems worldwide. Therefore,
a legal entity was created, IFSA (International feed
Safety Alliance). IFSA wrote a completely new standard
(IFIS), meant in the first place for the processed
feed ingredients . The standard contains four important
chapters: Quality management System, resources and
good hygienic practices, transport and product safety
management. This horizontal standard is a convenient
heading to classify several “sector notes”
under. The purpose of these sector notes is to lay
the emphasis on some sector specific requirements.
The risk analysis, which is sector specific, is translated
into the registration of the risks and the determination
and implementation of the necessary monitoring.
Of course, beside
the standard, some other certification rules need
to be figured out. The rules of certification contain:
Like already
mentioned IFSA’s standard (IFIS) covers in the
first place aims the processed feed ingredients. This
is the scope to start with. The producers of these
processed feed ingredients were closely involved with
the development of the standard and especially the
sector notes. It is expected that all suppliers worldwide
are certified against the IFIS-standard towards 01/01/2007.
Other stakeholders
have requested the extension of the IFSA initiative
to activities such as trade, transport, additives,
premixes, … IFSA is working on the evaluation
and implementation of these extensions.
Finally, in
several member countries, there was a fuss about the
notion of ‘zero-tolerance’. Methods of
analysis made tremendous progress which resulted in
LOD (Limits of Detection) at ppb-level. LOD’s
of less than 5 ppb’s are very common now. Production
processes are not developed to provide a zero-cross-contamination.
Food Safety Agencies, during their monitoring program,
detected residues of additives and medicines in meat,
milk, eggs as non-target product. This means, that
for instance coccidiostatica used in the feed for
target animals, can end up in the feed for non-target
animals, because of the dragging (cross contamination),
in spite of all necessary control measurements (flushing)
within the quality system of the feed manufacturers.
The compound
feed industry developed the necessary methods to measure
the cross contamination in the compound feed production
process. Only few countries in the EU, have developed
methods: Belgium, the Netherlands, France en Germany.
Apart from the cross contamination, the compound feed
manufacturer has to know the legal norms to be respected
at feed level. These norms have to guarantee that
the norms on finished products (meat, milk and eggs)
are not exceeded . So they postulate guarantees that
the national health won’t be put in danger.
Therefore, threshold levels were developed based on
scientific research (ADI as basis and if possible
transfer studies (carry over) from feed to food, the
ALARA principle and benchmark procedures on the ADI).
This proposition has been transmitted to the European
Commission and the EFSA.