Feed Safety: Evolution in Legislation, Implementation and Harmonisation

Ir. Yvan Dejaegher
info@bemefa.be
Director general Belgian Feed Compounders Association (Bemefa – www.bemefa.be)
Deputy Chairman Ovocom (www.ovocom.be)
Chairman IFSA
August 2005

As a result of several contaminations, especially in feed ingredients destined for the compound feed industry, various initiatives were undertaken. On the one hand authorities published new legislation with additional requirements. On the other hand the private sector invested a lot in a pro-active approach assuring feed ingredients at source being the most cost effective action for the feed chain as a whole.

First, the General Food Law was published. Following principles were established:

1. the responsibility of the producer
2. the obliged notification to the authorities concerning withdrawal and
recall
3. traceability.

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:

· The sort of certification (ISO guide 65: EN45011)
· The job description for the auditors
· The necessary training for the auditors
· The checklists
· The audit conditions
· The fees that go with the auditing and the fees for tha maintenance of the quality system.

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.