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Brussels, 30 may 1997
EURO COOP comments on the Commission's second consultation document"Simplification of veterinary legislation with regard to the production, marketing andimportation of products of animal origin intended for human consumption"
After the European Commission launched the consolidation of 14 vertical Directives governing production, marketing and importation of products of animal origin intended for human consumption, and after EURO COOP's its first comments on the "Guide" on 26.07.1996, it now welcomes the second stage dealing with simplification of all EU hygiene rules.
Before the forthcoming formal legislative proposal is advanced, EURO COOP would like to make a certain number of remarks on the second consultation document.
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Legal form of the future Commission proposal
EURO COOP believes that a Directive would allow for more flexibility and for the Member States to make adjustments when the need occurs, due to national or local circumstances.
Since the aim of such a piece of legislation is to ensure the production of safe and wholesome food, EURO COOP would welcome the inclusion in the recitals of general declarations dealing with:
- the need to avoid any contamination of products;
- the need to maintain the cold chain.
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Scope of the Guide
EURO COOP welcomes the fact that retail is still excluded from the scope, even if it still supports the Commission's overall "stable to table" policy. Directive 93/43 on the hygiene of foodstuffs already covers retailing and serves as the framework Directive for the implementation of HACCP ("Hazard Analysis Critical Control Point System").
Consumer co-operatives' own experience shows that the implementation of HACCP, of voluntary codes of practice and of self-monitoring programmes, in cooperation with national authorities, is a good approach which works in a satisfactory manner.
Limiting this second document to a confirmation and clarification of the actual scope of the consolidated veterinary health Directives is considered a good approach, because the main aim of vertical rules is to guarantee the safety of vulnerable raw products at the earliest stages of the food production chain.
EURO COOP welcomes the fact that the scope has not been extended to all products of animal origin not intended for human consumption.
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The link with Directive 93/43/EEC on the hygiene of foodstuffs
As we have always believed that the general food hygiene Directive 93/43/EEC should be the lead Directive covering all foods, EURO COOP welcomes the link established in this second consultation document between the general Directive setting out the rules for a safe handling of foodstuffs and the hygiene rules on animal products.
We note the inclusion of a certain number of requirements of a technical nature contained in the Annex to Directive 93/43 in Annex 11 ("common provisions") of the working document.
EURO COOP is surprised that some elements of Directive 93/43 have not been taken into account, in particular chapter X on initial training. The implementation of HACCP will require a reinforcement of training, so that at shop/retail level, understanding and self-awareness of hygiene from employees can be increased.
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Own checks and extension of HACCP ("Hazard Analysis Critical Control Point System")
EURO COOP supports the introduction of HACCP principles into the Guide. HACCP is the modern method of securing food safety and is accepted internationally.
Using end product testing by itself tells the user about only one product at one point in the handling chain at one moment in time. Using end -product testing alongside HACCP enables the testing to perform its rightful role, which is to act as an assurance that HACCP is working.
When properly implemented, HACCP allows for a reduction of prescriptive requirements.
However, EURO COOP does not think that own checks can immediately become the general rule; they should only be applied when it is possible. Putting more responsibility on producers should in no way remove the official authorities overall responsibility to fully enforce the rules and to supervise of the own-check system.
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Official checks
EURO COOP notes that there will be a separate text and looks forward to commenting on it. We have reservations about the move of the ante mortem inspection to the farm. This move should not preclude any ante and post mortem inspections in the slaughterhouse.
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Derogations for "low capacity establishments"
EURO COOP notes that there will be a separate text and looks forward to giving its comments on this specific issue.
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Temperatures
EURO COOP welcomes the fact that the Scientific Veterinary Committee has been asked to review temperatures controls for these products.
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Procedure of the Standing Veterinary Committee
EURO COOP, like the rest of the Advisory Veterinary Committee (cf. opinion of the AVC of 1st October 1996) insists on the need to have a flexible procedure to amend legislation, in particular given technical progress or new insights on detailed provisions, and considers that the SVC procedure does not allow for such flexibility and transparency. When addressing health rules, it is preferable to increase the joint role of the Council and on the European Parliament.
EURO COOP supports constructive proposal on the reinforcement of the Advisory Veterinary Committee's role.
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Conclusion
Consumer protection must be the overriding priority and simplification should not mean deregulation.
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