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Position Papers
Brussels, 27/02/2002


Consumers' safety requires stricter measures to combat food poisoning


Euro Coop welcomes the pair of Commission's proposals 1 aiming at improving and reporting system for diseases transmissible from animals to man and to reduce the prevalence of specified zoonoses. Food poisoning is a major public health problem, especially for vulnerable people such as elderly people, infants, pregnant women, and people with concurrent disease.

However, Euro Coop believes that consumer safety requires stricter measures to combat food borne zoonoses. We are deeply concerned about the potential effectiveness of the proposed monitoring and control schemes. Euro Coop is disappointed that the scope of the Regulation on controls is limited to salmonella, and feels that the timescales of the targets should be shortened. Finally, we believe that certain practical measures need further consideration to ensure the success of the reform.

We regret that, following the reform announced in the White Paper on Food Safety 2 , the Commission has not fully seized the occasion to bring major improvements to the existing situation. We urge the European institutions to enact stricter measures to control the presence of zoonotic agents at primary production level and throughout the rest of the production system in order to decrease the incidence of food borne diseases in humans.

The following comments explain more fully Euro Coop's position concerning the Commission's proposals on zoonoses:
  • Euro Coop agrees that the monitoring system should be strengthened, but is concerned about the potential effectiveness of the proposed Directive

Euro Coop agrees with the Commission's proposal to improve the current monitoring system. Today, existing incidence data on human food-borne zoonoses from different Member States are limited or not available. This situation prevents risk managers to take appropriated evidence-based decisions and to enact effective policies to combat zoonoses.

Euro Coop believes that strict measures should be set up to ensure the effectiveness of the proposed monitoring scheme. The current legal situation shows that EU Member States have not fully implemented Directive 92/227/EEC on zoonoses. We are afraid that imposing further requirements upon Member States on them without strict accompanying measures might not be sufficient to improve consumer safety.

We agree that Member States should bear the greatest responsibility in the establishment of national control programmes, and the control of their application, but we ask the Commission to allocate appropriate resources for regular Community controls of national programmes. Until now, too few Community inspections have been carried out in Member States to control whether zoonoses programmes are in place.
  • Euro Coop agrees that Community targets should be established, but calls for a shortening of their timescales

Euro Coop welcomes the set of Community pathogen reduction targets for selected zoonotic agents. We indeed feel that the current absence of EU standards has led to intra-Community trade conflicts.

However, we are seriously concerned about the timescales planned for setting the targets. The Commission's proposal for a Regulation 3 indicates that the targets are to apply from 2005 onwards for broilers, from 2006 onwards for turkeys, and from 2006 breeding herds of pigs. Mandatory testing and certification for trade will not apply before 2005 for salmonella in breeding flocks to 2008 for salmonella in breeding herds of pigs.

Euro Coop calls for a shortening of these timescales. We strongly believe that food borne zoonoses must be tackled as soon as possible in order to ensure consumers' safety. We regret that one of the key measures of the proposals would be implemented at such a late stage.
  • Euro Coop asks the European institutions to enlarge the scope of the proposed Regulation on controls

Euro Coop is concerned about the limited scope of Commission's proposal for a Regulation on the control of salmonella and other food-borne zoonotic agents, which only applies to certain types of salmonella, especially in poultry products and eggs. It is scientifically recognised that other zoonotic agents, such as Campylobacter, can cause serious food poisoning, which in numbers now exceed poisoning by salmonella.

We urgently ask the European institutions to enlarge the scope of the proposed Regulation on controls in order to include Campylobacter and E. Coli. This would be consistent with the proposed Directive on monitoring, which encompasses all zoonoses and zoonotic agents.
  • Euro Coop insists that the whole food production chain must be responsible for controlling and preventing food borne zoonoses

Euro Coop welcomes the stable-to-table approach of the Commission. We have always argued for an integrated approach, which we have reiterated in our comments on the Commission's draft proposal on EU meat inspection legislation of September 20014 .

However, we are concerned that Article 1, par. 3 of the Commission's proposal for a Directive on zoonoses refers to the Commission's proposal on the hygiene of foodstuffs, which exempts farmers from the HACCP system. Euro Coop reiterates its opposition to this exemption and urges the Commission to take appropriate measures to implement the farm to table principle. Exempting farmers is in contradiction to the "farm to table" principle. Euro Coop insists that feed producers and farmers bear a great responsibility in controlling and preventing food borne zoonoses. The control of the feed given to animals on the farm is indeed the first barrier to introduction of zoonotic pathogens in primary production 5.

Slaughterhouses also play a key role in controlling and preventing food borne zoonoses. Risk management of food borne zoonoses in the retail, catering and home stages is also extremely important. Residual risks for the earlier part of the food chain could cause public health problems.

Finally, we believe that consumers have a role to play as well. They should be educated on how to handle the food hygienically. Proactive EU programmes should be encouraged to communicate risks as well as to manage them to all sectors of the food chain, with simple and consistent messages targeted at different population groups. These programmes should be continuously evaluated.
  • Euro Coop agrees that antibiotic resistance must be included in the scope of the zoonoses proposals

Euro Coop welcomes the Commission's proposal to include antibiotic resistance in the monitoring scheme. As the Scientific Committee on Veterinary Measures Relating to Public Health states 6, antimicrobiological resistance is of relevance in relation to zoonoses. Zoonotic bacteria may develop acquired resistance to various antimicrobiological agents and thereby represent a health concern in addition to their virulent properties. As Euro Coop already indicated in 1998, antibiotic resistance is an important public and animal health problem 7.
  • Euro Coop asks for adequate co-ordination between the European Food Safety Authority and the national authorities

Euro Coop has always supported the creation of the EFSA 8, and we agree with the Commission that it can play a key role in coordinating national risk assessments on zoonoses and in dealing with food-borne outbreaks 9 . However, we believe that adequate co-ordination between the EFSA and the national authorities should be guaranteed. Some Member States now have their own Food Safety Authorities (FSA), but in countries with no FSA their lines of reporting could be extremely complex. Therefore, we believe that the co-ordination role of the Authority will be difficult to achieve without full support and diligent reporting from Member States. The rapid alert system has been made possible by modern technology but could easily lead to confusion when dealing with emergency zoonoses cases if all parties are not fully aware of their roles.
  • Euro Coop urges the Commission to adopt a Regulation on official food and feed safety controls

Controls are necessary to ensure the good implementation of any kind of legislation, including food legislation. We welcome the Commission's commitment 10 to the production of a new and comprehensive law on food and feed controls in order to improve the quality of control systems throughout the whole of the chain from farm to fork.

As the proposed Regulation on the General Principles of Food Law does not contain detailed provisions on controls, we urge the Commission to promptly adopt the Regulation on official food and feed safety controls, which was announced in the White Paper on Food Safety to be adopted by December 2000. Euro Coop reaffirms that a key objective of this law should be to ensure that adequate enforcement and control resources both within Member States and at Commission level are allocated appropriately throughout the food chain 11 .
  • Euro Coop calls for the full transparency of both national and Community monitoring and control system

Euro Coop strongly believes that the European network for detection of existing and emerging zoonoses should be accessible to the public. Today, a network exist for several zoonotic agents, but the range of activities is limited and there is no public access to the information produced in these networks established at the moment.

We also call for national and Community reports to be publicly available. As we have previously stated in our comments on general principles of food law and on the creation of the EFSA 12 , transparency is vital to regain consumer confidence. Consumers should be given the possibility to be fully informed about the implementation of measures to prevent and control food poisoning.
  • Need for a collaboration between all actors at the national level

Euro Coop believes that a close collaboration between veterinarians, medical, food and feed authorities in each Member States is needed to strengthen disease prevention, outbreak recognition and control.


Conclusion

A series of food scares, including Salmonella, verotoxigenic E. Coli 0. 157, Campylobacter, has damaged consumer confidence in the safety of food and the commitment of both the food industry and the regulatory authorities to protect that supply. Euro Coop believes that the Commission's proposals on zoonoses are a good step towards better prevention and control of food borne zoonoses, but strongly believes that consumers' safety requires stricter measures to combat food poisoning.


1.Proposal for a Directive on the monitoring of zoonoses and zoonotic agents, amending Council Decision 90/424/EEC and repealing Council Directive 92/117/EEC and Proposal for a Regulation on the control of salmonella and other zoonotic agents and amending Council Directives 64/432/EEC, 72/462/EEC and 90/539/EEC. Both proposals were adopted by the Commission on 1st August 2001.
2.Of 12 January 2000, COM (1999) 719 final, paragraph 70.
3.Annex I of the Proposal for a Regulation on the control of salmonella and other zoonotic agents and amending Council Directives 64/432/EEC, 72/462/EEC and 90/539/EEC.
4.See Euro Coop asks for a further strengthening of the EU meat inspection legislation, available in French and in English.
5.Opinion of the Scientific Committee on Veterinary Measures Relating to Public Health in its opinion on zoonoses,12 April 2000, page 43. The Opinion is available in English
6.Opinion of the Scientific Committee on Veterinary Measures Relating to Public Health in its opinion on zoonoses,12 April 2000 available in English.
7.See Call to the European Council, the European Parliament, European Commission, and Economic and Social Committee- Re: Request for a ban on the use of antibiotics as additives in feedingstuffs for breeding animals, Position
8.See Euro Coop asks for a strengthening of the general principles of food law and reiterates its call for an effective European Food Authority of April 2001 in English and Euro Coop comments on the establishment of a European Food Authority of April 2000 in English.
9.Articles 6 and 7 of the Proposal for a Directive on the monitoring of zoonoses and zoonotic agents, amending Council Decision 90/424/EEC and repealing Council Directive 92/117/EEC.
10.White Paper on Food Safety of 12/01/2000, COM (1999) 719 final, Chapter 6, pp.29-30.
11.Please refer to Euro Coop's comments on the hygiene of foodstuffs, 18/10/2000.
12.See Euro Coop asks for a strengthening of the general principles of food law and reiterates its call for an effective European Food Authority of 25 April 2001.


Contact :
Aude L'hirondel, Food Officer
Tel: +32.2.285.00.70 - Fax: +32.2.231.07.57 E-mail: alh@eurocoop.org