The audit also raised concerns around the application of Hazard Analysis and Critical Control Points (HACCP).
However, overall it found the control system can provide guarantees that fishery products placed on the market in the Netherlands are in line with regulation.
System in line with regulation
Objectives were to verify official controls of fishery products are within Regulation (EC) No 882/2004 and to evaluate the control system for production and placing on the market is in compliance.
Establishments are classified in four categories: green (no warnings or fines in a year) orange (one warning or fine in a year) dark orange (two warnings or fines in a year) and red for those with more than two warnings or fines.
All approved fishery product premises have to be inspected at least once a year. Once every three years an audit covers structural and hygiene aspects of premises and HACCP based procedures.
The audit team visited six processing sites, one cold store, factory vessel and freezer vessel in March this year.
One processing plant had deficiencies related to hygiene of operations, potential cross contamination due to lay out, cleanliness and maintenance of floors and the cold store.
Hazards not identified
The audit team found that in most cases some potential hazards had not all been identified such as histamine in mackerel in regards to the HACCP in plants/freezer vessels.
“In most cases the temperature of fresh fish was [considered] as a Critical Control Point (CCP), however, the limit set was not in compliance with EU requirements. The limit set for temperature for fresh fish was up to +7 °C (EU requirements specify that fresh fish must be maintained at a temperature approaching that of melting ice),” said the FVO.
In one freezer vessel histamine was tested for but only one sample unit was taken (legislation requires a sample of nine units) and an ELISA method used which is not the EU reference method.
Responding to the findings, the Netherlands competent authority said in the short term regular meetings with the involved inspectors will put a focus on the use of correct reference methods as described for histamine in the Regulation 2073/2005.
“The debriefing results will be brought under the attention of the inspectors in order to improve their work in accordance with the described working methods,” it added.
In two sites where analyses of additives were done, the results showed levels are often above the regulatory limit. At one site, four out of five results in 2012 were above the regulatory limit.
The food business operator revised its procedure to solve the problem. However, it did not include additives as part of own-checks during 2013.
HACCP problems
Facilities were found to be in compliance with EU requirements. However, HACCP procedures were inadequately implemented (relevant potential hazards not identified, limits set for some CCPs not in line with EU requirements, EU reference method for histamine not used), said FVO.
Food business operators’ own-checks did not always cover all relevant parameters (histamine, microbiology, additives).
The competent authority agreed the HACCP system of some visited companies showed certain shortcomings.
“But the [competent authority] is convinced however that an efficient follow up of responsibilities as described in the Regulation 882/2004 and 854/2004 will take place.
“Working methods and protocols for HACCP and microbiological criteria are well described and applied in the daily practice. However in order to improve in 2014 feedback is foreseen to the inspectors.”
A previous audit in 2004 highlighted deficiencies in official control of fishery products, and made a number of recommendations in respect to actions required by the competent authority.
Since 2011, 40 Rapid Alert System for Food and Feed (RASFF) alert notifications were issued referring to products imported from third countries via the Netherlands.
They cover a range of products and relate to dioxins, heavy metals, histamine, additives and undeclared ingredients.
In 2013 the competent authority carried out one investigation report, imposed 366 written warnings and 43 administrative fines.
Around 195,000 tons of frozen fish were imported in the Netherlands in 2012 from third countries.