Informationsonmicrobiologicalself-controlsaccordingtoRegulation(EC)2073/2005

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Jun 16, 2017 - Microbiology

Informationsonmicrobiologicalself-controlsaccordingtoRegulation(EC)2073/2005

Microbiological Self-Inspections of Food Companies 

Several reports from the regulatory authorities highlight the need for enhanced self-inspections by food companies (FC). The principle of “monitoring the monitoring” that has been demanded for several years is to be expanded through increased self-inspections by companies. Therefore, the regulatory authorities will increasingly monitor the implementation of self-inspections in the future. In this context, an inter-state working group within the food monitoring named AFFL (Working Group on Meat, Poultry Meat Hygiene, and Specific Questions of Foods of Animal Origin) has developed principles for official control of microbiological self-inspections of food companies. It is expected that the regulatory authorities will adhere more strictly to these principles during company inspections. 

Regulation (EC) No. 2073/2005 sets out the microbiological criteria for foods. Microbiological self-inspections by companies are required in this context. The project group has now developed principles that the authorities should demand during company inspections. The points listed here can be used as a sort of checklist for companies to prepare for official inspections:

• A sampling plan must be available that includes all foods that are required to be tested 
• The determined sampling frequencies must comply with the regulation's requirements
• Any claimed reduction in sampling frequency must comply with the provisions of the regulation (risk analysis, HACCP concept, …); in the case of a reduction, laboratory results and the measures described in the HACCP concept must allow for a reduced sampling frequency 
• The self-defined sampling plan must be adhered to 
• Samples must be taken at the correct stage; sampling times must be representative of the production process 
• The correct microorganisms must be investigated (the requirements of the regulation must be at least observed) 
• The prescribed analysis methods must be used 
• Alternative analysis methods must be demonstrably validated (e.g., according to ISO 16140) 
• Results must lie within the established limit values 
• Incoming test results must be clearly and promptly reviewed by an authorized and competent person within the company 
• Suitable corrective measures must be defined which are initiated when limit values are exceeded 
• In the case of unsatisfactory results, these corrective measures must be carried out and documented 
• Depending on the risk assessment, not only the foods but also the equipment and facilities must be examined 
• Special requirements for manufacturers of, for example, ready-to-eat foods or dried infant formula must be taken into account 
• Trend analyses must be created from the test results, from which suitable measures for hazard prevention are taken in a timely manner

Of course, this list cannot cover all inspection points of the monitoring and mainly refers only to the criteria of Regulation (EC) 2073/2005. Beyond this, aspects arising from diligence or other requirements or recommendations that reflect the current technical standards must be considered.