EUROPEAN COMMISSION HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL

Transcription

1 EUROPEAN COMMISSION HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL Directorate F - Food and Veterinary Office DG(SANCO)/8199/2006 MR Final FINAL REPORT OF A MISSION CARRIED OUT IN TURKEY FROM 4 TO 14 JULY 2006 IN ORDER TO EVALUATE OFFICIAL CONTROLS OVER THE PRODUCTION AND PROCESSING OF MILK, DAIRY PRODUCTS AND CASINGS INTENDED FOR EXPORT TO THE EU Please note that factual errors in the draft report have been corrected. Clarifications provided by the Turkish Competent Authorities are given as footnotes, in bold, italic, type, to the relevant part of the report. 24/11/

2 SUMMARY Turkey is authorised to export casings to the EU. Fourteen establishments are currently listed for this purpose. Turkey is also authorised in principle to export milk and milk-based products but all previously authorised establishments were de-listed in At the request of the Turkish competent authorities a FVO mission has evaluated official controls over the production and processing of milk and dairy products intended for export to the EU, in the framework of Regulations (EC) No 852/2004, No 853/2004, No 854/2004 and No 882/2004. The evaluation of casings in the framework of the above Regulations and Council Directive 92/118/EEC was added by the Commission Services to the scope of the mission. With regard to casings, with the exception of one establishment for which guarantees were requested, the general situation in processing establishments, and the related controls, were adequate. However, due to certain deficiencies the CA cannot at present guarantee that EU requirements are respected for casings, stomachs and bladders exported to the EU. Deficiencies in the official control system relate to: - re-export of casings to the EU from non-eu listed establishments and countries, - shortcomings regarding traceability within casing-processing establishments, - procedures not complying with minimum standards for certification. Although seven of the eight milk-processing establishments presented to the mission team complied with regard to structure, lay-out and equipment, controls over the production and processing of milk-based products are not adequate to guarantee that EU requirements would be met in the following areas: - animal health controls, - controls over raw material (raw milk and milk-based products), - controls over treatment requirements (e.g. heat treatment) for milk-based products produced in a Foot and Mouth Disease affected country, - capacity of the competent authorities to effectively address inadequate or fraudulent practices.

3 TABLE OF CONTENTS ABBREVIATIONS & SPECIAL TERMS USED IN THE REPORT INTRODUCTION OBJECTIVES AND SCOPE OF THE MISSION LEGAL BASIS FOR THE MISSION BACKGROUND Production and export data MAIN FINDINGS Competent Authorities Legislation Animal Health Controls Application of hygiene rules on dairy holdings and official controls Application of hygiene rules at milk-processing establishments and official controls Application of hygiene rules at establishments treating animal casings and official controls Official laboratories Import controls over animal products Official certification CONCLUSIONS Competent Authorities Legislation and procedures Animal Health Controls Application of hygiene rules on dairy holdings and official controls Application of hygiene rules at milk-processing establishments and official controls Application of hygiene rules at establishments treating animal casings and official controls Official Laboratories Import controls over animal products Official Certification OVERALL CONCLUSION CLOSING MEETING RECOMMENDATIONS TO THE COMPETENT AUTHORITIES OF TURKEY COMPETENT AUTHORITY RESPONSE TO RECOMMENDATIONS ANNEX - REFERENCES TO COMMUNITY ACTS RELEVANT TO THIS MISSION

4 ABBREVIATIONS & SPECIAL TERMS USED IN THE REPORT CA(s) CCA CCP CDB CFT DD EU FMD FVO GDPC HACCP MARA NRL OV PC PD QS SAT SCC TB TIGEM Competent authority (ies) Central Competent Authority Critical Control Point Central Data Base (for bovines) Complement Fixation Test District Directorate (İlçe Müdürlüğü) European Union Foot and Mouth Disease Food and Veterinary Office General Directorate of Protection and Control (Koruma ve Kontrol Genel Müdürlüğü) Hazard Analysis and Critical Control Points Ministry of Agriculture and Rural Affairs (Tarım ve Köyişleri Bakanlığı) National Reference Laboratory Official Veterinarian Plate Count Provincial Directorate (İl Müdürlüğü) Quarantine Station (Tahafuzzahne) Serum Agglutination Test Somatic Cell Count Bovine tuberculosis Agricultural Establishments Directorate General (Tarim Işletmeleri Genel Müdürlüğü) 4

5 1. INTRODUCTION The mission took place in Turkey from 04 to 14 July 2006, as part of the planned mission programme of the Food and Veterinary Office (FVO). The mission team comprised four FVO inspectors and was accompanied during the whole mission by representatives from the central competent authority (CCA), the Ministry of Agriculture and Rural Affairs (MARA) (Tarım ve Köyişleri Bakanlığı). The mission itinerary in pursuit of the mission's objectives included the following: COMPETENT AUTHORITIES Comments Central 3 Opening and closing meeting, clarification meeting Competent Adana, İstanbul, Kahramanmaraş, Sanliurfa and Provincial authorities Tekirdağ Local During on-site visits FOOD PRODUCTION/PROCESSING / DISTRIBUTION - ACTIVITIES Establishments processing In the provinces of Adana, Istanbul, 6 casings Kahramanmaras Milk processing plants 8 In the provinces of Bursa, İzmir, Kahramanmaraş, Kırklareli, Sakarya, Sanliurfa and Tekirdağ LABORATORIES 1 Tekirdağ Provincial Control Laboratory Directorate HOLDINGS Bovine 5 Dairy cows QUARANTINE STATION 1 At border with Bulgaria At the opening meeting, the objectives, itinerary, and reporting procedures were confirmed, and information complementary to that received in the course of the preparation of the mission was requested by the mission team. 2. OBJECTIVES AND SCOPE OF THE MISSION The objective of the mission was the evaluation of official controls over the production and processing of milk, dairy products and casings destined for export to the EU, in the framework of Regulations (EC) No 852/2004, No 853/2004, No 854/2004, No 882/2004 and Council Directive 92/118/EEC LEGAL BASIS FOR THE MISSION The mission was carried out under the general provisions of Community legislation and, in particular Article 46 of Regulation (EC) No 882/ BACKGROUND Turkey had been authorised to export milk and dairy products to the EU prior to By Commission Decision 2001/177/EC and with effect from 17/05/2001 all milkprocessing establishments were removed from the list of authorised establishments. The Turkish authorities had, however, undertaken to suspend certification for milk and dairy products immediately after the previous FVO mission, which took place from 3 to 7 1 References to Community acts are listed in the annex to this report 5

6 April 2000 (ref. DG(SANCO)/1069/2000). This report and other reports of the FVO are available at the address: Out of seventeen milk-processing establishments which applied to the competent authority (CA) for export approval, eight establishments were presented to the FVO team for review. Turkey has been authorised for export of casings by Commission Decision 1999/120/EC. The current list of establishments authorised to export casings (date of 21/06/2006) contains 14 entries Production and export data According to information provided by the CCA, about 2.1 million tonnes of milk and milk-based products are produced annually. The main products are Turkish buttermilk, yoghurt and various cheeses. In 2004 exports of 192 tonnes of milk-based products mainly cheeses, fermented milk and milk powder to the EU were reported. The main countries of destination were Germany and Belgium. These export figures were largely confirmed by EUROSTAT data. According to statistics provided by the CCA for the year 2005 a total of 1,511 tonnes of casings (which represent 31% of the total exports of Turkey in this sector) and 430 tonnes of stomachs and bladders were exported to EU Member States, mainly to Germany, Austria, Italy, Spain, France and Denmark. 5. MAIN FINDINGS 5.1. Competent Authorities Organisation of competent authorities The CCA with respect to the evaluated sectors is the General Directorate of Protection and Control (GDPC) (Koruma ve Kontrol Genel Müdürlüğü) of the Ministry of Agriculture and Rural Affairs (MARA). In the 81 provinces of Turkey the Provincial Directorates (PD), the Animal Health Units (Hayvan Sağliği Şubesi) and the Control Units (Kontrol Şubesi) are in charge of animal health controls and controls over food processing establishments respectively. The PDs are subdivided into District Directorates (DD) of which a total of 803 exist in the country. The DD are in charge of animal health services and food control services when authorised by the PD. Co-ordination between the GDPC and the PD was in place and effective distribution of instructions and circulars was observed. Animal Health Units informed food business operators about the change of animal health status (in particular FMD outbreaks), but the Control Units in the same PD were not informed. 6

7 The GDPC is responsible for Quarantine Stations (Tahafuzzahne) (QS) which work under the responsibility of the PDs. At the QS visited, it was observed that the officials had not been updated on certification procedures. In particular the officials were not informed of the appropriate model certificates to be used and the specific statement to be made for export of milk-based products Legal/enforcement powers Legal and enforcement powers are given to the CA in national legislation. The PDs have the legal power to grant and withdraw authorisations for EU export. The GDPC is responsible for notifying the Commission services and allocating the export approval numbers. Examples of withdrawal of authorisations for EU export were seen. The CA of the PD could not enter areas of food-processing establishments, which were under customs control. The CA stated that they do not have the legal power to enter. 2 In both cases seen, no official documentation was available to demonstrate that customs had actually sealed the areas. Both establishments where customs seals were used were involved in fraudulent activities, such as re-bagging of imported milk powder into own bags or reconstitution of milk from raw material that was not suitable for human consumption (see section 5.5) Independence With regard to the staff of the GDPC and the PD no indications of lack of independence were observed. Customs seals were used to close storage areas in milk-processing establishments but no official documents were available. Customs did not provide an explanation regarding the use of a customs seal to hide milk-based products from the CA and the mission team. The customs representative stated that the seal was not officially used at this establishment Supervision of the competent authorities The CCA stated that an internal audit system was in place. The QS visited was last audited in 1998 for technical performance. The last financial audit took place in Lack of enforcement of existing national legislation regarding animal health controls and public health was not effectively addressed (see section 5.3 and 5.5). 2 In their response to the draft report the Turkish Authorities noted that according to national legislation the CA must contact customs administration before entering into the customs warehouses for control. 7

8 Controls over official certification were not adequate the list of certifying officers is not updated and certificates are issued without adequate supporting documentation (see section 5.9) Training of staff A list of training schedules has been received. According to this list a large number of food inspectors have received training in the period of In addition, HACCP training was provided in the years to a smaller number of staff. According to the list, food inspectors of two provinces (Kirklareli and Sakarya) in which three milk-processing establishments proposed for EU export are situated have not been trained. 3 Animal health requirements as laid down in Council Directive 64/432/EEC and Council Directive 91/68/EEC were not known to staff at PD and DD. In effect the animal health controls performed were not in line with EU requirements (see section 5.3.). It was repeatedly found that food inspectors were not aware of specific heattreatment requirements as set out in Commission Decision 2004/438/EC and had not evaluated the production processes accordingly during their inspections (see section ) Resources Compensation for animals slaughtered or killed because of rinderpest, bovine tuberculosis (TB), bovine brucellosis and Foot and Mouth disease (FMD) is provided for in national legislation. The CCA stated that a shortage of financial resources was the principal reason for the lack of enforcement of national legislation pertaining to the controls over TB and brucellosis (see section 5.3.), in particular as no compensation could be paid for eradicated animals. The same reason was given regarding animals infected with FMD, which are not culled in Anatolia. There was no indication of staff shortage in controls over food-processing establishments involved or proposed for EU export Notification procedures of disease outbreaks Notification of 33 diseases is compulsory according to Turkish legislation. These include rinderpest, TB, bovine brucellosis, sheep and goat brucellosis and FMD. Notification procedures are laid down in the annual programme for disease control and surveillance. 3 In their response to the draft report the Turkish Authorities noted that the inspectors in the two provinces mentioned had also received specific HACCP training. 8

9 5.2. Legislation National legislation is in place for animal health and public health purposes. Procedures are in place in the dairy sector to complement the provisions of national legislation for export of milk and milk-based products to the EU Animal Health legislation The main animal health legislation with relevance to the mission comprises: Regulation on the identification, registration and monitoring of bovine animals (No of 2002), The Law on Animal Health Control (No 3285 of 1986), Regulation for Animal Health Control (Decision of 1989), Regulation on Cattle Tuberculosis (No 12 of 1978), Regulation on Control of Brucellosis (No 189 of 1960), Circular on animal Disease and Pest Controls (No 2006/13). The CCA provided two draft regulations based on Council Directives 64/432/EEC and 91/68/EEC laying down measures for the control of brucellosis and tuberculosis. The following points differ in national Turkish legislation from the relevant EU requirements regarding the animal health controls over milk-producing animals. The testing frequency for bovine tuberculosis on dairy farms has been defined as once per year but conditions for allocation of a 'free' or 'officially free' status to herds have not been defined. 4 For the retention of TB and brucella free status no conditions are set out for animals entering the herd. 5 Additional technical differences are outlined in section Public Health legislation The main legislation related to controls over food safety comprises: Food Law (No 5179 of 2004), Regulation on production, consumption and inspection of foods (No of 1998), Regulation on the market surveillance, control and inspection of food and articles and materials in contact with food and the responsibilities of food businesses (No of 2005), Regulation concerning water intended for human consumption, Turkish Food Codex, Communiqué on raw milk and heat treated drinking milk (ref. 2000/6). 4 In their response to the draft report the Turkish Authorities noted that Circular 2006/32 would address this point. 5 See footnote no 4. 9

10 The legislation reflects a number of requirements of EU legislation, including animal health requirements for herds supplying milk to milk-processing establishments and raw milk criteria Procedures for export The following procedures for export of milk and milk-based products have been issued: A circular Controls of Approved Holdings (ref 2006/28 of 23/05/2006) outlines the requirements for the approval of holdings, in particular with regard to the hygiene requirements as laid down in Annex III, Section IX, II of Regulation (EC) No 853/2004. The pre-requisite for the approval of a holding for supply of milkprocessing establishments for EU export is freedom from TB and brucellosis. The communication applies to cattle, buffalo and small ruminant holdings. The procedure for the determination of freedom from TB and brucellosis is based on Turkish national legislation and set out in the 2006 annual programme for disease control and surveillance. A communication Instruction for Inspection of Dairy Establishments to be Certified for Export (ref of 18/05/2006) contains instructions on the procedure to be followed for authorisation of milk-processing establishments for EU export. This procedure for inspection of milk-processing establishments does not correctly address the sampling point and the criteria for plate count (PC) and somatic cell count (SCC) as laid down in Annex III of Regulation (EC) No 853/ For the export of casings, no procedures in addition to the national legislation in place have been issued. Provisions to ensure compliance with the provisions of Council Directive 96/93/EC on the certification of animals and animal products are not in place Documented control procedures and control systems Documented control procedures are also available for official controls in the following sectors: - National Residue Control Plan, - controls over cattle holdings participating in the programmes to obtain disease free status for TB and brucellosis, - controls over establishments processing casings and milk to be placed on the national market. The EU specific requirements for animal health controls over dairy cattle and small ruminants holdings supplying milk-processing establishments for EU export were not included in the control procedures. 6 In their response to the draft report the Turkish Authorities noted that the procedure makes direct reference to Regulation (EC) No 853/

11 Specific documented procedures were not available for establishments processing casings for export to the EU. Certain specific requirements for EU export of milk-based products were not included in the control procedures. Consolidated documented control procedures are not available for certification of products for export to the EU Animal Health Controls Holding registration, animal identification, movement controls No national system of individual identification and registration is in place for small ruminants and no legislation exists yet. For bovine animals, the CCA stated that to be registered, the holdings had to fulfil certain criteria and that a number of small holdings were not yet registered in the Central Data Base (CDB) called VETBIS. However, it was stated that all cattle owners were recorded. In 2005, the bovine population was estimated at 10 million heads. Cattle movements are notified to the CDB, both by the DD at origin and at destination (or by the official veterinarian of the slaughterhouse). Cattle can be moved from one holding to another if they are ear tagged, accompanied by a passport and a veterinary health certificate. This certificate has a validity of 21 days and states that the animal is healthy and comes from an area where no outbreak of FMD was declared recently. In all bovine farms visited, the animals with a few exceptions were generally properly identified. In cases where the animals had lost their ear tag(s), no requests to order new ear tags had been made. In one bovine farm, two adult animals were not recorded in the CDB, and the OV stated that it was not possible to register them because they had not been notified at the farm of origin. When the movement is limited to the district, FMD vaccination is not compulsory and the veterinary health certificate is replaced by a certificate of origin, issued by the local administrative authority. The procedure controls of approved holdings, requires that small ruminants should also be ear-tagged and holding registers should be kept Animal health controls GDPC issues the annual animal health control programme. It is implemented by the PD and the DD. The CCA stated that, due to insufficient budget there are no national brucellosis and TB eradication programmes. With the exception of state farms, eradication of these two diseases is performed on a voluntary basis. A specific animal health control programme was implemented in the Thrace Region and extended to 15 provinces in

12 On state farms (Tarim Işletmeleri Genel Müdürlüğü) (TIGEM) tests for animal diseases are carried out by veterinarians of this organisation under the inspection of the CA. Although the CA (Animal Health Units of the PD) consider that these farms have disease-free status for tuberculosis and brucellosis, no official certificate is issued for the TIGEM farms visited. About 100 bovine holdings have received a certification as being free of TB and brucellosis with a validity of one year. The certification covered groups of animals and not the entire herd, contrary to the requirements laid down in Annex A of Council Directive 64/432/EEC. In several cases, the certified animals were not permanently and properly isolated from the rest of the herd. In addition, during the visit to a PD, the OVs confirmed that at local markets, certified cattle were in close contact with non-tested animals Tuberculosis The CCA stated that where the TB test is carried out, all the bovine animals above one month of age must be tested. A comparative test (bovine and avian tuberculin test) is systematically performed. In 2005, 9,417 cattle were tested for tuberculosis and 1,437 (15%) of them reacted positive. In Thrace region, where the testing was performed to obtain the free status, 19% of the tested animals reacted positive. The TB test is performed on pregnant cows during the period between 15 days before and after delivery. The comparative TB test is inconclusive when the difference of the skin-fold thickening of the bovine test reaction is from 3 to 4 mm greater than the avian test reaction, contrary to Annex B, point of Council Directive 64/432/EEC (from 1 to 4 mm). Dairy cattle are not tested annually in order to ensure that milk supply to the dairies originates from officially free herds, as laid down in EU and in national legislation. According to the procedure for approval of dairy farms for export to the EU dairy cattle on these farms should be tested. There was an increase of human cases in 2005 (18,789 cases) compared to the data for 2004 (17,605 cases) Brucellosis In 2005, 8,998 cattle were tested for brucellosis and 778 (8.6%) tested positive for the disease. In Thrace region, where the testing was performed to obtain the free status, less than 1% of the tested animals reacted positive. In 2005, 992 abortions had been notified and 342 were confirmed to be caused by Brucella abortus. 12

13 Since 1999, a vaccination programme has been implemented to limit the spread of the disease. The strain19 vaccine is used for cattle and rev 1 vaccine against Brucella melitensis. The vaccination of adult animals is permitted by national legislation and was practiced at the beginning of the programme. In two provinces visited, the CAs stated that female calves were vaccinated up to the age of 8 months, contrary to Annex A II Point 4(i) of Council Directive 64/432/EEC which provides for the vaccination before 6 months of age. According to national legislation, non vaccinated cattle show a positive reaction when the result of the Sero-Agglutination Test (SAT) is above 40 UI/ml or a Complement Fixation Test (CFT) above 50 UI/m,l contrary to Annex C points and of Council Directive 64/432/EEC, which provides for SAT, above 30 UI/ml and for CFT above 20 UI/ml. Ring tests on milk were not performed. Dairy cattle are not tested annually in order to ensure that milk supply to the dairies originates from officially free herds, contrary to the requirements laid down in EU and in national legislation. According to the procedure for approval of dairy farms for export to the EU dairy cattle on these farms should be tested. In one sheep farm, of 30 females out of a flock of 150 sheep, only 2 were tested Foot and Mouth Disease From 1 January to 4 July 2006, around 1,079 outbreaks have been reported from the different provinces. In order to limit the spread of the disease, vaccination of all cattle above 4 months of age has been carried out twice per year since In 2006 a vaccine composed of the strains O1, Asia1 and A22 is being used. Vaccination of at least 80% of the herds in each province is compulsory. Vaccination is a pre-condition to obtain the veterinary health certificate needed to move an animal outside the district. In the case of an outbreak, the restriction zone generally covers one village, unless there are cases in several villages. According to the CCA, an outbreak in Thrace region results in movement restrictions in all provinces of Thrace. Depending on the PD, the percentage of herds vaccinated varied from 24% to 100% in In Thrace region, when an outbreak is declared, the sick animals are slaughtered and the healthy animals are vaccinated. However, in Anatolia, where the disease is endemic, the sick animals are not systematically killed but can be treated and the healthy animals of the same herd are vaccinated. 7 In their response to the draft report the Turkish Authorities noted that the controls on the holding in question had not been performed to determine if the herd was free of Brucella melitensis. 13

14 In several outbreaks during 2006, the vaccination of contact animals was not completed Rinderpest Turkey has been recognised by OIE as officially free of rinderpest since 21 May No sero-surveillance programme for cattle is in place Application of hygiene rules on dairy holdings and official controls In addition to the certification as free of TB and brucellosis, the dairy farms that supply their milk production to dairies willing to export to the EU must obtain an approval. The instruction issued in May 2006 comprises a check list to be used for the evaluation. This check list covers the hygiene of the milking process, animal welfare, nutrition and the verification of the records regarding animal movements and administration of medicines. The CCA stated that so far only one dairy farm in Turkey had obtained this approval. During the visit to the approved farm, the mission team noticed that free status had been granted immediately after the first negative Brucella test, contrary to the requirements of Annex A to Council Directive 64/432/EEC. The PDs and the milk industries do not have the possibility to verify which dairy farm is approved, as there is no central information system in place. In one case, the OV of the DD stated that for his own territory, at least 3 dairy farms had already obtained the approval and could sell their production to milk processing establishments exporting to the EU Application of hygiene rules at milk-processing establishments and official controls General structure and hygiene requirements Seven of the eight milk-processing establishments visited were in general in compliance with EU requirements regarding structure, lay-out and equipment. One establishment was not in compliance with the provisions of Regulation (EC) No 852/2004, in particular, the following deficiencies were noted: ceiling and overhead structures dirty and not easy to clean in rooms where unprotected products is handled, floor damaged, wall to floor junctions not clean, not easy to clean, equipment poorly maintained (kept together with ropes, all recently painted over with silver paint), entrance to production areas and wash basins via outside, dilapidated rooms and roofs, storage facility for packaging material dark, not pest and dust proof. Packaging material kept together with obsolete material. In some of the other establishments condensation above exposed product was noted and several doors were not pest-proof. Hygiene of operations and general hygiene was adequate in production rooms but frequently not adequate in adjacent rooms or the vicinity of three establishments: 14

15 area for recycling of milk was untidy, packaging material and unused equipment was stored, re-bagging of milk powder in dirty storage area, dry stores dirty and dusty, milk powders and proteins stored in moist areas or cold store with development of moulds, heavily moulded cheese from own production retained for processing (initially hidden away by use of a customs seal), equipment, gratings and drains not clean Raw material Raw milk is usually collected directly from the holdings, from milk collection points, co-operatives or purchased from traders. The number of individual producers supplying milk-processing establishments visited can be up to several tens of thousands located in numerous provinces. The total volume of supply with EU-compliant milk, meeting the criteria for animal health status, PC and SCC is currently limited as the only approved holding in Turkey which can supply about 4tn/day. The establishments had not, in all cases, specified in writing which holdings they were planning to use as suppliers of EU compliant milk. Supplies of milk-based ingredients (e.g. milk powder, butter, milk protein) partially derived from establishments in Turkey or from non EU-eligible countries (e.g. Brazil) or the certificate with the imported consignment, did not specify compliance with EU requirements Own check programmes In seven of the eight establishments visited HACCP based procedures were in place. These had been designed for compliance with national provisions. Checks on raw milk to establish compliance with criteria for PC and SCC as well as checks for the absence of antibiotic residues were in place. The flow charts did not identify all the points critical to the production of milkbased products for the EU as critical control points (CCP) or control points. In processes where single pasteurisation was applied, acidification below ph 6, in particular during cheese production, was never identified as control point. Own checks for raw milk criteria were usually not in compliance with EU provisions as regards place of testing, frequency of testing and calculation of the results. Frequently, bulk milk was tested instead of farm milk. Rapid methods or automated methods were used for the determination of the SCC and substantial differences between results obtained by the establishments and the CA were encountered. In two cases results differed by factors of 10 and 50 (the results of the own checks being more favourable). Water from own deep wells was regularly tested and results were, in general, good. 15

16 Treatment requirements The main products proposed for export to the EU were ice-cream, cheese (fresh cheese, tulum, kashkaval or feta type), dessert, yoghurt, pasteurised milk and UHT milk. According to the establishments all products undergo heat-treatment at some stage. In one establishment the management stated that the milk for tulum production underwent pasteurisation, but records of the pasteurisation were not available. In three establishments production processes for ice cream, fresh cheese, yoghurt and dessert involved double heat-treatment. The process for pasteurised milk consisted of one heat-treatment of 90ºC (+/- 2ºC) for 30 seconds in one establishment. Milk for kashkaval cheese production is usually heat-treated and the cheese curd is cooked afterwards to up to 61ºC. At the end of the ripening the ph of the cheese is about 5. Milk for feta-type cheese was pasteurised once (at a temperature of 63ºC for 10 minutes) and ripened to a ph below 5 in one establishment Traceability systems In one establishment several pallets of unidentified cheeses 8 in tins were stored. In a cold-store of the same establishment, which was allegedly closed by customs, but later opened by the establishment, unidentified product and raw material was stored. A second establishment stored white cheese in wrongly labelled tins and the production code used for traceability was incorrect. Otherwise, traceability systems, when checked were reliable and could demonstrate details of the production process, production lines used and origin of the raw material. Another establishment kept several tonnes of milk powder in unlabelled own bags. Some bags of milk powder with the company s own label were present. The bags all carried a production code and the traceability demonstrated that they were re-bagging imported milk powder (from Israel) into their own bags either for processing or for sale. It was established that about 450 tonnes of imported milkpowder had been re-bagged in In their response to the draft report the Turkish Authorities noted that the tins contained cream. 16

17 Labelling One establishment used a mark identical to an oval EU identification mark, presenting its approval number (which was withdrawn in 2001) and the letters EEC Official controls Regular official controls were carried out at the milk-processing establishments visited. The minimum frequency of two inspections per year was respected and often exceeded. The approval procedure was followed as per instruction of May One establishment proposed for the FVO visit was deemed non-compliant by the CA and authorisation for EU export was not recommended. Regular official controls consisted of inspections, official sampling and visits for other purposes e.g. for certification. Checklists as laid down in national legislation and the procedure for EU export approval were used. The scope of the inspection visits was not clearly described in all cases. Official sampling of raw milk was either entirely absent or had only started recently in the framework of national legislation. Substantial discrepancies between official results and own-check results had not yet been addressed. Official sampling of final product for microbiological analyses varied from total absence to a regular sampling schedule. Provisions in national legislation (e.g. setting deadlines for rectification of shortcomings) were occasionally not enforced. The provisions of national legislation, in particular regarding the animal health status of holdings delivering milk to milk-processing establishments or the compliance with PC ( /ml) and SCC ( /ml) were not enforced. Threshold values for PC and SCC, which were applicable during a five-year transition period were not enforced. Specific requirements related to the production for the EU such as treatment according to Commission Decision 2004/438/EC were not subject to the approval inspection and conditions were not verified for the products proposed for EU export. Therefore products such as pasteurised milk were proposed for export to the EU. Other processes had not been verified (e.g. acidification and effectiveness of heat-treatment). Fraudulent practices (re-bagging of milk-powder), use of raw material unsuitable for human consumption and the use of the EU identification mark had not been addressed. 9 In their response to the draft report the Turkish Authorities noted that the establishment in question had been granted a pre-approval number, which had not been withdrawn. 17

18 5.6. Application of hygiene rules at establishments treating animal casings and official controls A total of 6 casing establishments were visited by the mission team, 5 of which are already included in the list according to Commission Decision 1999/120/EC and one was recently proposed by the CCA to the Commission services as compliant General structure and hygiene requirements All establishments visited, except one, were found in satisfactory conditions. However, some shortcomings were noted: doors and ventilation openings not properly pest proof, storage areas for salt and additives not suitably located (in transit rooms), inadequate ventilation leading to condensation. In one establishment more serious problems were detected: unacceptable layout for incoming raw products, packaging materials, salt and additives through a technical room with heating equipment, unsatisfactory layout for final processed products, dispatched directly through the working area, insufficient cleaning with presence of mould in working areas, common storage of salt, additives, cleaning agents and disinfectants without sufficient separation, presence of poison baits for pest control in working areas and storage rooms, storage of dried sheep rumens remaining from a consignment of early 2005, together with chilled salted casings. In this establishment the CA was requested by the mission team to re-evaluate the plant Origin of raw material Most of the raw cleaned and salted casings seen in the establishments visited originated from establishments (and countries) not listed in the Annex to Commission Decision 1999/120/EC: United Arab Emirates, Moldova, Russia (Dagestan), Azerbaijan, Kazakhstan, North Cyprus, Tadzhikistan, Kyrgyzstan, Qatar. From January to June 2006 these imports represented a total of 866 tonnes. Statistics provided by CCA showed that some casings could have been exported unprocessed to EU Member States In their response to the draft report the Turkish Authorities noted that the existing export certificate for exports to the EU requires processing. 18

19 Own-check programmes In one of the establishments visited neither a HACCP-based plan nor SOPs were in place. The other plants had developed procedures, although in some cases these were not completed: presence of flow-charts not up to date, some production processes were not described (e.g. tubing and packing in brine), as well as procedures for preparation of brine used as accompanying liquid were not described, absence of a plan for water sampling, although sampling had been carried out at some points of use Traceability systems Traceability systems were in place in all establishments visited, except one, mainly working on the basis of batches established by country of origin. They were not always fully reliable: in some cases it was not possible to link incoming raw materials to the final processed product. Problems were also detected in case of processing of a single batch over several production days. In one establishment, casings coming from third countries were not identified at all, with consequences on reliability of certification of final products dispatched to EU Member States Official controls Minimum frequencies of official controls (twice a year) were respected in all establishments visited, and more frequent visits are carried out for certification purposes. New check-lists, derived from implementation of the national Red Meat Regulation in the casing sector, and for checking of compliance with requirements of Regulation (EC) No 853/2004, were seldom used during official inspections. In one case, during inspection of an establishment in view of its possible listing for EU export, the CA used such a check-list but totally failed to identify the serious shortcomings detected by the mission team (among others, lack of traceability and absence of HACCP-based procedures). In the remaining establishments, reports in different format were seen, identifying the majority of the non-compliances. However, no defined deadlines have been fixed for their correction. 11 Follow-up was carried out only at the following planned visit. 11 In their response to the draft report the Turkish Authorities noted that Turkish legislation specifies the maximum duration for correction of technical and hygiene deficiencies. 19

20 Since 2005 the national Red Meat Regulation, requiring a working licence for all establishments also applies to casings plants: certain casings establishments lacking documentation were deleted from the EU list in One establishment visited has been proposed for EU re-listing once such a licence has been granted, although it was not in compliance with EU requirements Official laboratories Animal health controls According to the CCA eight Veterinary Control and Research Institute Laboratories and the Foot and Mouth Disease Institute Laboratory (under the GDPC) are involved in animal health controls. National Reference Laboratories (NRL) are nominated for brucellosis, bovine brucellosis and FMD. One laboratory is accredited according to ISO standard Public health controls According to the CCA 39 Provincial Control Laboratories and the Food Control and Central Research Institute laboratory (under the GDPC) are involved in official controls of foodstuffs. The Ankara Provincial Control Laboratory Directorate is the nominated NRL for milk. Accreditation has been achieved in six laboratories and is in progress in a further six Provincial Control Laboratories. Accreditation is carried out according to ISO standard One of the Provincial Control Laboratories in the process of accreditation was visited as it was responsible for the analysis of official samples from three of the eight proposed milk-processing establishments. Of approximately 20 microbiological analyses performed on milk and milk-based products only two methods are proposed for accreditation. The other analyses are carried out on the basis of documented procedures. The Peroxidase test is not offered by the official laboratory. Deviation from the documented method description was observed (incubation for Salmonella was at 35ºC instead of the documented 37ºC). For several microbiological analyses no positive controls were held (e.g. Salmonella spp., Listeria monocytogenes, Staph. aureus). The screening test system for detection of antibiotics was operated without a positive control. The CA had never submitted samples of heat treated milk or heat-treated milkbased products for phosphatase activity testing. 12 In their response to the draft report the Turkish Authorities noted that accreditation has been achieved in eight laboratories and in the other six Provincial Control Laboratories efforts are being continued. 20

21 5.8. Import controls over animal products Import controls for imports of casings and milk-based products are carried out on the basis of the national rules: the country of origin is not listed on a negative list, which is based on animal health information of the World Organisation for Animal Health, the import of the commodity is authorised (lists of commodities not authorised are held) and the consignment complies with the provisions of the Turkish Food Codex. In effect, imports of cleaned and salted casings from countries such as United Arab Emirates, Moldova, Russia, Azerbaijan, Kazakhstan, North Cyprus, Tadzhikistan, Kyrgyzstan and Qatar are authorised and performed. Milk-based products may be imported from the EU and a wide range of third countries, e.g. Brazil, India or Ukraine, which are not listed for exports to the EU. However, imports of milk-based products from some Member States of the EU are banned e.g. certain milk-based products from sheep milk from Belgium, Finland, France, Sweden, Portugal, Slovakia or Slovenia because of scrapie. The practice in relation to export of casings to the EU does not imply that the reexported casings may only come from EU-listed establishments (and countries) as per Commission Decision 1999/120/EC and the information contained in the incoming certificate is not required to be in line with the requirements laid down in the certificates issued to the EU. The procedure in relation to export of milk and milk-based products to the EU does not specify that the information contained in the incoming certificate should reflect the requirements laid down in the certificates issued to the EU Official certification The CCA for issuing certificates for export is the General Directorate of Protection and Control (GDPC). On the spot, this power is split between two organisations: the PD and Quarantine Stations (QS). 13 The QS are situated at the state borders close to customs border inspection posts in selected ports and road border crossing posts. There are currently five QS in the country. The Quarantine Station in Istanbul was closed in December It was explained to the mission team that in locations with international airports, working as customs gates, the QS duties in relation to certification were transferred to the PD. 13 In their response to the draft report the Turkish Authorities noted that with regard to dairy products the authority is assigned to the Provincial Directorate. 21

22 Models of certificates and list of certifying officers The mission team was initially informed that all certificates are pre-printed centrally under the CCA control. This was found not to be the case. Currently, there are three sources of certificate forms: the central printing office, producing certificates with pre-printed serial numbers: this office currently does not produce any certificate forms for casings and dairy products intended for the EU. the MoA Internet web site: there is a model of certificate for casings in Turkish and English, not updated, other sources: for example, certificates for casings in German and Italian (copies of relevant pages from the Official Journal). The list of certifying officers presented in the PD of Kirklareli consisted of two documents, one containing several names, and kept in one file, and the second containing only one name, and kept in a separate file. It was explained that the files completed each other, but no indication related to this fact was found in the documents. The mission team has also noted that in Istanbul, the certificates are signed by persons who are not on the list of certifying officers provided by the CCA Certification procedures The same consignment may be subject to different procedures depending on the means of shipment: Casings from an establishment in Adana may be send to the port of Mersin with a domestic movement permit. At the port the QS issues the export certificate. If the casings are sent from the airport in Adana, the export certificate is delivered on the spot by the PD of origin. Milk products from establishments in Kilklareli region are exported with certificates issued on the spot by the PD of origin. However, if the consignment is bought by a third party, it may be taken to any destination within the country, without any domestic movement permit. Later on, the export certificate may be issued by any QS or PD General principles of certification In a number of cases, the information contained in the certificates for casings imported into Turkey was not in compliance with Community requirements. For example, the certificates from Uzbekistan and Kyrgyzstan did not contain any reference to Regulation (EC) No 999/2001 concerning specified risk material. These casings enter the production chain in establishments exporting to the EU. It was found that in one PD the certificates were issued without any checks, by the certifying officer, of the compliance of the consignment with the certificate. In a number of cases the internal movement documents did not contain the information required by the certifying officers in the QS to issue export certificates for commodities exported to the EU (casings, fishery products). 14 In their response to the draft report the Turkish Authorities noted that Quarantine Stations are not authorised in importation or exportation of processed milk and milk products. 22

23 considerable number of certificates seen were not completed correctly. In particular the following deficiencies were noted: sections to be deleted were not deleted, providing an ambiguous message. When two certificates in different languages were issued for the same consignment, the same section could be deleted in one linguistic version, but not in another one, not all relevant sections were completed (e.g. address, destination, origin, products), the certificates were drawn up in a language which is not the language of the certifying country or a language the certifying officer is supposed to understand, for one consignment, two or more originals were issued, in one case five originals were issued, all containing original signature and stamp, some originals were not fitted with security stickers, or holograms, issuing collective certificates for export and re-export of products of different origin (Turkish and products imported from different countries of the EU) without any supporting documents Official controls on certificates and security labels In the offices visited the certifying officers had no register of certificates and security labels used. There is no system for reporting to the CCA the specific use of security stickers (which sticker used for which purpose) nor for the use of certificates. The responsibility for this remains with the Director of PD. Only in one case could the CCA show a comprehensive report indicating specific use of security labels. This, however, was produced on the PD concerned, on his own initiative. The CCA does not carry out official controls or audits of the certification procedures in the field Certificates alleged to be fraudulent The mission team found and presented to the CCA for comment two certificates for dairy products exported to the EU. These certificates had been issued by staff of a QS. In one case, the products came from a non-approved establishment. In the second case, the establishment was approved but the CCA had committed itself before the date of issuing, not to issue any certificates for dairy products intended for the EU. In addition, the QS issuing the certificate was closed down by the date of certification and the name of the certifying officer was not on the official list of such officers. The CCA admitted that these certificates should not have been issued but did not provide any explanations on the circumstances on this had happened. 23