Dr David Jukes, The University of Reading, UK

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Food Law News - UK - 2016

FSA Enforcement Letter (ENF/E/16/050), 8 September 2016

ENFORCMENT - Consultation on Risk Based Primary Production Food Hygiene Inspections

A copy of the consultation letter including the Annex is available on this site.  See: Risk Based Enforcement Letter


Following an EC audit, the FSA is developing a risk profile for enforcement authorities to deliver a prioritised risk based and proportionate primary production official controls inspection programme. The FSA would like to invite comments from enforcement delivery authorities on factors affecting primary production official controls inspections in their regions.

The text of the letter is the following:

A European Commission audit (2015-7456) evaluating the system of official controls relating to microbial safety of primary production of food of non-animal origin (FNAO) in the UK was published in April 2016. The link to the report is at:

One of the recommendations was to ensure that official controls adequately take into account identified risks to food safety. In response to this, FSA England, Northern Ireland and Wales are working jointly to develop a risk profile highlighting the most significant risks associated with FNAO primary production. This will include fresh produce which is ready to eat, but will not include sprouting seeds as these establishments have already been prioritised for inspection and approval.

There have been a number of high profile outbreaks over the last few years attributable to the consumption of fresh produce. For example most recently in June 2016 in the UK, an outbreak with 161 cases confirmed (including 2 deaths where the infection was a contributory factor) from a rare strain of E. coli associated with eating mixed salad leaves.

It is hoped that the risk profile will assist enforcement authorities to deliver a prioritised, risk based and proportionate inspection programme of food hygiene official controls at primary production, to be implemented from April 2017. The risk profile will need to be considered alongside the priorities for feed hygiene on–farm to determine the overall inspection programme for these premises. The prioritisation of food hygiene controls at primary production level will enable increased consumer protection. As enforcement authorities integrate the risk profile and inspection programmes for food hygiene with those for other primary production controls they will achieve efficiencies while limiting inspection burdens on businesses.

In recognition of the experience and knowledge of our local delivery enforcement authorities, we are writing to consult you for your opinions on the factors and issues in the attached Annex.

I would appreciate if responses could be returned to the representative for your country by 7th October 2016. Following robust consultation it is our intention to publish the enforcement priorities based on the risk profile as part of our National Feed Enforcement Priorities.

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