Philippe Houdart crisis prevention and crisis management unit head of unit Federal Agency for the Safety of the Food Chain FASFC CONTINGENCY PLANNING IN THE FRAMEWORK OF THE NEW REGULATION ON OFFICIAL FOOD AND FEED CONTROLS a Belgian perspective

New Regulation, chapter IV, stipulates: “Member States shall draw up operational contingency plans setting out measures to be implemented without delay when food or feed is found to pose a serious risk to humans or animals either directly or through the environment” Plans shall specify: - administrative authorities - powers and responsibilities - channels/procedures for sharing information

At first glance easy to comply with - Belgian control on the whole food chain (farm to consumer) is responsibility of a single body, the FASFC, with clear 2-level control structure peace time crisis situation national level:central services  central crisis centre local level: provincial control units  local crisis centres - sufficient legal powers and financial provisions comply with demands - contingency plans and emergency procedures exist - ample experience in dealing with crisis situations

However - experience is mainly based on eradicating animal diseases (list A of OIE) - food and feed safety is more related with chemical residues and contaminants, biological hazards, radionuclear contamination scope is different

Differences Animal diseases - limited number of hazards (15 OIE list A diseases) - limited number of hosts (farm animals) - sufficient knowledge available and generally well known Food and feed crisis - multitude of hazards with wide range of types - multitude of “hosts”, matrices, recipients and products - less knowledge available and less known

Animal diseases - primary production = beginning of food chain with little impact on consecutive stages and no human health risk - early detection through clear and typical clinical picture - all or nothing: detection = outbreak Food and feed crisis - can happen at every stage of production and distribution process with further impact in chain and human health risk - detection = lab finding, often not related to initial stages - grey areas: forbidden substances, MRL values, action limits, …

Animal diseases - limited number of (reference) labs - relatively easy and cheap tests - tracing is relatively simple and based on own data banks with relevant data Food and feed crisis - several labs, each specialised in group of substances - difficult and expensive testing (ppb level) - tracing is based on (often fragmented) information from industry

Animal diseases - contagious agent with “focal” spread - controlled through zonal approach - clear straightforward strategy based on culling, vaccination, movement control Food and feed crisis - non contagious agent with spread over a wider area and longer distances (internat.) - no real problem area: zonal approach is useless - case bound strategy, depending on substance, matrix, level of contamination, species, …

A few practical consequences and possible remedies - grey zonewhen can we speak of a crisis? (time pressure, media coverage)  action limits are required  important role for EFSA, SANCO  the fact that action limit is exceeded does not immediately imply crisis situation and vice versa extend of problem, public perception are important

- multitude of substances and matrices, lack of scientific knowledge health risk is not always clear case bound strategy, different according to situation  measures taken appropriate?  right strategy for right problem?  culling, slaughter in case animals are involved?  important role for EFSA, SANCO

- late detection = possibly widespread and great impact early detection is of utmost importance  appropriate control plan is needed that covers as much as possible critical control points for range of substances as wide as possible at intervals as short as possible  compulsory notification of non conform results by all labs and industry (ex. obligatory food safety systems as HACPP)  good administration and follow up of results is needed (ex. Belgian Consum program)

- possible widespread dispersion, non-zonal approach 2-level model in crisis structure is less effective  no delimited problem area where establishment of local crisis centre is useful  crisis will have to be managed more from within central crisis centre with multiple control units involved in the field  clearly defined communication channels and procedures are necessary to exchange information with field workers

- tracing role and involvement of industry is great  good labelling of products is essential  good administrative follow of dispatching should be standard practice  recall procedures must be developed

- laboratory analysis insufficient capacity for sampling load  clear inventory of laboratories, expertise and capacity must be made beforehand capacity often spread over different laboratories; dispatching samples is difficult logistic operation; different laboratories = different techniques  clear procedures in that respect with collection and distribution points are needed

lack of knowledge regarding sampling/analysis  not always clear which samples must be taken  not always clear which substance have to be tested to get the best result (ex. dioxins PCB)  important role for EFSA and SANCO

Contingency plans - base = general contingency plan supplemented with technical/operational manuals - general contingency plan is similar for different emergency situations  legal powers  financial provisions  description of chain of command  communication channels  refers to specific technical/operational manuals according to type of crisis (action limits) meets strictly spoken the demands of Regulation

- operational/technical manual is specific for residues, and contaminants gives detailed procedures for  immediate action after notification  general control strategy and SOP  laboratories  SOP for sampling, dispatching  specific communication requirements fills in the demands of Regulation in a more practical way

Training - essential to maintain vigilance and to test SOP and preparedness of your crisis structure  is difficult to organise specifically for feed and food type crisis  field simulations are limited to certain fields (ex. SOP for collecting/dispatching samples) - must be organised and conducted both by  authorities  industry (response to crisis situation, tracing, recall procedures, …) can be organised by external partner

Conclusion - prevention is better than curing early detection is of utmost importance  good control plan based on sound risk analysis  clear action limits  (obligatory) cooperation by industry - flexible crisis structure and collaborators that can handle both animal health crisis and food/feed crisis - preparedness within the organization with regard to  maintaining practical knowledge  laboratories  sampling procedures