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Ir. Tetty Helfery Sihombing, MP. Director of Food Inspection and Certification
NADFC
FOOD RECALL AND TRACEABILITY
IN ORDER TO ENSURE FOOD SAFETY
• The primary responsibility for ensuring the right to adequate food and the fundamental right to freedom from hunger rests with national governments.
• Food quality and safety are important aspects of the right to food. Food safety implies the absence or safe levels of contaminants, bacteria, naturally occurring toxins or any other substance that may make food injurious to health.
“Everyone has the right to a standard of living adequate for the
health and well-being of himself and of his family, including food, clothing, housing and medical care ...” (Universal Declaration of
Human Right, article 25)
Source: http://www.fao.org/focus/e/rightfood/right2.htm
ISSUES RELATED TO FOOD SAFETY IN 21TH CENTURY
Various types of food products in the market
Food Product Development
Global Economical Crisis consumer needs cheaper foods
Lower consumer trust on food product
Increased demands for healthy, safe & environmentally friendly food
Trend changing on food expense
traceability - lack of food safety control from manufacturer and supplier, as well as coordination.
NEED EFECTIVE AND STRONG FOOD SAFETY CONTROL SYSTEM
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EFECTIVE AND STRONG FOOD
SAFETY CONTROL SYSTEM
Protect community health from potential risk of food hazards
Ensuring Food safety and quality both exported and imported food products (as trade competitiveness)
Effective national food control systems are essential to protect the health and safety of domestic consumers. They are also critical in enabling countries to assure the safety and quality of their
foods entering international trade and to ensure that imported foods conform to national requirements. The new global environment for food trade places considerable obligations on both importing and exporting countries to strengthen their food control systems and to implement and
enforce risk-based food control strategies.
Food Safety Control Challenges in Southeast Asia Region
Source: Othman NM. Food safety in Southeast Asia: challenges facing the region. Asian J. Agric. Dev. 2007;4(2):83–92 (accessed: http://ageconsearch.umn.edu/bitstream/166014/2/AJAD_2007_4_2_6Othman.pdf)
Establish and update food regulations, as well as regulation gapsidentification
Management of food safety control development of a risk-based control system by applying risk analysis principles
Quality of food inspection needs competent food inspector and preventive inspection procedures
Inadequate laboratory infrastructure
Effectively and sustainably information sharing among stakeholders
The framework of regional and international trade (TBT dan SPS agreements
Compliance of food industries on regulations and standards
Food safety Control
Challenges in ASEAN
Formal establishment of ASEAN Economic Challenges
(2015)
1ST pillar of AEC : Single market and production base (Free
flow of goods, services, investment, and skilled labour
whitin the region)
Asean Population : 3rd largest in the world in 2014 (622
million)
Total Trade 2007-2014 increase by nearly US 1 T intra-ASEAN trade comprises the largest share of ASEAN’s
total trade by partner
ATIGA : Food safety becomes an important issue in food
trading, including those are related to its regulation
“Food recall is a fundamental tool in the management of risks in response to food
safety events and emergencies”
Competent Authority responsible to develop guidance on the establishment,
implementation and maintenance of food recall plans and traceability
ASEAN Member States should establish national food recall
procedure
Principle 8 : Reliable Traceability System
REGULATIONS RELATED TO FOOD RECALL AND TRACIBILITY
Law No. 8/1999 on Consumer Protections
Law No. 36/ 2009 on Health
Law No. 18/2012 on Food
Government Regulation No.
69/1999 on Food Labelling and
Advertisement
Government Regulation No.
28/2004 on Food Safety, Quality and
Nutrition
Other technical regulations
Food recall is stated in all articles related to administrative sanctions against violations related to food safety and quality, as well as other provisions.
FOOD RECALL ON LAW NO. 18/2012 ON FOOD
RECALL AND/ OR DESTRUCTION
Government Regulation No. 28/2004 on Food Safety, Quality and Nutrition
Article 47(1) If, based on the results of the investigations as contemplated in Article
45 paragraph (3) and/or the results of the investigations as contemplated in Article 46, there are any violations, the Governor, Regent/Mayor of the Head of the Agency shall be authorized to take administrative measures.
(2) The administrative measures as contemplated in paragraph (1) shall include: a. written warning; b. prohibition from distribution temporarily and/or instruction to
withdraw the food products from distribution; c. food destruction, if it is proven to risk human health and lives; d. temporary production halt; e. imposition of penalty no greater than Rp.50,000,000 (fifty million
rupiahs); and/or f. revocation of production licenses, business licenses, registration
approvals or home industry food production certificates.
RECALL AND/ OR DESTRUCTIONGovernment Regulation No. 28/2004 on
Food Safety, Quality and Nutrition
Article 481) Withdrawal and/or destruction of the food as contemplated
in Article 47 shall be implemented by any person who produces or imports food into Indonesian territories and in accordance with the food withdrawal and destruction guidelines.
2) Any party involved in food distribution shall assist in the food withdrawal and/or destruction as contemplated in paragraph (1).
3) The food withdrawal and/or destruction as contemplated in paragraph (1) shall, in respect of fresh food, be implemented at the instruction of the Governor, Regent/Mayor in accordance with their respective duties and authority.
4) The food withdrawal and/or destruction as contemplated in paragraph (1) shall, in respect of processed food, be implemented at the instruction of the Head of the Agency.
Good Manufacturing Practices Guideline (Ministry of Industry No. 75/M-IND/PER/7/2010)
Product recall is a process to withdraw products frommarket, in case the products suspected to have potentiallycause of food poisoning or other health issues.
Recall is taken if the product is suspected to have potentially cause of food poisoning or other health issues.
The process of recall should be paid attention
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DEFINITION OF FOOD RECALL
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• “The action to remove food from the market at any stage of the food chain, including that possessed by consumers”
WHO:
• ”Food recall is an action taken by a company to remove unsafe food products from the market”.
Canada:
• “A recall is an action taken to remove from distribution, sale and consumption, food which may pose a health and safety risk to consumers.”
ANZFA:
• a firm's removal or correction of a distributed product which involves a minor violation that would not be subject to legal action by the FDA or which involves no violation, e.g., normal stock rotation practices, routine equipment adjustments and repairs, etc.
Market withdrawal
• a firm's removal or correction of a marketed product that the FDA considers to be in violation of the laws it administers and against which the agency would initiate legal action, e.g., seizure. Recall does not include a market withdrawal or a stock recovery.
Recall
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Definisi Penarikan PanganDEFINITION OF FOOD RECALL BY FDA
THE SUBSTANDARD PRODUCT SHOULD BE RECALLED?
To protect people from substandard food that could be harm and / or endanger health, such as
food contaminated by microbiological contamination, chemical contamination, and / or
physical contamination; mislabeling related to unstated raw materials or food additives used;
other mislabeling issues, packaging damage; and other indications of nonconformity.
“Everyone who produce, import food products to Indonesia region”
FOOD CONTROL SYSTEM BY NADFC
• GMP, GDP evaluation• Evaluation of food safety and quality
as pre requisite to get registration number.
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• product imports control through publishing import recommendation letter
• Publishing export recommendation letter, (including certificate of health, GMP certificate, Hygiene and Sanitation Certificate, free sale recommendation, as required)
• Product specifications related to Food Safety and Quality
• Label monitoring• Routine manufactory Inspection• Mobile laboratory• Sampling and laboratory analysis• Intensification of food distribution control• Increasing Community Awareness
through IEC, GN-WOMI• Law Enforcement
PRE MARKET EVALUATION POST MARKET VIGILANCE
• Food recall from market is basically done on theorders of the Head of the POM RI (mandatory recall)
• However, manufacturer, importers, or distributorscan initiate food recall as their responsibility toprotect public health (voluntary recall).
• The manufacturer, importer, or distributor shall toreport voluntary food recall to the NADFC
MANDATORY VS VOLUNTARY
RECALL CLASSIFICATION
For food that potentially have seriously illness and death. I.e, contain hazardous material, pathogen microbiological, physical contamination (glass, metal, plastic, etc
Recall dateline : 24 h public warning and 14 days of recall process
Class 1 For food product
that has issues related to label, substandard food additives used, packaging damage, etc
Recall dateline : 30 days of recall process
Class 2
For food product that has other infringement beside Recall type 1 and 2
Recall dateline : 60 days of recall process
Class 3
TRACEABILITY SYSTEM AS PRE-REQUISITE OF EVECTIVE
RECALL PROCESS
• Manufacturers, importers and distributors are mandatory to have an effective and documented food recall system.
• As a pre-requisite for effective food recall, every food manufacturer, importer, and distributor, must have a food traceability system.
• Food traceability is the ability to track, identify a product unit or lot / batch at all food process stages, storage and distribution.
• The organization shall establish and apply a traceability system that enables the identification of product lots and their relation to batches of raw materials, processing and delivery records.
• The traceability system shall be able to identify incoming material from the immediate suppliers and the initial distribution route of the end product.
• Traceability records shall be maintained for a defined period for system assessment to enable the handling of potentially unsafe products and in the event of product withdrawal. Records shall be in accordance with statutory and regulatory requirements and customer requirements and may, for example, be based on the end product lot identification.
ISO 22000:2005 (clause 7.9)
TRACEABILITY SYSTEMINTERNAL vs EXTERNAL
Raw material Food processing Finish products
external externalinternal
• WHO are the raw material suppliers?
• HOW much each raw material from each supplier?
• IDENTITY of each raw material
• IDENTITY of raw material used? (including batch / lot / production code, received date, expire date)
• Production records (process temperature, process time, machine line, weighing, products amount)
• Records of food safety and quality control, including laboratory analysis
• Storage record, Storage conditions, product Stock
• WHO is the distributor?
• Distribution record (including product amount)?
• IDENTITY of finished product of each distributor?
Good Traceability System is useful to identify the origin of contamination that may occur during the food
production process
Source : Surono, I.S, Sudibyo, A, Waspodo, P (2016), Pengantar Keamanan Pangan untukIndustri Pangan. DeePublish, Yogyakarta.
CASE OF FOOD TRADE INFRINGEMENT CASE OF FOOD TRADE INFRINGEMENT
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TERIMA KASIH
Direktorat Inspeksi dan Sertifikasi PanganDeputi Bidang Pengawasan Keamanan Pangan
dan Bahan BerbahayaBadan POM RI