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									EFTA SURVEILLANCE AUTHORITY
GOODS DIRECTORATE

Doc. No: 02-1053-D Ref. No: VET 604.400.003

FINAL REPORT FROM A MISSION CARRIED OUT BY THE EFTA SURVEILLANCE AUTHORITY TO NORWAY FROM 15 TO 19 OCTOBER 2001 FOR THE PURPOSE OF ASSESSING THE APPLICATION OF COUNCIL DIRECTIVE 91/495/EEC, COUNCIL DIRECTIVE 92/45/EEC, AND OTHER ACTS RELATING TO FARMED AND WILD GAME MEAT

Please note that comments from the Norwegian Authorities to factual errors have been included in bold, italic print in the body of the report. Comments providing additional information or expressing their view on particular issues are included as footnotes in bold, italic print.

_______________________________________________________________________________________________ Rue de Trèves 74, B-1040 Brussels, Tel: (+32 2) 286 18 11, Fax: (+32 2) 286 18 00 E-mail: registry@surv.efta.be Homepage: www.efta.int

Page 2 Contents 1 2 3 4 Introduction Objectives of the mission Legal basis for the mission Background 4.1 Reference to previous missions 4.2 Production and trade information 5 6 Legislation Main findings 6.1 The competent authorities 6.1.1 Organisation of SNT 6.1.2 Organisation of KNT 6.1.3 Co-ordination between SNT and KNT 6.1.4 The organisation of SDT 6.1.5 Independence and resources 6.1.6 Recruitment and training 6.1.7 Prioritisation of controls / Reporting procedures 6.2 Veterinary supervision of farmed game meat and wild meat establishments 6.2.1 Approval procedure and suspension / withdrawal of approval of establishments 6.2.2 Control in the establishment 6.2.2.1 Central level 6.2.2.2 Regional level 6.2.2.3 Local level 6.2.2.4 Ante-mortem and post-mortem inspection 6.2.2.5 Health marking 6.2.3 Trichinae control 6.2.4 Veterinary supervision of own-check systems and staff training programmes 6.3 Visit to farmed game meat and wild meat establishments 6.3.1 Structure and layout 6.3.2 Installation and equipment 6.3.3 Maintenance, cleaning and pest contro 6.3.4 Operational hygiene 6.3.5 Traceability 6.4 Certificates and trade documents 6.5 Residues 6.6 Zoonoses Page 5 5 6 6 6 6 7 8 8 9 9 9 9 9 10 10

11 12 12 13 13 13 13 14 15 15 15 15 16 16 16 16 16 17 17

Page 3 6.7 Animal identification 6.8 Animal welfare 18 18

6.9 Visit to a collection centre approved for the national market only ("local place") 18 7 Conclusions 7.1 The competent authority 18 18

7.2 Veterinary supervision of farmed game meat and wild game meat establishments 19 7.3 Visit to farmed game meat and wild game meat establishments 7.4 Certificates and trade documents 7.5 Residues 7.6 Zoonoses 7.7 Animal identification 7.8 Animal welfare 8 9 Recommendations to the competent authorities of Norway Addendum to the mission report

20 20 20 20 20 21 21 21

Page 4 1 Introduction

The mission to Norway took place from 15 to 19 October 2001. The mission team comprised one inspector from the EFTA Surveillance Authority1 and one inspector from the Food and Veterinary Office of the European Commission. An opening meeting was held on 15 October with the Central Competent Authority (CA), the Norwegian Food Control Authority (SNT). The Authority’s inspector confirmed the objectives of and the itinerary for the mission. The Norwegian representatives submitted additional information required for the satisfactory completion of the mission. The inspections during the mission took place in the presence of representatives from the responsible Regional Offices as defined by SNT and from the Local Food Control Authorities (KNT). In each establishment a summary of the observations made by the Authority during the visit was presented, on which the representatives from the CA as well the establishment had an opportunity to comment. A final meeting was held on 19 October 2001 at SNT in Oslo where the Authority’s inspector presented the main findings and conclusions of the mission to the SNT’s representatives and representatives from the Regions who took note of the findings.

2

Objectives of the mission

The objective of the mission was to assess the performance of the CA, with regard to controls over the production of farmed game meat (including reindeer) and wild game meat, in the framework of Council Directives 91/495/EEC as amended (farmed game meat) and 92/45/EEC as amended (wild game meat). This was the first mission to Norway in this sector. In pursuit of this objective, the following sites were visited (table 1): Competent Authority Central CA Regional Offices Local level Control site for wild game meat So called “Local Place” Number 1 2 3 Number 1 Comments The game meat was for the national market only. Comments Both slaughtering reindeer only Integrated in a slaughterhouse Integrated in the slaughterhouses Comments One Regional Office is part of SNT and the other one is subordinated (see 6.1.1)

Food processing establishments Slaughterhouse Cutting plants Temperature controlled stores

Number 2 1 2

1

Hereinafter called the Authority

Page 5 3 Legal basis for the missions

The legal basis for the mission is laid down in point 5.1.5 of Chapter I of Annex I to the EEA Agreement concerning public health and animal health problems affecting the production and placing on the market of rabbit meat and farmed game meat (Council Directive 91/495/EEC as amended) and in the Act referred to in point 5.1.6 of Chapter I of Annex I to that Agreement on public health and animal health problems relating to the killing of wild game meat and the placing on the market of wild game meat (Council Directive 92/45/EEC as amended) and the Act referred to in part 1.2.74 of Chapter I of Annex I to the Agreement, laying down certain detailed rules concerning on-the-spot checks carried out in the veterinary field by Commission experts in the Member States (Commission Decision 98/139/EC). In addition an assessment was made on the application of the requirements laid down in the act referred to in point 1.1.9 of Chapter I of Annex I to the EEA Agreement, laying down the certification of animals and animal products (Council Directive 96/93/EC).

4 4.1

Background for the mission Reference to previous mission

Several missions, covering various sectors, have been carried out in Norway since 1995. The most recently completed mission having relevance for this mission was on the control over production and placing on the market of fresh meat (Doc. No. 01-1795-D)2. In this report reference will be made to the final report from that mission, which is available on the Authority’s homepage. There have been no previous missions specifically covering the farmed game and wild game meat sector.

4.2

Production and trade information

In the answer to the Authority’s pre-mission questionnaire, SNT submitted the following statistical information for the year 2000: Farmed game meat in accordance with Council Directive 91/495/EEC as amended (table 2) Production The total farmed game meat production The farmed game meat production approved for the EEA market  Farmed reindeer  Rabbit The farmed game meat production for the national market Total import of farmed game meat Total export of farmed game meat Amount in tons 1150 360 359,6 0,318 740 85,8 0,072

2

Hereinafter referred to as the fresh meat report (Doc. No. 01-1795-D). The mission reports are available on the Authority’s homepage (www.efta.int).

Page 6 Wild game meat in accordance with Council Directive 92/45/EEC as amended (table 3) Production The totalamount of the wild game meat production The wild game meat production approved for the EEA market The wild game meat production for the national market Total import of wild game meat Total export of wild game meat Amount in tons 617 0 617 337 0

5

Legislation

Council Directive 91/495/EEC as amended and Council Directive 92/45/EEC as amended have been applicable to Norway since 1 January 1999 and Council Directive 96/93/EC has been applicable to Norway since 26 June 1999. In the answer to the pre-mission questionnaire the Authority was informed that Council Directive 91/495/EEC as amended concerning rabbit meat and farmed game meat has been transposed into Norwegian law as follows: - Lov om kjøttproduksjon (meat production act), LOV 1997-01-10. - Forskrifter om offentlig kjøttkontroll m.v. (Regulations on official meat control), FOR 1978-07-14 9629 and last amended 1998-12-23 1531. - Forskrift om hygiene move. i slakterier, nedskjæringsvirksomheter og kjøle- og fryselager for ferskt kjøtt (Regulations on the hygiene etc. in abattoirs, cutting plants, cold stores and freezer stores for fresh meat), FOR 1994-02-18 137 and last amended 1998-12-31 1493. - Forskrift om kjøttkontroll og frambud move. av ferskt kjøtt (Regulations on meat inspection and the placing on the market etc. of fresh meat), FOR 1994-04-25 320 and amended 1998-12-31 1498. - Forskrift om internkontroll for å oppfylle næringsmiddellovgivningen (Regulations on in-house control, based on risk analysis, to meet food law requirements), FOR 1994-12-15 1187 and amended 1997-11-12 1240. - Forskrift om hygiene og kontroll move. ved produksjon og frambud av ferskt fjørfekjøtt (Regulations on hygiene and control etc relating to the production and placing on the market of fresh poultry meat), FOR 1995-03-21 265 and amended 2001-05-25 522. - Forskrift om hygiene i slakterier move. for rein og oppdrettsvilt (Regulations on hygienic conditions in abattoirs etc for reindeer and farmed wild game), FOR 1995-08-28 776 and amended 1996-01-19 99. - Forskrift om hygiene og kontroll move. ved produksjon og frambud mv av kaninkjøtt og kjøtt av oppdrettsvilt (Regulations on the hygiene and control etc relating to the production and placing on the market of rabbit meat and farmed game meat), FOR 1996-02-02 132 and amended 1998-12-31 1495. - Forskrift om maksimumsgrenser for restmengder av veterinærpreparater i næringsmidler av animalsk opprinnelse (Regulations on maximum residue limits for veterinary drugs in foodstuffs of animal origin), FOR 1996-10-10 997 and amended by 2001-07-05 803. - Forskrift om kontrolltiltak for restmengder av visse stoffer i animalske næringsmidler, produksjonsdyr og fisk for å sikre helsemessig trygge næringsmidler (Regulations on control measures relating to amounts of residues of certain substances found in foods of animal origin, production animals and fish, aimed at ensuring food safety), FOR 2000-01-27 65 and amended 2001-03-28 358.

Page 7 Forskrift om delegering av myndighet på næringsmiddelområdet til det kommunale og interkommunale næringsmiddeltilsyn (Regulations on the delegation of powers concerning food control, transferred to the municipal and inter-municipal food control authorities), FOR 2000-02-17 251. Instruks for kaninkjøttkontroll (Instruction of the kontroll of rabbit meat) of 15.04.1996 No. 393. Instruks for trikinkontroll (Instruction for Trichinae control) adopted 8.11.1995 No. 962. Instruks for kjøttkontroll (Instruction for meat control) adopted 25.05.1994 No. 369.

-

In the answer to the pre-mission questionnaire the Authority was furthermore informed that Council Directive 92/45/EEC as amended concerning wild game meat has been transposed into Norwegian law as follows: - Lov om kjøttproduksjon (the basic act concerning meat production), LOV 1997-01- 10. - Forskrift om hygiene og kontroll move. ved produksjon og frambud av viltkjøtt (Regulations on the hygiene and control etc relating to the production and placing on the market of wild game meat), FOR 1996-02-02 133 and last amended 199812-31 1496. - Forskrift om maksimumsgrenser for restmengder av veterinærpreparater i næringsmidler av animalsk opprinnelse (Regulations on maximum residue limits for veterinary drugs in foodstuffs of animal origin), FOR 1996-10-10 997 and amended by 2001-07-05 803. - Forskrift om internkontroll for å oppfylle næringsmiddellovgivningen (Regulations on in-house control, based on risk analysis, to meet food law requirements), FOR 1994-12-15 1187 and amended 1997-11-12 1240. - Forskrift om delegering av myndighet på næringsmiddelområdet til det kommunale og interkommunale næringsmiddeltilsyn (Regulations on the delegation of powers concerning food control, transferred to the municipal and inter-municipal food control authorities), FOR 2000-02-17 251. - Instruks for viltkjøttkontroll (Instruction of the control of wild game meat) adopted 15.04.1996.

6 6.1

Main findings The competent authorities

The separation of competencies is described under point 6.1 in the fresh meat report. The Ministry of Agriculture has delegated the responsibility for the official control to be carried out with regard to the control of farmed game meat and wild game meat to the Norwegian Food Control Authority (Statens næringsmiddeltilsyn/SNT), although it remains financially and administratively responsible for it (Myndighetsoverføring til SNT move. of 29 April 1988 no. 312). SNT drafts regulations concerning the official food control. In turn, SNT has delegated certain responsibilities to 81 Local Food Control Authorities (kommunale næringsmiddeltilsyn/KNTs), which are, inter alia, responsible for the daily supervision, inspection and the control of farmed game meat and wild game meat. This is formalised in Regulation No. 251 of 17 February 2000 (Forskrift om delegering av myndighet på næringsmiddelområdet til det kommunale og interkommunale næringsmiddeltilsyn) on the delegation of powers concerning food control transferred to

Page 8 the municipal and inter-municipal food control authorities. SNT issues instructions and administrative provisions describing how the KNTs should perform the delegated tasks. Finally, it should be noted that the Norwegian Animal Health Authority (Statens dyrehelsetilsyn/SDT) is responsible for the supervision and control of live animals including the welfare and handling of live animals to the point of stunning before slaughter. In the slaughterhouses SDT has delegated this responsibility to the OV. 6.1.1 Organisation of SNT The organisation of SNT as described under point 6.1.1 in the fresh meat report is still valid with the exception that legal acts are no longer drawn up by the legal service of SNT but within its different departments. Since the autumn 2000 SNT has been testing different alternatives for regional offices (Regionskontor), which are, inter alia, responsible for inspections of establishments before they are approved by SNT. Two out of three regional offices are part of SNT, thus no delegation of power has taken place. However, SNT has delegated its power to one regional office, which is under the responsibility of the Fylkesman, who is supervising communal activities and employed by the State of Norway (Delegering av myndighet på næringsmiddelområdet til Fylkesman i Sør- Trøndelag no.955 of 19.09.2000). This region has thereby the same responsibilities with regard to the approval and supervision of food processing establishments as SNT. All establishments visited during this mission were under regional supervision. 6.1.2 Organisation of KNT The organisation of KNT is still as described under point 6.1.2 in the fresh meat report. The Official Veterinarians (OVs) present in the slaughterhouses are employed by KNT. 6.1.3 Co-ordination between SNT and KNT In order to ensure a harmonised control system of supervision throughout the country SNT organises annual seminars where both local and central authorities must be present. SNT has issued instructions and administrative provisions (Rundskriv) and supervisory guidelines (Tilsynsveilederen) in order to specify how certain tasks related to the supervision of approved establishments have to be performed. In addition SNT regularly audits the KNTs, as further illustrated under point 6.1.7 concerning reporting. Finally, the SNT can withdraw the delegation of competencies given to a KNT but the dismissal of an OV can only be done by the KNT, which the veterinarian is employed by.3 6.1.4 The organisation of SDT The SDT is organised as described under point 6.1.4 in the fresh meat report. 6.1.5 Independence and resources The official veterinarians and inspectors in Norway are employed as civil servants by the public services in order to carry out the control according in Council Directives
3

The Norwegian Authorities informed in their comments to the draft report that SNT may instruct the KNT to relieve an OV from its duties, if necessary. If the KNT does not relieve the OV upon request, SNT can withdraw the delegation of competencies to the KNT. See point 1 in the addendum.

Page 9 91/495/EEC as amended and 92/45/EEC as amended. An OV supervises on behalf of SDT animal welfare at slaughter and the transport conditions of live animals, however he gets paied for this activities from SNT. It is possible that an OV carries out the official meat control in a slaughterhouse situated in the same area where he runs a private practise. The regional veterinary officer in the region where SNT has delegated its power to the local Fylkesman is employed by the local Fylkesman and not by SNT. There are three senior staff inspectors dealing part time with wild and farmed game meat at the central and regional and 80 inspectors at the local level. During the inspection the following observations were made:  On the regional and local level the staff was competent and motivated.  In one slaughterhouse for framed game meat the post of the OV was shared by two veterinarians who are both working as private practicioners in the same area. 6.1.6 Recruitment and training The OVs are recruited by SNT following suggestions made by the KNTs. In 1999 and 2000 SNT arranged courses for OVs dealing with the supervision of wild game meat (14 hours, including practical work). A similar course is foreseen for the year 2002. In addition SNT has issued guidelines for hunters and consumers with regard to wild game meat (Veiledning til jeger og forbruker ved godkjenning av viltkjøtt). The following observations were made during the inspection:  There are no specific training courses with regard to farmed game meat.  In the establishments visited the OVs had not yet participated in the abovementioned training courses for wild game meat as they were recruited in 2001.  In one establishment three OVs had been in charge for the past year and a half due to a difficult recruitment situation in this part of the country. In this area the KNT seemed mainly involved the OV’s training with regard to farmed game meat. 6.1.7 Prioritisation of controls / Reporting procedures SNT instructs the KNTs to base their supervision on a risk assessment for each individual establishment. Based on this risk assessment the KNTs decide themselves on what they want to focus. Each year the KNTs have to prepare a plan describing their foreseen supervisory activities. In case of new requirements, with regard to the supervision of establishments, SNT requests the KNTs to focus specifically on those. The KNTs distinguish in their supervision between audits and inspections. Audits are yearly-performed controls of the establishments own check system, while inspections focus on specific items such as the cleaning in the establishments and reflect the observations made on the day of inspection. The results of both, the audits and the inspections, are reported in writing to the establishment. The KNTs report annually to SNT about individual deficiencies and shortcomings found in the establishments and from the end of this year on the overall status of each individual establishment. The Authority was furthermore informed during the mission that the regional offices, which are part of SNT shall report regularly to SNT in Oslo while the region, which is under the authority of the Fylkesman, reports to him who then forwards the reports to SNT. The following observations were made during the inspection:  No reports to SNT from the regional offices, which are part of SNT, to SNT Oslo were presented.

Page 10      The report forwarded from the Fylkesman was a copy of a report on a single establishment and not comparable to the yearly reports from the KNTs. There was no information available on how often the regions intended to inspect establishments and on which criteria this would be based. There was no documentation available on how the KNTs visited had performed the risk assessment required by SNT. There were no reports available from the KNTs to SNT. In one KNT visited the report to the establishment had been written by the OV in co-operation with the KNT leader.

6.2

Veterinary supervision of farmed game meat and wild game meat establishments

6.2.1 Approval procedure and suspension / withdrawal of approval of establishments SNT is the competent authority for the approval of establishments producing and marketing meat in accordance with Council Directives 91/495/EEC as amended and 92/45/EEC as amended. As already described the regions are entitled to approve establishments, while SNT gives the approval number. There is a written procedure for the approval of establishments stating that an establishment has to send a request for approval to its KNT or regional office including a declaration that all requirements for an approval are fulfilled. The KNT or the regional office inspects the establishment and checks if the declaration is correct. A standardised checklist is used for this purpose and if necessary a more detailed report is made on the establishment. The KNT or the regional office then submit the file to SNT with a recommendation for approval. The inspection team was informed that SNT has introduced a new routine by which the KNTs should perform a follow-up visit three months after an approval has been granted in order to ensure that the operational hygiene of the new establishment is in conformity with the requirements. If an establishment does not fulfil the necessary requirements KNT can stop the production or temporarily suspend the approval until it can be proved by the establishment that the deficiencies have been remedied. Under certain circumstances fines can be imposed by KNT or SNT but a permanent withdrawal of an approval can only be done by SNT. In 2000 one establishment’s approval, for the production of farmed game meat for the national market only, has been suspended. The Norwegian Authorities presented in the answer to the pre-mission questionnaire a list of establishments approved in accordance with Council Directive 91/495/EEC, which mainly consists of establishments dealing with reindeer meat, while stating during the final meeting that they did not consider reindeer to be covered by Council Directive 91/495/EEC. During the mission it was explained, that one requirement for granting additional approval for the slaughter of reindeer to an establishment which is already approved for the slaughter of domestic animals in accordance with Council Directive 64/433/EEC is, that the reindeer slaughter takes place at a different time than the slaughter of domestic animals. In preparation to the mission the Authority received information that there is no trade of wild game meat within the EEA as almost all wild meat would be used in a way that Council Directive 92/45/EEC as amended would not be applicable (e.g. private

Page 11 consumption, direct supply of restaurants). Finally, there are about 1560 collection centres approved for the national market (so called “local places”), but none according to Council Directive 92/45/EEC as amended. The following observations were made during the inspection with regard to farmed game meat:  The approval documents issued for the reindeer slaughterhouses and the cutting plant contain no reference to the farmed game meat legislation.  According to the approval document one reindeer slaughterhouse visited was approved for the slaughter of all animals covered by Council Directive 64/433/EEC (fresh meat). However, only reindeers were intended to be slaughtered there thus the facilities and equipment presented were only suitable for the slaughter of reindeer according Council Directive 91/495/EEC as amended but not for domestic animals as for example suitable lairage and stunning facilities were missing.4  There was no written evidence that slaughter of reindeers is required to be performed at separate times from domestic animals.  A considerable amount of reindeer meat is slaughtered in slaughterhouses approved for the national market only.It as not clear, whether this was based on a derogation foreseen in Council Directive 91/495/EEC as amended.  Approval is granted to establishments to produce within the same facilities products approved for the EEA market and for the national market.  The submitted list of establishments approved in accordance with Council Directive 91/495/EEC as amended was incomplete.  It was observed in one region that the approval procedure had not been followed consistently. The following observations were made during the inspection with regard to wild game meat:  There is a considerable market for wild game meat involving for example the reindeer slaughterhouses visited. This activity was not covered by the presented approval documentation.  Although there are no collection centres approved in accordance with Council Directive 92/45/EEC as amended it was noted during the mission that an analogon exists with the “local places“, which fulfil the same purposes for wild game meat intended for the national market only.  It was not clear from the presented application form for the approval of wild game meat processing houses if approval can only be granted to establishments approved in accordance with Art. 10 of Council Directive 64/433/EEC or also to those approved in accordance with Art. 4 of that Directive.5  There are processing houses approved for the processing of wild game meat for the national market only. 6.2.2 Control in the establishments 6.2.2.1 Central level In the answer to the pre-mission questionnaire it was stated that SNT regularly audits the KNTs.
4

The Norwegian Authorities informed in their comments to the draft report that a new approval, excluding the slaughter of domestic animals, was issued. See comment point 2 in the addendum. 5 The Norwegian Authorities commented on the draft report with regard to the approval according to Art. 10 of Council Directive 64/433/EEC. See point 2 in the addendum.

Page 12 The following observations were made during the inspection:  There was no evidence provided that SNT has audited the KNTs and the region under the Fylkesman with regard to game meat and farmed game meat.  There was no information available on how SNT intends to supervise the other regional offices.  SNT has not issued any guidelines or requirements for the KNTs to supervise the establishments, producing EEA approved farmed game meat and non-EEA approved farmed game meat in the same facilities. 6.2.2.2 Regional level Two out of three regional offices which have been established were visited. These offices inspect establishments prior to approval and they are also responsible for their supervision. The following observations were made during the inspection:  There was no written evidence of a regional visit prior to approval in an establishment, which had recently been approved. However, there was an inspection report available including due dates for corrective actions.  In the second region an establishment had been inspected by the region. However, it was not possible to assess how often establishments would be inspected on a routine basis. 6.2.2.3 Local level As described under 6.1.2 the establishments are supervised on the spot by OVs from the local KNT. The responsibilities of the OV include the supervision of the establishment’s own check system, the participation of staff in training programmes related to operational hygiene and report regularly to the establishment’s management (see 6.1.7). SNT requires that all official samples taken by the OV be analysed in accredited laboratories. The Norwegian Metrology and Accreditation Service (NA) grants the accreditation for particular analysis. For the Trichinae sampling see 6.2.3. The following observations were made during the inspection:  In the cutting plant visited there was no written evidence that an OV had been present once a day during cutting although this cutting plant was integrated in an EEA approved slaughterhouse.  There were deficiencies detected in the supervision of the establishment’s own check system (see 6.2.4) and the health marks (see 6.2.2.5) as well as with regard to a documented follow-up of corrective actions.  There was little written evidence of a constant veterinary supervision especially with regard to incoming and outgoing meat (see also 6.3.5). 6.2.2.4 Ante-mortem and post-mortem inspection The performance of the ante-mortem and post-mortem inspection could only be seen in one establishment due to the unpredictable slaughter activities of reindeer slaughterhouses. With regard to wild game meat is it not possible for the OV to perform an ante-mortem inspection. In Art. 3 (1) of Directive 92/45/EEC as amended a limit of 12 hours has to be respected when delivering game meat to a processing house in order to ensure that the OV sees the carcass as soon as possible. In the case of remote regions where the climatological conditions permit the competent authority can fix another time limit. The inspection team

Page 13 was informed that according to the national rules applicable for the hygiene and placing on the market of wild game meat that the carcass should be delivered as soon as possible to the processing house if the climatic conditions allow or within a time limit fixed by the OV. The following observations were made during the inspection:  In both slaughterhouses the post-mortem inspection was difficult due to lacking equipment and space.  The green offal was not visually inspected and there was no link between the carcass, the green offal and the red offal.  In one establishment the records of the ante-mortem inspection were part of the establishment’s records and not linked to the flock.  The results of the post-mortem control were not recorded at the slaughterline but recorded later making them less reliable.  In one establishment the post-mortem records were only covering condemned carcasses. 6.2.2.5 Health marking In the answer to the pre-mission questionnaire it is stated that the health mark applied to farmed game meat approved for the EEA market is as described in Chapter III of Annex I of Council Directive 91/495/EEC as amended and wild game meat as described in Annex I, Chapter VIII of Council Directive 92/45/EEC as amended. The health mark for farmed game meat and wild game meat is a squared mark (5x5 cm), with 0,8 cm tall letters, 1,0 cm tall numbers, with NORGE in the upper part, in the middle part the establishment’s approval number and in the lowermost part N for national distribution. The Authority was furthermore informed that there are no procedures available to regulate the printing of labels and wrapping material bearing the health mark but the OVs are obliged to control their use in the establishments. The following observations were made during the inspection:  The health mark was applied before the post-mortem control was finalised.  The health mark was not applied in such a way to a label fixed to the packaging or was not printed in such way on the packaging, that it would be destroyed when the packaging is opened.  The establishments visited printed or ordered health marks, which were not numbered. They were administered and stored like commercial labels.  One establishment was producing in the same facilities the same products from EEA -approved raw material as well as from non EEA-approved raw material. The OV had no control over the health marks ensuring that the products were health marked according to the approval status of the raw material.  Cut meat intended to be placed on the market, without a health mark or a label which would have made it possible to identify whether it is originating from EEA approved meat or non EEA-approved meat, was observed in the intermediate storage visited.  There was no description available on health mark foreseen for the health marking of reindeer carcasses approved for the national market only.6

6

The Norwegian Authorities informed in their comments to the draft report that the health mark for reindeer carcasses, approved for the national market only, has a square form. Furthermore, reference was made to the health mark for wild game meat. See point 3 in the addendum.

Page 14 6.2.3 Trichinae control In Norway farmed wild pigs are defined as farmed game and wild boar and bears as wild game. No information was received regarding the examination for trichinae (trichinella spiralis) for farmed wild pigs, wild boar and other species susceptible to trichinosis as required in Article 6 (1) of Council Directive 91/495/EEC as amended and Art. 3 (3) of Council Directive 92/45/EEC as amended7. 6.2.4 Veterinary supervision of own check systems and staff training programmes All establishments visited had own check systems in place. SNT is issuing guidelines on how the own check systems must be supervised by the OVs. The establishments have inter alia to identify points of incoming and outgoing transport as critical control points, register and document them. This documentation has to be controlled by the OV on a regular basis. The OVs participate in drawing up training programmes for staff members. The following observations were made during the inspection:  The veterinary supervision did not include the incoming and outgoing meat. In one establishment both EEA-approved and non EEA-approved meat was handled in the same facilities (see also 6.4).  The supervision of the water quality did not ensure that the samples were taken before restarting the slaughter activity in the autumn.  Deficiencies were observed with regard to the corrective actions needed concerning the temperature of incoming meat.  There was no veterinary supervision on the means of transport for fresh farmed game meat.  In one establishment, the own-check system was not approved by the OV and the OV performed e.g. a sampling on the cleaning, but did not report the results to the establishment.  The temperature in the cutting room was in conformity with Council Directive 91/495/EEC as amended, however the inspection team was informed that the temperature was allowed to go up until 15°C in cutting plants for reindeer meat. 6.3 Visit to farmed game meat and wild game meat establishments8 6.3.1 Structure and layout The following observations were made during the inspection:  There was a risk of cross contamination due to insufficient separation between clean and unclean areas.  There was no separate space available for the storage of arrested carcasses.  One establishment was approved for the production of EEA approved framed game meat and farmed game meat for the national market only although the layout did not permit a clear separation between this two types of production. The routines, which were described to ensure that separation were not applied (see also 6.3.5).  In one establishment, certain problems were noted with the access control and the offal was stored outside in a container, which could not be locked.
7

The Norwegian Authorities informed in their comments to the draft report on the legal basis for trichinae examination, which include pigs, oild boar and other species suspectible to trichinosis. See point 4 in the addendum. 8 The detailed findings were presented to the establishment’s representatives on the spot after each visit.

Page 15 6.3.2 Installation and equipment The following observations were made during the inspection:  The wastewater was not under sufficient control, which resulted in splash contamination.  The equipment was not laid out in such a way as to ensure a proper post-mortem control (see 6.2.2.4).  In one establishment, the equipment did not prevent the carcasses to be contaminated during dehiding. 6.3.3 Maintenance, cleaning and pest control The following observations were made during the inspection:  The maintenance and the pest control in the establishments visited were in general satisfactory.  The cleaning programmes were not covering all rooms. 6.3.4 Operational hygiene A number of deficiencies were found, including the following:  In the establishments exposed carcasses were stored in layers in the freezer like firewood touching the wall, without identifying this special method as a critical control point, exposed and packed products were partly stored together and some accumulation of condensed water was observed.  In one establishments cartons were stored in the packaging / slicing room and the reception area for exposed carcasses.  In one slaughterhouse the staff working on the clean side was not wearing light coloured protective clothing and a shower was shared between those and the operators from the unclean side. 6.3.5 Traceability The traceability was observed to be satisfactory throughout the slaughtering process until the meat entered the cutting plant. The following observations were made during the inspection:  In general the system of traceability is satisfactory in the slaughterhouses, but the traceability was not ensured in the cutting plant and there was no documentation on the disposal of arrested carcasses.  In one establishment there was insufficient register on incoming meat, cutting activities and outgoing products. This establishment was handling EEA and nonEEA approved meat in the same facilities.  The system how to separate EEA and non-EEA approved meat presented in one establishment was not constantly followed and the information pre-printed on the packaging could jeopardise the possibility to trace back EEA and non-EEA approved meat.

6.4

Certificates and trade documents

The Authority was informed in the answer to the pre-mission questionnaire that under transport farmed game meat and wild game meat are to be accompanied by a commercial document stating the approval number of the establishment of origin and the amount

Page 16 (KG / tons) of meat. This documentation has to be stored by the establishment for at least two years. Furthermore, that there is no standardised form for the hunters declaration, which can be given to an OV in a wild game meat processing house. In Art. 6 and 7 of Council Directive 91/495/EEC as amended reference is made to Council Directive 64/433/EEC with regard to large farmed game meat and there are two separate models for health certificates for fresh rabbit meat (Annex II) and fresh farmed game meat (Annex IV). These in turn make reference concerning the veterinary inspection to Council Directive 90/495/EEC (Annex II) respective Council Directives 71/118/EEC and 64/433/EEC (Annex IV). The following observations were made during the inspection:  Commercial documents were used when receiving and transporting farmed game meat.  The commercial documents presented were not always containing the information given on the oval health mark.  The presented single model for a health certificate, to be used for fresh rabbit meat and fresh farmed game meat, did not contain the references made in Annexes II and IV of Council Directive 91/495/EEC as amended.  With regard to the requirements for the slaughter and placing on the market (with the exemption of storage and transport) of rabbit and framed game meat reference was made to the provisions regulating the slaughtering and placing on the market of poultry meat.  In one establishment deliveries of farmed game meat were accepted, which were not accompanied by individual documents and the pre-printed form of the commercial document, used for outgoing farmed game meat, was always bearing the oval health mark although the establishment produced also products approved for the national market only. Paper labels were used to adjust these documents when accompanying products approved for the national market only.

6.5

Residues

In the answer to the pre-mission questionnaire the Authority was informed that a monitoring programme is established according to Council Directive 96/23/EC. In the game meat production the most significant residue problem concerns radioactive Caesium in the environment due to the Chernobyl accident. Norway is divided into different zones where the intensity of the surveillance and the restrictions imposed correlate to radioactive exposure experienced from that accident. The slaughterhouses visited participated in the national residue sampling plan. In general residues issues are subject to separate missions carried out by the Authority.

6.6

Zoonoses

There was no evidence from the documents received at the slaughterhouses that the original herds had undergone veterinary inspection regularly. The inspection team was informed with regard to wild game meat that the hunters inform the KNTs when shooting sick animals as those are not deducted from their hunting quota. The hunter receives a certificate from the OV in order to maintain his quota. When the OV diagnosis a notifiable disease he informs SDT, which is the competent authority for animal diseases. The hunters are also obliged to inform SDT about these diseases, which they are informed about in courses held by the KNTs.

Page 17 6.7 Animal identification

For reindeer, the only large farmed game existing in Norway, a registration of holdings is not possible as the herds roam over extensive areas. However, every keeper of reindeers is registered and is assigned a unique earmark (ear cut) that must be applied to reindeer born in their herds. Any transfer of reindeer between owners must be recorded. When animals are slaughtered the slaughterhouse supplies a metal ear tag, which contains an ongoing number and ends in a label applied on the carcass. This ear tag in combination with the ear cuts should make it possible to trace the animals back to their origin. However, as the majority of OVs do not have the necessary skills to read the ear cuts an immediate verification of an animals' origin is difficult.

6.8

Animal welfare

In the reindeer slaughterhouse seen in operation, adequate stunning and bleeding was observed. A sheep restrainer had been adjusted to stun the reindeers separately, which led to a calm handling of the animals.

6.9

Visit to a collection centre approved for the national market only (“local place”)

As described under 6.2.1 only collection centres are approved for the national market, the so-called “local places” (Kontrolsted). Lists of approved local places within defined geographical areas are kept within the responsible KNT, which is also responsible for their approval. The KNTs have defined as requirements for their approval the presence of fly proof, dustproof walls, a roof and proximity to a road. No chilling facilities are required. The post mortem inspection of the carcasses can be carried out there by the OV and the carcasses can also be dehided there. The meat is supposed to be transported from the local place to the national processing house as soon as possible. A group of hunters owned the local place visited and paid the OV per hour for the postmortem inspection, thus they collect several carcasses before they call the OV.

7 7.1

Conclusions The competent authority

7.1.1 The competent authorities are independent, but the lack of co-ordinated surveillance programmes between SNT, the regional offices (both forms of organisation) and KNT is an obstacle to the effective functioning of the supervision of establishments. 7.1.2 The required participation of staff in training courses with regard to wild game was not regularly enforced by SNT and there is no training course for farmed game meat, thus adequate training of newly recruited staff, which has a high turn over, could not be guaranteed. 7.1.3 SNT instructs the KNTs to perform their supervision on the basis of a risk assessment for each establishment. There were no guidelines available for this risk assessment and no information about the criteria to be used by the KNTs. With regard to the supervision performed by the regional offices, there was no information available on which criteria they decide on their inspection frequency. There is therefore a doubt if a homogenous supervision is ensured.

Page 18 7.1.4 The reporting procedures, which have been initiated by SNT since the last inspection of the Authority9, could not be confirmed during the mission. No reporting procedure, like the yearly reports requested from the KNTs, was available between the regional offices and SNT. It is therefore not guaranteed that all relevant information reaches SNT.

7.2

Veterinary supervision of farmed game meat and wild game meat establishments

7.2.1 Establishments producing farmed game meat where approved on the basis of Council Directive 64/433/EEC, which is not in accordance with Council Directive 91/495/EEC as amended. 7.2.2 The visited slaughterhouse approved for all domestic animals in accordance with Council Directive 64/433/EEC, was not fulfilling all requirements of the Directive. However, it fulfilled to a large extend the requirements of Council Directive 91/495/EEC as amended. 7.2.3 No information was received that the approval of reindeer slaughterhouses for national production only is based on derogation provided for in Art. 6 (3) of Council Directive 91/495/EEC as amended. 7.2.4 SNT approves establishments, which produce in the same facilities farmed game meat approved for the EEA market and framed game meat approved for the national market only without ensuring adequate separation between these productions. 7.2.5 The submitted list of establishments approved in accordance with Council Directive 91/495/EEC as amended was not comprehensive, which is not in accordance with Art.14 of that Directive. 7.2.6 The approval procedure and the requirements for establishments approved for the slaughter of reindeer as well as other domestic animals could not be confirmed during the mission. There is a room for improvement with regard to the implementation of these procedures. 7.2.7 A system for the placing on the market of wild game meat on the national market operates parallel with an incomplete system for the placing on the market within the EEA. 7.2.8 The supervision of the SNT with regard to the regions or directly towards the KNTs needs to be improved. 7.2.9 The documentation of veterinary supervision concerning for example veterinary supervision of cutting plants, ante–mortem and post–mortem records needs improvement. 7.2.10 The post-mortem control observed was not completely performed as the green offal was not inspected. 7.2.11 The health marking was not always in accordance with Council Directive 91/495/EEC as amended. An improvement is needed with regard to the veterinary supervision of health marks and the application of the health marks.
9

See the final report on an inspection with regard to meat products, meat preparations etc, Doc. No. 01-4440-D.

Page 19 7.2.12 The trichinae control is not foreseen, which is not in accordance with the Council Directives 91/495/EEC as amended and 92/45/EEC as amended. 7.2.13 The veterinary supervision of the own-check systems needs improvement especially with regard to the incoming and outgoing meat.

7.3

Visit to farmed game meat and wild game meat establishments

7.3.1 In both of the slaughterhouses visited, the layout was not in such a way that clean operations were kept separate from unclean operations, which is not in accordance with Council Directive 91/495/EEC as amended. 7.3.2 In one establishment the layout and the demonstrated work routine did not ensure a clear separation between goods approved for the EEA market and goods approved for the national market only. 7.3.3 Some deficiencies were noted with regard to installation, equipment, maintenance, cleaning, pest control and operational hygiene. An improvement is especially needed with regard to the separate storage of exposed and packed products and the completeness of cleaning programmes. 7.3.4 The traceability of condemned carcasses and in the cutting plant needs to be improved.

7.4

Certificates and trade documents

7.4.1 An improvement is needed concerning the information provided for in the commercial documents. 7.4.2 It is not in compliance with Council Directive 91/495/EEC as amended that large farmed game meat is only accompanied by a commercial document. 7.4.3 Deficiencies were found with regard to the health certificated as required in Council Directive 91/495/EEC as amended.

7.5

Residues

No deficiencies were noted during this mission. However, this subject is covered by special missions from the Authority and was therefore not evaluated in depth.

7.6

Zoonoses

As far as this could be evaluated during this mission, no deficiencies were noted apart from missing evidence that the original herds had undergone regular veterinary inspections as required in Council Directive 91/495/EEC as amended. 7.7 Animal identification

The system in place is satisfactory.

Page 20 7.8 Animal welfare

The animal welfare was satisfactory.

8

Recommendations to the competent authorities of Norway

The Norwegian Authorities should notify to the Authority in writing of the actions it intends to take to rectify the deficiencies identified. In doing so, they should provide a timetabled action plan for the implementation of these actions and should provide guarantees that the plan will be realised. 8.1 relevant to the points mentioned in Chapter 7, except 7.3.1 and 7.3.2, within two months after receiving the final report. 8.2 relevant to the points 7.3.1 and 7.3.2 in detail within six months after receiving the final report.

9

Addendum to the mission report

The Norwegian Authorities informed the Auhority in a letter dated 7 January 2002 about their comments on the factual comment of the report. The full text of the letter is annexed: DRAFT REPORT FROM A MISSION CARRIED OUT BY THE EFTA SURVEILLANCE AUTHORITY TO NORWAY FOR THE PURPOSE OF ASSESSING THE APPLICATION OF COUNCIL DIRECTIVE 91/495/EEC, COUNCIL DIRECTIVE 92/45/EEC, AND OTHER ACTS RELATING TO FARMED AND WILD GAME MEAT According to report and letter of 27. November 2001 ref. VET604.400.003, the Norwegian Authorities are invited to comment on the factual content of the draft report received. On behalf of the Norwegian Authorities, the Norwegian Food Control Authority (SNT) would like to make the following comments: 1. Point 6.1.3 Co-ordination between SNT and KNT It is stated in the draft report that the dismissal of an Official Veterinarian (OV) can only be done by the KNT. SNT would like to add the following information to ESA in regard to this statement: Even though the dismissal of an OV can only be done by the KNT, SNT may instruct the KNT to relieve him/her of the official duties given the OV, when the OV is doing an unsatisfactory job. If the KNT does not relieve the OV upon request or makes other arrangements to fulfil the requirements, SNT can withdraw the delegation of competencies given to the KNT. 2. Point 6.2.1 Approval procedure and suspension/ withdrawal of approval of establishments In the draft report it is stated that it was not clear form the presented application form for the approval of wild game meat processing houses if approval can only be granted to establishments approved in accordance with Art. 10 of Council Directive 64/433/EEC or also to those approved in accordance with Art. 4 of that Directive. Establishments approved according to Art. 10 of Council Directive 64/433/EEC can have their approval extended to include wild game meat processing. Wild game meat

Page 21 processing houses can however be approved solely for this purpose without an earlier approval according to Art. 10 of Council Directive 64/433/EEC. SNT would also like to include this information: There has been issued a new approval to one reindeer slaughterhouse visited10, since the mission by the EFTA Surveillance Authority. According to the new approval, issued by the FNT on 05. November 2001, they can perform the following activities: slaughtering, cutting and cold- and deep- freezer storing of reindeer, plus function as a wild game meat processing house. 3. Point 6.2.2.5 Health marking It is stated in the draft report that there was no description available on health mark foreseen for the health marking of reindeer carcasses approved for the national marked only. After talking to the Authority11on telephone on 04. January 2002, it became clear that there had been some kind of misunderstanding during the mission by the EFTA Surveillance Authority. SNT would like to make reference to the pre-mission questionnaire point 3.2.2 where the health marks used for farmed game meat are described. The health mark used for export to the European Economic Area should be an oval mark with the features explained in point 3.2.2 of the pre-mission questionnaire. The health mark used for products designated only for the national market should be a squared mark as explained in point 3.2.1 of the pre-mission questionnaire. 4. Point 6.2.3 Trichinae control In the draft report it is stated that no information was received regarding the examination for trichinae (Trichinella spiralis) for farmed wild pigs, wild boar and other species susceptible to trichinosis as required in Article 6 (1) of Council directive 91/495/EEC as amended and Art.3 (3) of Council Directive 92/45/EEC as amended. SNT would like to add the following information to this point: The directions on examination for trichinae for farmed wild pigs, wild boar and other species susceptible to trichinosis is laid down in Regulations 14 July 1978 No. 9629 on official meat control § 20, Instructions 25. May 1994 No. 369 for meat control point 9 and Instructions 08. November 1995 No. 962 for Trichinae control. These regulations and instructions have been sent to the EFTA Surveillance Authority in regulation to inspections carried out previously (report of 10.11.2000 regarding application of 64/433/EEC, and report of 24.04.2001.) SNT has no further comments regarding the factual content in the draft report.

10 11

The Authority does not mention names of establishments in its reports. The Authority does not mention names of individuals in its reports.


								
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