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Hygiene rules
         on the hygiene of foodstuffs in
                     Europe:

       Which challenges for small scale
                 producers?


Elisa Bianco
Slow Food Studies Centre
April 2012
A need for change


Series of food scares
 at the end of 90s

       E.g. BSE
        Dioxin
Foot-and-mouth desease




                            GENERAL FOOD LAW
                            Reg (EC) No 178/2002

                              FOOD HYGIENE
                                  PACKAGE
                            Reg (EC) No 852/2004
                            Reg (EC) No 853/2004
                            Reg (EC) No 854/2004
New challenges for producers and competent
                            authorities

  The pillar of the general
       framework is              A sort of industrialization
         Flexibility                 of manufacturing
  both for producers and                 processes
      for competent
         authorities




Interpretation may become an   Potential requirement of new
            issue                structures, equipments,
                                      furniture, ecc
At the end what do producers complain about?


 Most of the problems arise with foodstuff of animal origin (specific
Regulation)



      Too many requirements for new equipment and for spatial separation
of processes (i.e. needing new infrastructures)



      Cost increase and time delay due to implementation of law
requirements



       In-house slaughtering becomes impossible
Raviggiolo cheese offers a good case study


Cow raw milk cheese
Available only from October to March
For more info:
http://www.presidislowfood.it/ita/dettaglio.lasso?cod=118&id_regione=&id_tipologia=9&




                                             Slow Food Presidium since 2002
                                             Produced in the Apennines
                                             mountains in Emilia-Romagna
Raviggiolo cheese offers a good case study


Especially the story of one producer can teach
something: the case of Azienda Agricola Bresciani




                   Bresciani farm transformed 5 litres of milk per day


                         Communication activities


              The farmer decided to increase his production trying to fully
                    comply with the initial authorities requirements
Azienda Agricola Bresciani: a never-ending story


? End of 2002: the producer asks for the approval of a 20 sqm
  transformation laboratory
? Beginning of 2003: first anticipatory approval is given by local
  governmental authorities. Bresciani starts the construction of the lab,
  health authorities are asked to verify the compliance with the law
? Mid 2003: health authorities give their positive opinion


¡­¡­ then at the beginning of 2004 new requirements were asked:
? 50 sqm transformation laboratory instead of 20 sqm
? Minor modifications to infrastructure (i.e. water plant) and manufacturing
  process (i.e milk pasteurization became essential)
Azienda Agricola Bresciani: the end of the story

  ? Beginning of 2006: the lab was active, its final cost was over 70,000 €
  ? Bresciani had to increase his production and cover the investment (90
    litres of milk per day)
  ? Out of the Presidium project because of the pasteurization



 ¡­ While those who followed the path with
Slow Food and the health authority of Forl¨¬

? Prepared a proper technical documents fully describing real risks and
  precautions needed
? Smaller modification of manufacturing process (costs dropped to 30,000 €)
? No need to pasteurize the milk
Raviggiolo Presidium: final lessons learnt

? Need of protecting traditional products before their manufacturing
  process is modified to comply with new or inappropriate rules
? Importance of consortium instead of single producers alone
? Importance of technical knowledge both for producers and for competent
  authorities
? Preparation of technical guidelines describing manufacturing process in
  order to protect the history of the products and the knowledge of
  producers
? Derogations are possible with proper documentation folders



   But what about small-scale producers not linked to
             peculiar traditional products?
The case of Bolzano province (Trentino-Alto
                              Adige region)


                                  Decree no 52 issued by the province of
                                     Bolzano on 26th September 2008
                                  All producers located within the province
                                        may take advantage of the law
                                    Many derogations are made for these
                                  producers, i.e. the possibility of avoiding
                                    spatial separation of processes, using
                                   home kitchen for the manufacturing or
                                         avoiding to stamp each egg




However, as far as meat production is concerned, exceptions are granted only
  for poultry and rabbits. No exceptions for ovine, equines, pork or cattle.
Take home message


   Flexibility offers a lot of solutions: it may open many
relevant opportunities but technical knowledge, expertise
  and collaboration between producers, technicians and
 competent authorities are crucial for the things to work
                           properly




                Thank you for your attention!

More Related Content

Hygiene rules challenges for small scale

  • 1. Hygiene rules on the hygiene of foodstuffs in Europe: Which challenges for small scale producers? Elisa Bianco Slow Food Studies Centre April 2012
  • 2. A need for change Series of food scares at the end of 90s E.g. BSE Dioxin Foot-and-mouth desease GENERAL FOOD LAW Reg (EC) No 178/2002 FOOD HYGIENE PACKAGE Reg (EC) No 852/2004 Reg (EC) No 853/2004 Reg (EC) No 854/2004
  • 3. New challenges for producers and competent authorities The pillar of the general framework is A sort of industrialization Flexibility of manufacturing both for producers and processes for competent authorities Interpretation may become an Potential requirement of new issue structures, equipments, furniture, ecc
  • 4. At the end what do producers complain about? Most of the problems arise with foodstuff of animal origin (specific Regulation) Too many requirements for new equipment and for spatial separation of processes (i.e. needing new infrastructures) Cost increase and time delay due to implementation of law requirements In-house slaughtering becomes impossible
  • 5. Raviggiolo cheese offers a good case study Cow raw milk cheese Available only from October to March For more info: http://www.presidislowfood.it/ita/dettaglio.lasso?cod=118&id_regione=&id_tipologia=9& Slow Food Presidium since 2002 Produced in the Apennines mountains in Emilia-Romagna
  • 6. Raviggiolo cheese offers a good case study Especially the story of one producer can teach something: the case of Azienda Agricola Bresciani Bresciani farm transformed 5 litres of milk per day Communication activities The farmer decided to increase his production trying to fully comply with the initial authorities requirements
  • 7. Azienda Agricola Bresciani: a never-ending story ? End of 2002: the producer asks for the approval of a 20 sqm transformation laboratory ? Beginning of 2003: first anticipatory approval is given by local governmental authorities. Bresciani starts the construction of the lab, health authorities are asked to verify the compliance with the law ? Mid 2003: health authorities give their positive opinion ¡­¡­ then at the beginning of 2004 new requirements were asked: ? 50 sqm transformation laboratory instead of 20 sqm ? Minor modifications to infrastructure (i.e. water plant) and manufacturing process (i.e milk pasteurization became essential)
  • 8. Azienda Agricola Bresciani: the end of the story ? Beginning of 2006: the lab was active, its final cost was over 70,000 € ? Bresciani had to increase his production and cover the investment (90 litres of milk per day) ? Out of the Presidium project because of the pasteurization ¡­ While those who followed the path with Slow Food and the health authority of Forl¨¬ ? Prepared a proper technical documents fully describing real risks and precautions needed ? Smaller modification of manufacturing process (costs dropped to 30,000 €) ? No need to pasteurize the milk
  • 9. Raviggiolo Presidium: final lessons learnt ? Need of protecting traditional products before their manufacturing process is modified to comply with new or inappropriate rules ? Importance of consortium instead of single producers alone ? Importance of technical knowledge both for producers and for competent authorities ? Preparation of technical guidelines describing manufacturing process in order to protect the history of the products and the knowledge of producers ? Derogations are possible with proper documentation folders But what about small-scale producers not linked to peculiar traditional products?
  • 10. The case of Bolzano province (Trentino-Alto Adige region) Decree no 52 issued by the province of Bolzano on 26th September 2008 All producers located within the province may take advantage of the law Many derogations are made for these producers, i.e. the possibility of avoiding spatial separation of processes, using home kitchen for the manufacturing or avoiding to stamp each egg However, as far as meat production is concerned, exceptions are granted only for poultry and rabbits. No exceptions for ovine, equines, pork or cattle.
  • 11. Take home message Flexibility offers a lot of solutions: it may open many relevant opportunities but technical knowledge, expertise and collaboration between producers, technicians and competent authorities are crucial for the things to work properly Thank you for your attention!