Mr Howgate.
Your answer is extremely instructive, I appreciate been treated with facts, particularly when as in this case, I?am dealing with a ?market access requirement? for the EU and not with an domestic issue, or a requirement for other exports markets that not require the intervention of a ?competent authority?.
I respect the understanding and distribution of the regulations, but not their use as an empowering tool... (I guess we fisherman have a bit of a an issue with blindly accepting authority!)
I like to be a responsible skipper, and I believe that big part of compliance is about the ?control? I can show over my systems and any potential problems, but not just about hypocritically ticking on a piece of paper.
I?m very honoured with your answer sir
Thousand thanks (mil gracias!),
Ignacio Irunaga
On Tuesday, May 02, 2006, at 02:06PM, P Howgate <phowgate@clara.co.uk> wrote:
>Ignacio has a dispute with his local fishery inspector and I am in no
>position to comment on the application of local regulations, but his message
>raises an interesting point of general interest relating to the relevance of
>medical inspection, and possible certification of food handlers.
>
>The booklet 'Food Hygiene Basic Texts, 2nd edn.. Recommended International
>Code of Practice General Principles of Food Hygiene' published by the Codex
>Alimentarius Commission, 1999, recommends in Section VII - Establishment:
>personal hygiene: "Medical examination of a food handler should be carried
>out if clinically or epidemiologically indicated." This suggests that
>medical examination of food handlers is dictated by circumstances and need
>not be a routine practice.
>
>The EU requirements for food hygiene are laid out in Regulation (EC) No
>852/2004 of the European Parliament and of the Council of 29 April 2004 on
>the hygiene of foodstuffs. Handling of fish aboard fishing vessels is
>covered in Annexe I, Primary Production, Part A: General Hygiene Provisions
>for Primary Production and Associated Operations. Section 4 requires that:
>"Food business operators rearing, harvesting or hunting animals or producing
>primary products of animal origin are to take adequate measures, as
>appropriate: ....(e) to ensure that staff handling foodstuffs are in good
>health and undergo training on health risks; ... ". This provision could be
>construed as governing the welfare of the crew of the fishing vessel, rather
>than the human health safety of the product. I am sure it is wise that
>anyone serving on a fishing vessel at sea to be in good health and there is
>no harm in training someone to avoid health risks. I am being facetious, but
>Section 4 (e) is a good example of poor drafting.
>
>However, the EU Regulation redeems itself in Annexe II, General Hygiene
>Requirements for All Food Business Operators (Except When Annex I Applies).
>Chapter VIII Personal Hygiene, requires that "No person suffering from, or
>being a carrier of a disease likely to be transmitted through food or
>afflicted, for example, with infected wounds, skin infections, sores or
>diarrhoea is to be permitted to handle food or enter any food-handling area
>in any capacity if there is any likelihood of direct or indirect
>contamination. Any person so affected and employed in a food business and
>who is likely to come into contact with food is to report immediately the
>illness or symptoms, and if possible their causes, to the food business
>operator." This is quite clear and the requirement is spelled out in detail.
>The EU regulation puts the onus on operators of food premises to apply the
>provisions of the regulation, and must do so as part of the continuous
>control of the safety of the products. There is no requirement in the
>regulation for medical examination of food handlers, and I assume this is
>left to the operator to decide as he thinks fit. As Ignacio points out a
>medical examination does not exclude a person's subsequently becoming a
>carrier of a disease likely to be transmitted through food. The emphasis, as
>it is in other matters concerning safety, has to be on continuous monitoring
>rather than spot checks.
>
>Generally chilled raw fish as handled on a fishing vessel is considered as
>posing a very low risk of causing bacteriological illness. Even if
>pathogenic organisms are transmitted to the product from handlers or
>surroundings chance of proliferation is low because the fish is kept
>chilled - indeed icing is a requirement of the EU regulations - and the
>product is almost invariably cooked before consumption. However, Ignacio
>tells me his boat is handling tuna for sashimi, and though well chilled
>would not have this final protection of cooking before consumption. Anyone
>care to estimate the risk of illness from consumption of sashimi produced
>from tuna contaminated from handlers on the catching vessel, and the likely
>reduction of this risk by medical examination of the handlers?
>
>Peter Howgate
>
>----- Original Message -----
>From: <ignaciopesca@mac.com>
>To: <seafood@ucdavis.edu>
>Sent: Monday, May 01, 2006 8:49 PM
>Subject: Medical Certificate on fishing boat crew
>
>
>> Dear Experts
>>
>> In order to be listed by our "competent authority" to be allowed to sell
>> our fish to exporters intending to send products to Europe, the local
>> inspector says that all crew on board need to have annual medical
>> certificates... I asked him to provide me with a reference of the
>> requirement but he does want to...
>>
>> I have read Regulations 852, 853, 854/2004 from the EC and found no
>> reference to medical certificates... they talk about product handlers
>> with good health... which is understandable... and we would not embark (we
>> have a small longliner) some one looking sick anyway... small confined
>> space and away from medical care... would be silly...
>>
>> Does anyone have a exact reference for a medical certificate in the EU
>> regs?
>>
>> What is the point of having a medical certificate if you could be really
>> sick a month later, anyway?
>>
>> Would a visual check of the general health (no dripping orifices, eyes,
>> nose, ears and so on?) before embarking and recorded in our daily
>> checklist satisfy the requirements?
>>
>> Your help is appreciated
>>
>> Ignacio Irunaga
>>
>>
>>
>>
>
>
>
>
This archive was generated by hypermail 2b29 : Tue May 02 2006 - 15:05:16 PDT