GSC CODEX MESSAGE CCFH42/2011/27 Codex Committee on Food Hygiene (43 rd Session) Miami (5-9 December 2011)

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1 GSC CODEX MESSAGE CCFH42/2011/27 Codex Committee on Food Hygiene (43 rd Session) Miami (5-9 December 2011) EU comments on the Proposed Draft Guidelines on the Application of General Principles of Food Hygiene to the Control of Viruses in Food (Agenda item 4, CX/FH 11/43/4 + Add.1) Mixed competence European Union vote I- General comments The European Union and its Member States (EUMS) congratulate the Netherlands and the working group for the considerable improvement of the document, which is now ready for final adoption subject to some fine-tuning. - Section 3.4 Cleaning, maintenance and personnel hygiene at primary production from the recommended international code of practice general principles of food hygiene is no longer included in the proposed main document. It is also not included in annex II on fresh produce. In the main document, it was most likely deleted because all the references to the international code were deleted. However, next to this reference, there was also a reference to Section 7 for aspects of personnel hygiene in the primary production area. As personnel hygiene is very important in the prevention of viruses, also at primary production level for food that isn t submitted to a virus eliminating step further in the food chain, and it is unclear if section 7 also applies to the primary production, we would like to suggest to reinsert the title of section 3.4 together with a reference to section 7 in the main document and in annex II. II- Specific comments 2.3. Definitions Ready-to-eat food (RTE-food) - any food that is normally eaten in its raw state or any food handled, processed, mixed, cooked, or otherwise prepared into a form, that which is normally eaten without further steps, which could remove viruses or eliminate their infectivity. 1

2 3.4 Cleaning, maintenance and personnel hygiene at primary production Entire section 3.4 CLEANING, MAINTENANCE AND PERSONNEL HYGIENE AT PRIMARY PRODUCTION Refer to Section 7 for aspects of personnel hygiene in primary production area. Rationale: Please reinsert the title + a reference to section 7 to clarify that section 7 also applies to the primary production, see (i) general comments Hand washing facilities 21. Hand washing facilities should be supplied with hand cleanser (soap) and be within close proximity to the toilets and positioned so that the personnel must pass by them before returning to the food handling area. Where possible, hand washing facilities should have non-hand operable taps to help prevent the recontamination of clean hands and single-use disposable paper towels. Hand washing and drying instructions should be visibly present for all users of these facilities. Rationale for deleting 'disposable paper': In a more developed food safety management milieu, hand-drying will be done using a single-use (washable) cotton towel roll. Other similar systems might also exist as an alternative to the standard disposable paper tissue, which will be more ecological and equally effective. 22. Hand washing sinks and drying facilities should be suitably located in food preparation or production areas to ensure food handlers have ready access to them. There should be hand washing facilities within close proximity to the toilets and positioned so that the personnel must pass by them before returning to the food handling area., regrouping of both paragraphs, so the first describes only the equipment of these facilities and the second the place of these facilities. 5.2 Key aspects of hygiene control systems 24. Any food possibly contaminated by vomit particles or by aerosols containing vomit particles should be disposed of. Any food handled by an ill person should be considered a risk and should be discarded evaluated to determine the need to dispose of it. Rationale: Alignment with paragraph Specific process procedures Last bullet Gamma (γ) Irradiation: γ-irradiation may reduce virus infectivity, depending in part on irradiation dose, virus type and food matrix, but it cannot be considered an effective generic measure to reduce viral loads on or in food. Rationale: to be consistent with the wording in bullets 3 and 5. 2

3 6.1.1 General 33. A food establishment shall have a set of procedures to be followed by employees when responding to vomiting or diarrhoea events that involve the discharge of vomitus or faecal matter onto surfaces other than those inside a toilet bowl and that address the specific actions employees must take to minimize the potential for the spreading of contamination and for increasing exposure of employees, food, and surfaces to vomitus or faecal matter. Rationale: even when inside a toilet bowl extra cleaning and disinfection might be necessary, as the door handle, the taps of these sanitary facilities, might also have been contaminated Cleaning procedures and methods 34. Each establishment should have a documented regular cleaning and disinfection procedures. Disinfection should always be preceded by cleaning. It is also recommended that establishments have a procedure for the disinfection of surfaces possibly contaminated with enteric viruses, such as NoV or HAV., to be consistent with paragraph 33 where a set of procedures are required. 38. Experiments have demonstrated that A a vaporized hydrogen peroxide (VHP) treatment at >100 ppm for 1 h has been shown to be effective against bacteria, bacterial spores and a range of viruses including poliovirus, rotavirus, adenovirus, and murine norovirus. This treatment can be applied to whole rooms, including kitchens, and results in disinfection of various different surfaces such as stainless steel and framing panel and is a less labour-consuming alternative to manual disinfection using chlorine solutions. Rationale: VHP is not yet used in practice and was only tested at experimental level. Editorial, 'different' is used in relation to something else. SECTION 7 ESTABLISHMENT: PERSONAL HYGIENE OBJECTIVES: To prevent food handlers from contaminating food with viruses, in particular NoV and/or HAV due to poor personal hygiene. RATIONALE: Food handlers may shed virus and the infectious dose is very low. There is a need for strict personal hygiene of control by food handlers, particularly in relation to the prevention of NoV and/or HAV, contamination. 7.2 ILLNESS AND INJURIES 45. Food handlers with clinical symptoms of gastroenteritis or with symptoms of acute hepatitis should be excluded from the handling of food, food contact surfaces As shedding of viruses, such as NoV or HAV, may continue for several weeks after symptoms have subsided (e.g., NoV can is post-symptomatically be present on average for 4 weeks in the stools of recently infected persons on average for 4 weeks and can be present for up to 8 weeks), training and instructions should be given to all personnel on 3

4 the infectivity, transmission and disinfection of foodborne viruses, and the importance of following strict hand hygiene instructions at all times., better text flow SECTION 9 PRODUCT INFORMATION AND CONSUMER AWARENESS 9.4 Consumer education Countries should give consideration to educational programs to make consumers more alert to the risk of viruses in certain ready-to-eat foods, such as raw bivalve molluscs harvested near areas of human habitation (e.g. presence of sewage plants)., it seems appropriate to put this new paragraph under the heading of 9.4 Consumer education. This might also have an impact on the numbering of other paragraphs. ANNEX I CONTROL OF HEPATITIS A VIRUS (HAV) AND NOROVIRUS (NOV) IN BIVALVE MOLLUSCS SECTION 3 - PRIMARY PRODUCTION Para 6 The sanitary survey of harvesting and/or growing waters should include an assessment of possible human faecal contamination sources. and tthe intensity of the survey should be in agreement with the occurrence of viral diseases in the human domain and weather conditions, e.g. after heavy rain fall rainfall The EUMS suggest replacement of the above sentence with (if this was not retained, the above amendments could be considered): A sanitary survey of harvesting and/or growing waters should be conducted prior to the commencement of growing and/or harvesting operations. The following are examples of factors that should be addressed during the sanitary survey and where possible supplemented by a practical shoreline survey: location and extent of the bivalve mollusc fishery type of shellfishery (species, method of harvest, seasonality of harvest) location, type and volume of sewage discharges location of river inputs and other potentially contaminated water courses (from maps/nautical charts) location of harbours and marinas (from maps/nautical charts) hydrographic and hydrometric data existing microbiological data from water quality or shellfish monitoring undertaken in the same area or adjacent areas. Areas of recreational bathing Rationale: The sanitary survey is an essential first step in assessing the safety of shellfish growing and harvesting areas. Due to the inadequacy of post harvest treatments to consistently reduce virus particles to safe levels prevention of contamination is paramount. The current sentence is confusing and does not emphasise the importance of the sanitary 4

5 survey. All surveys should be comprehensive and the provision of more details on the factors to be accounted for would provide countries with better guidance. ANNEX II CONTROL OF HEPATITIS A VIRUS (HAV) AND NOROVIRUS (NoV) IN FRESH PRODUCE INTRODUCTION 3.4 Cleaning, maintenance and personnel hygiene at primary production Entire section 3.4 CLEANING, MAINTENANCE AND PERSONNEL HYGIENE AT PRIMARY PRODUCTION Refer to Section 7 for aspects of personnel hygiene in primary production area. Rationale: Please insert the title + a reference to section 7 to clarify that section 7 also applies to the primary production, see (i) general comments.] Specific process steps Washing: The washing of fresh produce is not a suitable method to eliminate viruses as the surface topography may allow viruses to remain present. Rationale: Washing can be used to reduce the load of viruses in a product but not to eliminate it. It is important not to give the impression that washing is useless. This is also in line with the text in in the main document. 5