The Ministry of Agriculture and Forestry appointed a work group in 2008 to discuss the problems with food legislation and controls experienced by small and medium-sized enterprises in the food sector. The work group operated during 2008. The work group presented three types of development proposals in its report:
- The first development proposal concentrated on legislative requirements and food control. The risks of the operation should be better taken into account when applying the requirements and controls.
- The second development proposal concentrated on taking the customer’s point of view more into consideration in the monitoring. According to the food business operators, different authorities monitor the same target, and secondly, there would be a greater need for advice from the official control.
- The third development proposal was related to slaughter operations, where the fees for meat inspections were considered to be high, and, secondly, the number of animals permitted to be slaughtered in small slaughterhouses was considered to be too low.
Legislation revision projects
Evira is taking part in projects preparing amendments to the legislation under the management of the Ministry. Section 13 subsection 2 of the Food Act (23/2006) concerning such food production and food preparation which is exempt from the conditions for approval of food premises and self-checks is being amended in the spring of 2010. New statutes have been prepared by a work group of the Ministry of Agriculture and Forestry in which Evira also has taken part. The purpose of the change is to remove the requirement for approval at least for food premises carrying out low risk activities. Examples of such premises are retail shops which do not handle unpacked, easily perishable foods at all. Delivery of uninspected meat of wild game for retail sale could also be less restricted than it is currently. Flexibility in the approval of bakeries making the traditional pastry “kalakukko” (fish and pork baked inside sourdough bread) was gained at the initiative of the control authorities by way of amendments to the decrees on food establishments and on food premises of the Ministry of Agriculture and Forestry in 2009.
At the same time, a change to the decree (37/EEO/2006) of the Ministry of Agriculture and Forestry on food establishments is being prepared. The preparation for the change is carried out by the work group of the Ministry of Agriculture and Forestry, in which Evira is also taking part. The decree on food establishments is being changed so that it will contain less detailed requirements on premises and operations. If the revision is realised, it will be possible to use Evira’s guidelines more often than previously for the controls. Less detailed national legislation could make it easier to apply a risk-based approach in the monitoring of different operators and thus to provide more opportunities to be flexible when applying the requirements.
Development of the controls of small slaughterhouses
The Ministry of Agriculture and Forestry appointed a work group on 12.10.2009 to clarify the development of the meat inspection procedures, especially when it comes to small slaughterhouses. A work group was formed, mainly on the basis of the report of the project work group reviewing the problems of small and medium-sized enterprises. In addition to the Ministry of Agriculture and Forestry, the work group consists of operators in the sector, the regional administration, the Association of Finnish Local and Regional Authorities, The Central Union of Agricultural Producers and Forest Owners (MTK), Evira and the Ministry of Finance. The work group is seeking proposals for solutions to for example the high costs of meat inspections in small slaughterhouses.
Evira organises training annually on current issues for the food control authorities. In conjunction with the Regional State Administrative Agencies a total of five events will be held in different venues in the spring of 2010 for municipal control authorities who supervise small slaughterhouses.
Easing the administrative burden
Evira’s result targets for 2010 include a project aimed at easing the administrative burden of food business operators. This will be carried out in co-operation with the Ministry of Agriculture and Forestry and Statistics Finland. An extensive internet enquiry directed at the operators is part of the project and the results will be collated. The enquiry covers two subjects: the costs and work load to the operators caused by the approval procedures for the premises, and the work load caused by recording the results of the self-checks.
The flexibility mission
At the beginning of 2010, the European Commission organised a fact finding mission with the aim of gathering data in six member states. The objective was to gather information on the flexibility of the adherence to the hygiene legislation applied in these member states to small establishments in the meat and milk sectors. Finland took the initiative to be one of the participating member states. Based on this, it is being discussed whether changes are needed in the legislation at Community level, and how the flexibility allowed by the legislation can be increased more efficiently in the member states than it has been. The final report, where the situation in all the participating member states will be presented, will be completed in spring. The Ministry of Agriculture and Forestry and Evira will consider the proposals in the report when developing legislation and control procedures.
In practice the local control authorities are applying flexibility when monitoring small operators. According to Evira’s instructions, for example different small scale activities carried out on the same premises can be approved if they are separated by time. The limits set in conjunction with the approval have to be recorded in the decision on the approval of the premises and the separation by time of the activities have to be described in the self-check plan of the food business operator.