Since its work began in 2010, FACEnetwork has been trying to demonstrate the legitimacy of the practices applied in farmhouse and artisan dairies from a food safety perspective.
Indeed, the experience of the sector was that, in some countries, small scale cheese and dairy producers sometimes struggled to satisfy their national administrations that their products actually met the requirements of European regulations despite the flexibility allowed in the European « Hygiene Package ». This flexibility covers the application of the regulations, according to the size of the establishments and the « traditional » character of the products made.
FACEnetwork’s work on this topic led to the support of several European Members of Parliament and an agreement by the European Commission to mandate and finance the preparation of a Guide to Good Hygiene Practices (GGHP) for farmhouse and artisan cheese and dairy producers.
The work on the GGHP commenced in 2015. It mobilized the resources of FACEnetwork during a 2 year period. A team of 6 technicians wrote it, with the support of 4 dairy producers. In addition, 11 other technicians and dairy producers were tasked with proofreading the work. The completed guide is the result of the direct collaboration of 21 experts from the 15 countries of FACEnetwork. In addition, approximately 400 stakeholders based across Europe have been informed of our work on the guide as it progressed.
In December 2016, the guide was endorsed by the European Commission and the 28 Member States of the European Union. It is now an official reference document for farmhouse and artisan cheese and dairy producers as well as the competent authorities in each Member State.
The GGHP was published on 17th January 2017 on the website of the European Commission (see on the right). At present, only the English version is available, as the translations in the other 23 official languages of the European Union are in progress. All of the translations will be available from autumn 2017.
What type of guide is the GGHP?
This guide is a voluntary tool. It contains details of good hygiene practices; as practical and preventive recommendations, to help producers to be confident that their products are safe. These specifications comply with the general hygiene legal requirements (Regulation (EC) N°852/2004 and Regulation (EC) N°853/2004).
The Guide also applies the principles of HACCP, following a specific and adapted method, and presents a collective analysis of the hazards concerning the sector.
In addition, as the Guide benefits from the experiences of several EU countries, it provides examples of flexibility measures for small businesses and/or for operators using traditional methods which could be implemented in the application of the legislation. This “flexibility” concerns the possibility to exempt/derogate or adapt some of the content of the hygiene package, particularly in relation to buildings, layout, equipment and operational practices, in some circumstances.
What does the Guide contain?
The guide proposes a complete Food Safety Management System (FSMS) with three big sections:
- Good Hygiene Practices and Good Manufacturing Practices, which are essential to control risk posed by the relevant hazards, which are a foundation for the effective implementation of the HACCP-based plans.
- HACCP-based procedure, including a Hazard analysis and HACCP-based Plans for each family of cheeses and dairy products
- Other management policies, including: Traceability, Self-Monitoring Plans and Non-conformity Management
Which are the hazards taken into consideration?
The hazards’ analysis detailed in the guide leads to the following conclusions:
The most significant chemical hazards are considered to be the presence of residues of veterinary medicines and biocides and the presence of allergenic ingredients based on the frequency of use.
The most significant physical hazards are considered to be the glass and metal contamination based on the severity of injury.
The most significant microbiological hazards, based on the criterion outlined in Regulation (EC) 2073/ 2005 are Listeria monocytogenes, toxigenic Coagulase-Positive Staphylococci (CPS) and Salmonella (in raw milk products).
In addition to the microbiological hazards significant to milk processing, Tuberculosis, Brucellosis and CPS are considered to be the most significant hazards significant during milk production.
Table of content of the draft guide
Section I – THE PURPOSE AND APPLICATION OF THE GUIDE
Section II – GOOD HYGIENE PRACTICES (GHP)
- GHP staff: general hygiene, training and health
- GHP premises and equipment
- GHP cleaning
- GHP disinfection
- GHP pest control
- GHP water quality
Section III – GOOD MANUFACTURING PRACTICES (GMP)
- GMP cultures
- GMP coagulants: production, storage, use
- GMP additions to the milk and curd
- GMP salting
- GMP product storage and transport
- GMP direct sale
Section IV – HACCP-based Plans FOR MILK AS A RAW MATERIAL
- HACCP-based Plan milk production and storage on the farm
- HACCP-based Plan milk collection, storage in the dairy and treatment
Section V – HACCP-based Plans FOR EACH FAMILY OF PRODUCTS
- HACCP-based Plan lactic coagulation cheeses
- HACCP-based Plan enzymatic and mixed coagulation cheeses
- HACCP-based Plan cheeses and milk products made by evaporation and precipitation
- HACCP-based Plan pasteurized milk for consumption
- HACCP-based Plan raw milk for consumption
- HACCP-based Plan butter and cream
- HACCP-based Plan fermented milk products
- HACCP-based Plan non fermented dairy products
Section VI – TRACEABILITY
Section VII – SELF-MONITORING
Section VIII – NON CONFORMITY MANAGEMENT, WITHDRAWAL, RECALL
APPENDIX I – HAZARD ANALYSIS FOR MILK PRODUCTS
APPENDIX II – GLOSSARY
The writing team [names/organizations, country]:
A group of five technical experts from the sector responsible for writing the document:
- Marc Albrecht-Seidel / VHM – Verband für handwerkliche Milchverarbeitung im ökologischen Landbau e.V, Germany
- Remedios Carrasco / QueRed – Red Española de Queserias de Campo y Artesanas, Spain
- Cécile Laithier / Idèle – Institut de l’Elevage, France
- Miroslaw Sienkiewicz / Agrovis & Stowarzyszenia serowarow rodzinnych, Poland
- Paul Thomas / SCA – Specialist Cheesemakers Association, United Kingdom
A group of four producers and one local veterinary inspector working closely with the technical experts:
- Frédéric Blanchard / FNEC – Fédération Nationale des Eleveurs de Chèvres, France
- Kerstin Jurss / Sveriges gardsmejerister, Sweden
- Jane Murphy / CAIS – Irish Farmhouse Cheesemakers Association, Ireland
- Angel Nepomuceno / QueRed – Red Española de Queserias de Campo y Artesanas, Spain
- Irene Van de Voort / BBZ – Bond van Boerderij-Zuivelbereiders, Netherlands
A group of eleven others technicians and producers proof reading the draft chapters all along the program and contributing to corrections, precisions about products or practices:
- Brigitte Cordier / MRE – Maison Régionale de l’Elevage, France
- Sophie Espinosa / FNEC – Fédération Nationale des Eleveurs de Chèvres, France
- Maria Jesus Jimenez / QueRed – Red Española de Queserias de Campo y Artesanas, Spain
- George Keen / SCA – Specialist Cheesemakers Association, United Kingdom
- Marc Lesty / FNEC – Fédération Nationale des Eleveurs de Chèvres, France
- Paul Neaves / SCA – Specialist Cheesemakers Association, United Kingdom
- Bertram Stecher / Sennereiverband Südtirol, Italy
- Katia Stradiotto / ARAL – Associazione Regionale Allevatori della Lombardia, Italy
- Guido Tallone / Casare Casari – Associazione delle Casare e dei Casari di Azienda Agricola, Italy
- Angel Valeriano / QueRed – Red Española de Queserias de Campo y Artesanas, Spain
- Erkki Vasara & Risto Siren / Suomen Pienjuustolayhdistys ry, Finland
General coordination of the project was carried out by:
Yolande Moulem, Co-secretary of FACEnetwork