A failure to implement previously recommended supply chain improvements, a lack of adherence by some processing plants to HACCP and Codex practices, as well as traceability lapses are some of the problems identified by inspectors from the Food and Veterinary Office (FVO) after a visit to the South American country earlier this year.
The FVO team highlighted a raft of issues and called on the industry to implement good manufacturing practice after a ten-day visit to Brazil in March 2010. But the delegation did say that some improvements had been made – particularly in harvesting and first drying procedures – since the previous visit in 2004.
Aflatoxins are mycotoxins produced by certain species of Aspergillus, which develop at high temperatures and humidity levels and may be present in a large number of foods. The group includes a number of compounds of varying toxicity and frequency in food - with Aflatoxin B1 being the most toxic compound.
Last year, Brazil exported just under 500 tonnes of Brazil nuts into the EU – of which 161 tonnes were nuts in shells and 317.7 tonnes were unshelled. Aflatoxin contamination is a common problem in nuts. In 2009, there were 518 notifications under the EU’s Rapid Alert System for Food and Feed (RASFF) for aflatoxins in nuts, nut products and seeds - with a total of four relating to Brazil nuts from Brazil. The EU inspects 100 per cent of in-shell Brazil nuts.
HACCP
The EU inspectors listed a range of problems with both the regulatory regime and processing practices in Brazil. They said the country has a number of competent authorities involved in the inspection of Brazil nuts but “their competence and competence and responsibilities are not always clearly defined”.
Whilst highlighting the upgrading of good practice regarding harvesting and first drying, the team also said “a recommendation on quick delivery of collected nuts for industrial drying resulting from research projects in Brazil since the last mission is not being implemented, so further improvements are necessary in this regard”.
Furthermore, not all Brazil nut plants exporting Brazil nuts to the EU have procedures based on HACCP in place, added the report. The inspectors also found facilities used for the storage of incoming nuts and for the final product did not always comply with the requirements of the Codex Alimentarius Code of Practice. Full traceability of the products was not always possible as required by Article 33 of the Code of Practice, said the FVO.
Systemic issues
The inspectors also noted some systemic administrative problems within Brazil’s Ministry of Agriculture and Livestock (MAPA). It said that while MAPA procedures for the control of Brazil nut shipments to the EU do exist, there is no link between the ministry and customs controls. This means products can be shipped into the EU without a health certificate as required by Regulation (EC) No 1152/2009.
MAPA also has introduced a method to follow up on RASFF notifications However in practice these investigations are not always carried out because its system is “very slow”.
“Overall, the current control system in place cannot guarantee that all Brazil nuts exported to the EU meet the conditions of Commission Regulation (EC) No 1152/2009 and comply with the aflatoxins limits specified in the Commission Regulation (EC) No 1881/2006,” concluded the FVO report. “Further efforts are needed, in particular to implement good manufacturing practices throughout the Brazil nut production chain.”