The competent authority responsible for sesame seeds does not carry out any controls on growers, processors or exporters and there is a failure to follow up RASFF notifications, according to audit findings.
Laboratories were capable of relevant testing for Salmonella detection but the approach to sampling of consignments for microbiological testing prior to export was flawed.
The audit from 9 to 17 December 2014 assessed the systems to control microbiological contamination in seeds for export to the European Union (EU).
Increased level of controls
Since 1 October 2014 sesame seeds from India have been in the list of products subject to an increased level (20%) of official controls on imports of feed and food of non-animal origin (FNAO) due to Salmonella contamination.
Between 1/10/2014 until 6/1/2015 there were 14 notifications on the Rapid Alert System for Food and Feed (RASFF) system related to sesame seeds contaminated with Salmonella.
SHEFEXIL (formerly the Shellac Export Promotion Council) is the competent authority for issues relating to sesame seeds but has no powers to oblige exporters to be registered and does not do any official controls at facilities processing sesame seeds.
In response to audit recommendations, SHEFEXIL said all FBO’s involved in processing and exporting sesame seeds shall be registered with it.
“All FBO’s processing and exporting sesame seeds shall implement and obtain relevant certification of HACCP and Food Safety based Management Systems.
“Test report of sesame seeds for human consumption intended for exports to EU confirming to EU requirements of absence of microbiological contaminants following ISO 6579:2002.
“Issuance of Health Certificate (HC) will be issued by SHEFEXIL which confirm to importing country’s requirements only after the consignment clears the laboratory test report for microbiological contaminants and other quality and safety related parameters.”
RASFF notification control
FVO said the system in place for handling RASFFs related to sesame seeds was ‘not satisfactory’.
A number of exporters mentioned in notifications were not SHEFEXIL members and could not be followed up by them, said the FVO.
After the FVO visit, SHEFEXIL is receiving the RASFF’s directly and not through the MOC&I and several action points were put in place including communicate the RASFF to the food business operator within five working days.
It also involves requesting a root cause analysis for Salmonella contamination from the firm within 21 days and an action taken report to avoid Salmonella contamination within 45 days.
Up to 12 RASFFs for one firm in a year would lead to a warning with follow-up for root cause analysis.
Beyond 25 notifications could result in cancellation of registration certificate of exporter, de-recognition of authorized laboratory concerned or other action deemed fit.
A number of consignments tested and found to be Salmonella and E. coli free prior to shipment from India were Salmonella positive in the EU.
Agricultural and Processed Food Products Export Development Authority (APEDA) is the competent authority for sprouted seeds and seeds for sprouting. It had received no requests from exporters for certification to import sprouts and seeds into the EU.
The FVO audit team went on five site visits to processors and exporters of sesame seeds and was told all consignments for export to the EU were required to be sampled, tested and be Salmonella and E. coli free prior to shipment.
Traceability and sampling
There is no system of traceability from growers of sesame seeds to the point of sale, said FVO.
“There is no registration of FBOs involved in processing and exporting sesame seeds for food safety purposes.
“Some of the processors / exporters visited were involved in RASFF notifications, however, SHEFEXIL had not been involved in any follow-up of these. The processors met had HACCP plans in place.”
For each lot which could be up to 38 tonnes, an intermediate sample of five kilograms is taken from which five samples of 500g are produced and sealed.
Two samples are sent to the laboratory and the rest retained by the FBO.
A single analysis for Salmonella and E. coli is done which is not in line with section 3.2 of the CODEX General Guidelines on sampling CAC/GL 50-2004 which requires at least five samples to be analysed.
“Sampling procedures are not standardised and may differ between different sampling services. The sampling procedures observed by the FVO audit team and described in SOPs cannot guarantee that samples sent for microbiological analysis are representative of the whole consignment,” said FVO.
During the audit, at least seven laboratories were identified through reports provided by exporters.
The Indian authority said: “Samples shall be drawn by technical representatives of authorized recognized laboratories as per sampling plan for microbiological testing of sesame seeds and other commodities as outlined in the CODEX General Guidelines on sampling.”