31 Ağustos 2011 tarihinde Milano Üniversitesi, Milano / İtalya‘da ISEKI - Gıda Birliği (ISEKI - Food Association) tarafından düzenlenen "Avrupa Birliğinde Gıda Profesyonelleri Mevzuatı (Food Professional Regulation in EU)" başlıklı çalıştaya katıldığımızı daha önce paylaşmıştık.

Çalışmanın gereği olarak Avrupa Birliği Komisyonuna sunulacak rapora katkı metnimiz hazırlanarak iletilmiştir. İletilen metin soru-cevap şeklinde İngilizce olarak aşağıda bilgilerinize sunulmaktadır.

1.        The justification for the regulation of the FT/FE  (food technologist/Food Engineer)

Food safety affects human health directly. Today, great part of the food-borne diseases occur in conditions where safe food production/packaging/storage/transportation are not provided. These foods also facilitate the occurrance of other risky diseases. As number of scientific studies are increasing on this issue, the importance of safe food supply will be understood better. In the EU acquis, in order to eradicate risks originating from zoonoses, strict regulations have been put into force and veterinarian controls have been obligated in slaughterhouses. But, zoonoses are not the only source of food-borne risk for humans. Mycotoxins are carcenogenic metabolites and they are produced during and after harvest or because of improper production practices of farmers. Process contaminants (eg. Acrilamides) may also have adverse effects for human health. Pesticides, dioxin, PCBs that are stored in fat tissues and they lead to risks in milk and eggs. Further, marine biotoxins, PAH, heavy metal traces are risky metabolites for livestock and fishes. The prevention of risks can be realized via considering the scientific basis and mechanism of those risks.  Food professionals are the ones to supply safe food to the society by taking care of these risks.

Although there are veterinary controls before and after slaughter, other risks have to considered during storage, processing or marketing of the product. When the food process stages are scientifially considered, an animal is fed and brought up by zootechnician, animal health care is provided by the veterinarian. Hence, the products of that animal is processed, transported, packaged and marketed and at each of these stages the experience and expertise of food engineers and other  professions are believed to have signicant effect. As an process contaminant, acrilamide is a risky substance in food and only an educated and experienced processor, like food engineers and other related professions, can know how to deal with this contaminant. Therefore, all foodstuffs need to be considered to contain risks in their production processes. In Turkey, food engineers also take courses on zoonoses like E.coli, brucellosis, salmonellosis etc. and food safety problems caused by microorganisms and prevention of disease outbreaks. 

Additionally, implementation of hygiene criteria in food establishments, prevention of environmental contaminants, considering characteristics of foodstuffs (water activity, pH etc.), proper utilization of  food additives, packaging, storage etc., all necessitate expertise in the sector. If we take one of these stages as an example, like utilization of food additives, the misuse of additives is known to cause cancer in human body that can be considered as an important fact why to have food professionals in processing.

In the EU and Turkey, a prerequisite of food safety at processing lines is the implementation of HACCP. Without a food professional, it is generally hard to keep up with these systems in food establishments. To foresee risks, to determine critical control points, to take necessary corrective measures can be accomplished by these professionals in the sector.

Another role played by food engineers/food technologist in the sector is the food control. In the food control laboratories and inspections of establishments food engineers take responsibility with other related professions. Therefore, food control is another important field of food professionals and especially of food engineers with their technical background on design and safe working of food establishments as well as background on microorganisms and laboratory analysis.

As one has to make construction in the presence of a architect and an engineer or a medical doctor is needed to serve for preventive health care and diagnosis, food professionals have to be present in  food production and marketing chain. Hence, it was mentioned in the Workshop that both in Turkey and in the EU, food establishments are SMEs at a great extent. These owners and workers of these establishments are not aware of food-borne risks. Food safety is a field of expertise and this field and its working professionals have to be ruled by a regulation. This regulation should be likely to stimulate food establishments towards employing expert professionals in their sites, no matter how much their capacity are.

2. The advantages and disadvantages of the regulation of the FT/FE

Studying a draft regulation has advantages to reach food safety standards or presence of safe food in the market. General Food Law (178/2002) and Regulation (EC) No. 854/2004 of The European Parliament and of The Council of 29 April 2004 laying down specific rules for the organisation of official controls on products of animal origin intended for human consumption bring the obligation of employing veterinarians for veterinary controls. On the other hand, it is not clear who will provide hygiene inspections or market controls in the sector.  As mentioned above the implementation of HACCP conditions and harmonization of EU norms necessitate employment of expert professionals in every food establishment. Legal definition and employment of food professionals are supposed to create advantage for the consumers via rising production standards towards safer food supply.

Any cost-increasing measure may be refused by private sector establishments. Governments may give supports for the employment of food professionals in the establishments and can give responsibility to these professionals in order to make them contribute to food control system within the production sites.

It was mentioned by most of the participants in the Workshop that food is a multidisciplinary sector. In almost all countries there are different professions employed in the food sector with different education and different job titles. Therefore, it is a hard work to include all professions in one study. A new legislation on professionals should contain probable additional obligations on professions and should also arrange other necessary conditions. Such kind of a study necessitates extra efforts, full support of EU countries and coordination between them.

3. The competences that should be regulated (or that are regulated)

Food engineers, food technologists, milk technologists and other sector spesific professionals (if needed, any additional formation program suitable to their training programme and profession has to defined when employed in the sector), veterinarians (limits of the work field has to be defined and any additional formation program for them has to defined when employed in meat and milk establishments), biologists and chemical engineers (limits of the work field and any additional formation program for them has to defined when employed in food sector).

When we consider the related professions in Turkey, according to the current  legislation; Food Engineers, Agricultural Engineers (Food Technologists, Milk Technologists and Zootechnicians), Veterinerians, Chemical Engineers and Chemists, Fishery Products Engineer, Dieticians and Biologists take responsibilities in the food sector. For none of these professions an additional training requirement has been defined, but the sub-sectors in which each of these professions might be employed are defined.  For example, dieticians can be employed only in catering establishments, veterinarians in meat processing establishments. This current situation has to be regulated according to scientific basis. 

Among these professions only veterinarians, chemical and agricultural engineers have specific laws defining their responsibilities and duties with limits for being employed in the food sector. The definition for food technologists are given in the Law of Agricultural Engineers.

4. If you have some data, it would be interesting to know also what has changed with the implementation of the regulation in Italy/Turkey.

Until the enactment of the Law no. 5996 on Veterinary Services, Plant Health, Food and Feed in 2010; all food establihments in Turkey have had an obligation to employ at least one food professional. In Small and Medium-Sized Establishments a food professional could be employed for one day in a week. Food professionals were responsible from safety of food production  that was defined in the legislation. Because of that hard work, they were called as "Responsible Managers".

With the enactment of Law no. 5996, the employment requirement of food professionals in most SMEs has been dismantled. Only establishments (including food contact materials) that have equipment power of at least 30 hp and employing at least 10 personnel have to employ a food, chemical or agricultural engineer of related sub-topic or a veterinarian according to the work area. However, some of the establishments have to employ one of these professions without any specified criteria, for eg. Meat and meat products processing, functıonal food producing, catering, food irradiating establishments. FCE provides a licence to the member who become an employer in the establisment. Even more than one food engineer is employed in the establishment, FCE gives licence to only one of them but the others have to be members of FCE.

The criteria (30 hp and 10 personnel) used for the employment of engineers and veterinarians in the food establishments is not depending on a scientific criteria but only to a political choice. However, what is needed in any food establishment is food safety that has to be traced by food professionals. Food safety has to be the only criteria in  the employment of these people.