Two audits by the European Commission’s health and safety agency have looked at checks on food of non-animal origin (FNAO) and bivalve mollusks in Turkey.

A DG Sante audit on FNAO, in September 2022, made three recommendations. The focus was microbiological contamination of soft berries like strawberries, leafy crops such as lettuce, and dry tomatoes for export to the European unio.

Food safety at primary production is addressed through, and depends on, good agricultural practices inspection and private certification systems. However, this does not cover small growers supplying export channels outside the main supermarket chains, and authorities do not verify measures to prevent microbiological contamination.

Turkish officials said to prevent contamination of tomato, strawberry, and lettuce products before and during harvest, several provinces will be told to carry out official controls. Other steps include inspection programs, training, audits, and sampling.

During processing, official controls are in place. However, auditors found shortcomings as some potential risks are not covered. Authorities have not considered the process of drying tomatoes in open fields in control plans, or the risk of Listeria contamination in operators handling products intended to be eaten raw. These compromise the authority’s capability to detect and rectify deficiencies or practices that may pose a risk to consumers, said auditors.

Fruits and vegetables are not part of the annual national monitoring program and official sampling for microbiological analysis is only carried out upon special request or if there are complaints. The plan also does not include environmental samples for Listeria in such establishments. This limits the capacity of official monitoring to provide valuable information to food firms and authorities to address possible contamination in the production and processing stages, said auditors.

Following Rapid alert System for Food and Feed (RASFF) notifications, authorities implemented a monitoring plan for Hepatitis A in dried tomatoes exported to the EU but no more positives have since been detected.

Problems with mollusk controls
The second audit on bivalve mollusks had a remote part in October 2021 and an onsite element in May 2022. It found progress had been made since the last visit in 2015.

Turkey cannot export live bivalve mollusks to the EU but can send frozen and processed ones. All consignments must be tested at EU border control points for E. coli if frozen and biotoxins for frozen and processed bivalve mollusks.

The audit revealed weaknesses in biotoxin testing, which can lead to an underestimation of the number of biotoxins in mollusks. An audit report found the investigation of unsatisfactory microbiological findings is insufficient, which could lead to the misclassification of production areas and inadequate treatment of harvested bivalve mollusks. Incomplete sanitary surveys do not ensure that sampling points for microbiological monitoring are representative of production areas.

Management of re-opening production areas concerning fecal contamination criteria is inadequate and might result in unsafe products reaching the market, said auditors.

Following the extension of a ban on exporting live bivalve mollusks to the EU, Turkish operators tried to adapt to send frozen or thermally processed products instead. This led to the use of sites not prepared for handling and processing such products that had significant structural shortcomings.

The audit team also noted operational problems such as poor set-up and implementation of food safety prerequisites, absence of cold chain management during processing, and a high risk of cross-contamination of the final product. Some operators hadn’t applied or validated thermal processes to kill microorganisms. While companies had food safety management systems, they didn’t cover all hazards and risks.

Auditors said there are major shortcomings in factories which raises food safety concerns about products exported from them.

“The fact that the systematic official inspections of processing establishments did not detect any of the significant problems detected during this audit calls into question the ability of the authorities to enforce EU requirements. The absence of any procedures to verify the effectiveness of official controls raises further concerns over the ability of the authorities to recognize the weaknesses of their activities and their capacity to improve them.”

In the past few years, there were three notifications in the RASFF system for bivalve products from Turkey, one related to high levels of E. coli in frozen bivalve mollusks; another for lipophilic toxins and one due to Salmonella in a frozen pasteurized product. In all cases, the investigation by local authorities did not detect any deficiency in related establishments. However, the audit team noted several issues in one of the sites linked to the Salmonella RASFF case.