Skip to main content

Artisan Forum Meeting - 1 July 2024

Agreed

Monday 1 July 2024 at 10.30
Online

Present:

  • Micheál O’Mahony, FSAI, Chair (MOM)
  • Darina Allen, Ballymaloe Cookery School (DA) 
  • Sally Barnes, Woodcock Smokery (SB) 
  • Donal Lehane, Chair of Community Food Group (DLe) 
  • Dave Lang, ACBI, (DL)
  • Kevin Brennan, Teagasc (KB) 
  • Kevin Sheridan, Sheridan’s Cheesemongers, (KS) (for Jeffa Gill) 
  • Elisabeth Ryan, Independent Craft Brewers (ER) 
  • Sean Kent, Poultry Producer, (SK) 
  • John Cunninghan, Beekeeper (JC)

Apologies:

  • Mary Regan, Regan’s Organic Farm (MR)
  • Simone Kelly, Rocket Foods, (SiK)
  • Tom Dinneen, CÁIS, (TD)

Absent:

  • Dearbhla Reynolds, Cultured Club, (DRe)
  • Eoin Cluskey, Bread 41, (EC)
  • John Brennan, Leitrim Organic Farming Co-op (JB) 
  • Hugh Maguire, Maguires Butchers, (HM)
  • Jeffa Gill, Durrus Cheese, (JG)

In attendance:

  • Eileen Lippert, FSAI (EL)
  • Gail Carroll, FSAI (GC)
  • Linda Daniels, FSAI (LD)
  • Cristina Fernandez-Bugallo, FSAI (CF-B)
  • Ruth Conefrey, FSAI (RC)* (agenda item 3d)
  • Joe Hannon, FSAI (JH)**(agenda item 6a)

1.    Welcome

Micheál O’Mahony welcomed all to the meeting and especially welcomed John Cunningham to his first Artisan Forum meeting. The meeting was advised that Eoin Cluskey has replaced Declan Ryan who recently retired. 

2.    Agree Minutes of Meeting of 26 June 2023

The minutes of the previous meeting were approved without amendment.

2a.    Matters Arising

There were no matters arising and members stated that actions were completed to their satisfaction.  It was requested that offal from chicken slaughterhouses be discussed under AOB.

3.    Forum Functioning

3a.    Membership and Attendance

The Chair advised the meeting of the new members again and stressed the need for consistency and continuity in the attendance at meetings. 
Action 1: EL will circulate the current membership of the Forum to the members who will advise of any errors on the list. (Update: EL sent to DA)
Action 2:  DA will send the names of two new Artisan Forum members to EL. (Update: DA sent these in August 2024)

3b.    Terms of Reference

The Chair explained that following a meeting with DA & DL, he has been in discussions with FSAI colleagues about the terms of reference and when they are finalized, they will be circulated to the members.  MOM reiterated that the FSAI does not have a role in policy-making.  It advises on policy but does not make policy nor provide a voice for particular groups.  The members expressed concern at this, and the members were advised that if they have specific concerns about policy, they could articulate them via the Artisan Forum who would put them forward to the relevant policy-maker.  The members expressed a desire to be aware of changes to legislation before it is agreed and while this is not the role of the FSAI, the members will be advised by FSAI about upcoming legislation where at all possible. 
Action 3: The FSAI will look at methods of providing advance notice of upcoming legislation where feasible. 
Action 4:   MOM will work on the Terms of Reference and attempt to include the views expressed today and they will be circulated soon. 

The Artisan Forum members thanked the FSAI for making them aware of the recent PAH issue re smoking of food products. 

3c    Meeting Frequency

Agreed 1: The members unanimously agreed that it would be useful to have four meetings per year and that two of these meetings will be in person with online facilities available for those who cannot attend in person.

3d    FSAI Training Portal

he meeting and gave a presentation to demonstrate all the learning and development resources available gratis to members.  The members thanked FSAI for this resource and DL confirmed that the ACBI has links to the portal available on its website.
Action 5: EL will circulate the presentation to the members. (Update: presentation circulated to members 1.7.24)
Action 6: Members were asked to make their colleagues and peers aware of this resource and to provide FSAI with feedback, good and bad, on how to improve the portal.
Action 7:  DA will provide EL with contact details from Ireland’s Blue Book and Hidden Ireland so that FSAI can arrange to demonstrate the portal with them. (Update: contacts received 2.7.24)

4.    Honey Fraud

4a.  FSAI Update Presentation

Cristina Fernandez-Bugallo, Senior Agricultural Officer was introduced to the members and MOM explained that Cristina is new to the FSAI and has been tasked with honey fraud as one of her priorities.  She gave a presentation on the FSAI Honey Fraud Working Group that outlined what the FSAI and other official agencies are doing to try to prevent honey fraud.  She also elaborated on the revised Honey Directive (2001/110) which came into effect on 13 June 2024.  She also provided information on the Honey Platform and added that the deadline for interested parties to join the platform is 15 July 2024.  MOM confirmed that the FSAI cannot commit to anything further than what is planned by the Honey Fraud Working Group and the difficulties involved in keeping ahead of the fraudsters. 
Agreed 2: FSAI will keep members updated on the progress of the Working Group. 
Action 8: EL to circulate presentation to the members along with links referred to by CFB which might be useful to members. (Update: presentation and links circulated 1.7.24).
Action 9: FSAI encourages a representative from the Irish beekeeping sector to join the Platform By following the links provided in the presentation which was circulated on 1.7.24. Note closing date 15 July.

JC thanked he FSAI for the presentation and was pleased to see that something was happening in the area of honey fraud.  He would like to see and audit of honey imports into Ireland and DLe was in favour of FSAI carrying out a survey of all honey in the Irish retail market, and emphasised the need for action within a short timeframe

5.    Official Control Consistency

5a.    Non-specific Regulatory Requirements

DA introduced this item and elaborated on how inspectors such as EHOs in various areas require different things from place to place and some anecdotal evidence was cited.  ACBI confirmed that it offered EHO placements but that there was no uptake. The FSAI agreed that the Forum can discuss individual cases as long as individuals are not identifiable, for GDPR purposes.   MOM commented the EU legislation is framed very generally and this has pros and cons, the major benefit being flexibility but the obvious risk being lack of harmonisation.  Members were of the view that there should be a cohort of EHOs who have specific artisan training and that the education piece needs to be encouraged.  The FSAI confirmed that it does not get involved in the operational aspects of the HSE. 

5b    Influencing Third Level Training

It was noted that the FSAI had previously facilitated an introduction to TUD  and members were to follow-up on this.  (Update: On 28.8.24 EL contacted TUD for contact person to arrange follow-up of previous visit to TUD).

Agreed 3:  The FSAI agreed that it facilitate another introduction to TUD for the members to follow-up and FSAI cannot do anything further as it has no remit to influence the curriculum of third level institutions.  FSAI also agreed to invite a Senior EHO to a future meeting of the Artisan Forum and added that inspectors from all agencies are keen to keep training up-to-date.  This will provide members with an opportunity to share their views with the level of training of EHOs in specialised food production. 

Action 10:   FSAI will send information on how small producers can escalate an issue where they have an issue with their inspectors. In response to concerns about negative consequences,  The Chair clarified that all inspectorate are interested in feedback, and complaints will be considered professionally and constructively  with view to optimising regulatory service provision. (Update: EL circulated complaints and appeals procedures 28.8.24)

6.    Hops and EU Pesticides Limits

ER introduced this item and welcomed the reduction in limits for two specific pesticides but had a query regarding this reduction in relation to hops, especially from the USA.   JH addressed this and confirmed that DAFM are the policy lead on this so they should be consulted.  The argument that was proposed is that both pesticides are not transferred to the brew from the hops. This argument has also been used on the contaminants side for metals in grains used for brewing and led to an exemption from the ML for cadmium. The change (requested by IE) was brought in during the Recast and not through an amendment of repealed Regulation 1881/2006, so it’s in the recitals of Regulation 2023/915: 
 
(14)    As regards cadmium, it is appropriate to extend the current exemption for malt to all cereals used for the production of beer or distillates, provided that the remaining cereal residue is not placed on the market as food, because cadmium mainly remains in the cereal residue and therefore the content of cadmium in beer is very low.

The argument that the residues are retained in the hops which are discarded is based around lack of affinity to water (hydrophobicity). Hydrophobicity is determined based on octanol/water partition coefficient. If the substances are hydrophobic, they are likely to stay in the hops during brewing and are discarded. From a good search, Bifenazate and Etoxazole are relatively hydrophobic and therefore this argument may apply.  

Action 11:  MOM and JH to facilitate contact by ER with DAFM PCS to raise this issue with them.

6a. PAH in Smoked Food**

JH mentioned that the Artisan Forum had recently been consulted on this particular issue at an early stage in the process considering that the proposed changes to the legislation may be particularly relevant for smaller operators who smoke meat, fish and cheese.  He thanked SB for providing detailed information on fish smoking practices which was useful to have ahead of the discussions. 

JH explained that PAHs are compounds that arise in some food processes such as barbecuing or smoking. Following the decision not to re-authorise several smoke flavourings, the Commission has begun discussions on reviewing the current maximum levels (MLs) and derogations (of which Ireland avails of) for polycyclic aromatic hydrocarbons (PAHs) in food. This is on the basis of comments received that suggested PAH exposure may increase when manufacturers move away from the use of smoke flavourings towards conventional smoking practices to give food a smoke flavour. EFSA has also been asked to provide a comparative risk assessment between smoke flavourings and conventional smoking practices and a monitoring recommendation with a short timeframe (1 year) has been proposed for furan-2(5H)-one and benzene-1,2-diol in food to contribute towards this assessment.

There was a working group meeting last week on the 27th and 28th June and the Commission indicated that they will be circulating the proposal for targeted stakeholder consultation to EU stakeholder organisation. At that meeting Ireland emphasised the importance to have a long consultation period to allow time to get the views of smaller operators, particularly those smoking meat and fish. The consultation will be open until the end of September. The feedback received will be discussed in a working group after this date.

There was a query about the labelling of smoke flavourings and it was confirmed that smoke flavourings need to be specified on labels. 

7.    Derogations for Local Supply to Retail Establishments

7a.     Specific case of hens’ eggs

DLe outlined this query and how in France and Germany B&Bs make a feature of using fresh, local eggs and he queried if Ireland has this same flexibility. MOM gave a presentation on the four rules that had to be adhered to in order to avail of neighbours’ eggs in a manner exempt from the normal hygiene regulations. He pointed out the alignment between the exemption in the food hygiene regulations, and egg marketing standards for supply to final consumer, but a discrepancy for supply to other local businesses. In short, a B&B cannot use their neighbours’ hens’ in an exempt manner, eggs unless all four rules outlined in the presentation are adhered to and eggs are marked. 

Action 12: EL to circulate MOM’s presentation to the members (update: presentation circulated 4.7.24) and MOM is happy to facilitate a meeting with representatives of DAFM’s egg and poultry section to point out applicability the egg marketing standards. 


8.    Producers Test Results Data

KD outlined this issue.  In summary an inspector is demanding direct access to a producers private lab account in order to review lab testing results. KS explained that some of the results of testing would not be relevant to the inspector.  MOM explained that an inspector can insist on getting data, but legislation is silent on ongoing direct access. 

Action 13: GC and MOM will discuss this matter in more detail with DAFM colleagues and follow-up directly with KS.  If it is a more general issue and update will be provided at the next meeting of the Artisan Forum. 

9.    Raw Milk – Update on Regulations

DA sought clarity on raw milk regulations and if there is a requirement for additional testing or if there has been any change in legislation pertaining to raw milk.  MOM confirmed that there has been no change in raw milk legislation.  The members referred to a recent incident relating to a raw milk producer and a raw milk cheese producer and they commented that the incident needs to be reviewed. 

Agreed 4: MOM is happy to take part in discussions on the aforementioned incident outside of the Artisan Forum and the FSAI would be uncomfortable discussing an incident that involved a small number of producers at an open forum.  (Update: FSAI contacted DA on 8.7.24 re this and DA decided to leave this issue for the time being).

Action 14: The Artisan Forum members will arrange the aforementioned meeting.

Action 15: EL to circulate the 2018 Code of Practice re raw milk and the EU guide for artisan cheese to the members and they were asked to remind members of the sector of the relevance of these. (Update: both circulated 8.7.24).


10.    Animal Remedies in Organic Aquaculture

SB explained the background on this issue and forwarded a press release on the matter to FSAI indicating significant quantities of one product being used in Irish organic aquaculture. MOM confirmed receipt of said press release and he read it with interest.  MOM prepared some slides to share FSAI perspective on this matter and explained that from what he can gather no legislation is being contravened.

Agreed 5:  MOM agreed that there is a misconception about the use of animal remedies in aquaculture but pointed out that the allowance for antiparasitic products in organic aquaculture is more restrictive than other organic provisions. 

Action 16:  EL to circulate the presentation to the members. (Update: presentation circulated 4.7.24)

11.     Food Hygiene Rating Scheme

DL raised this issue which was recently discussed at a Food Safety Consultative Council meeting.  He queried who will develop the final hygiene rating system, how will it work and will there be an appeals system?  MOM confirmed that FSAI’s Scientific Committee is currently discussing this and there are numerous steps to go through and that anything that is introduced will have to comply with regulations.  He added that there will be ample consultation before anything is put in place and that this initiative is very much in the early stages. He described the regulatory basis for this in EU 2017/625 Article 11 and emphasized the provisions there around transparency consistency and fairness.

Action 17:  FSAI will keep the members updated on any changes in this area. 

12. Recent, Incoming or Potential Future Changes to Legislation

12a.    Dry aging of Beef

DL raised this matter and he referred to an article he wrote for ACBI members on the topic.  MOM prepared some slides to assist members on this issue.  He confirmed that new legislation on dry aging will come into effect on 9 November 2024. It was queried if any work has been done on how organic meat ages vs intensely reared meat and it was confirmed that there was not, and members were of the view that this should be considered.  There was also a query about the use of clean dry aging trimmings and it was confirmed that these trimmings can be used to make burgers, but it is not allowed to sell as mince to consumers.  

Action 18: DL sent the article to EL, who will send it to the members for info. (Update: circulated to members on 1.7.24).  EL will also circulate MOM’s presentation on the subject. (Update: presentation circulated 4.7.24)

Agreed 5:  It was proposed by the members that it would be useful if FSAI prepared guidance on dry aging and FSAI agreed with this proposal in principle and will liaise with DL on this. 

AOB

Offal from Chicken Slaughterhouses

DA queried if there is legislation regarding the selling of chicken giblets. MOM confirmed that there is not, but difficulty in sourcing giblets could be due to commercial decisions as there could be difficulties in safely separating offal from chickens. 

Action 19: MOM will look into the harvesting of giblets and respond to the Artisan Forum. 

Dates for meetings in 2024

The next meeting will take place in the FSAI office in September and EL will liaise with DA’s office to confirm a date.  Another meeting will take place in December at a date to be confirmed and the December meeting will be virtual.  Due to time constraints, it will not be possible to have four meetings of the Artisan Forum in 2024, but four meetings will be arranged for 2025.