Present
- Micheàl O’Mahony, FSAI, Chair (MOM)
- Sally Barnes, Woodcock Smokery (SB)
- Donal Lehane, Chair of Community Food Group (DLe)
- Dave Lang, ACBI, (DL)
- Kevin Brennan, Teagasc (KB)
- John Cunninghan, Beekeeper (JC)
- Blathanid Bergin, The Business of Food, (BB) (for Simone Kelly)
- Aoife MacGiolla Coda, Galtee Honey Farm (AMacGC) (for John Cunningham)
- Mimi Crawford, Crawford’s Farm (MC) (for Mary Regan)
- Sinead Moran, Gleann Bui Farm (SM) (for John Brennan)
- Niamh Hegarty, Bkultured, (NH) (for Dearbhla Reynolds)
Apologies
- Mary Regan, Regan’s Organic Farm (MR)
- Simone Kelly, Rocket Foods, (SiK)
- Kevin Sheridan, Sheridan’s Cheesemongers, (KS) (for Jeffa Gill)
- Jeffa Gill, Durrus Cheese (JF)
- Darina Allen, Ballymaloe Cookery School (DA)
- Gail Carroll, FSAI (GC)
- Sean Kent, Poultry Producer, (SK)
- Dearbhla Reynolds, Cultured Club, (DRe)
- Eoin Cluskey, Bread 41, (EC)
- John Brennan, Leitrim Organic Farming Co-op (JB)
- Hugh Maguire, Maguires Butchers, (HM)
- Tom Dinneen, CAIS, (TD)
- Thibault Peigne, Tartine Bakery (TP)
- Norbert Thul, SE Technological University (NT)
In Attendance
- Eileen Lippert, FSAI (EL)
- Cristina Fernandez-Bugallo, FSAI (CF-B)
- Linda Daniels, FSAI (LD)
- Rob Phillips, FSAI (RP)
- Ophelie Davis, FSAI (OD)
1. Welcome and Introductions
Micheàl O’Mahony welcomed all to the meeting and because there were new alternate members in attendance, invited everyone to briefly introduce themselves.
FSAI noted the agenda items as submitted, informing the committee that one of those (Ultra Processed foods) would be deferred to a future meeting to allow availability of the relevant FSAI expertise. All others were on the agenda.
2. Agree Minutes of Meeting of 1 July 2024
The minutes of the previous meeting were approved without amendment.
2a. Matters Arising other than those on the agenda
There were no matters arising that were not agenda items. The Chair provided a short update on FSAI actions from the previous meeting, all of which were carried out, but some await responses from external stakeholders.
Agreed 1: Include an additional item under AOB - Should information about the chemical sprays used on each product be included on food labels?
2(i) Update on honey fraud
Cristina Fernandez Bugallo gave a presentation to update the Forum on progress since the last meeting with the formation of a Honey Fraud National Working Group of Irish Competent Authorities and outlined changes to the Honey Directive. She also told the members about Import Certificate changes 2022/36 to require honey imported to Eu to be accompanied by an authenticity attestation, and a requirement for honey establishments exporting to EU to be ‘listed’ for that purpose.
After the presentation, the Chair learned that none of the Artisan Forum members joined the EU Commission’s Honey platform as outlined by at the previous meeting.
Action 1: EL will circulate the presentation to the members. (Update: circulated 19.9.24). CFB will provide a further update on this topic at the next meeting
Agreed 2: Honey authenticity will remain as a standing item on the Artisan Forum’s agenda.
2 (ii) Giblets
MO’M confirmed that there is no legal prohibition of harvesting of chicken offal. Competent Authorities are open, in principle, to including such activity in slaughterhouse approval if the necessary food safety assurances are in place. Some slaughterhouses do harvest some offal, but others make commercial decisions not to invest in the systems to harvest these.
2 (iii) Lab data
MO’M confirmed that whilst food business operators are obliged to make the results of their laboratory analyses available to their Competent Authority, those Competent Authorities do not compel food producers to give automatic access to data directly from the laboratory. Food producers may well prefer such a system but are within their rights to say no to this suggestion, provided they have other systems to ensure data availability.
3. Forum Functioning
3(a) Ratify new members and alternates
A list of new members and their alternates was shared with the members in advance of the meeting. MO’M thanked DA for all her hard work on this and welcomed all the new members.
Agreed 3: The members ratified the new members and alternates.
3(b) Terms of reference, proposed changes
The amended Terms of Reference (ToR) were circulated in advance of the meeting, and these led to a long discussion.
Members wanted FSAI to commit to influencing the training of EHOs, but FSAI confirmed that it could not agree to this as the core competencies of third level training programmes are a matter for the training institution. The issue of inconsistency of inspections was raised and discussed at length. Members commented that some producers are afraid to speak up as they are afraid they will be victimised by inspectors and several anecdotal examples were provided. The FSAI did not accept the potential for such outcomes and reminded the members of the recent circulation of all relevant complaints procedures of the respective authorities. The members were reminded that legislation is framed in a non-prescriptive manner to facilitate flexibility meaning that different solutions are possible to achieve the required outcome, but this is a double-edged sword that might result in inconsistency. The alternative is prescriptive legislation with rigid inflexibility which nobody wants.
The FSAI explained its existing work in supporting consistency within and across inspectorates, including the maintenance of an enforcement consistency group with National Environmental Health Service (NEHS). The FSAI gave a specific example that it recently provided training on the official control of production of chocolate and that at this training, the FSAI acknowledged that procedures for the production of artisan chocolate differs from that which is mass produced.
The members thanked the FSAI for all they have done for the Artisan Forum and gave special mention to the Guidance Note on Fermented Foods and the Food Safety Management System Guide for Small Meat Manufacturing Plants which members have found extremely useful.
Agreed 4: FSAI acknowledged there is a need for maintenance of consistency of inspection. FSAI also commented that respect should be mutual.
Action 2: RP agreed to raise this issue of the training of EHOs at TUD.
Action 3: To move from a general discussion and begin to deal with specifics, the FSAI asked the Artisan Forum to prepare the top three inconsistency issues they have encountered/heard about and send them to EL and she will share with RP who will raise them at the FSAI’s Consistency Forum.
Action 4: EL will send the Guidance Notes on Fermentation to Niamh Hegarty. (Update: GNs 33 & 37 sent to NH 19.9.24)
Agreed 5: The members agreed to the amended ToR subject to a review in 12 months.
4. Official Controls at Small Meat Plants
MO’M told the members that a Government Decision was taken to transfer official food controls undertaken by Local Authority Veterinary Services to the Department of Agriculture, Food and the Marine (DAFM). For additional information, a press release from DAFM dated 24 July was circulated to the members.
5. Food Legislation Changes
In response to a request for ongoing awareness of regulatory changes, a short information sheet on regulatory changes that recently came into effect was prepared by FSAI and circulated to the members in advance of the meeting. Members were told that significant editorial decisions were taken to include material of most relevance to Artisan forum, so the document should not be regarded as a complete list and such a document might not be available at every Artisan Forum meeting, but that every effort will be made to keep members updated.
At this point one of the members complimented the FSAI on its training portal and said that details have been shared with his members.
One of the members had a query about necessary frequency of checking PAHs and MO’M said that yes, all producers whose products might contain PAHs should have some testing to inform their awareness of the level of PAHs in their products, but for small operators with consistent production practices it would be reasonable for that to be relatively infrequent e.g. less than annually.
Agreed 6: The members were satisfied with the format and length of the document.
6. Escape of Farmed Salmon
SB introduced this agenda item and gave the background to it and stated that nobody knows what medication these salmon were treated with and asked if there is a system to alert the public about such issues/escapes. FSAI confirmed that there is no obligation for escaped salmon to be notified to FSAI. On the food safety risk of medication, MOM provided some context on the likely times for licensed medicines to be metabolised by live salmon to acceptable levels in their muscle, at typical Irish water temperatures, Some discussion on this issue took place.
7. Myxozoa (kudoa thyrisites) Fish Tissue Degradation
SB raised this item on the agenda and gave the meeting a synopsis of her concerns. MO’M confirmed that this is an animal health matter and with no significant indication of it being a food safety issue. The Emerging Risks Forum is keeping an eye on this issue but actual data on prevalence is poor.
Action 5: MO’M will make the Marine Institute as Ireland’s National Competent Authority for Fish Animal Health aware of the issues raised by SB.
8. Why is Wild Fish Excluded from National Organic Awards
SB introduced this agenda item by explaining that 80% of the public thinks that wild salmon is organic, and this is something that needs to be addressed. FSAI confirmed that the EU sets out the terms for organic production and it is regarded as a form of agriculture, thereby for fish, a system where animals are owned and kept by someone during their growth, therefore not including wild catches.
Action 6: FSAI will circulate the EU organic legislation to the members. (Update: Legislation circulated 19.9.24). He will also convey these concerns to Bord Bia. Meanwhile, while wild fish is excluded from the National Organic Awards, there is nothing preventing SB from setting up other e.g., wild-only, or wild & organic awards and she and DL will liaise on this.
9. Proposal for Guest Speaker on Protected Food Names and Protected Traditional Practices
Action 7: DA proposed a speaker on this topic and FSAI will arrange for him to speak at the next meeting of the Artisan Forum.
10. AOB
Should information about the chemical sprays used on each product be included on food labels?
MO’M confirmed that there is nothing in legislation that says that chemical sprays must be included on food labels. There is a requirement that only approved pesticides be used and there are testing and limits in the background. There is also a particular EU initiative ‘Sustainable use of Pesticides’ to bring about decrease in their usage.
Action 8: Invite Karl McDonald to present on what is being done to manage pesticides in food at the next meeting. The Sustainable Use of Pesticides EU Directive will also be circulated to members for information. (Update: SUP circulated 19.9.24)
Training of EHOs
BB queried if it would be possible for EHOs to do a masters in traditional artisan methods? LD elaborated on how the National Environmental Health Services operates when it needs specialist advice. The Artisan Members reiterated that they are the experts in their field and should be consulted on practices. The FSAI clarified that many of the members’ issues are not within the remit of the FSAI – FSAI is not involved in the training or employing of EHOs. FSAI had recently attempted to re-initiate the dialogue between TUD and Artisan Forum and encouraged forum members to engage with this and bring any proposals for under- or post-graduate training to that discussion.
Two Butchers Shops Closed Down
DL advised the Forum of the closure of two butcher shops over the weekend and wished to mark his concern that butchers are becoming a dying breed.
Dates of Next Meeting
The next meeting will be on 5 December and will be virtual.