Major impact of the new version of NVWA info sheet 64

A new version of an info sheet from the NVWA does spark everyone to think again, especially now that the NVWA is actually enforcing its implementation.
This article describes the objective of info sheet 64, the problems that this entails, and gives tips on how to deal with this. Although the principles have not changed, the new version sets the bar particularly high for traders and retail.

Legal basis

Info sheet 64 is about the demonstrable control of food safety hazards related to food procurement (including raw materials). It describes the NVWA’s interpretation of the applicable legislation (Regulation (EC) No. 178/2002, Article 17 and Regulation (EC) No. 852/2005, Articles 3 and 5). This new version replaces the previous versions of info sheet 64 and info sheet 65, where info sheet 64 described the control of hazards of raw materials and info sheet 65 described the hazards of finished products. Both subjects have thus been merged into one document.

Objective

Legislation states that a food company must apply HACCP principles for all stages of the process for which it is responsible. This therefore also applies to the procurement process. These HACCP principles must ensure that only safe products are purchased and that any residual hazards in the own process are controlled. This must be done in a way that is demonstrable. The info sheet 64 focuses on the hazards that the company cannot control itself and that must be prevented or controlled earlier in the supply chain. It describes the responsibility of different types of companies and indicates how a company must make the control demonstrable.

Responsible procurement

A company has the responsibility to only purchase foodstuffs of which the associated significant hazards (which the company cannot control itself) have demonstrably been controlled earlier in the chain. In order to be able to fulfill that responsibility, it is necessary to, in any case, have identified the significant hazards. As a producer, B2B trader, and importer you must demonstrate that they have been controlled. As a private label owner and as a B2C trader, you must make agreements with the producer about its control.

The bar is set high

Each food company is therefore expected to at least identify the significant hazards of the products it purchases. Therein lies a great challenge. This means that the producer, B2B trader, and importer must familiarize themselves with the purchased products and their ingredients. They must identify the associated potential food safety hazards and perform a risk analysis to identify significant hazards. This is a big task, but not new. For the private label owner and B2C trader, they must determine the significant hazards together with the supplier. This clearly goes beyond what is customary in current practice.

Verification control

Because it concerns hazards that a company cannot control in its own process, the demonstrability focuses on verification of the control by the (chain of the) supplier(s). Because it is virtually impossible to analyze every single batch, it is important to demonstrate that the products come from reliable suppliers. By organizing the supplier assessment carefully, you can do this in an efficient way. Here, it is important to check the role of the direct supplier: which hazards does he control himself (and how) and for which hazards does he depend on his suppliers? Sometimes the control of hazards can hardly be attributed to one supplier and is more dependent on the region or the type of product. This must be taken into account in the way of control and how this is to be verified.

Certificates

HDoing supplier audits or purchasing from certified suppliers is another way to demonstrate the reliability of a supplier. The info sheet indicates the requirements that an audit and the audit report must meet. The bottom line is that an assessment must be made at the hazard level, that all hazards are assessed. The report must provide insight into the facts on the basis of which the auditor concludes that the hazard has been controlled.
The info sheet also refers to ketenborging.nl. However, it does place a significant disclaimer here: The certificates listed here are not satisfactory because the stated requirements of an audit are not met. With the exception of one certificate: Riskplaza audit+. This one does comply.
It is not always well understood why a GFSI certificate is not satisfactory: that should also be sufficient, right? However, during the GFSI audits, there is not enough time for a thorough assessment of the control of raw material hazards and the report also provides insufficient information. That is why these schemes do not provide sufficient certainty.

RiskPlaza

The NVWA does have sufficient confidence in the Riskplaza audit+ certificate. Thanks to the connection of the certification scheme to the Riskplaza database for raw material hazards, the hazard identification is very accurate. The audit protocol guarantees an in-depth audit. The detailed audit report provides insight into whether the company purchases food-safe products. The NVWA rewards this with reduced supervision of certified companies.
Because Riskplaza stipulates a valid GFSI certificate as a condition, the hazards that the company itself controls are also demonstrably safeguarded. The combination of these certificates provides a unique assurance. That is why buyers of Riskplaza audit+ certified suppliers may assume that the food safety hazards have been controlled. No additional verification actions are required. Purchasing from a Riskplaza-certified supplier therefore yields enormous savings.

Confident about safe products

During the Riskplaza audit, certified companies are challenged to think about relevant hazards and how a company can convince itself (and thus the auditor and also the NVWA) that the hazard is under control. Thanks to this discussion, a company is not easily caught off guard by questions from customers or the NVWA. It increases confidence that the products that are produced are truly safe for buyers and consumers. Although Riskplaza is not yet well known abroad, companies with the Riskplaza audit+ certificate and (parts of) the audit report can also convince foreign buyers that they are dealing with a reliable supplier. This thanks to the external independent assessment.

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