In response, some 20 UK trade and professional organisations are working together as the Food & Biocides Industry Group (FBIG).
FBIG has developed guidance on the use of biocides in cleaning and disinfection, and is leading lobbying in the UK and previously with the European Commission.
- FBIG’s position paper
- FBIG responses to ACMSF (23 Sept 2018) and 16 April 2019
- ECFF, CLITRAVI, Eucolait & SIPA letter to Almut Bitterhof (EC) re QACs MRLs 24 March 2020
- FBIG submission to HSE on chlorate MRL Compliance (22 May 2020 Final)
- FBIG Chlorate MRLs compliance – Pointers on FBO statement – primary production – 7 September 2020
- Cleaning & Disinfection Technical Fact Sheet 22 Oct 2020
- FBIG submission to DHSC on definition of pesticide (6 Dec 2021)
Good practice for use of biocides
The positions of the food and biocide industries on the issue are aligned, including at EU level. The main aim is now for the EC to recognise in law that it is not appropriate to apply MRLs as biocides used for disinfection (of water and equipment etc) are not being used as Plant Protection Products (i.e. pesticides). Contaminants legal instruments should instead be used, balancing risk, recognising the need for microbiological food safety assurance with potential traces in the diet.
FBIG (via Karin Goodburn of the Chilled Food Association), contributed to the development of GFSI guidance on the use of biocides published in 2019:
- Chemicals in Food Hygiene. Volume 1: The optimal usage of cleaning agents, sanitisers and disinfectants to minimise the risk of traces in foods
- Chemicals in Food Hygiene. Volume 2: Cleaning agents, sanitisers and disinfectants in food businesses: detection of traces and human risk assessment processes
A GFSI technical review of the Relationship of Sanitizers, Disinfectants, and Cleaning Agents with Antimicrobial Resistance, led by Karin Goodburn, was published in the Journal of Food Protection in April 2019.
FBIG and its partners has secured:
- More rational MRLs in EU Reg 749/2020 published on 4/6/20, which came into force on 28/6/20
- Inclusion in the Regulation of the EU definition of ‘processed’ foods from EU Reg 852/2004, and special rules for processed foods
FBIG’s focus regarding chlorate is now on guidance on demonstration of compliance.
The HSE has advised FBIG that ‘companies should issue a statement confirming that, with respect to the practical interpretation of the Regulation in the UK, goods identified as processed foods may legitimately exceed statutory MRLs set for unprocessed foods (with no enforcement or restriction on sale/supply arising), with the following provisos’:
- That these special rules will only apply where businesses provide proof that there have been legitimate chlorate trace inputs at the processing stage, such as through the use of potable water or other sources in processed food production, or through legitimate disinfection practices to maintain hygiene.
- That each food business generates a full description of its production practices to serve as proof that these are legitimate additional inputs leading to the MRL being exceeded.
- Where exceedance results solely from a concentration of the residue through actions such as drying, and not because of additional chlorate inputs at the processing stage. In those cases, information on the process and calculated processing factors should be generated.
- It is also expected that the above arrangements will run alongside continuing industry efforts to minimise uses and traces arising from those uses, provided standards of food hygiene remain high.
- Any steps taken to comply with the MRLs Regulation should not undermine appropriate food hygiene controls.
FBIG suggests that FBOs should prepare such a statement where there is any likelihood of an MRL exceedance so that they can provide this statement to CRD should it be requested in the event of an exceedance arising.
FBIG is issuing a series of guidance documents developed by its members for different sectors of the food industry, published below:
- FBIG FPC CFA Chlorate MRLs compliance best practice guidance – fresh & prepared produce (7/9/20)
- FBIG CFA BFFF Chlorate MRLs compliance best practice – multicomponent foods V1.1 (9/12/20)
- FBIG PTF Chlorate MRL compliance best practice – cured meat, dried milk products, butter (19/11/20)
- FBIG BSDA Chlorate MRLs compliance best practice – soft drinks and fruit juices (21/1/21)
- FBIG Dairy UK Chlorate MRLs compliance – dairy (2/3/21)
Supporting Produce-Related Guidance:
- CFA (2010). Protocol for produce washing. Second Edition
- CFA (2010). Produce decontamination assessment protocol: Part 1 – Attachment
- CFA (2010). Produce Decontamination Assessment Protocol: Part 2 – Washing Validation
- FPC (2013). Guidance for FBOs on the hygienic sourcing, production and safe handling of ready to eat sprouts. Second Edition.
- IFST SOFHT FBIG Cleaning & Disinfection Technical Fact Sheet 22/10/20
- The Changing Face of Disinfection, SOFHT Focus, April 2019
- International Biocide Work – Outputs Revealed, CFA News 51, April 2019
- Pushing Forward on Global Biocides Work – CFA News 49, May 2018
- CFA lobbying secures ‘common sense’ EU agreement on biocides Regulation, CFA News 47, April 2017
- Biocides Defy Clean Definition, Food Manufacture, 13/9/16
- Changes to the regulation of disinfectants and the impacts on the food industry, TIFSIP, 18/8/16
- Cleaning Up Biocides Legislation, Food Science & Technology, August 2016
- EU Biocides Plans Pose ‘Food Safety Threat’, Food Manufacture, 6/4/16
Biocides in disinfectants and sanitisers are used routinely both in food production and in the home to prevent microbiological contamination of our food. They are used throughout the supply chain and are very important in the production of high quality safe food, contributing to food safety assurance and helping to protect the consumer. Concerns have been expressed repeatedly in UK official reports that clear guidance on cleaning and disinfection needs to be made available to enforcers and smaller businesses to ensure that it is being carried out properly.
The European Commission is reviewing regulation of the traces of such compounds in foodstuffs. The presence of a trace of biocide does not indicate that there is any risk to human health. The Commission in March 2017 recognised that positive benefits of using biocides to prevent microbiological contamination need to be balanced with the need to set practicable levels
Biocides essential to maintain food hygiene standards
Food poisoning outbreaks are rare in the UK. The UK food industry places an absolute priority on food safety. Good Agricultural Practices, hygienic preparation and packaging minimise the potential for contamination, and the use of biocides and cleaning agents play an essential role in maintaining high standards of food hygiene.
FBIG has stressed to both UK authorities and the European Commission the need to maintain an adequate range of effective biocides and cleaning agents in order not to compromise food safety through increased microbiological risk.
The safety and quality of food is paramount to the industry which is working with the UK authorities and participating in discussions with the European Commission to ensure that food safety remains the key driver for any recommendations to set Maximum Residue Levels (MRLs), or as, FBIG believes, to regulate traces of hygiene biocides and their derivatives under contaminants legislation.
FBIG is seeking:
- Continued ability to responsibly use effective biocides – achieved
- Rational basis for regulation – improved
- Recognise FBOs’ need to be able to protect hygiene for public health – achieved
- Full risk assessment of impacts of biocide regulation review on hygiene including water
- Non-pesticide use should not be regulated under 396/2005, but under contaminants legislation
- No ‘gold plating’, e.g. going beyond scope of legislation applying to end products not listed in 396/2005
- Clear enforcement guidance and rationale – processed foods special rules
FBIG member organisations:
British Beer & Pub Association
British Frozen Food Association
British Meat Processors Association
British Retail Consortium
British Sandwich Association
British Soft Drinks Association
British Specialist Nutrition Association
British Association for Chemical Specialities
Chilled Food Association
Food & Drink Federation
Fresh Produce Consortium
International Meat Trade Association
International Scientific Forum on Home Hygiene
National Craft Butchers
National Farmers Union
Provision Trade Federation
Society for Food Hygiene Technology
UK Cleaning Products Industry Association