EU REGULATION 382/2021
CHANGES TO FOOD HYGIENE

On March 3, 2021, the European Commission issued Regulation (EU) 2021/382, which amends Annexes I and II of Regulation (EC) No. 852/2004 of the European Parliament and the Council on food hygiene regarding the management of food allergens, food redistribution, and food safety culture.

While the main changes are related to food allergens (it is worth noting that around 4.0% of the global population suffers from food allergies) and changes in labeling, which led to a specific regulation (Reg. EU 1169/2011), there are several important points for companies working in Pest Management.

In terms of allergens, it is important for biocide manufacturers and distributors to provide the allergen list for products used in food businesses or to have products free of the 8 major food allergens (milk, eggs, fish, gluten-containing cereals, crustaceans, hazelnuts, peanuts, and soy) as outlined in Annex II of Reg. EU No. 1169/2011.

Looking into the details of Annex Regulation (EU) No. 2021/382, two new chapters were introduced. A careful reading highlights points that are crucial for those working in Integrated Pest Management, as they provide valuable insights for becoming an integral part of the increasingly effective management of services with a focus on food safety, quality, and security.

The new Chapter V bis “Food Redistribution” introduced after Chapter V highlights that food operators can redistribute food for donation purposes under specific conditions. It is important to note that, as specified, redistribution must comply with Article 14, Paragraph 2 of Reg. EC 178/2002. Point 2, Paragraph 2 states, “Food operators handling the food mentioned in point 1 must assess… [omitted]…the integrity of the packaging.” A critical eye in Pest Management, in addition to already performed checks on food-specific pests, identifies the need for careful monitoring of opportunistic pests (especially rodents) to spot secondary damage, such as contamination or gnawing of packaging, and to develop Pest Monitoring plans for areas where products may be stored before redistribution.

Even more engaging for a Pest Control Operator is Chapter XI bis “Food Safety Culture”, which contains two highly interconnected points.

Point 1 immediately highlights that “food operators must establish and maintain an adequate food safety culture and provide evidence of this…” This first point closely aligns with current voluntary certifications such as BRC Food Ver. 8 and IFS Food V7, where BRC, in paragraph 4.14.2, specifies that “records (related to pest management) may be in paper format, electronic format, or part of an online system,” while IFS, in requirement 4.13.4, stresses that “inspections for pest control and resulting actions must be documented” and that “the implementation of actions must be monitored and recorded.”

Examining Point 2, which requires management commitment to various actions including “ensuring that controls are carried out effectively and timely and that documentation is up-to-date” and “ensuring that staff receive proper training and supervision,” it seems to echo IFS Food V7’s requirement 4.13.3, which states that “A person within the company must be appointed and trained to monitor pest control measures” and that “even if pest control services are outsourced, responsibility for necessary actions (including continuous oversight of pest control activities) remains within the company.”

Thus, from a careful analysis of EU Regulation 382/2021 – Changes to Food Hygiene, it is clear that companies producing and marketing biocides used in the food sector must ensure increasing quality in terms of equipment and products to avoid any type of contamination. At the same time, they must guarantee ongoing training for food industry operators and Pest Control Companies. These companies, through constant and shared collaboration, are expected to function as true food industry operators. With detailed control plans, risk assessments, and proper documentation, PCOs are called upon to guarantee and implement a culture of food safety.