Food safety

European vs American food safety standards

Setting up a food business You must know the food safety standards that are acceptable to your local authority. Food ...


Setting up a food business

You must know the food safety standards that are acceptable to your local authority. Food quality is the quality characteristics of food that are acceptable to consumers. You need to consider some prerequisites before setting up a food business. Selection of right premises holds the necessary food regulations & allows you to prepare food safely. The law is complex, and most acts and regulations affecting the food industry are difficult to interpret. However, unawareness or ignorance of the law is no justification in the event of prosecution. 

The European Commission established an integrated approach to food safety 'from farm to fork'. The European versus US Food standards & law systems use different vocabulary, and we need to understand the structure of the food quality & safety standards first. 

The American food standards are examined by the Food and Drug Administration (FDA) of the United States Department of Health and Human Services (HHS), and the Food Safety Inspection Service (FSIS) of the United States Department of Agriculture (USDA). While the FSIS is accountable for examining poultry, egg, and meat products under the Meat and Poultry and Egg Inspection Act and for certifying organic products, the “FDA is responsible for almost all the remaining food supply

Whereas the food safety system in Europe is comprised of 27 member countries, and each generally developed a distinct food safety system. EU food safety legislation is more focused on food processing than farmers, who are greatly impacted by laws related to the management of animals, the usage of veterinary medicines and pesticides, and the enforcement of agricultural plans. The General Food Law Regulation in Eu guarantees the highest level of protection of human life and consumers' interests regarding food while ensuring the current functioning of the internal market.

Everyone involved in the food business, from farm to fork, shares equal responsibility to follow the food safety standards. The government plays a vital role by creating standards and administering their enforcement. Secondary roles are to be followed by trade and consumer organizations that inform policy, professional organizations, and academic institutions engross in research and education. Food safety involves the control measures and conditions necessary to control hazards and to protect consumer's health from any harm injury, or, illness. Those working with food can avoid food poisoning and other illnesses by practicing the four C's of food safety – cross-contamination control, cleaning, cooking, and chilling. 

 

What are food safety standards?

Food safety standards are a set of principles that a food must meet if it is to be appropriate for human consumption, such as food source from where it is purchased, color, permissible additives, freshness, composition, and total bacterial count. 

Food quality is a vital key to the success of the food products with regards to a food business to remain competitive in the global food market. It signifies all the traits and parameters of food items are acceptable to the consumer. The food quality parameters include external factors such as appearance, color, size, shape, gloss, texture, flavor, and consistency. The perception of product quality is not so abrupt and obvious. 

Although not commonly accepted, the definition for quality with greater unanimity is that "suitability for the consumer usage."

In 2019, the EU reviewed its General Food Law Regulation intending to increase the transparency of the Europe risk assessment in the food chain, strengthening the reliability, objectivity, and independence of the studies used by EFSA. The new provisions have applied from March 27, 2021. 

european vs american food standards


Food safety systems in the US and Europe

EU laws are harmonized by the European Food Safety Authority (EFSA), while the U.S. food processing sector is broadly regulated by state and federal agencies USDA FSIS. Food and drug administration responsibilities include measures to protect “the public health by assuring that food are wholesome, safe, sanitary and labeled properly while European food regulations cover the risk assessment, conducted by the EFSA, and risk management, conducted by the European Commission. One of the main dissimilarities between the US and EU food safety systems is the federal and centralized character of the United States versus the non-federal organization of Europe. At the same time, the implementation of food-related laws and enforcement in the U.S. is concentrated on a federal level.

 

What types of food safety standards are used in food production?

Food must be kept safe and of good quality in the supply chain for national and international trade. There are multiple food safety standards used in food production: International public standards (such as Codex Alimentarius), the foreign (importing) retailer's standards, internationally recognized food safety standards,  the importer's public standards, which may vary from country to country, domestic retailers standards, and domestic public standards. 

The food safety laws and regulations are implemented by food authorities and enforced by law and are usually developed and published under the umbrellas of national & local standards bodies. The developed countries should adopt the regulations for many types of food. However, differences in the quality standards do exist. It is because of variances in the background where the food is grown, climatic conditions, different food habits, and dissimilarity of raw material.  

In Europe, the EFSA evaluates the safety of regulated food ingredients such as additives,  enzymes, flavoring ingredients, and nutritional substances, intending to support risk managers in authorizing their use in foods. For example, EFSA has evaluated thousands of flavorings used in foods by 2020.  Access to an adequate amount of safe and nutritious food is key to sustaining life and promoting good health. Unsafe food containing harmful microorganisms, viruses, parasites, or chemical residues can cause more than 200 diseases ranging from diarrhea to cancers.

Why do restaurants follow food safety regulations? 

Your business reputation hinges on your customer's trust in the food premises to serve safer quality food. If word gets out that your egg salad sandwich, sushi, oysters, or steamed mussels caused food poisoning, you’ll not only lose customers and your reputation but may lose your food permit, fines and legal implications may occur.

Food safety standards help hotels, restaurants, catering companies, cafés, stores, canteens, and airlines to prepare and serve food safely so that customers don’t become sick. It is a moral, legal, and commercial obligation to provide safe food to the customers. It is by law for the restaurants to follow food safety regulations to make sure that they’re serving safe, quality food. Chicken that will be served undercooked or not properly defrosted, products made from raw eggs such as mayonnaise and mousse, shellfish, wild mushrooms, and fish must be sourced from approved or reputable suppliers or vendors. 

To run a successful food business, it must comply with the food safety law that will result in satisfied customers, brand protection, less food wastage, and higher staff morale and promotes increased productivity.  

Precautions must be taken to avoid the cross contaminations issues, for this raw food must be kept apart from high-risk food. It is recommended that separate clearly labeled units be used. A supervisor or manager is responsible for the overall process, including receiving the raw product, temperature monitoring, pest control, and personal hygiene competency under the requirements of HACCP. 

Supervisors have a key role in the successful implementation of HACCP and the promotion of positive food safety culture. Food safety awareness and induction training depending upon the level and understanding of personnel to be conducted and the laws to be implemented. High standards of personal hygiene are essential to prevent the contamination of food by food handlers. Many organizations have developed their quality assurance systems and may comply with the ISO 9000 series. More than 20 systems for quality assurance, food safety, retail trade systems, and certification systems are used in Europe. These standards have been developed by the industry to inflict standards on a great variety of food products. However, although food safety standards cover about 80% of the food production in Europe, consumers may still find it difficult to choose the right product, as standards differ in transparency, action, documentation, and control. Quality must be built into a food product – it cannot be inspected into it. 

 

COMPARATIVE ANALYSIS BETWEEN EU VS AMERICAN FOOD SAFETY STANDARDS

The great concern lies with consumers, who must be aware of the level of safety associated with the foods they buy. The main difference between the US and Europe is that Europeans do not let known or suspected carcinogens (cancer-causing agents) in their food. In contrast, the common use of Potassium Bromate KBrO3 (added to flour to make the dough rise higher and turn stark white) and Azodicarbonamide, or ADA (a whitening agent for cereal flour), are common in the United States, and not allowed in EU for human consumption. To understand the differences between European vs American food standards, the assembly of each system needs to be taken into consideration.

  America Europe
Food Regulations The food regulations in America is carried out by four major agencies: the Food and Drug Administration (FDA), which is part of the Department of Health and Human Services (DHHS), the Environmental Protection Agency (EPA), the Food Safety and Inspection Service (FSIS) of the US Department of Agriculture (USDA); and the National Marine Fisheries Service (NMFS) of the Department of Commerce. In Europe, the central government has been given the charge for protecting public health and ensuring food hygiene and safety legislation to local authorities.
Labeling Allergens In the US the Food Allergen Labeling and Consumer Protection Act (FALCPA) governs allergen labeling requirements for all FDA-regulated consumer-packaged foods but does not cover poultry, most meats, certain egg products, or most alcoholic beverages. The European regulations require food businesses to provide written oral information about allergenic ingredients for non packaged food such as retailers, restaurants, takeaways, bakeries, etc.
Common Allergens According to FDA policies, food packaging must disclose the presence of the following common allergens: milk, egg, fish, shellfish, tree nuts, wheat, peanuts, and soybeans. EU FIC guidelines require the compulsory listing of 14 common allergens.
Use of Chemical preservatives: What's the difference? Chlorine for washing chicken: American slaughterhouses wash chicken carcasses with chlorine after slaughter to kill any bacteria left on the skin in their production process. Stop chemical contamination:
The EU considers that depending on chlorine rinse at the end of the meat production, this could be a way of compensating for poor hygiene standards - such as crowded & dirty abattoirs. In comparison, the UK does not allow this practice to keep the meat as clean as possible throughout the processing without counting on decontamination & the use of chlorine.
Growth hormones are the new norm: The US uses growth hormones in animal feed to accelerate growth and boost up production. Say no to chemical pesticides on food: Pesticide residues are a common concern for European citizens. The EC urges to use the integrated pest management & other approaches such as non-chemical ones.
Use of chemical preservatives in the US: A loaf of bread in the US contains a minimal amount of potassium bromate, and FDA labels it generally recognized as safe (GRAS). According to the EU food safety regulations, the use of KBrO3 and azodicarbonamide are banned to be used as dough conditioners for bread making. Limits are set on the expectations that it is carcinogenic to humans.
GMO TECHNOLOGY The GMO predominantly plants, have been commercially grown in some countries, especially the Americas, since the mid-1990s. GMO plants are not yet permitted in Europe.
USE OF ADDITIVES IN FOOD Additives in US: Additives are referenced on ingredient labels by their full names in the US. Additives in Europe marked as E-Number: The food additives must be authorized, and under European legislation, the EFSA assesses the substance and its intended use and after the approval, a 3 to 4 digit code is assigned as the E Number for the additives.

 

Which countries have the highest food safety standards?

Numerous studies have been conducted into ranking the food standards of different countries, taking into account not only food safety but also food quality, affordability, and availability. A study conducted by the Global Food Security Index (GFSI) enlist the following 10 countries to have the top overall scores for affordability, availability, and quality, and safety. 

  • Singapore
  • Ireland
  • United States 
  • United Kingdom 
  • Netherlands
  • Australia
  • Switzerland
  • Finland
  • Canada
  • France

 

Food safety laws are regulated at the federal level in most countries because state and local government levels and systems are quite complicated and fragmented. As an outcome, the requirements for working and owning a food business usually vary state by state. The food laws will prohibit the import and export of adulterated food products or that have deluded the general food laws in any context. Thus the proper implementation of food laws encourages fair trade practices through compliance. It also helps in the development of the food industry because quality control along sound scientific lines tends to promote better consumer acceptance of foods. 

 

References: https://ec.europa.eu/food/horizontal-topics/general-food-law/transparency-and-sustainability-eu-risk-assessment-food-chain_en

Global food security index 2019 report 

http://www.foodshap.com/blog/author/admin/

ISAAA (2018) Global status of commercialized biotech/GM crops: 2018. http://www.isaaa.org/resources/publications/briefs/54/default.asp. Accessed 26 Nov 2019


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