Animal feed controls by Maltese authorities questioned in EU audit

There are “significant gaps” in Malta’s enforcement of animal feed regulations that undermine the effectiveness of official controls, an audit by the European Commission has found.

The audit exposed various deficiencies in the way commercial operators maintain samples of animal feed products to ensure complete traceability. More strikingly, deficiencies noted during the audit had not been flagged during inspections by Maltese inspectors.

Retaining samples from each batch of animal feed is crucial for guaranteeing product quality and safety.

In cases of safety concerns or potential contamination issues, these retained samples play a vital role in pinpointing the origin of the problem to a specific batch. This traceability is essential for identifying and addressing any potential hazards or contamination within the feed supply chain.

The recently published audit was conducted last May by officials from the Food and Veterinary Office.

It reveals significant gaps in the local enforcement system. While many essential components for effective animal feed safety checks, such as training for inspectors, guidelines, procedures, and checklists, are in place, the audit also highlighted critical issues. Specifically, Maltese inspectors exhibited shortcomings in evaluating local companies’ adherence to the rules governing animal feed production, including identifying potential hazards and checking for contamination.

Additionally, the report brought to light deficiencies in the way samples are collected, significantly undermining the trustworthiness of lab results and decisions based on these findings. These issues collectively hinder Malta’s ability to ensure the safety of animal feed. “Cumulatively, the many shortcomings found undermine the effectiveness of official controls on feed,” the report concludes.

Deficiencies in sample collection

During routine inspections by local authorities, an essential aspect is assessing how well companies monitor their products, including taking samples of ingredients and each batch of products. These samples, known as “retained samples,” must be handled according to specific rules. The audit team meticulously examined how companies documented and stored these retained samples during their inspections.

In two companies visited, operators failed to collect or store samples of all the ingredients they used as was the case with amino acids. In two companies, they found that the companies collected samples from the incoming ingredients and used them for their own lab tests, and then they kept the rest as retained samples. This means that the samples had been changed in various ways before they were kept, which isn’t allowed.

In two companies that produce feed materials, the companies consistently didn’t collect retained samples from each batch they made.

Remarkably, these infractions were not noticed in local inspection reports reviewed by the audit team.

Problems in inspections

The report acknowledges that Malta’s Veterinary Regulation Directorate (VRD), in collaboration with the National Veterinary Laboratory, has devised a plan to regularly assess animal feed quality.

The number of samples taken varies based on the number of companies, their production volume, and past inspection results. The plan covers most categories of harmful substances in animal food, but it omits two critical areas – natural toxins from plants and harmful plant impurities, along with pesticide residue testing, with no explanation provided for these exclusions.

Challenges arose due to COVID-19 restrictions, with only half of the planned samples taken in 2020. In 2021, all planned samples were collected, but in 2022, staffing shortages prevented the collection of 20% of the samples.

During a visit to a compound feed manufacturer, the audit team observed an inspector miscalculating the number of samples and failing to use a divider, as required. Moreover, the sampling protocols lacked necessary information about the sampled portions.

Another concern was the designation of three contracted labs in other EU countries responsible for analysing these samples. While these labs met the required standards for laboratory analysis, their designation did not fully align with EU regulations. Crucially, they were not mandated to provide specific essential analytical results, which significantly impacts the validity of testing-based decisions.

Shortcomings in labelling

The audit team identified various compliance issues related to the labelling of animal feed products. These problems included an exceedance of the maximum limit for vitamin A concentration on labels of feed used for fattening pigs.

Furthermore, a lack of instructions for proper use on labels of feed containing additives, as well as incomplete information on labels of medicated feed, was evident. Additionally, a distributor was found to maintain inadequate records regarding the quantities of different batches of medicated feed, an issue overlooked in previous local inspection reports.

Recommendations for improvement

The audit report offers nine pivotal recommendations for competent authorities based on their findings during inspections of animal food control measures. Malta is advised to conduct official controls with a risk-based approach to enhance their effectiveness. The audit also emphasizes consistent verification of feed business operators’ compliance with hazard identification requirements and the prevention of cross-contamination.

In addition, the importance of consistent checks on operators’ labeling and veterinary prescriptions for medicated feed to ensure legal compliance is underscored. The report calls for practices guaranteeing the legal and technical validity of the samples collected by staff during official sampling. The FVO further advocates the inclusion of all mandatory parameters in laboratory reports for tests on undesirable substances in feed to ensure the legal validity of decisions based on these tests.

Malta’s proactive response

In response to these findings, Maltese authorities have initiated several corrective actions. For example, four establishments identified in the audit were urged to improve the handling of retained samples, including the proper collection of samples from each batch of feed materials and final products, the collection of samples from amino acids and premixtures, the appropriate sealing of samples, and the resolution of issues regarding collecting and storing two different samples, one for retention and one for in-house laboratory analyses.

These establishments were provided deadlines in August 2023 to implement the necessary procedures, with the majority in compliance and one still in the process of procuring the required sampling items.

Additionally, local authorities took corrective actions with two establishments, urging them to review the method and results of the carry-over test, which is critical for minimising cross-contamination. One of the establishments promptly provided a correct sampling method, while the other sought clarifications from the Competent Authority.

To further enhance cross-contamination prevention efforts, the checklist for animal feed was updated to include specific inputs in this regard.

Furthermore, in August, Maltese authorities officially designated contracted feed testing laboratories as official laboratories, instituting suitable control arrangements in accordance with EU regulations. These authorities are also in the process of finalising agreements with these laboratories, which will include requirements for receiving audit and inspection reports from relevant competent authorities in other Member States, as well as the need for test reports to include details of uncertainty and recovery values for the tests of undesirable substances.