Risk Analysis for the Inland Waterways Hygiene Code Food and Feed

Centraal Bureau voor Rijn- en Binnenvaart (Rotterdam, Nederland)/ Productschap Diervoeder (Den Haag, Nederland)/ All rights reserved. The information in this publication may be consulted on the screen, downloaded and printed as long as this is done for your own, non-commercial use. For other desired uses prior written permission should be obtained from the Central Office for Rhine and Inland Navigation (CBRB) and the Product Board Animal Feed (PDV).

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1. Inland waterway shipping risk analysis guidance

1.1. Hazards identification The following hazards are distinguished in the hazards identification of the Inland Waterways Hygiene Code: Type of hazard Chemical hazards (C) Description of goods Undesirable chemical substances that may render the product unsafe for consumption. These may be present in the ingredients or contaminate the product during transportn, for example due to contact. Pertaining to presence of undesirable micro-organisms. The micro-organisms may cause contamination or growth due to their (natural) presence, making a product unsafe for consumption. Consumption of the product may in such cases cause food infections or food poisoning. Foreign bodies that may be present in ingredients or may enter the product. This makes the product unsafe for humans or animals. Substances or products which initiate an over-sensitivity response when consumed. Examples Residues of pesticides, hormones, antibiotics, heavy metals, environmental contaminants, mycotoxins, PCBs, dioxins, cleaning agents, lubricants, mineral oils, etc. Pathogenic organisms such as Salmonella, Listeria, Campylobacter, Enterobacteriaceae, moulds. Veterinary risks (animal diseases)

Microbiological hazards (M)

Physical hazards (F)

Glass, plastic, metal parts, stones, remains of packaging materials

Allergens, oversensitivity to food (A)

Grains retaining gluten, groundnuts, sulphite, soya, seafood, coriander, lupins

1.2. Risk assessment The term risk is defined by two elements: seriousness and probability of a potential hazard. The hazard must be of such a nature that eliminating or reducing to an acceptable level is essential for manufacturing safe animal feed (seriousness) and which realistically could be expected to occur (probability). Seriousness is the effect on the target animal's health as well as the consequential damage for humans when products of animal origin are consumed. Seriousness must be based on literature, practical experience and/or experimental data etc., and is classified into three levels:

Seriousness High Medium Low

Explanation Serious diseases, harmful effects and/or wounds, both occurring immediately and long-term effects, possibly with fatal consequences. Substantial diseases, harmful effects and/or wounds, both occurring immediately and long-term effects. Minor diseases, harmful effects and/or wounds, not or hardly occurring, or only long-term effects after extremely high doses

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Both the seriousness for humans and for animals must be established. The highest value applies. Probability is the chance of a hazard being present in the finished product at the time of consumption by the target animal and/or human. Probability is based on measurements, observations or expectations of the company specific situation and may be classified in three levels:

Probability Low Medium High

Explanation Theoretically possible, but hardly occurs in practice May occur, it has been known to occur with some frequency Occurs frequently

Probability x seriousness results in Risk, which may be classified in four levels:

Probability of presence in product (P) Seriousness of the hazard (S) High Medium Low Low 3 2 1 Medium 4 3 2 High 4 4 3

A company can ensure that the probability of risk is reduced and controlled by taking (control) measures. The next section provides more information about this. If the risk assessment of the hazard results in 4, it does not involve a critical control point (CCP). This determination will be made during the next phase in HACCP analysis. This serves to determine if a risk actually concerns a CCP. However, the company must realise that action is required for higher risks.

1.3. Determining control measure Once the risk class has been determined, it must be established which measures are necessary and where in the process to control these risks which means to prevent them or to reduce to an acceptable level. These measures are called control measures. The classification into a risk class determines the control measures to be taken. The following distinctions are drawn: Risk category 1 2 3 Control measures No control measures required No control measures required but review this conclusion periodically during the verification to be carried out annually Control measures required. In general, control by way of general control measures from the basic prerequisites programme will be sufficient. Specific control measures are necessary, specially developed to control the risk.

Control measures can vary from technical/technological solutions to organisational and/or procedural measures.

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1.4. Determining critical control points (CCPs) There must then be an assessment for each risk and the associated control measure whether this control measure is the last measure in the process of controlling this risk. If so then that point in the process is a critical control point (CCP). The assessment of whether a control measure relates to a critical point should take place systematically. An aid in this is the CCP decision tree. Each step in the process and the associated risk and control measure should be run through the CCP decision tree. Decision tree

Question 1 Which type of control measure is required according to the risk assessment (section 1.3)?

1 2 3

1. None 2. None 3. General control measure Are the relevant general control measures present and have these been implemented? If necessary draw them up and include in the validation and verification procedures 4. Specific control measure. Go to question 2

Question 2 Are the relevant specific control measures referred to present and implemented? NO Change the process, the process step or the product and start again at question 1

YES Question 3 Is this control measure specifically intended to eliminate the risk or to reduce it to an acceptable level? NO Question 4 Will a subsequent step eliminate the risk or reduce it to an acceptable level? NO YES

CCP

YES There is no CCP include in validation and verification procedures and continue with the next risk

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Control measures which are associated with Critical Control Points (CCPs) will be classified as specific control measures. Specific control measures relate to (process) parameters which can be so controlled that hazards related to the safety of food and feed are avoided, eliminated or reduced to an acceptable level. Specific control measures must be supported by instructions or specifications, education and training courses. The control measures must be monitored, provided with corrective actions and the control measures must be validated and verified. These obligations are discussed in detail in the following sections. Control measures which are not associated with Critical Control Points (CCP) will be classified as general control measures. General control measures are actions or activities which are often part of basic requirements programmes such as training of the personnel, infrastructure, vermin control and cleaning programmes, etc. General control measures must also be validated to demonstrate the proper functioning of the basic prerequisites programme. The general control measures are approved after validation.

1.5. Determine norms (action and rejection limits) for CCPs On the basis of the decision tree the critical control points (CCPs) within the process are established. By this is meant parameters (for example time and temperature) which can be controlled in such a way that the risks are avoided, eliminated or reduced to an acceptable level. A determination must be made in this step of for which measurement values for these CCPs a safe product can still be provided. This measurement value is called the rejection limit. A rejection limit is a value which designates the line between an acceptable and an Unacceptable product. If this limit is exceeded then the product is not suitable for use as food or feed. In order to limit the presence of risks as far as possible and therefore to prevent rejection of the products an action limit should also be established. An action limit for the parameter involved is derived from the rejection limit and should be clearly lower. If this limit is exceeded then an investigation into the cause should be undertaken and corrective measures should be taken to remove or control that cause. When establishing the action and rejection limits with respect to CCPs it is mandatory to comply with the requirements set by the relevant legislation and regulations. If there are no legal or sectoral action or rejection limits then the norms with respect to CCPs must be supported through company research and recorded.

1.6. Monitoring of CCPs The company must establish and implement a monitoring plan. Monitoring is the planned measurement, analysis and/or observation (visual testing) of the process parameters in order to be able to establish where a CCP is under control. The monitoring of CCPs can be a continuous, semi-continuous or random sample measurement depending on the process step and the nature of the (process) parameter to be measured. The results of the monitoring are documented.

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1.7. Determining / recording corrective measures with respect to CCPs After the establishment of action and rejection limits and the setting up of a monitoring programme, a decision must be made on corrective actions to be carried out if a rejection limit is nevertheless exceeded. In that case the safety of the end product can, after all, no longer be controlled. If there is no continuous monitoring then the corrective action must apply to the batch in question from the previous measurement moment. A distinction can be made between corrective actions to be taken internally (within the company with the aim of preventing delivery of the product) and external corrective actions such as the recall of a product. Such corrective actions should include the following: Specification of the person or persons who is or are responsible for carrying out the corrective action A description of the resources and the action to adjust the observed deviation The actions which must be taken with respect to products which are produced in the period in which the situation was not under control. A written record of the action taken, such as date, time, type of action, person involved and the subsequent check.

1.8. Validation and verification of the HACCP system Before the HACCP system is put into use it should be assessed to see if it can work as intended which is called validation. The HACCP system is then put into use after which there must be verification of whether it works in practice as it was intended. 1.8.1. Validation Before the HACCP system is put into use it should be established whether the HACCP system can work in practice. A determination must be made of whether the developed control measures will be able to control the hazards. This is also called validation. The following aspects should be assessed: the list of potential hazards which was drawn up is complete and is based on proper scientific data; the questions asked to check the meaning of the risks are answered on the basis of sound scientific data and technical expertise the general and specific control measures are sufficient to control the hazards fluctuations in the characteristics to be controlled (equal to a process criterion) with the established critical limits will have no influence on product safety. the characteristics and the methods used to monitor control measures are satisfactory corrective measures are satisfactory and will prevent an unsafe product from being released and provide proof that the situation can be immediately corrected. Each time that the company makes changes which might have a negative effect on feed and feed safety, the evaluation must be brought up to date. Examples of changes are: new products, the process circumstances (the infrastructure, cleaning programmes) the transport circumstances changes in use by the customer any information which shows that there is a new hazard with respect to the product 1.8.2. Verification Once the HACCP system has been set up then periodic verification of (elements of) the system must take place. Verification is the use of supplementary information to verify whether the system is still effective and whether it functions as intended. The verification is carried out by the company and the findings are recorded in writing. Verification of (elements of) a HACCP system must consist of: 1. Evaluation of the HACCP system and the records kept. This includes the checking of all specific control measures, non-conformities and corrective measures to confirm the implementation and effective control of the critical control Risk Analysis for the Inland Waterways Hygiene Code (February 2009) Page 6 of 16 CBRB/PDV

points (CCPs). And the checking of all general control measures to confirm the implementation and to demonstrate effective control of the related hazards. 2. Assessment of the basic prerequisites programme The company must find out whether the established basic prerequisites programme is still focused on the actual situation. 3. Assessment of analysis data for products. Periodic examination of end products for micro-biological and chemical characteristics is a method of finding out whether the HACCP system is still working as intended. The endproduct specifications are used for this. When analysis results do not conform to the endproduct specifications then corrective measures must be taken. 4. Verification of the hazards analysis. The company-specific process diagrams, map and risk analysis must be reviewed as often as necessary in order to discover whether it still corresponds to reality and whether any new or additional hazards may occur in the raw materials or during the production process. The HACCP team records how often this review will take place but this must be at least once a year or immediately whenever relevant information is made known. This review is relevant when: (the suspicion of) a crisis/emergency a report from an early warning system reports from the media updating of hazard analyses at chain level other indications (own sampling, databases) changes in the process It is even possible that hazards may be discovered which have been denied or not recognised for years. At the moment that a company has insight into the hazard potential then it should be immediately included in the company-specific HACCP plan. Not only external factors but also the results of ones own sampling of products and/or results from databases supply input for re-evaluating the companys hazards analysis and, if necessary, to evaluate it and review it. Assessment of the implementation of legislation and regulations The company must find out if it is still acting in accordance with the applicable legislation and regulations with respect to feed and food safety. The company must also be continually aware of changes to the legislation and regulations. For example: have there been changes with respect to legal or sector norms. Assessment of the level of knowledge of the personnel The company should assess whether the existing level of knowledge of the personnel with respect to feed and food safety and hygiene still matches the desired level. Training courses may be necessary. Internal audits. A large number of hazards are controlled by general procedures, regulations and instructions. These procedures and instructions fulfil many sections of the basic prerequisites programme. An audit has, among other things, the aim to check whether the procedures and instructions are being complied with. The verification of the basic prerequisites programme which covers a large number of general hazards is important for the functioning of the system. Analysis of complaints relating to food and feed safety of products. Complaint handling also provides information within a HACCP system about the effectiveness of the system.

5.

6.

7.

8.

The results of verification must be recorded. The company must evaluate the results of the verification and then record its findings.

1.9. Documentation and Registrations Documentation plays an important role in maintaining a process control system based on HACCP principles. Documentation ensures that the HACCP system is demonstrably present. Documents also provide information to employees about the tasks to be carried out and the agreements made within a company. Documents which must be present for HACCP: Details of the person responsible for HACCP analysis (expertise) Risk Analysis for the Inland Waterways Hygiene Code (February 2009) Page 7 of 16 CBRB/PDV

Explanation of the HACCP analyses with support for the choices made. End product specifications or end product group specifications Process diagrams and a floor plan Basic prerequisites programme as used by the carrier Hazards analysis (tables) Determination and description of CCPs Determining action and rejection limits Corrective measures Description of validation and verification procedures

Record keeping After implementation of the HACCP system data is collected at a number of places which has to be registered. The following are concerned: Monitoring details of CCPs and general control measures Verification of CCPs Verification of the HACCP system through the sampling and analysis of products Verification of the hazards analysis. Internal audits Complaints analysis

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2. Inland waterways transport risk analysis

2.1. Risk inventory and evaluation
Process step Description of the hazard Cat. Chance Seriousn ess Risk Establishment of CCP (SBM) and Control measure ABM V1 CLEANING (SECTION 6.2) Cleaning (bulk, all categories) Unsatisfactory cleaning: the lack of critical parts of the loading system (couplings, hoses, hatches, filters, etc.).) and tools (brooms, scoops, etc.) in the cleaning plan C/M/F/A 1 3 3 3 ABM1 Include both the parts of the loading system and The cleaning of the loading the tools in the cleaning plan. compartment, as holder of the product, is obvious. The cleaning of the loading systems and the tools requires specific attention because of the often difficult cleaning and the great risk of crosscontamination. Correct cleaning instructions depending on the type of load and the model of loading compartment. Use of dedicated transport (feed/food) Unsatisfactory cleaning can have various causes (parts forgotten, incorrect cleaning method, inexpert use of cleaning agents). The chance of cross-contamination is present in all cases. Inexpert use of cleaning agents with hazardous residues can lead to chemical contamination of loads V2 V3 V4 Reason

Insufficient cleaning

C/M/F/A

SBM1

Undesirable residues from cleaning agents

ABM2

Use of cleaning agents which are suitable for surfaces which come into contact with food and feed (=foodgrade) Use of foodgrade cleaning agents in accordance with instructions (pretreatment, dosage, after-treatment) Organoleptic check on residues (odour, foam) from cleaning agents

Pollution due to the use of unsuitable water during cleaning

C/M

ABM3

Exclusively use water of suitable quality

The use of polluted water can nullify the whole effect of an otherwise correctly carried out cleaning Disinfection (after the transport of microbiologically-contaminated batches) is only effective if there is first proper cleaning; organic material is inactivates the disinfectant.

Disinfection (bulk, all categories)

Ineffective disinfection as a result of incomplete, unsatisfactory or inexpert disinfection

1 2 1

3 3 3

3 4 3

3 4 3

J -

J -

ABM1 SBM1 ABM3

See Cleaning: incomplete cleaning See Cleaning: unsatisfactory cleaning Use of disinfectants in accordance with instructions (pretreatment, dosage, aftertreatment) ATP test, agar stamps or check on last flushing water to determine hygiene status

CLEANING (SECTION 6.2) - continued

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Process step

Description of the hazard

Cat.

Chance Seriousn ess 1 2

Risk

Establishment of CCP (SBM) and Control measure ABM V1 V2 V3 V4 LCIs may only be carried out by ISO 17020 or equivalent audit companies 2

Reason

LCI (bulk, all categories)

Carrying out of LCI by an inexpert inspector or an uncertified audit company

M/C/A/F

An LCI must be carried out expertly, but does not in itself improve or worsen the quality of the cleaning carried out.

ACCEPTANCE OF TRANSPORT ORDER (SECTION 6.3) Determination of loading category (bulk, all categories) Cross-contamination due to incorrect loading category before loading M/C/F 1 2 2 2 Confirmation of the loading category by the carrier before loading. Change cleaning protocol in accordance with new loading classification If the next batch is not yet loaded then modify the cleaning in accordance with the new loading category. If the next batch is already loaded then inform the client in question. After unloading apply the correct, stricter cleaning regime. A client may provide the wrong information. If this is noted in time (before the next loading of freight) then the risk is slight. After accepting a transport order a carrier may obtain information about the possible contamination of a batch whereby an LS4 (neutral) batch becomes an LS3 or LS2. This may be a problem for the subsequent freight depending on when the report is made. In specific cases such as glutenfree and biological products, products may require a modified loading category to prevent crosscontamination

Determination of loading category (bulk, all categories)

Wrong loading category after loading.

M/C/F

ABM4

Determination of loading category (bulk, dedicated feed/food)

Incorrect estimation of loading category as a result of the destination of subsequent freights For example: Feed/Food: GMO soya as the previous freight to biological companies. Food: Wheat as previous freight to companies with specific requirements with respect to allergens (gluten)

F/A

Correct and timely provision of information by client with respect to special requirements. Modification of loading category (LS4 > LS3) so that cleaning can be changed. Further specification of products in the dedicated transport statement

LOADING (SECTION 6.4) Check loading category (bulk, all categories) Incorrect cleaning regime due to incorrect loading category designation M/C/F 1 2 2 2 Check carriers product and loading category before starting loading. Change cleaning protocol in accordance with new loading classification A client may provide the wrong information. If this is noted in time (before the next loading of freight) then the risk is slight.

LOADING (SECTION 6.4) continued

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Process step

Description of the hazard

Cat.

Chance Seriousn ess 1 3

Risk

Establishment of CCP (SBM) and Control measure ABM V1 V2 V3 V4 ABM5 Communicate deviations to the customer (customer is responsible for the batch and decides whether or not to transport it) In the event of the actual loading, change cleaning protocol in accordance with new loading category 3

Reason

loading

Delivery of non-standard batch (colour, odour, structure, temperature, (bulk, general cargo , moisture, damaged packaging, broken seals, etc.) all categories)

C/M/F

A deviation in a batch may be known to a customer. In principle this must already have been communicated during the loading order. The customer may, however, decide later to proceed with purchase. The subsequent transports must be protected against cross-contamination. Deviations in prescribed temperatures can have a highly negative effect on food safety. An interruption to the cold chain can also have negative effects which are not resolve by refrigerating or freezing again. General cargo can be damaged by careless loading. Good (transport) packaging and careful loading can control this problem. In most cases the consequences are of a commercial nature and food safety is not threatened. Rain, snow and hail bring moisture into a batch. This moisture can have serious consequences for the quality (overheating, mould formation) Lack of clarity in the tracking & tracing of batches can, in the event of deviations or recall-situations, lead to serious consequences. In theory it is possible that loads have been tinkered with. In the event of a seal it is possible to be alert for this. The chance is small.

Loading Batch with non-standard temperature (bulk, general cargo, conditioned transport)

F/M

SBM2

Check temperature on receipt and compare to customers instructions r standard values from Work Plan 10a (Oils Tanker Transport) or 10c (Other Critical Foods). Record temperatures in the cargo record book.

Loading (general cargo)

Damaged packaging due to careless loading.

Correct supply of packaged products. (wrapped, in transport packaging) Loading instruction (incl. correct use of tools (pulleys, etc.))

Loading (bulk, solid, general cargo)

Contamination of the product by precipitation during loading.

F/M

SBM3

In the event of precipitation, the intrusion of moisture during loading must be minimised.

Loading (bulk)

Reduced traceability do to change of loading compartments or loads

C/M/F/A

ABM6

Check freight documents of offered batch against data from the initial transport order. In the event of doubts, inform the freight broker.

Loading (bulk: tank; general cargo :(sea) containers, IBCs)

Fraudulent actions in the event of broken seals or the lack of seals on loads to be sealed.

C/M/F/A

Check status of seal. If fraud is suspected then inform the freight broker.

LOADING (SECTION 6.4) continued

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Process step

Description of the hazard

Cat.

Chance Seriousn ess 1 2

Risk

Establishment of CCP (SBM) and Control measure ABM V1 V2 V3 V4 Extra check of the parts of the loading system in the event of successive loads. Visual check at the start of loading for mixing in (if possible) Use of dedicated transport (food of feed). 2

Reason

Loading (bulk)

Carry-over / cross-contamination by subsequent loading without proper cleaning of the loading system.

F/A

In the event of multiple loading compartments in a vessel then carry-over can occur in the event of unsatisfactory cleaning of the loading system (pipes, couplings, valves, etc.) in spite of well-cleaned loading compartments. Rain, snow and hail bring moisture into a batch. This moisture can have serious consequences for the quality (overheating mould formation)

TRANSPORT (SECTION 6.5) Transport (bulk, general cargo, unconditioned transport) Water in product due to not or incompletely closing loading compartments. F/M 1 3 3 3 ABM7 Loading compartments must be closed during transport. If ventilation is necessary then only in suitable weather conditions (dry, windy) and under regular supervision.

Condensation and mould formation due to unsatisfactory ventilation of batches which are damp / not fully ripened / refrigerated.

ABM8

Check batch on loading (moisture, temperature). In addition to external moisture Agree ventilation in consultation with the freight (precipitation), there can be internal broker moisture as a result of incomplete ripening or a processing process. Warm batches can also produce condensation during cooling which can have a negative effect on quality. Check ventilation openings on loading. In the event of closed ventilation openings, make a note in the cargo record book. The temperature can climb sharply in metal (sea) containers. This can lead to a reduction in quality and even food risks, certainly in combination with closed ventilation openings. Vermin and pets can cause damage to batches (gnawing, faeces). In addition to physical contamination, pathogens can also be spread in this manner.

Transport (containers, unconditioned)

Condensation formation as a result of temperature variations (possibly in combination with closed ventilation openings)

ABM9

Transport (all types)

Damage by vermin and pets.

M/F

ABM10

Closing loading compartments In the event of ventilation, keep pets under control. Do not allow pets into loading compartments (full / empty) Take suitable measures against vermin. Take care with the effects of pesticides on sensitive inhabitants of the vessel (pets, children)

Transport (all types, conditioned)

Temperature variations due to refrigeration equipment faults.

M/F

SBM4

Properly functioning refrigeration equipment

Refrigerated or frozen products can heat up or even thaw as a result of faults. Lasting microbial or structural damage to products can be caused even after repeated refrigeration or freezing.

TRANSPORT (SECTION 6.5) continued

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Process step

Description of the hazard

Cat.

Chance Seriousn ess 1 2

Risk

Establishment of CCP (SBM) and Control measure ABM V1 V2 V3 V4 Daily measurement of the temperature of the load involved (temperature must be readable from the outside). Check operation of heating equipment 2

Reason

Transport (liquid, bulk, container, conditioned)

Cooling of product due to fault in heating equipment.

Many vegetable and animal oils and fats are are heated while being transported. This is done in particular to prevent coagulation and flocculation and to simplify loading and unloading. Faults in the heating equipment can lead to problems during loading and unloading. The deviations are not, however, permanent and there is no lasting damage. Transport can be delayed for all sorts of reasons so that durations are exceeded. This often causes logistical or commercial problems. Because the delay is often limited to a few days, the risk to food and feed is limited all the more because most products have a long product life and, if this is not the case, then they are transported in refrigerated or frozen condition.

Transport (all types)

Exceeding the maximum transport duration.

M/F

Proper transport planning in which account is taken as far as possible of working and waiting times and delays such as canal locks. Seasonal influences and any blockages due to strikes must also where applicable be taken into account (low river levels, recreational traffic).

UNLOADING (SECTION 6.6) Unloading (bulk) Reduced traceability due to unclear or incorrect data during the transfer of loads. C/M/F/A 1 3 3 3 ABM11 Check freight documents of batch to be delivered against data from the initial transport order and the delivery address. In the event of doubts, inform the freight broker. Extra check of cleaning of parts of the unloading system in the event of successive loads. Visual check at the start of loading for mixing in (if possible) Lack of clarity in the tracking & tracing of batches can, in the event of deviations or recall-situations, lead to serious consequences.

Unloading (bulk)

Carry-over or cross-contamination due to successive loads without proper interim cleaning of the own unloading system (pipes, tubes, filters, couplings, valves, etc.)

F/A

In the event of multiple loads in a vessel then carry-over can occur in the event of unsatisfactory cleaning of the unloading system (pipes, couplings, valves, etc.) in spite of well-cleaned loading Use of dedicated transport (food of feed). compartments.

UNLOADING (SECTION 6.6)

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Process step

Description of the hazard

Cat.

Chance Seriousn ess 1 3

Risk

Establishment of CCP (SBM) and Control measure ABM V1 V2 V3 V4 ABM12 Visual check of cleaning of parts of the unloading system and the unloading location of the recipient. Visual check at the start of unloading for mixing in (if possible) Insight into the cleaning records for the unloading equipment. Record deviations in the cargo record book and also the delivery documents. Sound packaging (wrapped, in transport packaging, on whole pallets, etc.) Unloading instruction (incl. correct use of tools (pulleys, etc.)) 3

Reason

Unloading (bulk)

Carry-over or cross-contamination due to contamination by previously unloaded batches because of contaminated unloading equipment at the receiver (suction, cranes) and poor hygiene circumstances at the unloading location.

F/A/M/C

Cleaning of the unloading equipment and hygiene at the unloading location are, of course, fully the responsibility of the recipient and the ability to check of the carrier is limited. Nevertheless, checking is not an unnecessary luxury and can help to avoid possible (legal) problems during unloading and afterwards. General cargo can be damaged by careless unloading. Good (transport) packaging and careful unloading can control this problem. In most cases the consequences are of a commercial nature (partly dependent on the moment of transfer of the goods (INCO terms)) and food safety is not threatened. Rain, snow and hail bring moisture into a batch. This moisture can have serious consequences for the quality (overheating mould formation)

Unloading (general cargo)

Damaged packaging due to careless unloading.

Unloading (bulk, solid, general cargo)

Contamination of the product by precipitation during unloading.

F/M

SBM3

In the event of precipitation, the intrusion of moisture during loading must be minimised.

Unloading (bulk)

Unrepresentative sampling Contamination with loose objects belonging to the sample (pens, GSM, keys, etc.) Contamination due to contaminated sampling equipment.

F/C F

1 1

1 2

1 2

1 2

F/M/C/A

Careless sampling can lead to an incorrect estimation of quality and often only commercial Check on loose contents of pockets, etc., during consequences. Strictly speaking, sampling. sampling is not the responsibility of the shipper but can be carried out under his supervision shortly before or during unloading. Check cleanliness of sampling equipment.

Supervision during sampling.

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2.2. Risk control: checking, corrective action and documentation.

SBM Number (process) Risk Norms Action limit Rejection limit Cleaning and, if necessary, disinfection of loading compartment and loading equipment and tools in accordance with the instructions in the loading category classification Control measure Method Organoleptic (visual, odour) check of loading compartment and loading equipment Inspection of the cleaning of critical components. Control Frequency After every cleaning Responsibility Corrective action Method Responsibility Shipper Documentation Work Plan

SBM1 Unsatisfactory cleaning (Cleaning) with as a result: - Microbial contamination

Traces (visual, odour) of previous load, dry floors in loading compartments. Salmonella absent in 25g.

Shipper, Inland Clean again, possibly extend waterway transport cleaning (with water, cleaning staff agent) and check again.

Work Plan 5a, 5b and 5c, Appendix 1

- Physical contamination

- No demonstrable traces of glass, metals, plastic - Botanical purity (feed) min. 95% - Contractual agreements

After every cleaning

Shipper, Inland Clean again, possibly extend waterway transport cleaning (with water, cleaning staff agent) and check again. Revise cleaning plan in the event of repeated nonconformity. Inspector Clean again, possibly more extensively and resubmit the loading compartment for inspection. From last non-dedicated load, set new period of 6 months for fresh inspection.

Shipper

Work Plan 5a, 5b and 5c

- Chemical contamination In accordance with legal norms.

LCI

Before every load

Shipper

Work Plan 2

Dedicated transport

Check freights for last 6 months. Comparison to standard value Compare product to recorded batch details

Once on inspection request

Inspector

Shipper

Work Plan 1a, 1b

SBM2 (Loading)

Non-standard temperature with as result: - Physical deviations (colour, odour, viscosity)

In accordance with temperature overviews Work Plan 10. - In accordance with product characteristics in the specification. - Pumpability (fats and oils) Salmonella absent in 25g.

- Measure, compare and record temperature on receipt.

Every relevant Shipper, Inland - Stop loading load waterway transport - Inform client staff - Follow-up action in consultation with client.

Shipper

Work Plan 10a, 10b and 10c. Work Plan 11

- Organoleptic check (colour, structure, odour)

- Microbiological growth

SBM3 (Loading /

Precipitation during loading or unloading with the risk of:

Protect loading compartment and load against precipitation

Supervision of For any form Inland waterway the best possible of precipitation transport staff sealing of the

- Modify loading / unloading in accordance with weather

Shipper

Work Plan 6 Work Plan 8

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SBM Number (process) Unloading)

Risk

Norms Action limit Rejection limit

Control measure Method loading/unloadin g opening and of the loading compartment.

Control Frequency Responsibility

Corrective action Method conditions - Request statement by owner - Note in cargo record book - Inform client - Follow-up action in consultation with client. - Block load - Block load - Note in cargo record book - Inform client - Follow-up action in consultation with client. Shipper Responsibility

Documentation Work Plan

- Physical damage (increased moisture content, damage to packaging) - Microbiological growth

No external traces of damage to products or packaging

Work Plan 11

Salmonella absent in 25g.

Visual assessment of rained on batch for mould or condensation Properly functioning refrigeration equipment - Measurement of the temperature of the load involved (temperature must be readable from the outside). - Check operation of refrigeration equipment

Shipper During delivery of Inland waterway batches where transport staff loading took place during precipitation. Daily for Shipper refrigerated Inland waterway batches. transport staff Registration in cargo record book

SBM4 Temperature variations (Transport) due to fault in refrigeration equipment with as a result: - Physical damage No traces of organoleptic (structure damage, colour deviations in load. or odour deviations, packaging damage) - Microbiological growth Salmonella absent in 25g.

Work Plan 10 a, 10b and 10 c. Work Plan 11

Vessel refrigeration: monthly

Shipper

- Inform client - In consultation, transfer load to another vessel - Note in cargo record book - Repair equipment - Possibly switch to emergency arrangements. - Inform client - In consultation, transfer load to another container. - Note in cargo record book - Possibly switch to emergency arrangements.

Shipper Refrigerated container Inland waterway (reefer): during transport staff loading

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