In order to implement the important instructions and requirements of the”four strictest”, urge food producers to implement the main responsibility of food safety and the continuous compliance of the production process, further improve the ability of risk prevention and control, realize the expected effect of food safety governance, improve the supporting mechanism and system, and realize good law and good governance in food safety governance, The Tianjin municipal market supervision and Administration Commission (hereinafter referred to as the Tianjin Municipal Market Commission) has prepared and drafted the measures for Tianjin food producers to implement the food safety self inspection system and the management of risk problem reports (hereinafter referred to as the”measures”). The relevant drafting is now explained as follows:
1、 Necessity of formulation
In order to improve the supervision system and mechanism, innovate supervision methods and solve the problems of food safety supervision, we must improve the system of food safety laws and regulations, improve and refine the principled provisions of laws and regulations, and enhance operability. It is necessary to formulate this method.
The formulation and implementation of these measures will help food producers strengthen internal management and process control and resolve potential safety hazards as soon as possible. At the same time, enhance the scientificity, targeting and effectiveness of supervision, and also provide decision-making basis for food safety supervision.
II. Main basis
The drafting basis of the measures is the food safety law of the people’s Republic of China (hereinafter referred to as the food safety law) and the administrative measures for the supervision and inspection of food production and operation (Order No. 49 of the State Administration of market supervision) (hereinafter referred to as the administrative measures for inspection).
(I) the food safety law stipulates that food producers should establish a food safety self inspection system to regularly inspect and evaluate the food safety situation. If the production and operation conditions change and no longer meet the food safety requirements, the food producers and operators shall take corrective measures immediately; If there is a potential risk of food safety accidents, the food production and operation activities shall be stopped immediately and reported to the food and drug supervision and Administration Department of the local people’s government at the county level.
(II) the inspection management measures stipulates that the key points of supervision and inspection of food production links should include food producer qualification, production environmental conditions, incoming inspection, production process control, product inspection, storage and delivery control, unqualified food management and food recall, labels and instructions, food safety self-examination, employee management, information recording and tracing, food safety accident disposal, etc, That is to clarify the food safety self-examination obligations of food producers.
3、 Drafting process
On October 20, 2017, the municipal Marketing Committee issued the administrative measures for Tianjin food production enterprises to implement the food safety self inspection system and risk problem report (Trial) (hereinafter referred to as the measures (Trial)), which came into force on January 1, 2018. After nearly five years of good operation, food producers’ awareness of implementing the main responsibility for food safety has been enhanced, and food safety governance has achieved certain expected results, effectively improving the effectiveness of food production safety supervision.
With the promulgation and implementation of the inspection management measures and the expiration of the five-year period of the measures (for Trial Implementation), the municipal market committee drafted and prepared the measures in 2022.
IV. main contents of the measures
At present, there are 5 chapters and 20 articles in the measures. The first chapter has four general provisions, which mainly stipulate the purpose and basis of preparation, scope of application, scope of responsibilities, etc. Chapter II food safety self inspection includes three articles, which mainly stipulate the obligations and contents of enterprises to establish a food safety self inspection system, as well as the cycle, frequency and reporting method of self inspection. The third chapter, risk problem report, consists of two articles, which mainly stipulates the content, time limit and method of enterprise risk problem report. Chapter IV Supervision and management consists of seven articles, which mainly clarify the relevant measures to be taken by the district supervision department and the legal responsibilities to be borne by the enterprise. There are four supplementary provisions in Chapter V. It mainly stipulates the scope of application, implementation date, etc.
5、 Key points
(I) enterprise self inspection frequency
In order to urge food producers to further implement the main responsibility for food safety, combined with the current reality of the city’s food production supervision, and with reference to the effective operation of the measures (Trial), after repeated discussion and research, the cycle and frequency of enterprise self-examination should not be less than the regulatory cycle and frequency specified in the Tianjin food production risk classification management code. Producers should strengthen the control of production process and investigate potential food safety hazards to implement the main responsibility. Therefore, seasonal food producers should carry out food safety self-examination at least once during the production season to ensure the continuous compliance of food production and avoid all their self-examination during the shutdown period, so as to avoid losing the pertinence and effectiveness of self-examination.
(II) situation of risk problem report
By analyzing the causes of food safety related problems in China in recent years, according to the problem clues of food production supervision and troubleshooting, the control of ingredients, feeding, workshop disinfection, main equipment, inner packaging and other key links, as well as the changes of personnel in key positions such as legal representative, quality director and inspection personnel, are easy to affect food quality and safety. Therefore, the relevant risk problems (including but not limited to the above situations) found in the self-examination of food producers should be actively reported to the regulatory authorities.
(III) retention of risk problem report
Food producers and district regulatory departments should properly keep the risk problem report and refer to its contents, which will help producers implement rectification and improve quality; It helps the regulatory authorities to accurately mine and focus on supervision; It will help producers and regulators draw inferences from one instance and continue to carry out risk screening and prevention and control.
July 5th, 2022