One of the important roles of SMEs in the European food business is that they offer a great food diversity in Europe. They constitute for 99% of food enterprises, but face a growing level of restrictions in their way of operation. A string of problems with public health in the past, mostly related with big industry, has led to rules and standards of general application. It is necessary to make these rules size-dependent so that they could be usable for an average food operator.

In standardisation we are active in technical committees dealing with machinery used in food sector. As many requirements in this sector are regulated by law, we are also present in the UEAPME Food Group that deals with the European legislation on food. One of the main points of interest of this group at the moment is the regulation on the provision of food information to consumers (i.e. labelling requirements).

Currently our expert Mr Bob Salmon is present in three CEN Technical Committees:

• TC 146 - Packaging machinery - Safety
• TC 153 - Food processing machinery
• TC 182 - Refrigeration systems, safety and environmental requirements

CEN TC 153

TC 153 has ten Working Groups, dealing with bakery machines WG1, meat processing machines like saws, mincers and mixers WG2, slicing machines WG3, catering equipment WG4, centrifuges WG5, pasta processors WG7, bulk milk coolers WG8, fish processing WG11, safety WG12 and hygiene WG13.

The new Machinery Directive has made necessary the revision of most of the standards in this TC. It has introduced the concept of risk assessments to take account of many of the factors including operator fatigue and unauthorised use. It is estimated that there may be as many as 600 standards to revise. As this is a somewhat tedious process there appears to be some reticence among the industry experts to undertake the work.

It is worth emphasising that all those standards are designed for commercial and industrial machines, which means that small producers/users who opt for domestic machines would not be covered by the standards. Thus, it is also necessary to investigate the consequences of this situation, as many small food operators tend to use domestic machines in their commercial activities.

In addition the WGs need to consider that for SMEs it might be more convenient to use multifunctional machinery that could be subject to many different product standards. The problem arises where the primary drive machine is made by one manufacturer and the attachments by another. This issue is under discussion.

Furthermore, the expert of NORMAPME tries to ensure that the machinery receiving CE marking on the basis of compliance with a given standard would not only be safe for the operator but would also assure a safe product.

CEN TC 146

The main work item of the TC 146 WG1 is the revision of EN 415-2 Safety of packaging machines. Pre-formed rigid container packaging machines. NORMAPME expert tries to simplify this standard by proposing reduction of the number of normative references and detailed wording revisions that would ensure that the right terms are used to make the revised standard clear to the average reader.

CEN TC 182

The work of TC 182 is rather technical and there are not so many issues of concern for SMEs. Nonetheless, our expert has already managed to make an important intervention. One new draft standard demanded that any refrigeration system – that is not charged with gas at the factory – must only be adjusted by someone holding a certificate of competence. Most small butchers and retailers will have refrigeration systems for their cold rooms. For them not to be able to turn on or off their plant or to adjust the temperature settings without calling in an expert would be unreasonable. Luckily this point was acknowledged and the standard was amended accordingly.

It is difficult to quantify every benefit for the SME sector that has been achieved in the last years. Things like the height of hoppers on dough mixers which were going to be considerable to allow for purely mechanical filling had to be modified to allow for the craft bakeries to load by hand. Security systems that may be acceptable in large undertakings may be so inconvenient that they are bypassed in a small enterprise thereby exposing employees to unacceptable risks. Furthermore, we managed also to stop the initiative of CEN BT TF 158 to make a standard for drink dispensers (see our position paper on the subject). Besides, we submitted a detailed set of amendments to ISO 22000, a standard on food safety management systems. Some, but not enough amendments were incorporated into the final version and hence we decided that a much simplified approach is still needed.

For more information please contact Mr Maciej Grzeszczyk at m.grzeszczyk@normapme.com

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