Somehow, auditors currently seem to default to viewing failure to comply with a legal requirement as a critical. If the Dutch Food Safety Authority audited in this way, we would have had a recall after every Dutch Food Safety Authority visit. The law distinguishes between primary conditions and principles based on HACCP. Only when food safety is at risk does a critical normally apply, after a risk-based assessment.
In this case, not only when the refrigeration system does not register correctly when products are cooled under the legal norm or when the periodic cleaning van is improved. Moreover, when raw poultry products are transported, between 4 and 5 degrees or the temperature of organ meet is approximately 3,5 degrees during storage and the products will be supplied to the consumer.
These are cases where the legal standard was exceeded. However, these cases are not food safety issues, and therefore a legal incompliance does not equal a critical.
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