Multi-Annual National Control Plan (MANCP)

The purpose of the plan is to describe how the Norwegian Food Safety Authority organises, plans, prioritises, performs, follows up and reports on official controls in accordance with the Official Controls Regulation (lovdata.no) (OCR).

This MANCP primarily covers official controls governed by Regulation (EU) 2017/625. Other official activities, or control and supervisory activities outside the scope of the Regulation as applicable under the EEA Agreement, are described only where this is relevant to explain the organisation, planning or follow-up of official controls.

Official controls include inspections, audits, sampling, documentary checks and other control methods and techniques used to verify operators’ compliance with the applicable rules.

The Head Office of the Norwegian Food Safety Authority has been designated as the single body for the Multi-Annual National Control Plan (MANCP). The Head Office is responsible for:

• coordinating the preparation of the plan across the inspection divisions and the Head Office
• ensuring that the MANCP is coherent
• coordinating the annual reporting on official controls (AROC) in accordance with Article 113 of Regulation (EU) 2017/625 and the applicable reporting format.

The scope covers all official controls performed by the Norwegian Food Safety Authority to verify compliance with the rules in the following areas:

• food and food safety, integrity and wholesomeness throughout the agri-food chain
• animal health and welfare, including aquatic animals
• feed and feed safety
• plant protection products
• organic production and animal by-products and derived products
• entry of animals and goods into Norway/the EEA, and official controls, official certification and official attestations related to export within the areas listed above.

The Norwegian Food Safety Authority also carries out control and supervisory activities in certain areas that fall outside the scope of Regulation (EU) 2017/625 as applicable under the EEA Agreement. These areas are not part of the OCR-based MANCP requirements but are described where relevant to provide a complete overview of the Authority’s control responsibilities. They are managed according to corresponding principles of risk-based planning, quality and equal treatment, where appropriate.

The MANCP also describes how official controls are supported by delegated bodies, scientific support institutes and laboratories.

Controls performed by the Norwegian Food Safety Authority on behalf of other public authorities are not covered.

The Norwegian Food Safety Authority has developed a strategic compass that summarises its mandate, public mission and overall direction on one page.

More specifically, the objectives are to

• ensure that operators comply with the applicable rules
• prevent and reduce risks to human, animal and plant health
• protect consumer interests and contribute to food safety
• promote a high level of animal health and animal welfare
• prevent and limit the spread of pests of plants and plant diseases
• maintain confidence in the rules, official control systems and competent authorities
• contribute to a level playing field through consistent and effective enforcement of the rules
• deploy official control resources on a risk basis and where they have the greatest effect

Where risk categories are used, they are applied to support consistent planning of official controls across areas. Risk categories are used as an analytical and planning tool and do not in themselves constitute decisions on official control. This means that areas presenting the highest risks to public health, animal health, plant health, animal welfare and the environment are prioritized when official controls are planned and performed.

The organisation has two levels: the Head Office and the inspection divisions.

Head Office

The Head Office performs the Authority’s directorate functions and is responsible for overall governance, strategic development and shared corporate support. It ensures consistent administration of the rules, coordinates contingency planning and international work, handles appeals, and facilitates knowledge-based and risk-based official controls throughout the organisation.

The Head Office operates from six locations, with its main office in Oslo.

Inspection divisions

The inspection divisions are responsible for planning and performing official controls within the Norwegian Food Safety Authority’s areas of responsibility.

The inspection divisions exercise delegated authority as the first-instance administrative level, verify compliance with the rules, provide guidance to operators and individuals, and take administrative decisions in individual cases. They are also responsible for contingency planning and incident management within their respective areas. The operational organisation comprises four inspection divisions: Aquaculture, Terrestrial Animals and Slaughterhouses, Food and Border Control and Plants, Feed and Drinking Water.

Resources are allocated between the Head Office and the inspection divisions based on their portfolio of tasks, the risk picture and priorities. Resource allocation is reviewed regularly to ensure that capacity is aligned with official control needs.

The inspection divisions operate from approximately 100 locations, including border control posts and meat inspection locations.

The Norwegian Food Safety Authority has approximately 1 260 employees, of whom around 700 are inspectors.

The Norwegian Food Safety Authority cooperates with several public authorities, including the Police, Norwegian Customs, the Coast Guard, the County Governors and municipalities. This cooperation supports coherent and effective official controls through exchange of information, coordination of activities, joint follow-up of incidents, and assistance with enforcement and contingency situations.

The Norwegian Food Safety Authority’s powers to perform official controls and take individual administrative decisions are delegated to the inspection divisions.

The delegation covers powers to perform official controls and take individual administrative decisions assigned to the Norwegian Food Safety Authority by law, regulations or specific delegation from the ministries, where the administrative level is neither specified in legislation nor delegated to another body, see The delegation of authority from the Head Office to the inspection divisions. (lovdata.no)

The Norwegian Food Safety Authority performs most of the official controls itself, but certain official control tasks and other official activities have been delegated in specific areas:

• Debio: official controls and decisions relating to organic production
  Debio is a membership organisation whose purpose is to promote trust and cooperation among parties involved in the production, marketing and consumption of organic products.
  
  Debio’s principal task is to verify whether organic operators produce, label and market organic products in accordance with the rules on organic production.
  
  The Norwegian Food Safety Authority audits Debio annually to verify that delegated official control tasks are performed in accordance with the applicable rules and the terms of delegation.
  
  
• County Governors and municipalities: tasks relating to plant protection products and wild oats
  
  County Governors and municipalities have been delegated authority under Section 8 of the Norwegian Regulation on Plant Protection Products (FOR-2015-05-06-455) to organise examinations and issue certificates of authorisation for the use of plant protection products.
  
  Municipalities have been delegated authority to decide on permits for aerial application of plant protection products under Section 17 of the same Regulation. They have also been delegated certain other official activities relating to the management of plant protection product use under Sections 19 and 22.

Norwegian Scientific Committee for Food and Environment (VKM)

The Norwegian Scientific Committee for Food and Environment (VKM) provides independent, interdisciplinary risk assessments to the Norwegian Food Safety Authority and the Norwegian Environment Agency on matters relevant to food safety and the environment. Its secretariat is hosted by the Norwegian Institute of Public Health.

Government scientific support institutes

The Norwegian Food Safety Authority receives research-based scientific support through cooperation with government institutes. This provides the scientific basis for administrative decisions and covers contingency support, reference functions and support for monitoring and control programmes.

The following institutes provide scientific support and perform analyses, investigations and diagnostics:

• Norwegian Veterinary Institute (VI) - terrestrial and aquatic animal health, feed and food safety
• Norwegian Institute of Public Health (FHI) - communicable diseases, drinking water, toxicology and nutrition
• Norwegian Institute of Bioeconomy Research (NIBIO) – plant health, plant protection products, soil and environment
• Institute of Marine Research (HI) - health and welfare of aquatic animals, seafood and feed
• Norwegian University of Life Sciences (NMBU) – animal health, food safety, veterinary medicine and competence development

Other scientific support institutes and laboratories

• Denmark’s Technological University (DTU) – food contact materials
• Kimen Seed Laboratory – seed quality and seed-borne diseases
• Wageningen Food Safety Research – residues of veterinary medicinal products and contaminants in food of animal origin

Details of the services provided are set out in the relevant agreements.

Other advisory bodies

The Norwegian Food Safety Authority obtains advice from:

• Council for Animal Ethics – ethical assessments
• Veterinary Forensic Council – expert assessments in veterinary matters
• National Committee for the Protection of Animals Used for Scientific Purposes – advice on responsible use of animals for scientific purposes

Official laboratories

Official laboratories are designated in accordance with Article 37 of the Official Controls Regulation to carry out laboratory analyses, tests and diagnoses on samples taken during official controls and other official activities.

Designation is based on documented technical competence, including accreditation in accordance with EN ISO/IEC 17025, participation in relevant proficiency testing and access to the necessary resources. Official laboratories must perform their tasks impartially and independently.

Laboratories may be designated following an application, based on audits and proficiency-testing results, through procurement procedures, or by virtue of their function as a national reference laboratory.

The Norwegian Food Safety Authority requires laboratories to notify the relevant authorities of findings that may indicate a risk to health or the environment or non-compliance with the rules. Subcontractors may only be used where they meet equivalent requirements and are approved for the task.

Where relevant findings are made, analyses are to be verified by the national reference laboratory.

Official laboratories are followed up primarily through Norwegian Accreditation and the national reference laboratories, which help to ensure compliance with quality and methodological requirements.

National reference laboratories

The Norwegian Food Safety Authority designates national reference laboratories in accordance with Article 100 of the Official Controls Regulation for areas in which European Union reference laboratories have been established.

The Norwegian Veterinary Institute (VI) has primary responsibility for terrestrial and aquatic animal health and microbiological agents in food. The Institute of Marine Research (HI) covers seafood, Norwegian Institute of Bioeconomy Research (NIBIO) covers plant health and pesticide residues, and Norwegian University of Life Sciences (NMBU) covers algal toxins and bee health. Where the necessary national expertise is not available, laboratories abroad are designated.

The national reference laboratories are accredited in accordance with EN ISO/IEC 17025 and support the quality and consistency of analytical methods. They coordinate official laboratories, participate in EU networks and inter-laboratory comparative testing, contribute to the development and implementation of monitoring and control programmes, provide scientific and technical assistance, report relevant information to EFSA, and provide laboratory support in contingency situations.

Risk-based official controls

For the planning of official controls, the Norwegian Food Safety Authority uses updated situation assessments (up-to-date information base) as the starting point for identifying risks and preparing a documented risk picture. The information base includes, among other things, emerging risks, scientific findings, results of official controls, internal audits, ESA controls and relevant third-country audits.

The inspection divisions are responsible for preparing and updating the information base within their areas of responsibility. The situation assessments provide the evidence base for identifying risks and preparing a documented risk picture. From this, the principal challenges and responsible organisational owners are identified. The risk picture is used as input to decisions on official control priorities, control methods, appropriate frequency and allocation of resources. Decisions on priorities and resources are taken after the risk assessment and are reflected in the relevant planning processes. The MANCP describes how, as a whole, the Norwegian Food Safety Authority plans, performs, follows up and evaluates official controls. It is a dynamic document that is further developed and updated as the new organisation matures, considering changes in the risk picture and other needs for adjustment.

Mandatory official controls

Certain official controls are subject to specific requirements in Union legislation concerning frequency, methods, scope or target population. These requirements apply in addition to the general obligation to perform official controls regularly, on a risk basis and with appropriate frequency. Examples include official controls on meat production and controls on animals and goods entering from third countries

Animal health, animal welfare and food safety for terrestrial animals and at slaughterhouses

During the planning period, emphasis will be placed on maintaining and documenting Norway’s animal health status through surveillance and early detection, effective contingency preparedness and incident management, preventive biosecurity in animal holdings, and risk-based official controls on animals and goods entering Norway/the EEA. Further priorities include follow-up of antimicrobial resistance, targeted measures in specific risk areas, further development of data and methods for both animal health and animal welfare, and follow-up of international obligations.

With regard to animal welfare, emphasis will be placed on strengthening risk-based follow-up of serious non-compliance of animal welfare rules, particularly in holdings with persistent challenges, and on ensuring faster and more targeted handling of serious notifications of concern. Further priorities include reducing losses and suffering among grazing animals and continuing targeted follow-up of pigs, poultry, small ruminants and cattle.

The knowledge and database for official controls will also be strengthened through improved system support and increased use of slaughterhouse data, while follow-up of the national animal welfare policy and new rules in this area will continue.

Feed safety, plant protection products and animal by-products

Other official activities concerning pests of plants will continue, including surveillance and monitoring activities, to support early detection and provide updated information for planning and follow-up. Work will also continue to reduce the backlog in authorisations of plant protection products and to follow up their use to limit risks to health and the environment.

Other priorities are to ensure safe and sustainable handling of animal by-products, digestate and fish sludge, perform controls in the biogas and fertilising-products sectors. In addition, emphasis will be placed on following up non-compliances and weaknesses in the feed sector, contributing to development of rules for sustainable feed and circular use of resources, and ensuring appropriate, risk-based official controls on organic production and marketing.

Food safety, entry controls and exports

During the planning period, emphasis will be placed on strengthening risk-based official controls on microbiological and chemical hazards in food, in particular Listeria, EHEC, Salmonella and higher-risk imported goods. Emphasis will also be placed on further developing monitoring and survey programmes, improving the data basis for controls in the retail and import sectors, strengthening preparedness and incident management for outbreaks and import-related incidents. Efforts to combat food fraud and serious infringements of agri-food chain rules will also continue.

Further priorities include strengthening consumer protection through follow-up of labelling, allergen information, food additives, voluntary labelling schemes and marketing, as well as targeted follow-up of food supplements, cosmetics and other products that may pose health risks, mislead consumers or involve non-compliance with the rules.

Aquatic animal health and welfare

During the planning period, efforts will focus on reducing mortality and strengthening aquatic animal health and welfare through risk-based official controls and clear use of enforcement measures at establishments with persistent challenges. Biosecurity and preparedness for transmissible diseases and environmental incidents will be strengthened, alongside improved compliance with rules on the handling and slaughter of fish. Targeted follow-up of sea lice and other major disease challenges will continue, supported by increased use of data and technology in official controls. Rules and coordination between authorities will also be further developed to support a more sustainable aquaculture sector.

Regarding the welfare of farmed fish, priority will be given to reducing mortality and poor welfare through risk-based follow-up of establishments with the weakest welfare outcomes. Surveillance, management systems and the use of technology for welfare assessment will be strengthened, and incidents and production conditions causing serious welfare impairment will be followed up. Efforts will also support the transition to production methods and farming systems that reduce sea-lice pressure and the need for burdensome treatments. The regulatory and control framework for aquatic animals will continue to be developed.

The quality management system contains procedures, guidelines, instructions and other documents used to support consistent official controls.

Control methods

The Norwegian Food Safety Authority uses several methods and techniques for official controls to verify compliance:

• inspection (mainly without prior notice)
• audit (system-based control)
• documentary check
• sampling
• system audits and coordinated controls of corporate groups and chains

Effectiveness and appropriateness of official controls

The Norwegian Food Safety Authority works to ensure the effectiveness and appropriateness of official controls, including through:

• evaluation of achievement of objectives and the effects of control measures
• use of data and analysis to improve the evidence base for risk categorisation
• development of digital solutions and standardised methods

The inspection divisions are responsible for contingency preparedness within their respective areas, while the Head Office is responsible for the corporate and directorate functions. Roles, responsibilities and powers are laid down in a common contingency instruction for the Authority. The structure and content of the contingency plans are being further developed to reflect the current organisation.

The Norwegian Food Safety Authority facilitates administrative assistance and cooperation with other EEA countries in accordance with the Official Controls Regulation, including exchange of information, coordination of measures and cross-border follow-up of incidents.

The Norwegian Food Safety Authority cooperates with:

• The Police, customs authorities, the Coast Guard and municipalities, which provide assistance to the competent authority upon request
• Nordic-Baltic memorandum on veterinary cooperation
• Total Defence – the modernised Total Defence concept encompasses mutual support and cooperation between the Armed Forces and civil society across the full spectrum of crises, from peace to security-policy crisis and war

The Norwegian Food Safety Authority develops staff competence through:

• training required by law
• training of inspectors
• subject-specific training activities
• participation in the EU programme ‘Better Training for Safer Food’

Most important common training courses are organised and documented through the Norwegian Food Safety Authority’s learning platform.

Managers must maintain an overview of their unit’s long-term competence needs and ensure appropriate and necessary competence through rolling plans and individual development plans.

All relevant staff in the inspection divisions have basic competence in official controls. This includes the core knowledge and skills required to plan, perform and follow up official controls in a technically sound and consistent manner.

Long-term competence plans must be aligned with the multi-annual plans of the inspection divisions.

These procedures are intended to assess whether official controls are performed consistently, effectively and in accordance with applicable requirements, documented procedures and the planned control approach. Findings from verification are followed up through corrective actions, management review and, where relevant, updates to procedures and planning.

Internal audits

Internal audits of the competent authority’s official control system are carried out under arrangements established by the Norwegian Food Safety Authority. Audits may be performed by an external party to support independence and objectivity. Audit results are used as input to management review, corrective actions and updates of the MANCP where relevant.

External audits

• ESA carries out regular audits and controls
• The Office of the Auditor General of Norway audits financial management and public administration
• audits by third countries

These audits are an important supplement to the Authority’s own evaluations and audits.

Audit and follow-up of delegated bodies and external support functions

The Head Office audits delegated bodies such as Debio, where official control tasks have been delegated. It also follows up external scientific support institutes and designated official laboratories in accordance with their respective roles in supporting official controls and other official activities.

The results of official controls are systematically reviewed through four-monthly reports and management dialogues. The review includes, where relevant

• records of official controls, including documented non-compliances and follow-up actions
• outcomes of appeal procedures
• other relevant information from the performance and follow-up of official controls

The evaluations support organisational learning, continuous improvement, and the prioritisation of future official control activities.

The information is also used as a basis for the Annual Report on Official controls (AROC).

Identified non-compliances and findings are followed up through

• four-monthly reports and management dialogues between the Director General, Head Office directors and inspection division directors
• annual management review of the quality management system
• corrective actions, where required

Findings from audits and verification are used as input to the review and, where relevant, update of the MANCP, documented procedures and planning of official controls

Updates to the MANCP are used to ensure that the plan continues to describe the organisation and operation of the official control system accurately and supports coherent planning, performance and follow-up of official controls.

The MANCP is made publicly available on the Norwegian Food Safety Authority’s website.

The plan is based on the requirements of Regulation (EU) 2017/625, in particular Articles 109–111, the corresponding Norwegian regulations on official controls, and the EU guidance document Requirements for the multi-annual national control plans (eur-lex.europa.eu)