Cattivo Stato di Conservazione

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Capita spesso che, a seguito delle ispezioni degli organi di controllo presso le aziende agroalimentari, venga rilevata l’inosservanza dell’articolo 5, lettera B, delle Legge n. 283/1962 (“Disciplina igienica della produzione e della produzione e della vendita delle sostanze alimentari e delle bevande”) e successive modifiche.

Più precisamente tale articolo recita “è vietato impiegare nella preparazione di alimenti e bevande, vendere, detenere per vendere o somministrare ai propri dipendenti, o comunque distribuire per il consumo di sostanze alimentari…

  1. b) in cattivo stato di conservazione”.

Questa contestazione di frequente lascia sorpresi gli OSA (Operatori del Settore Alimentare) perché reputano tali contestazioni esagerate e alcune volte anche fuori luogo. Per tale motivo svariate volte questa infrazione e le rispettive sanzioni vengono contestate generando una nutrita giurisprudenza.

Attraverso la sintetica analisi di una parte della giurisprudenza vediamo alcune contestazione che sono state fatte cercando di capire gli errori igienico-sanitari spesso frequenti che vengono fatti nelle imprese agroalimentari.

  1. A) bruciature da freddo e congelazione inadeguata. A seguito del sopralluogo del personale ispettivo della ASL di competenza in un agriturismo furono trovati e sequestrati 70 kg di alimenti deperibili (mozzarelle, carni e pesci) in quanto stoccati in condizioni igieniche non idonee perché alcuni alimenti presentavano bruciature da freddo, ma soprattutto perché questi alimenti erano stati congelati senza l’utilizzo delle specifiche apparecchiature.

Il titolare dell’attività avanzò un’azione difensiva nella quale si sosteneva che gli alimenti contenuti nel congelatore erano destinati all’abitazione vicina al locale dell’agriturismo. Tale giustificazione non fu accettata.

Cassazione Penale, Sezione III, Sentenza n. 39879/2014

  1. B) promiscuità degli alimenti. A seguito del ritrovamento di alimenti (pesci, carni e verdure) conservati in stato di promiscuità (sfusi e disposti alla rinfusa) e senza etichetta. Tale condizione fu giudicata come “cattivo stato di conservazione”.

Da questa azione si evince che i prodotti alimentari di diverso gruppo devono essere conservati separatamente sia per evitare specifiche contaminazioni microbiologiche che per poter rispettare le differenti temperature che ogni categoria di alimenti richiede per legge.

Cassazione Penale, Sezione III, Sentenza n. 40554/2014

Il rappresentante legale di un supermercato è stato condannato per il trasporto di latticini (formaggio fresco tipo ricotta) in promiscuità con alcuni tipi di ortofrutta con un mezzo non coibentato e non refrigerato quindi con una temperatura maggiore di 4°C (quindi non idoneo al trasporto degli alimenti che devono rispettare la catena del freddo).

Cassazione Penale, Sezione III, Sentenza n. 24332/2014

  1. C) A seguito di un’ispezione la cucina di un locale fu trovata in cattivo stato igienico e di manutenzione. Le pareti risultavano essere sporche e con muffa, gli infissi presentavano polvere, ecc. Oltre a ciò su alcuni scaffali furono trovati dei contenitori (barattoli) con ruggine contenenti alimenti scaduti.

Cassazione Penale, Sezione III, Sentenza n. 39409/2014

Dall’analisi di questi recenti casi di “cattivo stato di conservazione” degli alimenti emerge che è assai facile incorrere in questa infrazione e che le più comuni azioni difensive non cambiano lo stato di quanto riscontrato dagli organi di controllo. Quindi l’unica soluzione per non trovarsi nella condizione di “cattivo stato di conservazione” consiste nel predisporre un ottimo piano H.A.C.C.P. (considerando attentamente tutti gli aspetti produttivi e i connessi rischi) e ovviamente nell’effettuare costantemente quanto prescritto.

Appare chiaro che serve a ben poco avere un buon Manuale di Autocontrollo Alimentare (redatto secondo il sistema HACCP, contenente il piano di sanificazione, il piano dei campionamenti, la rintracciabilità, ecc.) se lo si lascia a “prendere polvere” in un cassetto e a fargli “prendere luce” solo quando viene richiesto dagli organi di controllo durante le ispezioni.

Il rispetto di quanto predisposto nel proprio manuale di autocontrollo alimentare non solo evita di incorrere in infrazioni amministrative e penali, ma evita anche l’insorgenza di MTA (Malattie Trasmesse dagli Alimenti) nei propri clienti/consumatori, riduce drasticamente le lamentele e migliora l’immagine dell’azienda.

© Produzione riservata

—————

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Dr. Luciano O. Atzori

Biologo – Esperto in Sicurezza degli Alimenti e in Tutela della Salute

Divulgatore Scientifico – Consulente aziendale

Co-founder di ISQAlimenti.it

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