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Discussion Paper on the Application of HACCP in Small and/or Less Developed Businesses (SLDBs) (Agenda Item 10)[12]

120. The Delegation of the Netherlands introduced the document which was revised by the drafting group and indicated that this issue had been on the Agenda of the Committee for several years. The delegation pointed out that despite a growing consensus in applying HACCP throughout the world, (as a science based, well structured, preventive system and the best way to control food safety), problems such as the lack of technical expertise, economical and cultural difficulties existed in the application of HACCP in SLDBs, especially in developing countries.

121. The Delegation reminded the Committee that to resolve the above difficulties, WHO, in cooperation with the Government of the Netherlands, convened a Consultation on Strategies for Implementing HACCP in Small and/or Less Developed Business to develop strategies for governments, trade and industry in order to assist the SLDBs, in implementing HACCP. The Delegation pointed out that the seven basic principles of the HACCP system could be applied in SLDBs, however the existing HACCP Guidelines did not provide enough guidance and flexibility for application to SLDBs, as for example in the Guidelines there was a requirement for a team of experts to identify hazards and establish corrective actions, therefore SLDBs had to rely on external expertise.

122. The Delegation recommended that the preferable way to overcome those difficulties in SLDBs could be an amendment of the existing HACCP Guidelines, by incorporating additional text into specific areas for the use in SLDBs without altering the seven principles of HACCP in any way.

123. The Committee expressed its appreciation to the Netherlands and its drafting partners for their work and efforts to progress this issue.

124. The Delegation of US, supported by Consumers International stated that original the seven HACCP Principles and the Guidelines should remain unaltered in their approach and meaning and indicated that it could support advancement of the document only if the proposed changes were considered as specific amendments to the HACCP Annex of the Recommended International Code of Practice-General Principles of Food Hygiene.

125. The Delegation of India pointed out problems associated with financial constraints, extensive documentation and lack of expertise and etc in developing countries were not fully reflected in the proposed amendments and were, in some cases, even more stringent than the current Guidelines, and that input from developing countries was required. This view was supported by many other delegations. In view of this, the Delegation of India proposed revision of the document which should be kept at a discussion paper status.

126. The Delegation of France, speaking on behalf of the Member States of the European Community present at the Session, supported the approach recommended by the drafting group and indicated that proposed amendments allowed more flexibility in application of HACCP Guidelines without compromising public health. This view was supported by several delegations.

127. The Delegation of Peru, in addition to its written observations presented in CRD 3, indicated the necessity of a process of adjustment in the application of HACCP requirements and that FAO/WHO should provide more training on the matter. The request for training was supported by many other delegations.

128. The Delegation of Venezuela pointed out that inconsistencies in the current document, CX/FH 00/10, could be eliminated at a later stage. Some delegations pointed out the necessity of participation of developing countries and involvement of all stakeholders in this process. The need for application of GHP and GMP as the prerequisite of HACCP and the exchange of experience in application of HACCP was emphasized.

129. Some delegations indicated the necessity to define SLDBs and indicated that it should be left to national authorities to decide.

130. The Delegation of Chile referring to the CRD 21 of Peru indicated that its country strove to apply the seven principles of HACCP that would not to be made more flexible, that HACCP was not the only tool to achieve food safety and that the CCFICS should provide guidance on equivalent systems.

131. The Observer of Consumers International expressed concern that while redrafting the document the basic principles of HACCP should not be diluted.

132. The Observer of IDF, while recognizing the usefulness of the HACCP system to ensure food safety, indicated that problems could be different in various kinds of industries and favoured using sector specific hygiene codes in dairy industry.

133. The Committee concluded that the document was useful, and there was general support to further elaborate it, and therefore agreed to an amendment to the existing HACCP Guidelines without altering the seven HACCP principles and to inform the CAC accordingly. However the Committee decided to ask for comments on the current document CX/FH 00/10 especially from developing countries on how to develop the Guidelines and requested the Delegation of the Netherlands, together with its drafting partners to revise the document that will be circulated at Step 3 for comments prior to the next session of the Committee. The Committee invited the delegations of developing countries to actively participate in this process.

[12] CX/FH 00/10, CRD 3 (comments of Peru); CRD 11 (comments of European Community); CRD 17 (comments of Italy); CRD 21 (comments of Chilli); CRD 22 (comments of Brazil).

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