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Date: Thu, 9 Oct 2003 11:02:32 +0100
Reply-To: PSA Forum
Sender: PSA Forum
From: Brian Whitehouse
Subject: Comments on papers1c, 2a, 2b, 2c, 3a & 3c.
Comments: To: psaforum@who.int
Content-Type: text/plain;charset=us-ascii;format=flowed

Participant in CCFAC for 16 years; Member of FAO group of JECFA for 8 years. >30 years in industry.

Paper 1c
Paragraph 3 a.(i) There are JECFA participants with strongly held views, which do not preclude their participation! The opinions are on a consensus basis, and there has not been a need for Members to vote in the past 8 years. I do not agree that there should be a declaration of strongly held beliefs.

Paragraph 3 a.(ii) I have no problem with open meetings, but do not think it would be of benefit either to JECFA or those attending unless they were scientists.

Paragraph 3 a. (iii) JECFA only exists when the Committee is in session, so as currently constituted, only the Secretary is available to interact with the CCFAC.

Paragraph 3 a. (iv) The Chairman of CCFAC attends the JECFA meeting.

Paper 2. a.
Paragraph 3 Budget. Constraints of resources have delayed reporting on more than one occasion. Not just budgets for the FAO Secretariat, but conflicts for resources within FAO have caused publication delays in the recent past.

Paragraph 5. I have the impression that recommendations from JECFA have more impact on CCFAC than ad hoc consultations. The Chairman of CCFAC would be better placed to answer with authority.

Paper 2.b
Paragraph 6.3 (d) Disclosures should be a matter of public record. At present they are not 'public' even at the JECFA meeting!

Paragraph 6.6 (e) The timely issuing of reports is more a budgetary than a scheduling matter, in my view. (See 6.7(a))

Paragraph 6.7 (b) There may be some proprietary aspects of equipment used in food processing, or sequence details in a process, but there can be no secret ingredients in food! Neither in the raw materials, nor methods used in the manufacture of food additives. Both materials and methods will affect the composition of the finished product. The material in commerce must reflect the material evaluated. There is, in my view very little in a food additive dossier submitted to JECFA which should be treated as confidential, or proprietary.

Paper 2.c The balance of gender/geography has been improved on JECFA. To be realistic, there is less expertise in underdeveloped countries on food additives, because their priority is food not food additives.

Paper 3.a
Footnote 2. '100% safe/ zero risk requirement ' is the biggest obstacle to public understanding of the safety of anything, at least in the UK! I am clear that JECFA, for instance, carries out risk assessment and CCFAC does risk management, but I am not clear about the third aspect. Who is responsible for risk communication? Probably member states governments. Whoever it is has this major obstacle of understanding to overcome in the UK.

Paragraph 5. I do not see the need for an overarching 'Scientific Committee' at least not in the regulation of advice from JECFA to CCFAC.

Hope this is helpful.
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Brian Whitehouse
6 Church Bank
Richmond Road
Bowdon
UK WA14 3NW
+44161 928 6681
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Brian Whitehouse