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Date: Mon, 13 Oct 2003 14:19:54 +0200
Reply-To: PSA Forum
Sender: PSA Forum
From: Lindsay Martinez
Subject: FW: Contribution to 3.d
Comments: To: psaforum@who.int
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-----Original Message----- From: Antoine Kabwit Nguz [mailto:kabwit.nguz@ugent.be]
Sent: Monday, 13 October 2003 12:47 To: martinezl Subject: Contribution to 3.d

In academia and research and public service since 25 years in food and food related areas in Africa and Europe. Involved in last five years in various progamme dealing with food safety improvement and harmonization in (developing countries) the SADC and COMESA regions. These are some personal views related to 3.d.

Dear Moderator,
First of all I would like to state that: - In most of developing countries with few exceptions Food Safety is linked to trade and not to the improvement of food safety assurance system in order to protect consumer's health. - Most the countries are able to perform all needed chemical and (micro)biological usually required by the importing countries however some technical skills problems exist.

Standards ownership and data.
The applications of different standards according to the exporting market throws doubts on the "scientific validity" of food standards. This situation creates confusion and lack of ownership of the so-called standards. Although it could be understood in the context of risk that standards levels could be different but usually these differences are very big. For instance the limits for total aflatoxins in USA and Australia for variuos foods and feeds is 20ppb and only 1ppb for B1 imposed by the EU. The EU level is far from the Codex one. For fresh cuts vegetables, a big difference exists in terms of number of microbiological criteria and levels. Big differences exists between standards and guidelines from UK, France, Germany and South Africa for instance.When it comes to trade, no reference is directly made to Codex but to the standards of the importing country. In most of the cases governmental laboratories are not always involved in the process of product certification, third parties are often used eventhough this could be sometimes understood ( skills, equipment, reagents and media etc...). Agreements are done between the "private" laboratory, the exporting firm and the food safety officers of the importing country. Data obtained are relevant for the importing country not for the exporting country.There is no clear mechanisms to report data ( by the third parties or other private laboratories) to concerned or responsible institutions in the exporting country. Eventhough these data are reported, what will be their usefulness for the calculation of risk as they do not refer to local food safety measures. In developing countries data are collected for any outbreak ( not necessarily food outbreak) and quite often qualitative or boundary tests are performs not quantitative tests. The differences in standards create within the exporting country different categories or levels of standards, for export, for local or regional market. This add again more confusion on data collection.

Case study pesticide residues.
The harmonization of pesticides residues is a long process. In the EU, the programme for harmonizing the MRLs for agro-chemicals permitted in agricultural products is started in 1993 and is yet to be completed in 2003. In the mean time the national provisions in force in the EU member states are applicable and can vary from one country to the other. So far hundred active substances have been regulated. Some MRLs having already been fixed on the basis of scientific data. However, many of the first 100 active ingredients used by developing country growers on minor crops have been set at the Limit of Determination (LOD). Although some of these chemicals are currently seen to be essential for producing crops for export, in the case a LOD has been set the use of that particular pesticide on that particular crop is not possible. The fact that these active substances have been set at the LOD will require also more sophisticated and sensitive analytical equipment. This add again another burden on the developing countries. To my knowledge, sustained sensitization programme on pesticides residues started some 3 years ago at least in the SADC region and it is not possible in such short time to adjust agricultural production systems. For instance the major UK supermarkets, the most important export outlet for fresh vegetables from many SADC countries are gradually implementing more strict pesticides regulations than the EU and are in general aiming at 'zero tolerance' rather than MRLs. In this area also data relevance is questionable.

Answer to the questions.
- Promote the implementation of well coordinated food safety system as in most the cases more than 6 ministries and other institutions are involved in food safety issues. There is lack of communication, conflict of interest and no clear definitions of level and nature of interventions. The coordination could be done under a single Food Safety Authority for instance based on EU model. This structure should include all stakeholders, government, academia, research, food industry, NGO's etc... -FAO and WHO should use more qualified expert from developing countries in their respective competences to deal with project or programme related food safety issues. FAO and WHO local and regional offices should link up with experts working in academia and research for instance through a structure like the Food Safety Authority. Experts should be selected on the basis of objective criteria (qualifications, experience, technical skills, etc...) - First of all FAO and WHO should sustain regional organizations that conduct laboratory accreditation and laboratory performance assessment through laboratory testing schemes. In this way laboratories will provide valid and reliable data. -FAO and WHO should play a more important role in the "implementation" and limit their interventions to the "policy" level only. real problems are with implementation of food safety regulations not policy. People should be chosen on the basis of their competence and not based on subjective criteria.

Regards,
Dr.ir. Antoine Kabwit Nguz, PhD Department of Food Technology and Nutrition 653 Coupure Links- B 9000 Gent BELGIUM Phone + 32 9 264 61 63 Fax + 32 9 264 6218