The principal objectives of national food control systems are:
Protecting public health by reducing the risk of foodborne illness;
Protecting consumers from unsanitary, unwholesome, mislabelled or adulterated food; and
Contributing to economic development by maintaining consumer confidence in the food system and providing a sound regulatory foundation for domestic and international trade in food.
Food control systems should cover all food produced, processed and marketed within the country, including imported food. Such systems should have a statutory basis and be mandatory in nature.
While the components and priorities of a food control system will vary from country to country, most systems will typically comprise the following components.
The development of relevant and enforceable food laws and regulations is an essential component of a modern food control system. Many countries have inadequate food legislation and this will impact on the effectiveness of all food control activities carried out in the country.
Food law has traditionally consisted of legal definitions of unsafe food, and the prescription of enforcement tools for removing unsafe food from commerce and punishing responsible parties after the fact. It has generally not provided food control agencies with a clear mandate and authority to prevent food safety problems. The result has been food safety programmes that are reactive and enforcement-oriented rather than preventive and holistic in their approach to reducing the risk of foodborne illness. To the extent possible, modern food laws not only contain the necessary legal powers and prescriptions to ensure food safety, but also allow the competent food authority or authorities to build preventive approaches into the system.
In addition to legislation, governments need updated food standards. In recent years, many highly prescriptive standards have been replaced by horizontal standards that address the broad issues involved in achieving food safety objectives. While horizontal standards are a viable approach to delivering food safety goals, they require a food chain that is highly controlled and supplied with good data on food safety risks and risk management strategies and as such may not be feasible for many developing countries. Similarly, many standards on food quality issues have been cancelled and replaced by labelling requirements.
In preparing food regulations and standards, countries should take full advantage of Codex standards and food safety lessons learned in other countries. Taking into account the experiences in other countries while tailoring the information, concepts and requirements to the national context is the only sure way to develop a modern regulatory framework that will both satisfy national needs and meet the demands of the SPS Agreement and trading partners.
Food legislation should include the following aspects:
it must provide a high level of health protection;
it should include clear definitions to increase consistency and legal security;
it should be based on high quality, transparent, and independent scientific advice following risk assessment, risk management and risk communication;
it should include provision for the use of precaution and the adoption of provisional measures where an unacceptable level of risk to health has been identified and where full risk assessment could not be performed;
it should include provisions for the right of consumers to have access to accurate and sufficient information;
it should provide for tracing of food products and for their recall in case of problems;
it should include clear provisions indicating that primary responsibility for food safety and quality rests with producers and processors;
it should include obligation to ensure that only safe and fairly presented food is placed on the market;
it should also recognise the country's international obligations particularly in relation to trade; and
it should ensure transparency in the development of food law and access to information.
Guidelines for the development of food laws are contained in Annex 6.
Effective food control systems require policy and operational coordination at the national level. While the detail of such functions will be determined by the national legislation, they would include the establishment of a leadership function and administrative structures with clearly defined accountability for issues such as: the development and implementation of an integrated national food control strategy; operation of a national food control programme; securing funds and allocating resources; setting standards and regulations; participation in international food control related activities; developing emergency response procedures; carrying out risk analysis; etc.
Core responsibilities include the establishment of regulatory measures, monitoring system performance, facilitating continuous improvement, and providing overall policy guidance.
The administration and implementation of food laws require a qualified, trained, efficient and honest food inspection service. The food inspector is the key functionary who has day-to-day contact with the food industry, trade and often the public. The reputation and integrity of the food control system depends, to a very large extent, on their integrity and skill. The responsibilities of the inspection services include:
Inspecting premises and processes for compliance with hygienic and other requirements of standards and regulations;
Evaluating HACCP plans and their implementation;
Sampling food during harvest, processing, storage, transport, or sale to establish compliance, to contribute data for risk assessments and to identify offenders;
Recognizing different forms of food decomposition by organoleptic assessment; identifying food which is unfit for human consumption; or food which is otherwise deceptively sold to the consumer; and taking the necessary remedial action;
Recognizing, collecting and transmitting evidence when breaches of law occur, and appearing in court to assist prosecution;
Encouraging voluntary compliance in particular by means of quality assurance procedures;
Carrying out inspection, sampling and certification of food for import/export inspection purposes when so required;
In establishments working under safety assurance programmes such as HACCP, conduct risk based audits.
Proper training of food inspectors is a prerequisite for an efficient food control system. As current food systems are quite complex, the food inspector must be trained in food science and technology to understand the industrial processes, identify potential safety and quality problems, and have the skill and experience to inspect the premises, collect food samples and carry out an overall evaluation. The inspector must have a good understanding of the relevant food laws and regulations, their powers under those laws, and the obligations such laws impose on the food sector. They should also be conversant with procedures for collecting evidence, writing inspection reports, collecting samples and sending them to a laboratory for analysis. With gradual introduction of HACCP systems in the food industry, the inspector should be trained to handle HACCP audit responsibilities. Clearly, there is a continuing need for training and upgrading the skills of existing inspectional staff and having a policy for human resource development, especially the development of inspectional specialists in specific technical areas.
As human resources in some food control agencies in developing countries may be limited, environmental health inspectors are often also asked to work as food inspectors. This is not the ideal situation as they may lack the skills and knowledge to effectively evaluate and inspect food operations. If environmental health inspectors must be used, then they should be carefully supervised and provided with on-the-job training.
Laboratories are an essential component of a food control system. The establishment of laboratories requires considerable capital investment and they are expensive to maintain and operate. Therefore careful planning is necessary to achieve optimum results. The number and location of the laboratories should be determined in relation to the objectives of the system and the volume of work. If more than one laboratory is required, consideration should be given to apportioning the analytical work to achieve the most effective coverage of the food analyses to be performed and also to having a central reference laboratory equipped for sophisticated and reference analyses.
All food analysis laboratories may not be under the control of one agency or ministry, and a number could be under the jurisdiction of the states, provinces and local authorities. The Food Control Management should, however, lay down the norms for food control laboratories and monitor their performance.
The laboratories should have adequate facilities for physical, microbiological and chemical analyses. In addition to simple routine analysis, the laboratories can be equipped with more sophisticated instruments, apparatus and library facilities as required. It is not only the type of equipment that determines the accuracy and reliability of analytical results but also the qualification and skill of the analyst and the reliability of the method used. The analytical results of a food control laboratory are often used as evidence in a court of law to determine compliance with regulations or standards of the country. It is therefore necessary that utmost care be taken to ensure the efficient and effective performance of the laboratory. The introduction of analytical quality assurance programmes and accreditation of the laboratory by an appropriate accreditation agency within the country or from outside, enables the laboratory to improve its performance and to ensure reliability, accuracy and repeatability of its results. Prescription of official methods of sampling and analysis also support this effort.
An important element of a national food control system is its integration in a national food safety system so that links between food contamination and foodborne diseases can be established and analyzed. Access to reliable and current intelligence on the incidence of foodborne illness is critical. The laboratory facilities for this type of activity are generally situated outside the food control agencies. It is essential, however, that effective linkages are established between food control agencies and the public health system including epidemiologists and microbiologists. In this way information on foodborne diseases may be linked with food monitoring data, and lead to appropriate risk-based food control policies. This information includes annual incidence trends, identification of susceptible population groups, identification of hazardous foods, identification and tracing of causes of foodborne diseases, and the development of early warning systems for outbreaks and food contamination.
An increasingly important role for food control systems is the delivery of information, education and advice to stakeholders across the farm-to-table continuum. These activities include the provision of balanced factual information to consumers; the provision of information packages and educational programmes for key officials and workers in the food industry; development of train-the-trainer programmes; and provision of reference literature to extension workers in the agriculture and health sectors.
Food control agencies should address the specific training needs of their food inspectors and laboratory analysts as a high priority. These activities provide an important means of building food control expertise and skills in all interested parties, and thereby serve an essential preventive function.