Rome, 29 November-10 December 2003
MINISTERIAL ROUND TABLE ON THE DIMENSION OF FOOD SAFETY IN FOOD SECURITY
1. The aim of this document is to elaborate on the inter-relationships between food security and food safety. The document identifies some of major issues that merit debate at the international level.
2. An estimated 840 million people world-wide are undernourished. Without a significant acceleration in the rate of reduction of undernourishment, the World Food Summit objective of halving the number of hungry people by 2015 will not be met. At the same time, food safety concerns are receiving ever increasing attention, while globalization and increasing trade in food and agricultural commodities are making the task of ensuring food safety more complex.
3. The relationship between food safety and food security seems to warrant particular attention. The main question is: does the implemention of higher food safety standards contribute to food security, or is this at the expense of food security?
4. The 1996 World Food Summit Plan of Action defines food security in the following way: “Food security exists when all people, at all times, have physical and economic access to sufficient, safe and nutritious food to meet their dietary needs and food preferences for an active and healthy life”.
5. Food safety refers to those hazards associated with food that can cause ill-health in humans. A number of the hazards are naturally occurring; others occur through contamination. Some may cause acute illnesses, for example microbial pathogens; others may increase the risk of chronic diseases such as cancer. There is a universal agreement that food should be safe.
6. On the one hand, ensuring safe food has positive implications for food security:
Food-borne illnesses may have serious social and economic consequences, including losses in income and income-generating capacity. People who consume unsafe food and/or suffer from food-borne diseases are less productive. This means lower incomes, less access to food and increased food insecurity.
7. However, the application of food safety standards also involves costs which may have negative food security implications:
8. The above-mentioned points underline that the establishment and application of appropriate food safety standards and regulations involve a trade-off between costs and benefits, which may have major food security implications.
9. Food-borne diseases are a worldwide problem of great magnitude in terms both of the human suffering caused and the associated economic costs. Numerous biological and chemical agents and hazards, cause food-borne diseases with a varying degree of severity, ranging from mild indisposition to chronic or life-threatening illness. It is estimated that food-borne contaminants cause 70% of the 1.5 billion episodes of diarrhoea that occur in the world annually. Although many different pathogens have been identified, food contaminated with pathogenic E. coli causes up to 25% of all diarrhoeal episodes in infants and children, while Campylobacter jejuni and Shigella spp. account for 10-15% and 5-15%, respectively.
10. Food-borne diseases are one of the most important underlying factors for malnutrition and, indirectly, for respiratory tract infections in developing countries. Repeated episodes of food-borne diseases over a period of time can lead to malnutrition with a serious impact on the growth and the immune systems of infants and children.
11. There is no evidence that evaluated food additives or pesticides used in accordance with international recommendations have been the cause of harm to humans. There is, however, a risk that inappropriate use of such chemicals can cause health problems. Plant toxins have also been implicated in food safety problems. An example is Lathyrus sativus adulteration in certain food grains, which has led to food-borne disease outbreaks. Other outbreaks have involved contaminants such as lead, mercury, cadmium; mixtures of mustard seeds with argemone seeds; and adulteration of olive oil with mineral oil. Marine biotoxins have also been implicated in several poisoning episodes. Mould growth by-products called mycotoxins are ubiquitous. Some are powerful carcinogens and can also cause other health problems to humans and animals. There are several recorded cases of mycotoxin contamination having led to serious disease outbreaks.
12. Estimation of the economic consequences of unsafe or contaminated food is complex. It involves consideration of the value of crops and animal products spoiled or destroyed as a result of such contamination, the value of rejections/detentions in the export trade, medical treatment costs and loss of output or earnings resulting from morbidity, disability or premature death. It is the last of these economic consequences that is the most difficult to measure, but on a global basis it is probably the single largest element in the entire cost of unsafe food.
13. Understanding the cost of complying with food safety standards is a complex process. Studies on this issue are being carried out, in particular under the aegis of the World Bank. According to these studies, the general issues involved in the compliance process would include: differences in technical requirements; implied changes in supply practices; costs incurred by domestic suppliers and exporters; total cost of implied changes in supply practices; net additional cost of compliance; etc.
14. A recent study1 quantified the trade effect of the European Union (EU) aflatoxin standard on African exports of cereals, dried fruits and nuts to Europe in comparison with the relevant, less stringent, international standard. The study shows that the new EU standard, which would reduce consumers’ health risk by approximately 1.4 deaths/billion/year, will lead to a decrease in African exports of the products in question by 64 percent or US$670 million. A similar methodology is applied by the World Bank in a study covering 10 developing countries, the results of which will be known shortly.
15. Diverging national standards persist. Within the SPS Agreement, national standards exceeding internationally established ones are permitted in the presence of scientific justification. It is nevertheless a widely held view that national standards should be harmonized at levels agreed internationally.
16. When establishing the appropriate levels of national food safety standards, countries would (ideally) be balancing the benefits from reduced hazards from food-borne diseases against the associated costs. This balance will depend on a number of factors, including differing priorities. In many low-income countries, scarce resources may yield higher returns, in terms of enhanced food security, food safety and improved public health, when invested in basic sanitation, water supply, improved housing and environmental conditions rather than in comprehensive systems of food safety regulation. At the same time, however, more stringent food safety standards may be necessary to comply with requirements faced on export markets. This necessity often leads to the existence of dual food production and distribution systems: one for the local market and one for the export market.
17. For many countries, such duality may ensure competitiveness in exporting specific commodities and be an affordable option in the short-term. However, a broader adoption of international standards on local markets would increase countries’ flexibility to seize emerging export opportunities more expeditiously.
18. Another particularly sensitive issue relates to the safety of donated food (food aid). In most countries, donated food is considered as imported food and is subject to the same controls. Problems arise when the donated food item does not comply with the national standards of neither the importing nor the exporting country, and is not in conformity with international standards. The issue is of a general ethical nature. The Codex Code of Ethics in International Food Trade, currently under revision, includes a number of recommendations to prevent such practices with particular regard to food aid.
19. Issues for consideration include:
20. Currently, international standard setting in bodies such as Codex Alimentarius is achieved through intergovernmental decisions based on science-based assessments. In this context, the costs associated with the implementation of and compliance with those standards are generally not explicitly considered. This practice is not without controversies. It has been suggested that international standards be set after considering the trade-offs between the benefits and the costs. A few specific issues can be drawn into the discussion.
21. Measurement problem: For several food contaminants, for which no Acceptable Daily Intake (ADI) has been established by national or international scientific assessment bodies, a zero tolerance level is often called for by food safety regulators. This means that the contaminant should not be detectable by any existing analytical method. With the advances in analytical techniques and the increase in the sensitivity of laboratory instruments, it has become possible to detect quantities as low as a fraction of a picogramme2 of contaminants in food. Such low quantities may be found in the environment, or as by-products of packaging materials or ingredients. It can be asked if the detection of very low levels of residues of certain contaminants with no ADI does indeed constitute a real threat to consumers’ health. Also, concerns can be raised whether the improved detection techniques do not imply a risk that very low or zero tolerance levels become a disguised technical barrier to trade. This issue will be on the agenda of the Joint FAO/WHO Expert Committee on Food Additives and Contaminants (JECFA) when it evaluates chloramphenicol at its next session (February 2004).
22. Risk management: The Sanitary and Phyto-sanitary (SPS) Agreement has emphasised the need for SPS measures to be based on sound science and established through appropriate risk analysis. The Codex Alimentarius Commission has defined food safety risk analysis as the structured process of evaluating the risks involved, comprising three distinct but closely linked components: (1) risk assessment, which is the scientific evaluation of the hazards involved; (2) risk management, which is the process of weighing policy alternatives to deal with risks in the light of the results of risk assessment; and (3) risk communication, the interactive exchange of information and opinions concerning risks among all stakeholders.
23. Risk management must take into consideration the economic consequences and the feasibility of different risk management options. It should ensure transparency and consistency in the decision-making process in all cases.
24. According to Codex, “Precaution is an inherent element of risk analysis. Many sources of uncertainty exist in the process of risk assessment and management of food hazards to human health. The degree of uncertainty and variability in the available scientific information should be explicitly considered in the risk analysis” and reflected in the risk management option selected.
25. Issues for consideration include:
26. The adoption of more rigorous food safety standards, although implying short-term costs, may nevertheless have positive dynamic benefits, also for developing countries. Enhanced food safety standards tend to induce innovation and improvements in technology, which in the longer run lower the costs of complying with the higher standards. For developing countries, they can also be advantageous in particular because of their catalytic effect on the development of the food export business and the improvement in the quality and safety of domestically consumed products. Several studies carried out in recent years substantiate this argument.
27. Exports of fishery products by Bangladesh, Kenya, Morocco, and Thailand, for example, have increased steadily during the last decade as a consequence of efforts made by the concerned authorities to implement quality assurance systems, such as Hazard Analysis Critical Control Point (HACCP), and comply with food safety regulations of importing countries. For instance, the average volume of Bangladesh’s shrimp exports grew from about 24,000 metric tonnes in 1990-92 to about 30,200 metric tonnes in 1999-2001. Improvements have often been the result of increased public sector intervention coupled with private sector investment.
28. Issues for consideration include:
29. Food safety requirements have profound effects on the way food supply chains operate and on the economic situation of actors throughout the chain. In particular, the question arises: which capacity enhancing investments in production and distribution systems in developing countries are needed for effective food safety controls? Another issue is the distribution of benefits amongst small-scale producers, processors and traders and their broad participation in complying with higher food safety standards.
30. Depending on countries’ specific needs, investments are required, and developing countries will benefit from capacity building efforts and technical assistance from developed countries and relevant international agencies. Such capacity building should address all expressed needs relating to the whole production chain. A related need is the support of effective participation of developing countries in international standard setting processes, for which the members of the Codex Alimentarius Commission have established a special Trust Fund.
31. Issue for consideration include:
32. The basic issue before this Round Table can be expressed in one fundamental question: Is the trend towards increasingly rigorous and comprehensive food safety standards, which is meant to satisfy the needs of all people, rich and poor alike, compatible with the short-term needs of the poor and food insecure to have access to sufficient quantities of food that satisfies their basic health needs?
1 Otsuki, T., Wilson, J.S., and Sewadeh, M. (2001) : Saving two in a billion: quantifying the trade effect of European food safety standards on African exports. Food Policy, 26, 495-514.
2 Picogramme = 10-12 gramme.