COMMITTEE ON AGRICULTURE
Rome, 13-16 April 2005
FAO’s Strategy for a Safe and Nutritious Food Supply
Item 5 of the Provisional Agenda
Strengthening the international regulatory framework and its scientific basis
Strengthening national regulatory systems and other programmes
Mitigating costs of application
Stressing information and advocacy
Addressing needs for emergency response and rapid alert
Improving cooperation and coordination
1. The 28th Session of the Committee on World Food Security (CFS, June 2002) discussed, inter alia, the issue of access to safe and nutritious food. The CFS recommended that the Secretariat submit a draft framework document to COAG, COFI and CFS on strategies to address key elements of policy advice, capacity building and technical assistance, and actions that need to be taken at national and international levels for ensuring access to safe and nutritious food.1 The matter was subsequently discussed at the 17th Session of COAG, 2003.2
2. The present paper addresses the second of three main elements which together provide an overall framework for ensuring that all people at all times have access to sufficient, safe and nutritious food to meet their dietary needs and food preferences for an active and healthy life. These are:
The paper stresses the food chain approach for food safety discussed by the 17th Session of COAG and extends it to cover questions of nutrition. It sets out a proposed strategy for FAO at the international level that may also serve as a model for the national level.
3. Throughout this paper the expression “safe and nutritious” will be taken to mean the “assurance that food will not cause harm to the consumer and will provide the expected nutritional value when it is prepared and/or eaten according to its intended use”. This definition is based on the Codex definitions of food safety and food suitability contained in the General Principles of Food Hygiene.4
4. Throughout this paper reference to “prevailing norms” should be taken to mean: (i) at the international level the standards, guidelines and recommendations of the Codex Alimentarius Commission and other officially adopted normative texts such as the International Code of Conduct on the Distribution and Use of Pesticides and the FAO Code of Conduct for Responsible Fisheries; and (ii) at the national level measures based on these international texts or other measures based on scientific principles, risk assessment or the assessment of nutrient requirements.
5. The “food chain approach” will be taken to mean the application of regulatory and non-regulatory measures at appropriate points in the food chain from pre-production practices to the point of sale or distribution to consumers so that the food meets prevailing norms. It includes the adoption of good agricultural practices that establish basic principles for farming (including aquaculture), soil and water management, crop and animal production, post-harvest handling and treatment, good manufacturing practices for storage, processing, and distribution to the consumer. It is understood to include feed for animals.
6. This paper introduces the concept of the “expected nutritional value”. The expected nutritional value includes macro- and micro-nutrients and other food components that have known positive physiological effects, for example the omega-3 fatty acids. It should always be supported by scientific evidence, in particular by an understanding of human nutritional requirements and the composition and nutritional value of the food components. A consequence of this concept is that all foods provide an inherent “expected nutritional value” and that it is the selection from among a variety of such safe and nutritious foods that allow people to meet their optimum dietary needs and food preferences.
7. The paper COAG/2003/5 described the use of regulatory food safety systems throughout the food chain. However, a true food chain approach for a safe and nutritious food supply should recognize that regulatory enforcement is only one of several elements that need to be brought together in an integrated manner to reduce risks to the safety and nutritive value of food. To develop a fully integrated strategy it is necessary to examine firstly the nature of food chains and then the types of interventions that can be applied along the food chain for protecting the safety and nutritional value of the food supply.
8. Food chains range from being extremely short and simple to being very long and complex. At the short end of the scale the family of a farmer or fisherman prepares and eats the food they grow or catch. At the long end of the scale, foods may be prepared from a variety of ingredients, some of which may have been grown in one country, transformed or processed in another, and transported and sold in supermarkets in yet another before being finally consumed.
9. Food chains may be informal, formal, or a mixture of both. At the informal level, a farmer middleman or trader may sell fresh produce directly, or sell it cooked at the roadside to the consumer. Street foods and street markets frequently draw on both formal and informal food chains to provide a variety of foods to the consumer. Formal food chains are characterized by documented commercial transactions frequently carried out according to authorized operations, established commercial regulations, and agreed specifications between buyer and seller.
10. For the purpose of food safety, it is now generally accepted that food chains cover all inputs into the production of the food, including feed for animals, chemical treatments at the production and post-harvest stages, and even the land or water from which the food is harvested. Nutrient values also may vary within species and different growing conditions, with implications for level of nutrition that may be expected from foods from different sources. The food chain approach must also address urban and peri-urban production and marketing systems which present special problems due in part to the close confinement of production, the close proximity to human dwellings, the lack of adequate sanitary conditions, the use of unsafe water, and the absence of agricultural technical support systems.
11. Effective regulatory systems, including appropriate legislative and administrative frameworks, are essential for the application of a food chain approach. Such frameworks would include inspection systems, auditing and trace-back procedures, and enforcement mechanisms. The legislative framework can incorporate a food chain approach by privileging preventive rather than punitive measures. The food chain approach is consistent with FAO’s Biosecurity approach to animal life and health, plant life and health, and food safety regulation.5
12. As was stated in COAG/2003/5, “food safety has traditionally focused on enforcement mechanisms to remove unsafe food from the market after the fact, instead of a more pronounced mandate for the prevention of food safety problems”. As a result, the orientation of many regulatory food safety systems tended to be reactive and defined by enforcement criteria instead of using a preventive approach to risk assessment and reduction. However, several countries are moving towards a food chain approach for the management of food safety by applying regulatory controls at the point where they are most effective.
13. Among the preventative measures now frequently required by governments for both domestic and international trade, are management systems such as Good Agricultural or Good Manufacturing Practices and the Hazard Analysis and Critical Control Point (HACCP) system, both of which follow the models developed by Codex. Attention has also been paid to preventative measures to reduce levels of environmental and industrial contaminants at the production stage by the application of source-directed measures.
14. Within the Codex Alimentarius Commission, elements of a food chain approach, concentrating on production requirements rather than end-product specifications, have also emerged. Foremost among these developments has been the adoption of the General Principles of Food Hygiene6 which follows the food chain from primary production through to final consumption, highlighting the key hygiene controls at each stage. Similarly, the FAO Code of Conduct on Distribution and Use of Pesticides includes references to guidelines on equipment, regulations and practices for pesticide application to avoid the source of contamination in the field. The food chain approach for safe and nutritious foods contributes to the management of antimicrobial resistance and other food production issues by strengthening good agricultural and good veterinary practices at critical points in the food chain.
15. Whereas regulatory strategies towards ensuring a safe food supply through a food chain approach have received considerable attention, the same cannot be said for ensuring that foods meet their expected nutritional value. For nutrition, the most common types of prevailing norms are:
16. International guidance in these areas is provided by the relevant Codex standards and guidelines, however requirements for nutrition labelling at the national level are evolving.7 While there is not an international consensus on how to promote the use of responsible nutrition and health claims, it is generally accepted that such claims should have a scientific basis. Prevailing norms used to establish or define an “expected nutritional value” through specific standards or labelling are not applicable to the vast array of nutritious foods sold to the consumer in an unpackaged or unprocessed form, such as fresh fruits and vegetables. In these cases, the general protection provided by food laws against spoilage and deterioration also provides protection to the expected nutritional value. Within a food chain approach, non-regulatory interventions as described below may be more effective than regulatory interventions for this purpose.
17. The regulatory system for ensuring safe and nutritious foods includes associated legislation in areas that affect inputs to the food chain. In addition to areas covered by FAO’s Biosecurity framework, areas such as environmental legislation or land, soil and water legislation must be taken into account and opportunities for synergies exploited, especially when considering source-directed measures for the control of contamination in the food chain. These opportunities include both regulatory cooperation and cooperation in non-regulatory interventions.
18. Inherent in the food chain approach is the concept that official inspection and control procedures are documented and certified by regulatory authorities. Substantial international guidance in this area is provided by the work of the Codex Committee on Import and Export Inspection and Certification Systems.
19. There is a wide variety of non-regulatory interventions that can be used as part of a food chain approach for ensuring safe and nutritious foods. Because many of these interventions fall within the traditional strengths of the food and agriculture sector, and of FAO in particular, they are of considerable interest in developing a framework strategy for ensuring access to safe and nutritious food. Foremost among these interventions are management systems designed to improve efficiencies, reduce losses, enhance quality and where possible create added value for food products.
20. Although some of these interventions may have compliance with prevailing norms also as an objective, their main characteristic and potential effectiveness is that they are oriented to an operations approach for implementation by producers, processors and marketers themselves rather than by the official food control services.8 Therefore, their technical feasibility, cost-effectiveness and economic viability are enhanced. On the other hand the presence of multiple industry-imposed standards can create confusion, duplication of effort, additional costs and further difficulties for exporting countries.
21. Other non-regulatory interventions can also have a strong impact in promoting a food chain approach to provide safe and nutritious foods. These include education programmes in schools, technical colleges and universities; extension services for small-scale producers; and rural radio and other communications programmes to sensitize on the need to ensure that foods are safe and nutritious.
22. The risk management-based food chain approach described in this paper is not limited to the application of regulatory systems, but includes the application of a variety of regulatory and non-regulatory interventions applied, as appropriate to the circumstances, at different steps in the food chain. These are applied to the protection of consumers against food safety risks and against undesirable effects on the expected nutritional value.
23. Although from the point of view of identifying and assessing risks and undesirable effects a “whole-of-chain” approach is necessary, interventions to manage them must be focused on the particular point or points in the food chain where they are the most effective and this should be determined scientifically. The food chain approach is therefore a matrix of interventions, regulatory and non-regulatory, targeted to these points in the chain. The institutions responsible for these interventions may be the food regulatory agencies; associated agencies such as agricultural extension services; schools and academia; rural radio and other information services; producers, processors, vendors and other operators; farmer organizations and NGOs, and, finally, the consumer.
24. Such a strategy meets international requirements of the Codex Alimentarius and other prevailing norms. It minimizes the accumulation or amplification of risks; involves the food and agriculture sector in the decision-making process for establishment and cost-effective application of standards; has the capacity to improve efficiencies in the production, post-harvest treatment and handling, processing and distribution of foods; reduces nutritional losses; minimizes economic risks associated with direct losses and the loss of trade opportunities; and allows better management of crises affecting food safety and nutrition.
25. The risk analysis framework followed by the Codex Alimentarius Commission for food safety9 serves as the basis for a food chain approach to providing safe and nutritious foods, by extending the concept of food safety risks to those hazards that may negatively affect the expected nutritional value. Risk management options can be applied at the most outcome-effective points in the food chain and a wide variety of options ranging from education and communication to strict regulatory measures may be applied where they are most effective. Options include regulatory measures such as end-product standards and production or processing standards and labelling requirements, but may also include systems-based “technologies and good practices” operated by producers, post-harvest handlers, processors and marketers and other interventions. Consistent with the objective being sought, risk management should also take into account economic consequences and feasibility.
26. In the period since the 17th Session of COAG in April 2003, the Codex Alimentarius Commission has continued its discussions on “traceability/product tracing” and its application. In July 2004, the 27th Session of the Commission adopted a definition”10 and the concept has been included in several Codex texts adopted by the Commission in 2003 and 200411. The integration of traceability into a food chain approach to ensuring a safe and nutritious food supply will depend on the development and application of prevailing norms, especially the guidance under debate by the Codex Alimentarius Commission. Although the food chain approach described in this paper is not dependent on the application of traceability, the general statement contained in COAG/2003/5 that a food chain approach facilitates the application of traceability remains valid.
27. The matter of precaution has been addressed by the Codex Alimentarius Commission in relation to its own standards and is now included in the Codex Working Principles for Risk Analysis for Application in the Framework of the Codex Alimentarius.9 The Commission, through its Committee on General Principles, is currently developing advice to Members on the application of risk analysis, including the use of precaution. The outcome of these discussions should assist in an improved international understanding of the role of precaution in relation to food safety.
28. An FAO Expert Consultation on Food Safety: Science and Ethics was held in September 2002 in collaboration with WHO as part of an ongoing effort to adequately address ethical issues in food safety. The aim of the Expert Consultation was to advance the global debate on the roles of science and ethics in food safety decision-making, thus guiding deliberations within FAO and WHO on their food safety programmes and informing the wider community. Its report was recently published in the FAO “Readings in Ethics” series.12 Within Codex, the revision of the Codex Code of Ethics for International Trade in Foods13 is being considered by the Codex Committee on General Principles.
29. The 17th Session of COAG “emphasized that any framework must take into consideration the specific conditions of, and cost implications for, developing countries, where small-scale economic activities predominate. A step-by-step and sequential approach to implementation in developing countries and countries with economies in transition should be adopted as part of any framework”.14
30. There are few, if any, studies on the costs of transition from an exclusive end-product testing regime to the institution of a food chain approach for food safety, and probably none at all in relation to protecting the expected nutritional value. The strategy described below addresses means of mitigating costs of transition from an end-product approach to a food chain approach especially in developing countries and countries in economic transition.
31. It is proposed that FAO’s strategy for ensuring safe and nutritious food would be based on an interdisciplinary approach to provide normative, policy and technical advice for implementing prevailing international norms through a mixture of regulatory and non-regulatory interventions, as appropriate, at the most outcome-effective points in the food chain. It would address both formal and informal food chains and allow countries to implement elements of the strategy on a step-by-step basis according to their needs and their capacities. Implementation of the strategy therefore foresees enhanced technical assistance and capacity building activities, policy advice to mitigate increased costs, and improved investment by both public and private institutions at appropriate stages in the food chain. It foresees a major role for communication and extension services in its implementation and it also foresees enhanced cooperation with other international agencies working in the same or related fields.
32. The main objectives of the strategy include the continued strengthening of the international regulatory framework for food safety and nutrition, especially Codex as well as other international standards and guidelines developed by FAO that have a strong positive impact on the food chain approach, including:
33. In order to ensure that these international standards have a strong scientific base, FAO in collaboration with the WHO, IAEA, OIE and other agencies as appropriate, will continue to provide risk assessments and other expert scientific advice for standards setting through expert committees and/or meetings. Under the proposed strategy these will need to be expanded to include consideration of the expected nutritional value based on the scientific FAO/WHO assessments of human nutritional requirements. FAO’s coordinated studies on food composition and on the nature and effects of different post-harvest handling and processing technologies and practices will aid in determining the expected nutrition value of specific foods. This is true particularly for local and traditional foods that are marketed through informal or semi-formal food chains.
34. The transformation of international standards, guidelines and other recommendations concerning safe and nutritious foods into a food chain approach for their practical application at the national level will require a variety of instruments that address both regulatory and non-regulatory interventions. The proposed strategy will give emphasis to:
35. The proposed strategy will seek to enhance further FAO’s current strong emphasis on food law and regulation and the application of international standards. This would include improving access to information; strengthening of food inspection systems; developing laboratory capacities and skills (where appropriate on a regional or sub-regional basis); and strengthening the capacity of countries to participate in the international standards-setting process including the ability to undertake risk assessments when required. New elements under this strategy would be the involvement of local producers’ organizations, small and medium scale enterprises/operators and NGOs in applying codes of good practice for ensuring safe and nutritious foods. Projects supporting agricultural education, extension services, and rural communication have a strong potential for encouraging a food chain approach for safe and nutritious foods.
36. The strategy would also seek to enhance the development and provision of basic infrastructure and cost-effective technologies and practices; applied research and technology transfer; and advice to small and medium sized enterprises in developing countries, including the management and financial aspects of the food chain approach. It would seek to engage the private sector in capacity building and technical assistance activities.
37. The adoption of a food chain approach for ensuring safe and nutritious foods should enable access to a broad base of resources for capacity building, including from the private sector. The establishment of FAO/WHO/OIE/WB/WTO Standards and Trade Development Facility also provides an additional mechanism for access to resources for capacity building in the food safety area.
38. Importantly, the food chain approach recognizes the role that the food and agriculture sector itself plays in ensuring that foods are “safe and nutritious”. Most of the investment that goes into ensuring a safe and nutritious food supply is provided by the private sector (including small-scale producers). These investments can be relatively simple, such as improved storage in small fishing boats, or very complex such as in-house quality control laboratories and management of HACCP systems. In addition to the costs for operators, the framework must take into account the transitional and on-going costs of administration by the regulatory control services.
39. The proposed strategy would contain elements of economic policy research and advice including:
40. The proposed strategy would seek to promote investment in the food chain approach for ensuring safe and nutritious foods either from the private or public sector as well as international lending institutions, or by levering other local resources.
41. The proposed strategy foresees a major role for education, extension and communication services to promote a food chain approach for ensuring that foods are safe and nutritious. At the top level, the proposed strategy would extend access to the International Portal on Food Safety, Animal and Plant Health15 (IPFSAPH) as a primary entry point for access to technical and scientific information. It would also provide technical support and capacity to countries wishing to participate in the information sharing capabilities of the Portal.
42. The strategy would also use FAO’s knowledge base and information systems as means of delivering messages about protecting the safety and nutritional value of foods throughout the food chain, and promoting these issues in rural radio, popular television, school food and nutrition programmes, and in education, research and extension services. The proposed strategy would also promote the development of an information programme within FAO that addresses these issues on a permanent basis including the development of background materials for the media and the establishment of regular communication channels.
43. The International Food Safety Authorities Network (INFOSAN) recently developed by FAO and WHO and operated by WHO will serve as a vehicle for food safety authorities and other agencies involved in food safety to share information and experiences and learn from each other in managing food safety issues.
44. Unfortunately, international and domestic trade in foods remains subject to serious disruptions when food safety and related incidents suddenly arise. Many of these disruptions create confusion and doubts in the minds of the consumer, present problems for official agencies managing the emergency, and negative economic and business effects along the food chain. The proposed strategy would provide for emergency response by FAO to these situations, including the provision of authoritative advice, rapid dissemination of information, and where necessary, assistance to developing countries. The strategy should allow for access through the IPFSAPH to existing emergency information networks, such as the emergency arm of INFOSAN for food safety, the OIE notification system for animal health and zoonotic emergencies and the International Phytosanitary Portal for plant pests.
45. The food chain approach relies on an interdisciplinary understanding of the factors that affect the safety and nutritional adequacy of foods and the management of these factors. This is true at both the national and international levels, including within FAO. The proposed strategy foresees an enhanced cooperation between standard-setting bodies whose work has an impact on the food chain approach and an extension of this cooperation to include nutrition. At national level, it will encourage cooperation between relevant institutions.
46. The proposed strategy draws on many of the traditional strengths of FAO, particularly those that address international and national regulatory frameworks for food safety and consumer protection. It also places considerable emphasis on “non-regulatory interventions”, especially the technical strengthening of handling, processing and marketing practices and in the areas of extension, information, education and communication. These may be expected to play a major role in enhancing the safety and nutritional adequacy of foods in the mainly unregulated informal and semi-formal sectors. In time, as these sectors become more formalised and amenable to regulation, progress will have been made towards an understanding of the prevailing norms and their application, smoothing the transition.
47. FAO already has major regular and field programme activities that are directed towards ensuring a safe and nutritious food supply. The development of a strategic food chain approach offers the opportunity to draw upon the strengths of FAO’s wide-ranging programmes, improve coordination and include activities that to date have not been considered as part of this overall framework. 16
48. The Committee is invited to provide its views on the present paper and the proposed framework strategy for a food chain approach to ensuring access to safe and nutritious foods. In particular, it may wish to:
49. It may wish to recommend that Council endorse the proposed strategic approach by FAO for ensuring access to safe and nutritious foods.
1 Report of the 28th session of the Committee on Food Security, 6-9 June 2002, Rome, CL 123/10, para.11.
2 Report of the 17th session of the Committee on Agriculture, 31 March – 4 April 2003, Rome, CL 124/9, paras. 30-35. See also “FAO's Strategy for a Food Chain Approach to Food Safety and Quality: A framework document for the development of future strategic direction” (COAG/2003/5).
3 Strategies and policy advice on access to food are discussed by the CFS. Strategies and policy advice on nutrition and diet were discussed by COAG at its 18th Session, February 2004.
4 Recommended International Code of Practice – General Principles of Food Hygiene CAC/RCP 1-1969, Rev.4 (2003), in Food Hygiene Basic Texts, Third Edition - FAO/WHO, Rome, 2003.
5 See COAG/2003/9 Biosecurity in Food and Agriculture.
6 CAC/RCP 1-1969, Rev. 3-1997, Amended 1999.
7 Hawkes, Corinna (2004). Nutrition labels and health claims: the global regulatory environment. ISBN 92 4 159171 4, WHO, Geneva.
8 Many of these interventions are covered in the major outputs of Programme Entity 2.1.4.A9 Enhancing Food Quality and Safety by Stregthening Handling, Processing and Marketing in the Food Chain.
9 The risk analysis framework comprises the elements of risk assessment, risk management and risk comunication and also interactions between these elements. For more details see Working Principles for Risk Analysis for Application in the Framework of the Codex Alimentarius: Procedural Manual of the Codex Alimentarius Commission, 13th Edition, FAO/WHO, Rome, 2003.
10 It should be noted that the Commission adopted the definition for “traceability/product tracing” as proposed by its Committee on General Principles and requested its Committee on Food Import and Export Certification and Inspection Systems to present a proposal for new work on principles for the application of traceability/product tracing as a matter of priority. The Delegations of Mexico, Argentina, Chile and India maintained the view that the application of the definition should be deferred until the principles under development had been finalized. (Report of the 27th Session of the Codex Alimentarius Commission, ALINORM 04/27/41, para. 20).
11 See Principles for the Risk Analysis of Foods Derived from Biotechnology (CAC/GL 44-2003), General Principles of Meat Hygiene (CAC/GL 42-2003), Model Certificate for Fish and Fishery Products (Sanitary Certificate) (CAC/GL – xx-2004) and Codex Code of Practice on Good Animal Feeding (CAC/RCP xx-2004).
12 FAO (2004): FAO Expert Consultation on Food Safety: Science and Ethics. FAO Readings in Ethics No.1.
13 Code of Ethics for International Trade in Foods. CAC/RCP 20 -1979, Rev.1-1985.
14 CL 124/9, Para. 34.
15 See also COAG/2005/INF.3.
16 Current activities that contribute to a food chain approach are managed by LEG, AGA, AGE, AGP, AGS, ESN, FII, FIR and FOR. Additional supporting activities foreseen in this paper are managed by ESA, ESC, SDR and GII.