12. The theme paper, presented by Mr Paul Merlin on behalf of the Joint FAO/WHO Secretariat of the Forum (the Secretariat), described the different elements of a national food control system and discussed three possible types of organizational structures for national food control systems, namely a multiple agency, single agency and integrated systems.
13. He then presented key management elements of food safety control services that would improve their effectiveness, including task definition and harmonization, effective supporting legislation and crisis preparedness. Finally, specific issues of developing countries for which technical assistance would be useful were raised, such as weak basic infrastructure, a fragmented food processing industry, dual standards for export and domestic markets and a lack of resources for official services.
14. Several delegations from developing countries re-iterated that continued technical assistance was needed to improve their food safety systems and thanked FAO and WHO for their past support. The importance of strengthening national food control systems to address the needs of the domestic consumer, rather than only to improve food exports, was noted.
15. Other specific concerns raised regarding aspects of food safety control services are included in the discussion portion of the relevant section of these Proceedings.
16. The topic paper presented by Mr Alan Reilly, Deputy Chief Executive of the Food Safety Authority of Ireland, outlined the importance of sharing the responsibility for food safety among all stakeholders involved in the production and marketing of foods, in light of decreased consumer confidence in food safety. It was emphasized that while government and regulatory agencies must work to ensure that consumer's health and interests are adequately protected, consumers must also play a role in ensuring the safety of the food they consume.
17. The speaker noted that effective food control at the national level can be undermined by the existence of fragmented legislation, multiple jurisdictions, and inconsistencies in enforcement and weaknesses in food surveillance and monitoring. Responsibilities should be shared by national governments, farmers, food processors and manufacturers, food retailers, caterers and consumers.
18. The speaker emphasized that the development of effective national multi-disciplinary, inter-agency networks utilizing the food chain approach can be hampered by disagreements regarding areas of competence of national authorities.
19. Several delegations noted the importance of the involvement of all stakeholders, including consumers and industry, in effective national integrated food safety systems and informed the Forum of various actions taken by governmental authorities and international agencies to engage these groups in food safety matters.
20. The following points emerged from the discussion:
Countries must address consumer interests and enable consumer participation, both in training and in decision making activities, in the development or re-organization and implementation of national food safety systems.
It is important to gain political commitment to ensure food safety along the entire food chain. This can be achieved by establishing high level food safety advisory bodies.
National and sub-national interaction and coordination is important in the implementation of a national food safety strategy.
When countries are able to develop and implement effective and comprehensive national food safety strategies, the regional or international sharing of these policies with other food safety regulators allows countries to better garner the political will to advance food safety.
Educating and involving farmers in the production of safe food is also important.
Consumers should be educated in hygienic handling and proper cooking of food, as well as in the importance of making wise nutritive food choices to protect their own and their family's health. Proper food labelling can also assist in protecting consumer health, both in the areas of food safety and nutrition. The current global epidemic of obesity requires interventions by all stakeholders to promote healthy lifestyles and healthy diets.
21. The participants were informed that the WHO Five Keys to Food Safety are an example of a source of the basic information the consumer needs to protect themselves and their families from food safety outbreaks.
22. Mr Alex Seremula, Deputy Director of the Department of Agriculture in the Republic of South Africa outlined the legislative framework that governs food safety control in that country. The speaker gave a detailed account of the various departments involved in food safety, their respective roles and mandates, as well as the relevant private sector food quality assurance and certification schemes operating in that country. He explained that despite the complexity of the system and the large number of players involved, its coordinated implementation is still able to ensure food safety from farm to fork.
23. He noted the value of the co-existence of private sector standards, such as ISO standards, with official standards. He emphasized that countries cannot base their arguments in international trade disputes on these private standards, but need to utilize officially recognized standards.
24. The delegate of the Netherlands highlighted the legal basis of the food safety system of the European Union. In the past decades, legislation in the field of food safety has been largely harmonized across the EU, which has led to uniformity of requirements for countries exporting to the EU Member States. The speaker noted that emergencies related to food and food production that have occurred in the past 15 years have urged the European Union to strengthen their food safety systems in order to protect consumers. These hazards comprise food-borne diseases, zoonoses, residues of unwanted substances in food and dangerous animal diseases.
25. The EU "White paper on food safety" establishes the current food safety policy in the European Union and is based on the risk analysis approach. In this framework, the EU General Food Law of 2002 has led to the establishment of the European Food Safety Authority and several legal measures to be enforced by the Member States. Some of the key elements are 1) the responsibility of producers for safe food and 2) the task of the Government to check that this responsibility is adequately met. It was noted that traceability throughout the entire food production chain is also an important tool to strengthen consumer confidence.
26. The speaker highlighted the challenge of developing a more holistic approach to dealing with food risks by comparing different risks while retaining optimal consumer protection. It was noted that a balance should be found between dealing with microbiological risks and risks of chemical residues. The speaker emphasized that food safety requirements in the European Union are the same for local producers as for countries exporting to the EU Member States.
27. The speaker emphasized that industrialized countries must be aware of the constraints of developing countries in exporting to industrialized countries as developing countries do not always have adequate production and control facilities to comply with international or EU food safety standards. Accordingly, technical assistance, capacity building and partnerships are important instruments to support countries with specific needs.
28. Several delegations informed of actions taken recently to strengthen and streamline their food control services, including identification of the role of the various agencies involved, as well as the coordinating mechanisms established to reduce duplications and eliminate gaps. They noted that developing countries face serious difficulties because of the lack of resources, physical as well as human, necessary to carry out the relevant food control tasks. They stressed the need for an aggressive strategy in favour of consumer awareness so that consumers can play a proactive role in fostering improvement in food control services.
29. The following points emerged from the discussion:
Private standards such as the EUROPGAP scheme, introduced by retailers, are often stricter than EU or Codex standards, and could therefore act as a technical barrier to trade;
Partnerships between food control agencies in developed and developing countries help reduce the differences in food legislation;
The application of the principle of "as safe as possible" and that of "as safe as necessary", as a basis for food safety decisions, reflect different philosophies in the expression of the appropriate level of protection;
Food exports, including food aid, to countries which do not have the capacity to control their quality and safety need to be in conformity with the regulations of the exporting country.
30. The participants noted the need to conduct an analysis of the food safety situation in African countries and to use such an analysis to assess their needs in capacity building and technical assistance. They were informed of an FAO and WHO plan to carry out this analysis in connection with the joint Regional Conference on Food Safety for Africa, scheduled to take place in 2005.
31. Mrs Claire Gaudot, Scientific Adviser of the Permanent Representation of France to FAO outlined the training of official food safety control services personnel. She began by reviewing the context in which official control services operate, with rapid and significant changes that call for constant adjustment in the ability of food safety control personnel.
32. The speaker emphasized the importance of distinguishing the three types of training: pre-recruitment training, which should cover the full range of ability required at recruitment, post-recruitment occupational training given before taking up duties and staff development or further training. Training needs should be defined through multi-factor analysis of the context in which control personnel operate.
33. It was noted that training is an essential tool for building the capacity of control authorities and for managing human resources. It requires a specific policy and proper resources. The speaker noted that the organization of a national or regional training mechanism needs to reflect the mandates and responsibilities of official control services. The training programme should cover all aspects relating to the activity of official food safety control service personnel, including knowledge, experience and self-management skills.
34. The discussants stressed the strategic value of training for implementing effective food safety control systems and criticized the lack of resources made available by governments. Several delegations noted that the absence of local expertise meant that training had to be sought outside the national context, incurring high costs and limiting resources for local experts. The delegations called for the support, especially from FAO and WHO, of initiatives to develop training opportunities, including basic training, for food safety control personnel. It was also stressed that the growing focus on shared responsibility needed to be accompanied by the training of producers and consumers through their respective associations, in order to help them to shoulder their new responsibilities.
35. The representative of the European Commission informed the Forum of the proposal to set up a European training centre for official food safety control officials. This centre was to be run by the Food and Veterinary Office based in Dublin, Ireland, and would be open to inspectors from EU Member States as well as those from developing countries exporting to the Community (3000 trainees scheduled for 2006). The representative of the IAEA drew attention to Conference Room Document 22 on activities in food safety training proposed by the Joint FAO/IAEA Division of Nuclear Techniques in Food and Agriculture.
36. Ms Sirilak Suwanrangsi, Minister Counsellor, Royal Thai Embassy, Tokyo, Japan, presented the principles governing the role of governmental agencies in the implementation of HACCP by the private sector using examples from the Thai experiences in this area. She emphasized the vital role the Government has in supporting HACCP implementation through cooperation of all sectors in the food chain including industry associations, academia, individual processors and producers, suppliers of raw materials, exporters and importers. Government agencies have strategic roles in the implementation of HACCP as well as operative roles on assessment of effectiveness and compliance.
37. She also noted that, in fostering HACCP implementation, it is vital that governments have sufficient capabilities to perform the tasks. Governments should allocate resources and when necessary, reorganize the works and work forces to support the industry. HACCP generic models <http://www.inspection.gc.ca/english/fssa/polstrat/haccp/modele.shtml>, hazard identification and control guides could be provided to enhance the development and to ensure uniformity and scientific integrity. Schemes for recognition of the HACCP system, such as audit and certification, would enhance effective implementation and market access.
38. She added that HACCP is one risk management tool. HACCP alone cannot resolve food safety problems, and should be complemented by other control measures such as monitoring programmes at primary production for agriculture chemicals, pollutants, contaminants and natural toxin, traceability and labelling.
39. She concluded by noting that the HACCP programme should be kept simple and based on science and international standards. Countries should share experiences and collaborate in training. FAO and WHO can assist in training and make available relevant information. Assistance to small scale entrepreneurs and the lesser experienced countries should be focused.
40. Several delegations described similar positive experiences in governmental support to HACCP implementation. There was general agreement that small scale producers have particular needs in terms of HACCP implementation due to the often limited human resources available in these enterprises. Difficulties in conducting proper hazard analysis, as well as auditing were mentioned as other areas of concern.
41. Several delegates thanked the international organizations for their support in introducing HACCP in their country and urged countries with a long experience in HACCP to support them by sharing their experiences.
42. There was discussion about the use of certification schemes with a general agreement that these are mostly used for market access and provide only one piece of evidence that a proper and efficient system is in place.
43. The representative of the FAO Secretariat announced the current development of an FAO/WHO guidance document to support HACCP implementation in small scale businesses and suggested to the delegates, in particular from developing countries, to participate in its elaboration by taking part in the E-forum organized by FAO for this purpose.
44. The presentation by Ms Karen Stuck, Assistant Administrator of the Food Safety Inspection Service, United States of America focused on the purpose of import controls, principles for designing an import control programme and the tools available for carrying out import control programmes.
45. The speaker noted that the SPS Agreement permits countries to establish their own level of protection provided the standards are based on science, applied consistently and are transparent. The speaker outlined the tools available for import control programmes which include equivalence determination, audits, port-of-entry inspections, automated systems to facilitate rapid clearance and statistically-based random sampling.
46. A paper on Food Export Control and Certification was presented by Ms Shashi Sareen, Director, Export Inspection Council of India. The speaker noted that while most governments focus on import systems only, food export control and certification such as that implemented by India plays an important role in assuring food safety and quality.
47. Advantages of the food export certification include reduction of the time required to test food imports, minimization of import rejection, decreased duplication, cost effectiveness, reduced variation of food products, and improvement of the exporting country's image. India has developed rules for export certification and implements these rules for several commodities. Ms Sareen outlined the challenges faced by developing countries when exporting to major importing markets and made suggestions on actions needed to overcome them.
48. Mr Henri Belvèze, Deputy Head of Unit, European Commission, presented Conference Room Document 28 on Practical considerations of the operation of the EU import/export controls.
49. As part of its gradual integration, the European Community has enacted detailed legislation for the control of foods imported from third countries. Regulations on the import of products of animal origin were the first to be put in place, covering aspects relating to public health and animal health. They place primary responsibility for inspection and certification on the competent authorities of the exporting country, in follow-up to an evaluation mission of the Commission's Food and Veterinary Office (FVO). With the exception of plant health regulations applying to selected fruits and vegetables, import regulations for foodstuffs of non-animal origin are at a less advanced stage of Community harmonization. However, on 1 January 2006, new regulations will be introduced that will reinforce the integration of the food import control system and reduce the area of competence remaining under national legislations.
50. The speaker noted that controls envisaged in community legislation are made by the inspection services of the Member States under the supervision of the FVO. They can take place at the border or at destination, depending on the foods imported. The nature and frequency of actual material controls, basically in laboratory analysis, are determined by the level of risk and the results of previous controls of products of the same origin. The special needs of developing countries, if they are to adapt to the new conditions of 2006, will be taken into account by the Commission, especially as regards time frames, training and technical assistance.
Follow up Discussion
51. Several countries commented that while the WTO allows for a determination of equivalence, this concept is often difficult to implement. It was pointed out that a standard coding system and common language would facilitate food trade and import assurances. Several delegates commented that Codex standards should be expanded to cover all food safety needs (e.g., limits on microbiological contamination) and be more detailed. Also, the issue of food quality should be given due consideration as a large proportion of food import rejections are caused by quality deficiencies.
52. It was noted that food safety authorities should also be held to a standard of performance as a consistent standard of performance for food agencies will increase trust and confidence in the safety of exported products. Other delegates noted that infrastructure development in countries would contribute to facilitating food trade. Some delegations emphasized the moral and humanitarian responsibility of countries, especially those which food may be transported through, to assist in coordinating and monitoring of the safety of food imports in order to protect consumers in a country where the food safety programmes have been disturbed due to a major crisis.