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5.1 Principles of Food Control: Issues for Consideration

When seeking to establish, update, strengthen or otherwise revise food control systems, national authorities must take into consideration a number of principles and values that underpin food control activities, including the following:

Certain key principles and related issues are discussed below.

(a) Integrated farm-to-table concept

The objective of reduced risk can be achieved most effectively by the principle of prevention throughout the production, processing and marketing chain. To achieve maximum consumer protection it is essential that safety and quality be built into food products from production through to consumption. This calls for a comprehensive and integrated farm-to-table approach in which the producer, processor, transporter, vendor, and consumer all play a vital role in ensuring food safety and quality.

It is impossible to provide adequate protection to the consumer by merely sampling and analysing the final product. The introduction of preventive measures at all stages of the food production and distribution chain, rather than only inspection and rejection at the final stage, makes better economic sense, because unsuitable products can be identified earlier along the chain. The more economic and effective strategy is to entrust food producers and operators with primary responsibility for food safety and quality. Government regulators are then responsible for auditing performance of the food system through monitoring and surveillance activities and for enforcing legal and regulatory requirements.

Food hazards and quality loss may occur at a variety of points in the food chain, and it is difficult and expensive to test for their presence. A well structured, preventive approach that controls processes is the preferred method for improving food safety and quality. Many but not all potential food hazards can be controlled along the food chain through the application of good practices i.e. good agricultural practices (GAP), good manufacturing practices (GMP), and good hygienic practices (GHP).

An important preventative approach that may be applied at all stages in the production, processing and handling of food products involves the Hazard Analysis Critical Control Point system (HACCP). The principles of HACCP have been formalised by the Codex Committee on Food Hygiene[1], and provide a systematic structure to the identification and control of foodborne hazards. Governments should recognize the application of a HACCP approach by the food industry as a fundamental tool for improving the safety of food.

(b) Risk Analysis

The Codex Alimentarius Commission defines risk analysis as a process composed of three components:

Risk analysis is well established for chemical hazards, and FAO and WHO are now extending the experience and expertise developed from risk analysis of chemical hazards to that of microbiological hazards.

Risk analysis must be the foundation on which food control policy and consumer protection measures are based. While not all countries may have sufficient scientific resources, capabilities, or data to carry out risk assessments, it may not even be necessary in all cases to generate local data for this purpose. Instead countries should make full use of the international data and expertise as well as data from other countries that are consistent with internationally accepted approaches. Risk assessments carried out at the international level by JECFA, JMPR (See Annex 7), and other expert bodies are particularly useful. Developing countries should take a pragmatic approach and develop a cadre of scientists to interpret such data and assessments, and to use this information for the development of national food control programmes.

Codex standards take into account risk assessments carried out at the international level and are accepted as scientifically valid under the SPS Agreement. Hence their adoption and implementation within national food control systems is encouraged.

Risk management should take into account the economic consequences and feasibility of risk management options, and recognize the need for flexibility consistent with consumer protection requirements.

(c) Transparency

A food control system must be developed and implemented in a transparent manner. The confidence of consumers in the safety and quality of the food supply depends on their perception of the integrity and effectiveness of food control operations and activities. Accordingly, it is important that all decision-making processes are transparent, allow all stakeholders in the food chain to make effective contributions, and explain the basis for all decisions. This will encourage cooperation from all concerned parties and improve the efficiency and rate of compliance.

Food control authorities should also examine the manner in which they communicate food safety information to the public. This may take the form of scientific opinion on food safety matters, overviews of inspection activity, and findings on foods implicated in foodborne illnesses, food poisoning episodes, or gross adulteration. All this could be considered as a part of risk communication to enable consumers to better understand the risks and their responsibilities for minimizing the impact of foodborne hazards.

(d) Regulatory Impact Assessment

When planning and implementing food control measures, consideration must be given to the costs of compliance (resources, personnel, and financial implications) to the food industry, as these costs are ultimately passed onto consumers. The important questions are: Do the benefits of regulation justify the costs? What is the most efficient management option? Export inspection systems designed to assure the safety and quality of exported foods, will protect international markets, generate business and secure returns. Animal and plant health measures improve agricultural productivity. In contrast, food safety is an essential public health goal and may impose costs on producers, yet investments in food safety may not be immediately rewarded in the market place.

Regulatory impact assessments (RIA) are of increasing importance in determining priorities and assist food control agencies in adjusting or revising their strategies to achieve the most beneficial effect. They are, however, difficult to carry out. Two approaches have been suggested for determining cost/benefit of regulatory measures in food safety:

Both approaches require considerable data for interpretation. COI estimates are perhaps easier for policy makers to understand and have been widely used to justify measures for food control, even though they do not measure the full value of risk reduction. Not surprisingly, it is easier to perform a RIA for an export inspection intervention, than for regulatory policy which achieves a public health outcome.

5.2 Developing a National Food Control Strategy

The attainment of food control system objectives requires knowledge of the current situation and the development of a national food control strategy. Programmes to achieve these objectives tend to be country specific. Like socioeconomic considerations, they are also influenced by current or emerging food safety and quality issues. Such programmes also need to consider international perceptions of food risks, international standards, and any international commitments in the food protection area. Therefore, when establishing a food control system it is necessary to systematically examine all factors that may impinge upon the objectives and performance of the system, and develop a national strategy.

(a) Collection of Information

This is achieved through the collection and collation of relevant data in the form of a Country Profile (See Annex 8). This data underpins strategy development, with stakeholders reaching consensus on objectives, priorities, policies, roles of different ministries/agencies, industry responsibilities, and timeframe for implementation. In particular, major problems associated with the control and prevention of foodborne diseases are identified so that effective strategies for the resolution of these problems can be implemented.

The profile should permit a review of health and socioeconomic issues impacting on foodborne hazards, consumers concerns, and the growth of industry and trade, as well as identification of the functions of all sectors which are directly and indirectly involved in ensuring food safety and quality and consumer protection. The collection of epidemiological data on foodborne illness is an indispensable component of a country profile and should be done whenever possible.

(b) Development of Strategy

The preparation of a national food control strategy enables the country to develop an integrated, coherent, effective and dynamic food control system, and to determine priorities which ensure consumer protection and promote the country's economic development. Such a strategy should provide better coherence in situations where there are several food control agencies involved with no existing national policy or overall coordinating mechanism. In such cases, it prevents confusion, duplication of effort, inefficiencies in performance, and wastage of resources.

Devising strategies for food control with clearly defined objectives is not simple, and the identification of priorities for public investment in food control can be a challenging task. The strategy should be based on multi-sectoral inputs and focus on the need for food security, and consumer protection from unsafe adulterated or misbranded food. At the same time it should take into consideration the economic interests of the country in regard to export/import trade, the development of the food industry, and the interests of farmers and food producers. Strategies should use a risk based approach to determine priorities for action. Areas for voluntary compliance and mandatory action should be clearly identified, and timeframes determined. The need for human resource development and strengthening of infrastructure such as laboratories should be also considered.

Certain types of food control interventions require large fixed capital investments in equipment and human resources. While it is easier to justify these costs for larger enterprises, imposing such costs on smaller firms who may coexist with larger enterprises may not be appropriate. Therefore the gradual phasing in of such interventions is desirable. For example, countries may allow small enterprises longer periods of time to introduce HACCP.

The strategy will be influenced by the country's stage of development, the size of its economy, and the level of sophistication of its food industry. The final strategy should include:

5.3 Strengthening Organizational Structures for National Food Control Systems

Given the wide scope of food control systems, there are at least three types of organizational arrangements that may be appropriate at the national level. These are:

(a) Multiple Agency System

While food safety is the foremost objective, food control systems also have an important economic objective of creating and maintaining sustainable food production and processing systems. In this context, food control systems play a significant role in the following:

The systems that deal specifically with these objectives can be sectoral i.e. based upon the need for development of the particular sector such as fisheries, meat and meat products, fruit and vegetables, milk and milk products. These systems can be mandatory or voluntary, and put into effect either through a general food law or a sectoral regulation. Examples include:

Where sectoral initiatives have resulted in the establishment of separate food control activities, the outcome has been the creation of multiple agencies with responsibilities for food control. Typically, under such arrangements the food control responsibilities are shared between Government Ministries such as Health, Agriculture, Commerce, Environment, Trade and Industry, and Tourism, and the roles and responsibilities of each of these agencies are specified but quite different. This sometimes leads to problems such as duplication of regulatory activity, increased bureaucracy, fragmentation, and a lack of coordination between the different bodies involved in food policy, monitoring, and control of food safety. For example, the regulation and surveillance of meat and meat products may be separate from food control undertaken by a Ministry of Health. Meat inspection is often done by Ministry of Agriculture or primary industry personnel who undertake all veterinary activities, and the data generated may not be linked to public health and food safety monitoring programmes.

Food control systems may also be fragmented between national, state and local bodies, and the thoroughness of implementation depends upon the capacity and the efficiency of the agency responsible at each level. Thus consumers may not receive the same level of protection throughout the country and it may become difficult to properly evaluate the effectiveness of interventions by national, state or local authorities.

While multiple food control agencies may be the norm, they suffer from serious drawbacks including:

During the preparation of a national food control strategy, it is important to consider the type and size of the organization(s) that are necessary to implement the strategy. It is often not possible to have a single unified structure or an integrated food control system, due to various historical and political reasons. In such cases, it is necessary for the national food control strategy to clearly identify the role of each agency to avoid duplication of effort and to bring about a measure of coherence among them. It should also identify areas or segments of the food chain which require special attention and need additional resources for strengthening.

(b) Single Agency System

The consolidation of all responsibility for protecting public health and food safety into a single food control agency with clearly defined terms of reference has considerable merit. It acknowledges the high priority that Government places in food safety initiatives and a commitment to reducing the risk of foodborne disease. The benefits that result from a single agency approach to food control include:

While a national strategy helps to influence both the legislation and the organizational structure for enforcement, it is not possible to recommend a single organizational structure that will universally meet the requirements and resources of every country's socioeconomic and political environment. The decision has to be country specific and all stakeholders should have the opportunity to provide inputs into the development process. Unfortunately, there are often few opportunities for countries to build a new food control system based on a single agency.

(c) Integrated System

Integrated food control systems warrant consideration where there is desire and determination to achieve effective collaboration and coordination between agencies across the farm-to-table continuum. Typically, the organization of an integrated food control system would have several levels of operation:

Level 1: Formulation of policy, risk assessment and management, and development of standards and regulations.

Level 2: Coordination of food control activity, monitoring, and auditing.

Level 3: Inspection, and enforcement.

Level 4: Education and training.

In reviewing and revising their food control systems, governments may wish to consider a model which calls for the establishment of an autonomous national food agency which is responsible for activities at Levels 1 and 2, with existing multi-sectoral agencies retaining responsibility for Level 3 and 4 activities. The advantages of such a system include:

Responding to these benefits, several countries have established or are in the process of creating such a policy making and coordinating mechanism at the national level. Case studies demonstrating national food control systems in selected countries are presented in Annex 9.

By placing management of the food supply chain under a competent, autonomous agency, it is possible to fundamentally change the way food control is managed. The role of such an agency is to establish national food control goals, and put into effect the strategic and operational activities necessary to achieve those goals. Other functions of such a body at the national level may include:

An integrated National Food Control Agency should address the entire food chain from farm-to-table, and should have the mandate to move resources to high priority areas and to address important sources of risk. The establishment of such an agency should not involve day-to-day food inspection responsibilities. These should continue to lie with existing agencies at national, state/provincial, and local levels. The agency should also consider the role of private analytical, inspection, and certification services particularly for export trade.

See Annex 10 for further details on selected organizational components of a National Food Control Agency.

See Annex 11 for details on possible activities to be undertaken during the establishment and initial operation of a National Food Control Agency.

5.4 Funding National Food Control Systems

The funds and resources required for reorganizing and strengthening food control systems would normally be made available from the national government. In countries where food control responsibilities are spread across many government agencies it may be necessary to negotiate a revised funding structure and establish transition arrangements to ensure continuity of funds and resources. For this to occur, it is essential there is full commitment by the government for establishing appropriate structures and developing policies to deliver the optimum level of consumer protection.

Securing sufficient resources may be a problem, as the trend towards reduced public sector spending is influencing governments to review their priorities and funding arrangements. Cost recovery is practised in many countries. It is important that this is managed carefully as any costs passed directly onto the food industry will ultimately be passed onto consumers as an indirect tax on food. This falls disproportionately on the poorer sectors of society. Cost recovery options include fees for licensing, inspection activity, and food analysis. In some countries the trend towards smaller governments has resulted in the contracting of food control services from the private sector. This involves private providers contracted to undertake specific food control activities such as food inspection and surveillance.

[1] Codex Alimentarius (1997). Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application. Annex to CAC/RCP 1-1969, Rev. 3 (1997)

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