ALICOM 99/11  |
| ALICOM 99/11 |
Conference on International Food Trade
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Assuring Food Quality and Safety: Back to the Basics - Quality Control Throughout the Food Chain
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by |
Edward Groth III, PhD, Consumers Union of United States, Inc, USA |
1. To average consumers in most countries, the GATT, SPS and TBT Agreements, the Codex Alimentarius Commission, the World Trade Organization and other agencies that address food quality and food safety issues at the international level are unfamiliar, abstract, distant entities. It is hard for ordinary consumers to grasp how the work of these bodies affects their daily lives and food choices.
2. At the same time, food quality and safety are universal and personal consumer concerns. Everyone cares about what they eat, and food quality and safety rank high on the list of consumer product issues in both developed and developing countries. Those aspects of food quality and safety that most concern consumers are likely to vary from country to country, from North to South, from developed to developing societies, from large to small countries, and within each of these groups of countries as well. But many consumer concerns about food issues are nearly universal.
3. As we enter the 21st century, governments and the international business community have long seen the need to address food safety and quality issues in the context of international trade. National governments, the FAO, WHO and WTO, multinational corporations and food and agricultural industry organizations have all participated actively in shaping policies that govern international food safety and trade.
4. Consumers, and consumer organizations that represent the voice of consumers in policy forums, have not been so prominently involved in most international food policy debates. Many consumer organizations perceive, justifiably, that decisions that affect what we will eat in the coming century are being made behind closed doors, by business and government experts, in forums where the public is often not invited to participate.1
5. There are many reasons why consumer organizations should play, and I believe in the future will play, a larger role than they have to date in food policy decision making. Foremost among these reasons is the need for consumer acceptance of innovations in the food marketplace. If consumers don't "buy into" new food technologies and new sources of foods, the market may become dysfunctional in several ways. Consumers may distrust sellers; the public may reject innovations; international trade in foodstuffs may be much more difficult than it should be; and so on.
6. We should not presume that business and government always have consumers' best interests in mind, or can automatically tell what consumers would like them to do. For the policy process to address consumers' needs, consumers need to be "at the table" and to articulate their wants and needs. If the international marketplace for foods is to function smoothly during the next century, consumer organizations at the national and international levels will need to become more fully engaged in the policy process.
7. To play an effective role as individual buyers in the foods marketplace, ordinary consumers need information. To represent consumers effectively in food policymaking discussions, consumer organizations also need a great deal of information.
8. Most consumers, to differing degrees, are concerned with and have at least some knowledge of the quality and safety of the foods they eat. Sensory quality, freshness, and nutritional benefits of foods are aspects that most consumers consider each time they buy groceries. Consumers generally presume that foods offered for sale should be safe, but also realize that they have a role to play in ensuring food safety-washing fresh produce, thoroughly cooking meats, and so forth. Consumers also recognize that there are food safety aspects over which they have no control-pesticide residues, or mycotoxins, for example-and they rely on governments to set safety standards, and on industry and governments to ensure that foods on the market meet those standards.
9. In different societies, specific food quality and safety concerns certainly differ. A consumer in a developing country may be most concerned with obtaining sufficient food to meet her family's nutritional needs, while one in a developed country may place more emphasis on avoiding excessive intake of calories and fat. But consumers everywhere are looking for foods that are tasty, nutritious, available at reasonable cost and as free as possible of unwanted additives and toxic contaminants.
10. As the world food market becomes globalized, the eating habits of developing countries are becoming more and more like those of developed countries. We in the West, I fear, have exported some of our culture's less admirable inventions, like soft drinks and fast foods, and with them our nutritional problems. And a survey of several south Asian countries found that consumers there expressed a strong interest in buying organically grown foods.2 The gap among nations may be narrower than we think it is.
11. While the particular issues that attract attention are likely to be very specific to individual nations and cultures, consumers in both developed and developing countries are all concerned with food safety. Avoidable food-related risks, such as those posed by food additives, pesticides and other contaminants, are high on the list of food problems consumers expect their governments and industry to address, in most countries.
12. Consumers today are also increasingly concerned with how food is produced. Many consumers want to use their buying power to support environmentally sustainable and ethically sound food production methods.3
13. While there are differences from country to country and region to region in terms of what most visibly concerns consumers about foods, the world is shrinking. Today's concerns in Europe or North America will be tomorrow's concerns in Asia, Africa or Latin America, and vice versa. From my experience within the international consumer movement, I also believe that certain concerns are essentially universal. For example, consumers in all nations want safe foods, they want choices, and in specific contexts, they want foods clearly labelled, so they can choose. Across all cultures, consumers have a right to know what they are buying and a right to decide whether to buy it or not, based on whatever values they consider most important. These themes resonate in consumer food policy positions the world over.
14. For consumers to exercise informed choice in the global marketplace for foods, they need solid factual information. Those with expert knowledge about food quality and safety-industries, academic scientists, government agencies, and non-governmental organizations, including consumer organizations-must share their knowledge with the public. This sharing may range from putting information that consumers demand on food labels to a variety of broadly-based public education programs on food issues.
15. Some changes in the global food marketplace in recent years have been driven largely by consumer demand. The proliferation of low-fat foods and the expansion of nutritional labelling, for example, reflect growing consumer concern with diet, health and nutrition. The increased variety of food choices, including imports from faraway lands, reflects not only the revolution in transport systems, but also a revolution in consumer expectations. For example, 20 years ago American consumers hardly knew what a kiwi fruit looked like, but as the century turns we encounter this tasty fruit daily, and take for granted our routine ability to buy foods from foreign lands. Trade in foods has enriched consumer choices in supermarkets not just in the wealthy nations, but the world over. Consumers welcome progress of this nature and have no desire to reverse the trend.
16. Some other changes in the food marketplace, however, have taken place largely independent of expressions of consumer demand. Perhaps the most prominent example is the proliferation of genetically modified (or GM) foods. New genetic traits have been introduced into crops primarily to enhance agricultural production efficiency, and only rarely to make foods obviously better for consumers. Consumers, seeing no personal benefits in the technology and being aware of possible unwanted environmental costs, have asked whether it is really in society's best interests to invest in food biotechnology.
17. The biotechnology industry, in fact, has been shaken when consumers have questioned the acceptability of certain GM foods. Consumers in many countries have expressed concerns that GM foods have been inadequately tested for public health and environmental safety. Some consumers have expressed ethical qualms about transferring genes across species boundaries, uneasiness about "tinkering with nature," and various other concerns about GM foods. There is broad international support among consumer organizations for mandatory labelling of GM foods.
18. To many consumers, it appears as if these legitimate concerns have been brushed aside by a paternalistic industry/government coalition that is telling us to "Be quiet and eat your (GM) vegetables." While the public may eventually come to accept specific applications of GM food technology, the path to acceptance has been made far more difficult by public distrust and anger over the way this technology has been imposed on consumers. Unless concerted efforts are made to address and resolve these legitimate concerns that consumers have about GM foods, these obstacles may not be overcome for a very long time.
19. Sometimes, consumer demands for quality and for safety may conflict directly with each other. For example, consumers in developed countries are accustomed to buying unblemished, cosmetically "perfect" fresh fruits and vegetables. But quality standards that promote cosmetic appeal also lead to much greater use of insecticides. Consumers also want fruits and vegetables that are as free as possible of potentially harmful pesticide residues.
20. Would most consumers accept an occasional blemish on an apple or orange, in order to reduce the amount of pesticide residues in their diets? Undoubtedly, many would. In North American and much of Europe, the food marketplace now includes produce with "green labels," ranging from "organically grown" to grown with various regimens that reduce pesticide use and other technological inputs. If the foods are less than cosmetically perfect, many consumers don't care; when they make choices in the supermarket, they express a preference for sustainable food production methods.
21. Consumers in developing countries also want to buy sustainably grown foods, but currently may have fewer obvious opportunities to do so. The global food marketplace of the 21st century will need to make such choices more widely available to consumers in all nations. Along with meaningful choices, consumers need information, to know precisely what they are buying, and to understand the consequences of their choices.
22. In my opening remarks, I said that consumers, typically represented by consumer organizations, need and deserve a seat at the table in food quality and safety policy-making processes. What roles are consumer organizations now playing in these policy processes, and how can the consumer role be enhanced as we enter the 21st century?
23. Consumer participation in food policy processes is essential at both national and international levels. Participation of consumer organizations in food policy processes at the national level supports the soundness and the acceptability of national decisions. Since the specific details of food issues and of consumer concerns differ substantially from country to country, it is critical for consumer organizations to participate in their national dialogues on food quality and safety. Participation at the national level also will help build technical knowledge and experience with policy processes needed to support international consumer participation.
24. Situations vary widely among countries, in terms of the number and nature of consumer organizations, the extent to which they are interested in and knowledgeable about food policy issues, and the extent to which the national food policy process is open to consumer participation. Each Codex member government has been asked to establish a National Codex Committee and a National Codex Contact Point. Not all governments have achieved these objectives. Among those that have, the degree of participation by consumer organizations varies widely from country to country.
25. At the international level, consumers have participated in Codex work for many years. Consumers International, representing some 230 consumer organizations in about 110 countries, sends delegations to meetings of about eight "horizontal" Codex technical committees, as well as to meetings of the Codex Commission, the Committee on General Principles, and the regional Codex Coordinating Committees. Through following Codex proceedings for many years and being actively involved in debates on numerous issues, CI has built experience among its members and plays an effective role in Codex work.
26. Within the past year or two, one additional international consumer organization has begun attending Codex meetings. Unfortunately, only two of the more than 100 recognized Codex observer organizations are consumer NGOs, and only a handful of others are non-industry. At least numerically, consumers are seriously underrepresented in Codex. And consumers are barely represented at all at the World Trade Organization and in GATT negotiations. If the consumer voice is to be heard in these international forums, consumer organizations will need to give the same priority to being actively involved there that they have given in recent years to Codex work.
27. When consumer organizations have participated in the food policy process, at both national and international levels, they have brought certain assets to the table. First, they have brought information and expertise. At minimum, consumer organizations can express to policymakers what consumers care about, or at least voice their members' concerns. Some consumer organizations in both developed and developing countries also have substantial expertise on scientific aspects and economic aspects of food issues, on policy-making processes, and on other relevant topics. Often, experts associated with the consumer sector have different scientific or analytical perspectives than those of experts from industry and government. Participation by experts from consumer organizations thus can help ensure a balance of perspectives.
28. A second asset consumer organizations bring to the table in the food policy process is sensitivity to a broad range of societal and ethical issues. While food safety and quality decisions must rest heavily on scientific data, science also needs to be applied in a social context. Consumer organizations can often articulate concerns that should be given weight in policy. In the coming century, many issues beyond science, such as the ethical treatment of food animals and the need to use food production technologies that are environmentally sustainable, will grow in importance. Consumers, and consumer organizations, are usually somewhat ahead of government and industry in identifying and responding to such concerns. Consumer participants in policymaking can serve as an "ethical compass," pointing in directions that government and industry will need to go in order to meet public expectations.
29. In all candor, one important reason why consumer organizations have been under-represented in negotiations over food safety, quality and trade issues is that, until very recently, participation in these processes has not been a high priority of the consumer movement. Most consumer NGOs are national in focus, and until the 1990s, few such organizations appreciated the fact that food policy decisions are increasingly being made in international forums, rather than just at the national level. This situation is changing, and consumers are beginning to assert themselves in the international food policy arena.
30. But, although consumers now want to participate, there remain barriers that make it difficult for consumer organizations to play a meaningful role in crafting international food policy agreements. I hope, by the end of this conference, we will all agree that it is essential for consumers to be meaningfully involved in this process. Our task will then be to address some of the problems that make this difficult. Important barriers include:
31. From the perspective of most ordinary consumers, international food standards and trade policies are worked out in an inner sanctum, out of public view, by a small circle of high-level experts. This sometimes feels like a club we have not been invited to join. In many ways, some overt and some subtle, the policy making process is less open and less transparent than it needs to be.1
32. One factor that contributes to this perception is the heavy emphasis by industry and governments on the need to base food policy decisions on science. Everyone, of course, consumers included, agrees that science provides an essential, objective basis for food safety decisions. But consumers also recognize that making policy, be it on safety, quality or trade, requires making value choices. Policy must seek to balance the diverse needs of society, and that is a political process, not a scientific one. This insistence that science, and often by implication, only science, is a legitimate basis for decisions strikes many consumer organizations as an effort to deny the essentially political nature of food policy decisions, and to categorize things that matter to consumers, like environmental sustainability, social justice, and ethics, as out-of-bounds in food policy decisions.
33. I believe one of the greatest challenges to the international community as we enter the 21st century is the need to define the principles by which we make food policy. It is clear both that science is vital, and that factors other than science must be part of the basis for decisions. How should these decisions be made, so that all legitimate factors get their due weight? Where in the process does the science come in, and where are social factors considered? We all need to know what the rules are, so we can play the game correctly.
34. A problem created by the current lack of clearly agreed rules in this regard is that non-scientific social judgments often get mixed in with what purports to be science, in a very non-transparent way. For example, scientific bodies like JECFA do more than just scientific work; they propose definitions of "acceptable risk," and in other ways make recommendations based on subjective value judgments, as well as on the science they have reviewed. JECFA, JMPR and other scientific advisory groups do their work behind closed doors. Scientists from the consumer (or industry) sector cannot serve on JECFA, and meetings are not open to observers. Reports with full details of the evidence and reasoning behind decisions are not published for up to a year after meetings. In at least one specific recent case (BST), allegations have been made (and denied) that the JECFA process was manipulated by government and industry interests to achieve their desired outcome. On the whole, this component of the process is far less open and transparent than it needs to be if it is to be credible with the public.
35. While many consumer organizations are quite competent in scientific aspects of food policy decisions, our concerns also typically mix science and non-scientific factors. Beyond our understanding of the scientific facts, we are also addressing more subjective perceptions of what is in the best interests of society. Consumers need to feel that these concerns are being taken seriously by policymakers. For that to occur, the policy process must address the value components of decisions more openly and transparently.
36. An effort in this direction is currently under way within Codex, in the process of defining Principles for Risk Analysis, and within that process, a focus on defining "other legitimate factors" in addition to science that should be a basis for Codex decisions. The consumer movement is actively participating in this Codex work and following it with great interest. Unfortunately, I must say the effort is proceeding very slowly, and the task is dauntingly difficult. But I can't overstress how important it is.
37. Communication with the public about food safety issues, and lately, food trade policy as well, has never been a simple or easy process. One of the things that makes it more difficult than it needs to be, in my view, is an attitude encountered too often among the expert community. This attitude holds that the public is ignorant, and we, the expert community, must "educate" them-that is, that we must make them see things the way we see things. If that is our objective, our communication efforts are doomed to fail.
38. Many people think communication about food safety and quality is essentially a one-way process: Those with expertise offer facts; consumers become better informed. But effective communication is a two-way, interactive process. Consumers are often concerned with aspects of food quality and safety that most experts don't ordinarily think about. For consumers to accept facts that the expert community wants them to accept, the public must perceive that the expert community is listening to, and is taking seriously, consumer concerns. Communication with the public about foods must include respectful efforts to identify and address the evolving array of food issues that concern consumers. I mentioned some of these factors earlier, in discussing the role of consumers as a force in the food marketplace.
39. A current example of poor communication with consumers on food policy issues is the case of genetically modified foods, to which I already alluded. Although consumer leaders have publicly raised questions about food biotechnology for over ten years, the biotechnology industry has engaged primarily in "top-down communication." Rather than identify legitimate consumer concerns about GM foods and systematically address and try to alleviate them before bringing new GM foods onto the market, the industry has generally adopted the technology first, then tried to persuade consumers that the crops they are planting and foods they are selling are safe and just like any other foods. This approach has not only failed to resolve consumer concerns, it may actually have placed the social acceptability of food biotechnology as a whole in some jeopardy.
40. Foremost among the issues that has not been addressed forthrightly is the global consumer demand for labeling of GM foods. Consumers have a fundamental right to eat what they choose, and to choose what they eat. Both those who want to buy GM foods and those who may wish not to buy them need GM foods clearly labelled, so they can make informed choices. The industry posture that labelling cannot be justified because GM foods are safe strikes consumers as an attempt to dismiss their legitimate concerns, and to shield GM technology from market forces.
41. Some participants in this debate assert that labeling of GM foods would constitute a "barrier to trade." It is true that the GATT, the SPS and TBT agreements all place great emphasis on facilitating trade, and say that safety measures and other standards should be no more restrictive of trade than necessary to achieve their legitimate objectives. But I cannot accept that these trade agreements ever intended to take away consumers' rights to know and to choose. Nor can we allow them to have that effect. I believe "trade" means opening national markets to imported foods. It does not mean, and it cannot mean, taking from consumers the right to know the essential nature of the foods they buy.
42. Some members of the international food policy community seem to believe that it is the role of industry and government to decide what is safe and what should be allowed to be sold, and that the consumer's only role is to buy what is offered for sale. The same perspective also presumes that industry and government should decide, paternalistically, what information consumers need and should be permitted to have about products. But I believe, in contrast, that consumers know what aspects of products matter most to them, and business and government should respond to clearly articulated consumer demand for information. To resist providing the information is disrespectful of consumer concerns.
43. If consumers choose not to buy certain foods because of ethical concerns or based on their desire for more environmentally sustainable production methods, this choice can guide society towards more appropriate uses of technology. In my opinion, that is how a free market is supposed to function.
44. To improve communication, to make it more interactive, more respectful, and less top-down, and also to allow the market to work as it should, some food policy makers need to update their perspective on the role of consumers. If anyone here today believes that consumers should just passively accept whatever foods industry offers for sale and government says is safe, I offer you a new concept for the next millennium. Consumers have the right to know and the right to choose. Consumer preference is a legitimate and powerful market force that can improve the quality and safety of the global food system. Your goal should be to harness this force, not to deflect it.
45. The FAO and WHO held an expert consultation in 1998, on risk communication about food safety issues. I was privileged to be a member of that consultation, as were several others here today. I believe the report we produced4 can be usefully applied to the challenges of communicating with consumers about food trade issues, as well, and I commend it to you. It is available on the FAO web site.
46. Consumer participation in food policy work at the national and the international level is often resource-limited. Many national consumer organizations lack expertise on food issues. Those that have expertise often find they are "spread too thin" to participate effectively in expanding policy discussions. In developing countries, many grass-roots consumer organizations are run by volunteers and have little or no money. Even to travel to another city to attend a meeting where a national policy position is developed may be beyond the means of many consumer organizations.
47. Some governments that have tried to encourage consumer participation in their national Codex process have found it difficult to identify qualified organizations, or to persuade them to invest the time and effort to take part. Despite these limitations, many national governments, the FAO, the WHO and other international agencies, and many consumer organizations themselves have worked hard to improve consumer participation in national food policy work, and participation has grown at a slow, steady pace.
48. Resource limitations are also a major concern at the international level. There are relatively few international consumer organizations, even fewer with the expertise needed to participate effectively in meetings like this, or in the ongoing work of Codex and other bodies. Even if consumer organizations have the expertise to develop policy positions on issues, the cost of travel to international meetings is often prohibitive.
49. Nevertheless, over the past five or six years, Consumers International's Codex work has been expanding gradually. Much of this growth has been due to the dedication of volunteers from CI member organizations. But CI also has received a generous grant from the government of the Netherlands, which I would like to acknowledge here. The FAO has been supportive as well. For example, the FAO regional office in Santiago has made it a priority to help consumer organizations learn how to take part in the Codex process, and its energetic efforts have contributed to notable growth of consumer representation in Codex work in the Latin American region.
50. The need for and the quality of consumer participation in Codex work has been examined from time to time by the Codex Commission, most recently at its June 1999 meeting. A background paper prepared for that discussion outlines both the progress and some of the remaining problems with consumer participation in Codex.5 Much of this analysis may be applicable beyond the Codex system, as well.
51. Not surprisingly, consumer organizations from different countries, and even those within one country, do not always agree on issues. Yet, when presenting consumer views to either national governments or international bodies, there is a compelling need to speak with one voice. Multiple organizations, all claiming to speak for consumers and arguing for conflicting policy views, can be a recipe for confusion. The larger the context of the food policy debate, the more need there is for consumer organizations to find consensus and take consistent positions with governments. To a degree, this is already happening, within organizations like Consumers International. But the need will grow.
52. On some issues, consumer organizations from different countries may need to work out real differences in their positions if they are to be effective in negotiating with governments on food trade and safety issues. Consumers in developed and developing countries both want strong food safety standards, but when confronted with a specific issue, they may have different perspectives on what is "safe enough." In practical terms, it may be difficult for some countries to achieve the same level of health protection that other countries find feasible and desirable. At Codex, Consumers International has taken the position that Codex standards should promote "upwards harmonization;" international standards should push less capable nations to raise their standards, not establish a "lowest common denominator." Many Codex members agree that consumers in the developing countries deserve to be just as fully protected from food-borne hazards as consumers in developed countries are.
53. But this ideal may be put to the test by trade considerations. For instance, let's suppose that a developed country imports nuts from a tropical, developing country, and that climate conditions in the exporting nation make it impossible to achieve an aflatoxin level low enough to meet the stringent standard in force in the importing nation. Should the importing country relax its standard for aflatoxin? Should the exporting country be held to a very high standard? Facilitating trade could benefit consumers in the importing country (perhaps by lowering prices), and would benefit the economy, and consumers at least indirectly, in the exporting country.
54. Consumers in both countries have a stake in this decision; and their interests may appear to be opposed to each other. To guide their governments, consumer organizations from both countries, ideally, should collaborate and develop a mutual position. How they would balance the benefits of trade against the need for strict safety standards is hard to predict. Perhaps consumers in the exporting country would demand tighter safety limits, using the benefits of trade as a lever to persuade their producers to adopt best available practices for limiting aflatoxin. Maybe consumers in the importing country could accept a slightly higher risk from aflatoxin in exchange for quality nuts at a low price, or in the altruistic interest of supporting development for their colleagues across the sea. However it might turn out, if the consumer groups from the two countries wanted to influence what their governments decided to do, they would strengthen their hand by acting in concert.
55. An example of international consumer collaboration on food issues is the recent creation of the TransAtlantic Consumer Dialogue, or TACD for short. The United States and the European Union are each other's largest trading partners, and have established a "Trans-Atlantic Partnership" to negotiate trade policies. Business organizations formed a TransAtlantic Business Dialogue group, TABD, which has a policy agenda supported by corporate leaders on both sides of the Atlantic, to pursue with both governments. When consumer organizations in the US and the EU saw government and business meeting in private to decide issues that profoundly affect consumers, we asked for a seat at the table, and our governments agreed to that request. TACD was set up in September 1998, and has rapidly developed mutual policy positions to take to the government trade partners on a range of issues, including food quality and safety. Despite some notable differences in priorities and positions on issues, US and EU consumer organizations have worked well together and begun their dialogue with government.
56. As trade in food continues to grow, and trade considerations enter into more and more national food safety decisions, consumer organizations will increasingly need to get their acts together on such matters. This need will exist in bilateral trade situations, at the regional level, and in negotiating global trade agreements.
57. Consumers want, and are entitled to, a role in making international policies that govern food quality, food safety and food trade. Their presence "at the table" offers many advantages, not the least of which is increased legitimacy of policies in the eyes of consumer organizations involved as stakeholders in crafting the policies, and associated enhancement of public acceptance of these policies.
58. My own personal experience of international food policymaking has been almost entirely within the Codex system. I believe that consumer participation there has grown significantly in recent years, and has begun to fulfil its promise, although there are still a number of improvements being pursued. My impression, based on much less knowledge of other forums, is that there has been far less of an effective consumer presence at the GATT and SPS negotiations, at the World Trade Organization, and in other forums for international food policy decisions. In part I believe this is due to lack of awareness of the need to be there, and lack of resources that would enable consumers to participate in these other forums. In part I believe it may also be because the Codex system, despite a few remaining problems, is more open to consumer participation, and its procedures are more transparent to interested observers, than is true for most international bodies.
59. Perhaps because of the lack of more effective consumer participation, I believe current world food trade policies place more emphasis on the rights of business to sell in global markets than they put on the rights of consumers in those markets. My colleagues in the consumer movement and I look forward to working with you all in the 21st century as we strive to restore a proper balance to these agreements.
60. I offer the following recommendations to national governments, international agencies, and consumer organizations:
REFERENCES
1. Gerth, J. (1998) Where Business Rules: Forging Global Regulations That Put Industry First. New York Times, Section D, page 1, January 9, 1998.
2. A survey on consumer awareness of "sustainable consumption" issues was carried out in 1997 by academic researchers and the Regional Office of Consumers International in Penang. A preliminary report was presented at the CI World Congress in Santiago in November 1997. For details of the final report, contact Josie Fernandez, Director, CI Regional Office for Asia and the Pacific, e-mail [email protected].
3. Hartman, H., et al. (1996) Food and the Environment: a Consumer's Perspective. Phase I. The Hartman Group, Bellevue, Washington. [Also, Phase II report (1997), and Phase III Report (1999).]
4. FAO (1999) Report of the Joint FAO/WHO Expert Consultation on the Application of Risk Communication to Food Standards and Safety Matters. Rome, FAO, January 1999. (Available at http://www.fao.org)
5. Codex Alimentarius Commission (1999) Consumers' Involvement in the Work of the Codex Alimentarius Commission. ALINORM 99/8, background paper prepared for the 23rd Session of the Codex Alimentarius Commission, held 28 June-3 July, 1999. Rome: FAO (February, 1999)