ALICOM 99/10  |
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Conference on International Food Trade
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Assuring Food Quality and Safety:
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by |
Prof. J.A. Abalaka
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1. This paper will start with a quotation thus, "We shall not cease from exploration. And at the end of all our exploring will be to arrive where we started and know the place for the first time", T.S. Elliot.
2. The beauty and of course the strength of the concept of modern quality management is the recognition of the importance of continuous evaluation of our systemic practices and of continuous improvement in those practices. This concept presupposes that the human knowledge is never perfect and there is always the possibility of improving on practices and performances.
3. One of the major problems facing the world and, indeed, many nations today, is the provision of enough acceptable and safe food to meet the demands of an ever-increasing world population. The integral efforts of increasing food products has over the years revolved around the planned use of fertilizers, pesticides, veterinary drugs, other chemical aids and, recently, the application of genetic engineering to agriculture, large scale processing, preservation, packaging, transportation and storage of the foods. The campaign for prevention of food wastage by encouraging the processing of foods, so as to improve distribution and prolong time/shelf life involved some technological procedures likely to alter the chemical composition of the food itself and may also require the use of intentional food additives or processes likely to increase contamination. Thus the existence of possible health problems/hazards being associated with the quest for more food is real.
4. Health hazards from food can arise from the raw materials used, from handling and through all the stages involved in the processing, transportation, storage and sale of the food.
5. Major food hazards include:
7. Food quality is an instrinsic property of food by which it meets pre-defined standard requirements. Determinants of food quality can be grouped into four properties as follows:
Food quality therefore refers to the value, which is subjectively or objectively attached to food with respect to any or all of the above four qualitative properties.
8. Food safety may be defined as all conditions and measures that are necessary during the production, processing, storage, distribution and preparation of food to ensure that when ingested, it does not represent appreciable risk to health. It is noteworthy to mention that absolute safety of food is not attainable, as microbiological requirements are also set for foods which above certain levels may be considered to be harmful for human health.
9. Individual differences also come into play in relation to food safety as a result of food intolerance or allergies, low immunity etc. There is no international consensus as to what constitutes a "safe food', and it is usually the decision of a national government to state what constitutes a "safe food" for its citizens, while taking into consideration economic, social/cultural, and other considerations.
10. Food safety is multi-dimensional and dynamic in nature and so a food considered as safe under one circumstance may not necessarily be safe under another.
11. While the safety of food is viewed as the joint responsibility of government, industry and the consumer, government plays a pivotal role in this relationship by providing the enabling environment and the laws (regulations and guidelines) that regulate the activities in the food industry in the supreme interest of all concerned.
12. The process of providing a safe, nutritious and wholesome food is the responsibility of government and it involves many critical and complex issues among which is an understanding of risk assessment, risk management and risk communication.
13. Food safety laws and regulations are essential for providing the legal framework for establishing an effective food safety control infrastructure.
14. Food legislation serves to define what is expected as the minimum standard for a large and diverse industry. To the consumer, it defines what is safe and wholesome for consumption. To the industry, it also specifies the criteria to be met if a manufactured food is to be accepted as safe.
15. Good manufacturing practices (GMP) including Good Hygienic Practices should be implemented by manufacturers in order to achieve not only a generally good quality food but also to ensure that the required shelf-life and safety of the food is assured. Good manufacturing practices (GMP) determine the hygienic aspect of food production. Unfortunately, many of the practices have not been specifically developed to guarantee the safety of a food. Hence GMP is usually applied along with other systems.
16. The Hazard Analysis Critical Control Point (HACCP) was developed as a concept aimed at ensuring the safety of foods. Government has the responsibility of encouraging the industry to embrace HACCP which analyses potential hazards, identifies where such hazards can be controlled and describes the process parameters and their critical limits as well as monitoring procedures. The operators are trained to keep their part of the process under control, to monitor the effectiveness of their control and to take appropriate corrective actions in case of deviations.
17. The ISO quality system standards are harmonized quality assurance standards that represent international consensus on the best way to establish a reliable quality system that can easily be verified by the purchaser or third party.
18. The ISO generic management standards focus on establishing the guidance and requirements for satisfying customer's requirements in business practices. Hence, it has relevance in the current concepts in food quality and safety regulation. The requirements of ISO 9000 standards specify requirements for the establishment, documentation and maintenance of an effective quality system. The systems aim towards attaining a zero-defect in the production operation while continuous improvement of the system is limitless.
19. The evolutionary trend of quality management concept led to the establishment of the ISO 9000 Certification scheme. Many governments have adopted the ISO 9000 standards as well as the certification scheme as an appropriate means of evaluating the system and this has been used as a corresponding strong base for the food quality safety regulation. The advantage of this scheme is that it contains both product and systemic indices for compliance.
20. It is however important to state that ISO 9000 series of standards can assure the quality of the product and lead to increased profitability of the industry but, it does not necessarily guarantee in absolute terms the assurance of products and their safety, except when they are combined with others such as Good Manufacturing Practices (GMP) and the Hazard Analysis and Critical Control Point (HACCP) system.
21. National standards on food products contain specific requirements relevant to each food which form the basis of enforcement by governments.
22. The publication of functional standards is fundamental to effective management of product quality as these standards serve as reference for coordination, monitoring, implementation, sustenance of and improvement of the manufacturers by government. Standards therefore lay the foundation for sound management of food product quality which embraces safety also. The standards should be reviewed from time to time in order to ensure that they conform, where possible, to generally accepted international standards.
23. This scheme is a third party quality assurance programme whereby manufacturers of good quality products are awarded the certification mark of quality. This exercise which is voluntary needs to be employed by governments to encourage manufacturers to comply with set standards and they are indeed employed in many countries by national governments. In the food manufacturing sector, quality and safety of food is positively promoted through this scheme. The awards trigger health competition amongst manufacturers of similar food products. The resultant effect is compliance with legislation.
24. Government regulatory authorities should provide relevant information to consumers on the safety of foods. The relative low level of education for the greater population of most developing countries is a major barrier to consumer participation in food control activities. Through consumer information and education, consumer awareness of food quality and safety issues can be improved upon.
25. To bring about a measure of transparency in the decision making process, national government bodies should prepare educational and information material to describe and explain important food safety issues to consumers.
26. Governments should clearly outline the role of the consumers and consumer bodies, and the active participation of consumer organizations in national and international food policies and regulations should be encouraged by various governments as this will improve transparency and engender commitment. The national food control system should be made to be very responsive to and responsible for national food related challenges.
27. The responsibility of every government is the protection of its population against health hazards and commercial fraud from food. Thus all food supplies have to be protected in order to guarantee a certain measure of quality and safety. This is achieved through food control systems. This responsibility, in most countries, involves more than one government department. In some countries such control systems have been developed to varying degrees of sophistication, in others they need strengthening while in some they are almost non-existent.
28. Food import/export control is a regulatory activity based on implementation of legislation and regulation dealing with chemical or microbiological contaminants, food additives, etc. and there should be food standards against which compliance is measured. Inspection and laboratory services form the core of most food import/export control services. The release of imported foods depends on the results of food examination and analysis conducted by the government of the importing country. In some cases a release/acceptance certificate or letter is required before the release of the food consignment. However, if the consignment is rejected for any reason, it may be required to be re-conditioned or may be re-exported or destroyed depending on the degree and nature of non-compliance or defect.
29. This mandatory activity is enforced by governments of the importing country, in order to provide consumer protection. With the growing use of synthetic food components, it is absolutely ncessary that the use of additives in food be regulated. There must be standards limiting the extent to which such additions may be permitted for use after providing the technological and nutritional needs for their use in order to reduce the possible health risks. Surveillance and enforcement of compliance with necessary standards are the responsibility of the government.
30. Food regulatory activities differ from one country to another in implementation. There is need for the various governments to ensure that while carrying out these statutory responsibilities, they do not generate non-tarriff trade barriers and serious dislocation in international and regional trade.
31. Without doubt, the conclusion of the Uruguay Round of Multilateral Trade Negotiations in April 1994 by way of the Marrakech Agreements and the establishment of the World Trade Organization (WTO) in January 1995 have had tremendous impacts not only on international trade in foods, but also on the various national governments and their respective food industries. For some, the development associated with the Agreements have helped in introducing a wider variety of foods into the diet by providing consumers with a larger/wider and better choice of products. As for the net-food exporting countries there have had more prospects and/or probability of increasing their food exports, and therefore, an enhanced prospect of improved economic development and improved standard of living for their citizens.
32. The term "probability" above has been deliberately applied because, on this very issue, the experience in real terms in the last few years with the implementation of the WTO Agreements has varied from one country to another. On the other hand, for the net food importers the WTO Agreements have increased their burden in the sense that they have to cope with all manners of food products resulting from the need to further strengthen their food regulatory system to face the challenges of increased imports.
33. For the country aspiring to join the league of major food exporters, the experience could best be described as one of mixed feelings. While it could be a good challenge to serious minded business operations by way of an increasing competitive scenario, it becomes more daunting, harrowing and relatively prohibitive to those who are technologically and scientifically disadvantaged. The experience is very frustrating for developing countries whose grasp of the provisions of the WTO and TBT Agreements cannot be said to be encouraging.
34. It is generally agreed that the developments associated with the WTO Agreements have played an increasingly important role in the provision of safe and nutritious diets for the world's populations. In this context, and with a view to achieving the objective aspects of food safety in international trade, the WTO Agreement on the Application of Sanitary and Phytosanitary Measures (SPS) was drawn up and signed so as to ensure that countries apply measures to protect human, animal and plant health based on the application of pure science through risk analysis/ management.
35. The overall objective of the SPS Agreement is to permit countries to take "legitimate" measures to protect the life and health of their consumers (in relation to food safety matters), while prohibiting them from using those measures in a way that unjustifiably restricts trade.
36. Thus, the primary goal of the SPS Agreement is to limit the use of measures that may restrict trade to those that are justified to provide the necessary level of health protection. It recognises the right of the Member Nations to protect consumers at a level they consider necessary, subject to certain disciplines, such as consistency and transparency.
37. Despite the important and complementary roles of the Agreements on Sanitary or Phytosanitary (SPS) and Technical Barriers to Trade (TBT), otherwise know as the SPS/TBT Agreements, to food trade, it is observed that the fears and concerns that necessitated the establishment of these protocol agreements have continued to afflict world trade in various forms.
38. Of great significance to many countries especially the developing ones is the recognition of Codex as a baseline for consumer protection under the SPS Agreements, and of special significance to some are a number of provisions in the SPS Agreements which include:
39. Conceding the facts that formed the basis for the above exceptions, it is a sad commentary on our development that the situation in developing countries may not have changed appreciably today. Yet the world must move forward.
40. It is our view in this paper that developing countries have to face the challenges of the reality of our time and spend more funds on their regulatory bodies through enhancement of their capacities and capabilities in the form of strengthening their national food regulatory systems, improving the information technology system, participating more actively in meetings of technical committees as well as in various Commission meetings dealing with food production, food regulations and safety. Such an investment will do them more good than indulging in or allowing their nations to be consumed in internal dissension, intra and inter-regional crises and expending money and resources on activities of a less constructive nature.
41. Establishment of food and food-related regulatory systems where they do not exist is likely to alter significantly and positively the fortunes of many countries. Governments of many nations may be better placed by adopting Codex standards and standards of international standards bodies and adapting them, where necessary, to suit individual and cultural backgrounds instead of dissipating energy and large amounts of money trying to re-invent the wheel. This view, however, does not preclude governments or regional groupings from elaborating and/or harmonising standards that promote their internal or sub-regional interests as long as this does not impede progress towards international harmonization.
42. A lot can be achieved by governments of developing countries by accepting to stand up firmly to the challenges posed by the advent of WTO/TBT/SPS Agreements instead of entrusting their fate entirely or almost so to donor agencies and governments. A donor agency or government can only complement but not substitute.
43. On the other hand, and in the interest of harmonious and prosperous global development, governments of advanced countries would find it of benefit to all to do their utmost to support the food production and food control endeavours of less developed countries.
44. The assistance by governments of developed countries should be on the basis of time- sequenced programmes in which the results of assistance should be evaluated over a time period, and success or failure assessed to provide guidance on whether assistance should be continued or discontinued.
45. Given the foregoing scenarios, the Codex Alimentarius Commission has adopted the concepts of good manufacturing practice, codes of hygienic practice and of use of the Hazard Analysis Critical Control Point (HACCP) System as veritable means of food safety management and/or control.
46. Similarly, risk analysis has been widely recognised as a fundamental methodology underlying the development of food safety management and of standards. While, at the international level, attempts are being made to harmonise the approach to risk because of the obvious differences in our perceptions/environment and other associated factors, it has been recognised that this is one venture which many member nations do not have the capacity/capability to embark upon. The world has to find a way out of this quandary.
47. The safety of food cannot be clearly removed from a consideration of its quality. Safety is one aspect of quality. The past decade has witnessed very positive developments in the establishment of models for the management of quality systems by the various international standardization bodies. Just like the WTO Agreements, these models and their corresponding standards have been employed to great advantage by business organizations in many countries and have, undoubtedly contributed to the development of world trade. Applied in conjunction with Codex texts, the quality system standards of the ISO have generated positive results for business in meeting market requirements. Yet these are two separate and parallel efforts at producing consumer satisfaction, but the cost of participating fully in these two international bodies has been astronomical and unaffordable by most developing countries which wish to derive maximum benefits from the progammes of the two. It is our sincere expectation that a greater acceptable harmonization of programmes between the two will be found in the course of time in order to ameliorate the financial burden on governments and industries thereby allowing for a greater concentration of focus on quality and safety legislation. In this paper, an attempt has been made to present the concepts of the management of food quality and safety that are attainable today. In consideration of the above, it is the view that the convening of this Conference to appraise the issues relating to international food trade beyond the year 2000 in general and food quality and legislation - the role of governments in particular, is timely. I am optimistic that other presentations will surely raise more issues for consideration.
48. Finally, the views expressed in this paper cannot succeed without enactment of proper legislation on the effective management of the environment and without good governance.
49. The following recommendations are made on the basis of foregoing comments and observations of the paper.