COFI:FT/VII/2000/7 |
| COFI:FT/VII/2000/7 |
Item 7.3 of the Provisional Agenda |
COMMITTEE ON FISHERIES |
SUB-COMMITTEE ON FISH TRADE |
Seventh Session |
Bremen, Germany, 22-25 March 2000 |
SAFETY AND QUALITY OF FISHERY PRODUCTS |
1. In spite of significant progress in medicine, food science and the technology of production of food, outbreaks of food-borne illness stubbornly continue to increase. In recent years there have been a number of extremely serious outbreaks in virtually every continent. In addition to these outbreaks, caused by pathogens or toxins, the safety of the food supply is also threatened by contaminants, resulting from man's industrial activities. As a result of the failure to control food-borne disease both the food industry and government regulators are feeling a backlash of consumer mistrust, which is reflected in growing consumer activism. Consumers are increasingly becoming involved in the process of regulation and are no longer just a part of the market place, accepting or rejecting products on the grounds of price or quality.
2. The reasons suggested for the increase in outbreaks are many and varied. They include: better reporting, the globalization of food trade (implying that food can become contaminated in one country and infect people in another), increasing urbanization and dependence on stored food and an ageing population that is more vulnerable to infection. In addition the intensification of food production and consolidation of food industries present opportunities for contaminated products to affect large numbers of people. A further complicating factor has been the emergence in recent years of pathogenic bacteria, such as Listeria monocytogenes and Escherichia coli 0157:H7, capable of causing very serious illness in susceptible people. Consumer confidence in the food industry, and government's ability to regulate it, has been shattered, compounded by further revelations of feed contamination with dioxins. Serious fish safety problems in developing countries are poorly quantified, such as those involving parasites and natural toxins; and there are specific safety problems related to aquaculture.
3. The record shows that, with the exception of molluscan shellfish (eaten raw or undercooked), fishery products are not strongly implicated in disease outbreaks even though, in the public's view, seafood is suspected of being a common vehicle for food poisoning. As an example in the USA from 1990-98 molluscs were implicated in 2060 cases of food-borneillness, while fish were suspect in only 316 cases, of which 260 resulted from scombrotoxicosis. Although this probably represents a substantial under-reporting it is nevertheless of paramount importance, to industry and government regulatory agencies alike, that the safety of the seafood chain should not be compromised.
4. It is essential that industry and government have an agreed strategy to ensure seafood safety to the extent possible. In recent years many advances have been made with integrating safety into production and moving control from end-of-line testing to being a part of the process. It is important that these advances be consolidated as the practical success of a seafood safety programme will depend on the proper use of appropriate methods and tools as well as on flexibility to respond to new ideas. Tools available include Good Hygienic Practice (GHP), Good Manufacturing Practice (GMP) and the Hazard Analysis and Critical Control Point (HACCP) system, which are all specifically targeted to safety. While the regulatory agencies concentrate on the safety aspects, industry would be short-sighted not to incorporate quality assurance systems along with HACCP systems. HACCP is now widely adopted by industry and regulatory agencies as an essential approach to identification and control of hazards associated with the preparation, storage and distribution of fish products. It provides mechanisms to define preventive methods to control hazards that may be unique to a particular product or process. GMP and GHP cover the generic requirements for the production of safe seafood and thus provide the basic pre-requisites on which a HACCP system is built. Increasingly national legislation and international initiatives the application of HACCP in seafood production and this has led government bodies, at national and international levels, to introduce the concept of risk in dealing with hazards. Over the years the Fish Utilization and Marketing Service of FAO has made a significant contribution to training in the field of fish quality and safety. Since 1971 a programme has been implemented with DANIDA funding, first in general fish technology, inspection and quality control, then concentrating on fish handling and processing and subsequently on the introduction and auditing of HACCP-based systems. Almost 2 400 professionals have been trained through 91 separate workshops, providing a nucleus of staff to implement the existing provisions. However, the introduction of the concept of risk and the development of risk analysis will require sustained inputs, from FAO, WHO and other interested parties.
5. Nothing in life is entirely risk free and the food supply is no exception. The concept of accepting and managing a low level of risk is a new departure for regulatory systems, particularly those from countries with a more litigious culture. However, it is now certain that this is the new wave as a logical extension of the principles of HACCP. Risk therefore needs to be understood and codified, which is being achieved through risk analysis dealing with biological, chemical and physical hazards. Although still in its infancy risk analysis is a deliberate, structured and formalised approach to understanding and, where necessary reducing risk. The first structured risk analysis was conducted for Listeria monocytogenes in pasteurised milk in Canada in 1994 and extended there to other products in 1996. In 1997 the USA initiated a risk analysis for Salmonella enteritidis in pasteurised egg and in 1998 for E. coli 0157:H7 in hamburger meat. Australia is currently examining the possibilities of risk analysis for seafood. The process consists of three components: risk assessment, risk management and risk communication. The conduct of risk analysis is a government responsibility and is being widely taken up. It leads to the formulation of (national) food safety objectives, which are a statement of the maximum level of a hazard in a product considered acceptable for human consumption. Wherever possible these food safety objectives should be quantitative and verifiable. Based on the government's food safety objectives the industry is in a position to establish its food safety requirements, which are achieved through a combination of GMP, HACCP and quality assurance programmes. Because risk analysis is being introduced at a national level it is only a matter of time before regulatory agencies incorporate it in the requirements for imported products. In fact the first component, risk assessment, is already codified in Article 5 of the SPS Agreement, which calls for the use of available scientific evidence in the assessment of risk. WHO has also called recently for the establishment of a joint risk assessment body, together with FAO, to review the most important micro-organisms in food, with the intention of reducing food-borne illness.
6. The three components of risk analysis form an integrated whole and are reviewed below:
7. As noted above the process of risk analysis is primarily the prerogative of government bodies that will have to collect all the relevant data and research findings. Although the techniques are at an early stage of development it is likely that in the near future the approach will play a more important role in the determination of the level of consumer protection that a government considers necessary. There will inevitably be a significant impact on domestic and international seafood trade. In the Asian region the Fishery Industries Division has established a programme to collect the necessary information for the conduct of national risk assessments for a number of seafood products. It is hoped that this initiative might lead to the wider understanding of the process and, in the long term, to the introduction of risk analysis at the regional level.
8. The Sub-Committee may wish to discuss the implications and to recommend that FAO continue to collect, analyze and disseminate information and arrange training in the subject matter area for the benefit of those involved both in trade and its regulation. Also, how FAO should be involved in developing the new "risk approach", foster research in practical HACCP implementation, and generally, how it can best serve its member countries in this area.
