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DISCUSSION PAPER ON RECOMMENDATIONS FOR THE MANAGEMENT OF MICROBIOLOGICAL HAZARDS FOR FOODS IN INTERNATIONAL TRADE (AGENDA ITEM 10)[18]

77. The Delegation of France introduced the discussion paper which had been prepared by the drafting group in the light of the comments received. The document addressed new concepts, such as “Food Safety Objectives (FSO)” and “Risk Profile”, for managing hazards associated with food in international trade, and also emphasized the involvement of all stakeholders in each step of risk management as appropriate. The Delegation pointed out that without clear definition of those concepts, it was not easy to address the management of microbiological hazards. The Committee was informed that the discussion paper incorporated some of the concepts included in the document to be considered under the Supplementary Agenda Item.

78. The Committee expressed its appreciation to the Delegation of France for its outstanding efforts in preparing this document. Many delegations supported the structure proposed by the Drafting Group. It was pointed out that this document would be very valuable to governments in providing a coherent approach in the conduct of Risk Analysis.

79. The Delegation of India expressed its concern about the deletion of Annex 2 of CL 97/44-FH entitled World-wide Initiatives to Develop Models and Information Systems for Improving Risk Assessment. The Delegation of France recalled that many aspects from Annex 2 were already incorporated into the new discussion paper and this Annex focused more on Risk Assessment than on Risk Management. However, its relevance in the paper on Risk Management was noted and it was agreed that the ideas reflected in Annex 2 would be taken into account when developing the document in the future.

80. The Delegation of India supported by some other delegations stressed that the implementation of the recommendations in the document would require financial resources in developing countries and this should be recognized by the relevant international organizations.

81. The Committee had an extensive discussion as to the meaning of “Food Safety Objectives” and how they should be incorporated in the document. It was proposed to include FSO into the section on Risk Management Principles. The Observer from the European Community supported by other delegations emphasized that this concept was not clearly defined and no internationally accepted definition existed at this stage. It was pointed out that the work of other Codex Committees (CCFICS and CCGP) on this issue should be taken into account. Confusion should be avoided between principles and tools, as Food Safety Objectives represented one of the important risk management tools. Some delegations stressed the need to separate principles and tools. The Delegation of the United States, while generally supporting the development of the document, pointed out that risk management was the responsibility of individual countries and the inclusion of FSO was premature until this concept had been clearly defined.

82. Many delegations pointed out that it would be useful to merge the paper on the Implications of Regional Differences in the Prevalence in the Management of Microbiological Hazards for Foods in International Trade prepared by the Delegation of Norway with the paper under discussion since they dealt with related subjects.

83. The Committee accepted the proposal of the Delegation of the United Kingdom to change the title of the document to Principles and Guidelines for the Conduct of Microbiological Risk Management in order to be consistent with the document on Risk Assessment forwarded to the Commission at Step 8 (see para. 34).

84. The Observer from the European Community supported the inclusion of FSOs in the document but felt that this issue should be referred to the Committee on General Principles, although work on FSO should continue in parallel in the CCFH. The Observer stated that the document omitted the concept of a precautionary approach, in the consideration of which the principle of proportionality needed to be respected and the relationship between risk and benefit examined. The Observer noted that these concepts should not be misused to create unnecessary barriers to trade, and proposed to send a contribution on the precautionary approach to the Delegation of France to be considered for inclusion in the document.

85. This position was supported by the Observer from Consumers International who emphasized the need to balance the concept of “tolerable” risk or level of protection with the concept of preventing/minimizing risks when possible. The Observer also supported the notion of public involvement in Risk Assessment policy, and the inclusion of a discussion of the appropriate role of Codex in risk management, in addition to the role of national governments.

86. Several delegations, while supporting the development of this document, stressed the importance of focusing on the international aspects of risk management.

87. The Committee agreed that the Delegation of France, with the assistance of a drafting group[19], would redraft the recommendations as Proposed Draft Principles and Guidelines for the Conduct of Microbiological Risk Management for circulation at Step 3 and consideration at the next session.


[18] CX/FH 98/10
[19] Argentina, Australia, Canada, Denmark, Germany, India, Italy, Japan, New Zealand, Netherlands, Norway, United Kingdom, United States, ICMSF)

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