98. The Delegation of the Netherlands introduced the document Discussion paper on HACCP in Small and Less Developed Businesess, which had been developed following a meeting of the drafting group in April 1998, and pointed out that the revised title did not any longer refer to developing countries but to “small and less developed businesses” because difficulties existed both in developed and developing countries in the application of the HACCP system.
99. Several delegations stressed the difficulties related to a definition of small businesses, as this term might be understood to include retailers or restaurants, whereas the focus of the paper should rather be on small and medium industry; it was proposed to refer to processing units and to put more emphasis on the level of technological development and food safety education. The Delegation of Argentina proposed to delete the reference to “small businesses” in view of these difficulties and the Committee agreed that this issue should be addressed in the redrafting of the document.
100. The Committee generally recognized that there might be some flexibility in the application of the seven principles of HACCP but that the principles themselves should be retained. It was proposed to develop generic plans to facilitate HACCP application but these should be used only as examples.
101. The Committee discussed whether or not the scope should cover both export industry and production for the domestic market. In this context and with a view to suggesting a practical orientation for the document, the Delegation of Mexico highlighted the importance of HACCP application in exporting industries, which although being small, would serve as a model and motivate other businesses of all sizes for its application within the country, thereby facilitating a generalized application of HACCP. Some delegations noted that manufacturers involved in international trade had to apply the HACCP System in order to export their products, irrespective of their size. The Delegation of Argentina pointed out that there should be no distinction on the basis on the destination of the product (export or domestic market) as the essential objective was to ensure consumer protection. In this sense, the concept of equivalence should be taken into account, as currently under discussion in the CCFICS in order to ensure food safety. This view was supported by several delegations, the Observer from Consumers International and the Representative of WHO. The Representative pointed out that according to the WTO/SPS Agreement countries that require application of the HACCP system for imported food should apply similar requirements to their local food productions.
102. Some delegations pointed out that exchange of information between governments on the implementation of HACCP programmes and training would be useful to official authorities, as they would benefit from the experience of other countries in this relatively new discipline.
103. The Representative of FAO informed the Committee about the experience of FAO in technical assistance to small and medium industry in developing countries and drew the attention of the Committee to the Training Manual on Food Hygiene and the HACCP System. Although the usefulness of the HACCP system was recognized, the application of Good Hygienic/Manufacturing Practices seemed to be the priority for this type of industries. The difficulties in the identification of the hazards and the Critical Control Points appeared to be the major problems in the implementation of HACCP. The measures which could be taken to solve these difficulties included direct technical assistance from governments and research institutes.
104. The Representative of PAHO stressed the limitations of small and medium businesses and the need to apply GMP before the introduction of the HACCP system could be envisaged. The Representative underlined the necessity to stimulate the involvement of industry at the management level in the application of HACCP, and that the Committee should define clearly how HACCP could be applied with flexibility in those cases.
105. The Representative of WHO supported work on this Agenda Item and offered its collaboration in the further development of the document. The Representative referred to the long standing experience of WHO in the application of HACCP and stressed the importance of the document in order to address food safety problems associated with small businesses as they are the source of a significant proportion of foodborne diseases. The Representative recommended that the outcome of the work on this question could be in the form of guidance to governments in the implementation of HACCP in small businesses.
106. The Committee had an extensive exchange of views on the purpose of the document; there was general support for the application of HACCP and the need to address the difficulties of food businesses which were unable to apply the present HACCP system, irrespective of their size and of their involvement in international trade. The Delegation of Germany, supported by other delegations, pointed out that in situations where the GPFH and HACCP could not be applied, alternative systems to ensure food safety were likely to be more complex and onerous for the industry, as was the case in certain current codes of practice.
107. The Delegation of France expressed the view that the current Annex on HACCP in the General Principles of Food Hygiene already provided valuable guidance and that it was the responsibility of governments to implement HACCP and Good Hygienic Practice at the national level in view of specific conditions in their industry; it did not therefore appear necessary to develop other texts as international recommendations in the framework of Codex. Several delegations supported further development of this document in order to provide useful guidance on the application of HACCP, while some delegations questioned the purpose of this exercise as related to the elaboration of Codex Guidelines on this specific subject. The Delegation of the United Kingdom expressed the view that guidelines for the application of HACCP were needed for all businesses unable to apply the present application Guidelines.
108. The Committee agreed that the discussion paper would be revised by the Delegation of the Netherlands, assisted by the countries involved in the initial draft (see ALINORM 99/13, para. 92), taking into account the above discussion, for circulation and further consideration at the next session.
