Proposed Draft General Guidelines on Sampling (Agenda Item 4a)
Draft Revised Recommended Methods of Sampling for the Determination of Pesticide Residues for Compliance With MRLs (Agenda Item 4b)
9. Since its 19th Session in 1994, the Committee had considered General Guideline on Sampling which should be applicable to all commodities. At the last Session, the Committee had decided to return the Proposed Draft Guidelines on Sampling to Step 3 for further revision and agreed to a number of elements to be included in the revision. The Committee recalled that this text was intended to replace all previous texts on sampling recommended by the Committee including the Sampling Plans for Prepackaged Foods (AQL 6.5). The Proposed Draft Guidelines had been revised by a Codex Consultant with assistance offered by Australia, Austria, Canada, Czech Republic, France, Hungary, India, Netherlands, Thailand, United Kingdom and United States.
10. While the current text was recognized to be a significant improvement from the previous version and to contain useful information, many delegations were generally of the opinion that it still was very complicated and difficult to understand and therefore it required revision to make it easier for both government officials and Codex commodity committees. For that purpose some delegations proposed to prepare a brief explanatory note elucidating what was a “sampling plan” in a simple manner and which kind of sampling plan was to be used according to the control to be performed. The Delegation of France offered to prepare the explanatory note with assistance provided by Australia, Netherlands, United Kingdom, United Stated and IDF.
11. On the question of whether the Guidelines should be based on the statistical approach as currently drafted or the pragmatic approach as in the case of the sampling methods for the determination of residues of pesticides and veterinary drugs, a majority of the delegations were in favour of the statistical approach as being scientifically defendable. (see para. 15)
12. The Committee decided to defer detailed discussions on the text due to its complexity. However, it agreed that the text should be revised with an objective to make it easier, simpler and more user-friendly by using appropriate structure and wording. The Committee requested the above mentioned countries to undertake this task as well. It reiterated its decision of the last Session that a new text should contain worked examples for specific cases to facilitate the use of the text. As to where these worked examples should be obtained, the Delegation of Hungary offered to provide some of them. It was pointed out that experts in specific commodities in those countries participating in the drafting could also contribute. The Committee agreed that specific attention should be given to matters relating to “heterogeneity” in bulk materials. The Committee further agreed that information should be sought from Codex commodity committees on the acceptance of the statistical approach to sampling when defining compliance with the specifications established in Codex standards.
Status of the Proposed Draft Guidelines on Sampling
13. The Committee returned the Proposed Draft Guidelines on Sampling to Step 3 of the Codex Procedure for redrafting by France in collaboration of Australia, Netherlands, United Kingdom, United States and IDF, including the preparation of an explanatory note, taking into consideration comments provided as appropriate. The Committee requested that modern technologies should be utilized for timely development of the text for distribution for comments in six months’ time. The Committee agreed to examine the new text in depth at its next Session.
14. The Committee was informed that the Codex Committee on Pesticide Residues (CCPR) had started the revision of the Recommended Methods of Sampling for the Determination of Pesticide Residues at its 28th Session in 1996, and at its 30th Session (1998) had agreed to advance the amended Draft Revised Methods to Step 8 for adoption by the Commission. In order to promote harmonization within Codex, it had also agreed to bring the text to the attention of this Committee for consideration. A brief oral report on the opinion of the Codex Committee on Residues of Veterinary Drugs in Foods on the Draft Revised Recommended Methods was provided by the Secretariat[5].
15. It was recognized that the referenced Methods of Sampling and the Guidelines on Sampling being developed by this Committee were based on two different approaches; the former on the practical approach for economic reasons, and the latter on the statistical approach (para. 11). Therefore, it was felt inappropriate to combine these two documents. However, it was stated that the CCPR Sampling document should not contain any contradiction to the Guidelines on Sampling.
16. A number of delegations stressed the need to harmonize those terms used in the document to internationally agreed ones, such as ISO 7002.
17. Other comments included: (1) Table 2 should be clarified to indicate that for plant products composite samples were prepared whereas for each animal product a single primary sample was taken; (2) Table 2 indicated that where the incidence of violative residues in the lot was below 5%, the number of samples to be taken would be unrealistic; (3) the procedure contained in Section 4.4 for the evaluation of results was too complex.
18. The Committee agreed to forward all written and oral comments to the CCPR for consideration.
