85. The Committee noted the decision of its last Session that a discussion paper would be prepared by Australia for consideration at its current meeting.[14] The Committee was informed that the paper was designed to explain the history, role of industry and the relationship between the Hazard Analysis and Critical Control Point (HACCP) System and other quality management systems including ISO 9000, as had been discussed at its previous session. The representative emphasized the intention of avoiding recommendations to use any particular systems and especially proprietary methods.
86. The Committee welcomed the work of Australia. Several delegations were of the opinion that further elaboration of the paper was necessary due to the adoption of quality assurance systems and the HACCP system on a voluntary basis by industry. Several delegations were of the opinion that the guidelines should concentrate on food safety (sanitary) issues rather than on quality factors. It was noted that quality systems were used between commercial partners while the HACCP system was often used on a regulatory basis. Concern was also expressed that the promotion of quality assurance systems was beyond the mandate of the Codex Alimentarius Commission.
87. The Delegation of Germany emphasized the importance of limiting the scope of the text to food inspection and certification systems only and not to quality assurance, audit, surveillance systems and the HACCP system. It was stated that HACCP may be integrated into the system on a voluntary basis and it was recognized that the voluntary use of quality assurance system might provide additional value.
88. Some delegations[15] were of the opinion that the paper should be developed in a way to explain the relationship between quality assurance and HACCP systems and the mechanisms of these systems. It was stated that the application of HACCP should be additional to the use of good manufacturing practices taking into account the fact that HACCP was not necessarily the only applicable system. The text should be limited to develop guidelines on how to use the quality assurance systems applied by industry in the context of Food Import and Export Inspection and Certification Systems applied by regulators. Some delegations suggested that the text should be treated as an Information Paper only.
89. It was suggested that guidelines to harmonize inspection systems based on quality management systems were timely and could include issues such the frequency of surveillance and the use of third-party systems.
90. In response to concern expressed that the adoption of the guideline could result in unnecessary technical barriers to trade, it was pointed out that the purpose of the document was to assist both industry and regulators. Further elaboration of the text would not imply that the use of quality assurance systems was being made mandatory. It was for individual businesses to decide whether to implement a quality assurance system or not. However, once a quality assurance system was in place, the approach taken by regulators to inspection procedures could be modified to take the quality assurance system into account. This should result in a saving of resources while at the same time strengthening confidence in the outcome of the regulatory inspection.
91. The Delegation of Uruguay expressed concern at the content of the text and the possibility that it might lead to a situation where governments were compelled to apply it as a result of the WTO Agreements. The representative of WTO reaffirmed that Codex texts served as reference points under the SPS Agreement and reiterated the response of the Chair of the SPS Committee that how a text would be considered depended on its substantive content rather than on the category of the text.
92. The Delegation of Germany reminded the Committee that the 30th Session of the Codex Committee on Food Hygiene had discussed a paper on HACCP-like systems in small businesses with special reference to developing countries and such guideline should also be taken into account.
93. The Committee agreed to request the Commission to approve the elaboration of the Guidelines as new work. It agreed that the paper should be redrafted in the light of the comments expressed and in the Conference Room Documents and then circulated to governments for comments prior to discussion at the next session. The Committee appointed a drafting group consisting of United States, Canada, Denmark, France, India, New Zealand and South Africa to undertake the revision and requested Australia to coordinate this work.
