Codex Committee on General Principles: Role of Science and Other Factors in Relation to Risk Analysis (ALINORM 99/33A, paras 64-76)
5. The Committee recalled that the Committee on General Principles, while considering the role of other legitimate factors in relation to risk analysis, had sought information from other committees on the relevant factors taken into account in their work. It was also noted that the Joint FAO/WHO Expert Consultation on Risk Management and Food Safety had recommended that the Commission should clarify how to apply the Statement of Principle concerning other legitimate factors, and that clarification should include explicit description of the factors which may be considered, the extent to which these factors should be taken into account, and the procedures to be used in this regard.
6. The Delegation of India pointed out that the conditions prevailing in different regions of the world represented an important factor to consider in the development of standards, in order to ensure that they were really international in their scope and application. Some delegations pointed out that the rationale for decisions taken by the Committee in the past in the elaboration of food hygiene texts needed to be clarified and explained in relation to other legitimate factors. The Committee had an exchange of views on whether to consider the application of such factors in current work on risk analysis or to provide a historical background for earlier decisions on adopted texts.
7. The Committee agreed to consider this question further under Agenda Item 8 in conjunction with the discussion on risk management in order to decide how to proceed in this area (see paras 103-111).
WTO Committee on Sanitary and Phytosanitary Measures
8. With respect to the referral to the Codex Alimentarius Commission from the WTO Committee on Sanitary and Phytosanitary Measures (WTO SPS) of: 1) Bacillus cereus as a potential pathogen in canned/bottled products, including jams; and 2) the necessity of certification regarding the absence of pathogens in raw meat products, the Committee provided the following advice.
9. The Committee noted that both issues involved the rationale and basis for the establishment of microbiological criteria and drew attention to the Codex Principles for the Establishment and Application of Microbiological Criteria for Foods (CAC/GL 21-1997). This document provides guidance to countries on the development and implementation of microbiological criteria for food. The Committee recommended that countries review the guidance given in this document to establish the need and suitability of criteria for B. cereus in foods, for pathogens in raw meat products, or for any other microbiological criteria issue.
10. The Committee further noted that the food hygiene provisions for Codex commodity standards, as revised and adopted by the Codex Alimentarius Commission[3] provided general guidance to Codex Committees in establishing food hygiene requirements. Additionally, the Committee noted that the Codex standards for processed fruits and vegetables were currently under revision and encouraged the expeditious revision of pertinent standards, as appropriate, to facilitate the incorporation of updated food hygiene provisions.
11. The Committee noted that meat industry and consumer health protection problems could not be solved by certification for complete absence of pathogens in raw meat. The Committee recognized that it was scientifically impossible to provide such certification as it concerned only one step of the HACCP system. Adherence to good manufacturing practices, Recommended International Code of Practice-General Principles of Food Hygiene (CAC/RCP 1-1969, Rev.3 (1997)) and application of HACCP system as well as the Principles for the Establishment and Application of Microbiological Criteria for Foods (CAC/GL 21-1997) provided the basis to assure that food met the requirements of safety and international food trade, and therefore there was no need to develop new documents in this area. The Delegation of Norway stated that certification of certain low levels, or statistical probability of absence of pathogens, could be useful.
COMMENTS IN RESPONSE TO THE CODEX CIRCULAR LETTER CL 1999/17 -FH[4]
Priority Issues
12. The Committee recalled that a Joint FAO/WHO Expert Consultation on Microbiological Hazards in Foods was held in Geneva in March 1999 to provide advice on the development of an international strategy and a supporting mechanism for risk assessment of microbiological hazards in foods[5]. The Representative of WHO stated that the Consultation had recommended that FAO and WHO establish an expert advisory body on microbiological risk assessment and that the two organizations had decided to convene a series of ad hoc Expert Consultations on microbiological risk assessment in order to provide advice in response to requests from CCFH.
13. The Committee had an exchange of views on the priority issues for microbiological risk assessment, which would be addressed by the Expert Consultations. The Committee agreed that there was an urgent need to establish a vehicle for providing advice on this issue and that a series of ad hoc Expert Consultation would be appropriate until a more formal body could be established. The Committee noted the importance of transparency, independence and pluralism of sources of information/expertise, and recommended that these matters be considered by FAO and WHO in organizing the expert consultations and the formal body. The Committee also recognized the need for technical assistance to developing countries in this area.
14. Several delegations noted that it would be necessary to clarify the terms of reference of the ad hoc Expert Consultation and the working procedures between the Consultation and the CCFH. It was suggested that these areas be fully developed on a priority basis while not hindering the initiation of the work by the ad hoc Expert Consultation. The Secretariat noted that establishing an expert body and its terms of reference fell outside the Terms of Reference of the Committee and that it should be determined by FAO and WHO themselves.
15. Concerning the priority issues that would require risk assessment by the Expert Consultation, many delegations supported the idea of a pathogen-commodity combination approach and the following combinations (some without identification of commodity) were indicated as significant public health problems in Member countries. The Committee further noted that the list below was tentative and that it would be revisited at each Session of the Committee;
16. The Delegation of the United Arab Emirates expressed the view that Bacillus cereus in infant formula was a significant health problem and that E. coli and total count were a problem in international trade. The Delegation of Cuba stressed the importance of Salmonella in meat products and of Staphylococcus aureus in relation to foodborne diseases in Latin America, as reported by PAHO. The Delegation of the Netherlands proposed that risk assessment should focus on Salmonella in eggs and on Listeria in ready-to-eat foods which supported its growth by prolonged refrigerated storage. The Delegation of Switzerland proposed that risk assessment should focus on emerging pathogens such as Cryptosporidium and small round structured viruses rather than Salmonella or other pathogens for which extensive data was already available.
17. The Committee identified the following as the criteria for prioritization of the combinations:
18. In the light of the background information provided in CRD 20 on the public health significance of specific pathogens, the Committee agreed on the following pathogen-commodity combinations as the priority issues for consideration by the ad hoc Expert Consultation:
19. In relation with the combinations mentioned above, the Committee tentatively suggested on the following statement as the risk management questions on each combination, which would be addressed by the ad hoc Expert Consultation.
“CCFH suggested that the ad hoc Expert Consultation on the microbiological risk assessment review and summarize national and regional risk assessment data and other relevant data on this issue. In doing so the ad hoc Expert Consultation should take into consideration the general description of output provided in the Report of the Joint FAO/WHO Expert Consultation on Risk Assessment on Microbiological Hazards in Foods in 1999. Especially, the ad hoc Expert Consultation should consider the risk estimations and evaluate the relative influence of relevant risk factors. Additionally, the ad hoc Expert Consultation should evaluate the risk reduction potential of relevant risk management options from farm-to-table continuum”. The Delegation of France stated that risk management options should be those suggested by risk managers.
20. The Committee recognized the importance to initiate work on microbiological risk assessment and agreed that working principles/procedures between the ad hoc Expert Consultation and CCFH should be further discussed in the following Sessions of the Committee, taking into account the progress made by the ad hoc Expert Consultation.
