71. The Delegation of Canada introduced the Proposed Draft Code and noted the following changes that were made taking into account the discussion at the previous Session: 1) The Code addressed not only microbiological contamination but also contamination by chemicals including pesticides as they relate to GAP and GMP; 2) The Code applied to products from organic agriculture; 3) The Code was intended to be outcome based without an unnecessary level of prescriptive recommendations; 4) Recognizing the practical limitations to the use of HACCP, emphasis was made on GAP and GMP; 5) the Annex on sprouts should be examined after the Code was completed, as the Code could address hygienic requirements for the production of seeds intended for sprouting.
72. The Committee expressed its appreciation to the Delegation of Canada and the drafting group for their work in elaborating the Proposed Draft Code. The Committee, following the explanation by the Delegation of France regarding the Proposed Draft Code of Hygienic Practice for Pre-Cut Raw Vegetable Products Ready for Human Consumption that would be discussed under Agenda Item 7, discussed the appropriateness of merging the two Codes. Several delegations opposed merging the two Codes as the risks to be addressed within primary production and in the processing industry for pre-cut vegetables were different. The Delegation of France, supported by several other delegations proposed to merge the Codes as they overlapped in many sections, such as in Section 3, which would result in unnecessary discussions. The Committee agreed that the two codes should be discussed separately at this stage and that the drafting groups for the Codes should work in close cooperation.
73. The Delegation of India stressed the importance of risk assessment within the elaboration process of this Code. The Delegation also mentioned that the Commission recommended that risk assessment should take into account global data, including that from developing countries and that the Code should not be elaborated in a hasty manner. The Delegation further mentioned that the Draft Code put great emphasis on pre-harvest operations, whereas the probability of risk is greater in post harvest operations which would be borne out through risk assessment.
74. The Committee generally agreed on the changes presented by the Delegation of Canada. It recognized that the focus of the Code was not restricted to microbiological contamination and agreed to delete the words “which are not processed to eliminate pathogens” from the last sentence in the section on Introduction.
75. The Delegation of France questioned whether, for example, mushrooms, seaweeds and berries were covered by the Code. The Committee agreed that “cultivated” fruits and vegetables should be under the scope of the Code and that the word “cultivated” should be inserted after the word “vegetables” in the first sentence of section 2.1 Scope.
76. The Delegation of Malaysia sought clarification on whether genetically modified vegetables were covered by the Code. It was noted that the Code applied to all fresh fruits and vegetables so defined in the Code, regardless of the use of plant breeding or production method.
77. The Delegation of India expressed the view that application of stringent hygienic practices for small holding was impractical in developing countries because those countries have neither the appropriate infrastructure nor trained manpower. The Delegation of Thailand suggested that the Code should not be too prescriptive for developing countries as primary production in these countries heavily relies on small farms.
78. The Delegation of India proposed to add a new annex to addresses the above concern. Several other delegations proposed to take up this concern in Section 2.2 Use. The Committee agreed to add the following wording before the last sentence of Section 2.2. “However, it is recognized that the provision would be difficult to implement in areas where primary production is conducted in small holdings, in developing countries and also in areas where traditional farming is practiced. Therefore, the concerned government should cause awareness in the primary production of produce.”
79. In the Section on Definition, the Delegation of the United Kingdom pointed out that the definition of “Primary Production” should be consistent with that of the General Principles of Food Hygiene and the Committee agreed to amend the definition accordingly.
80. Regarding the definition of “Fresh Fruits and Vegetables”, the Delegation of Spain mentioned that mushrooms, even cultivated, were not generally eaten raw, and that the current definition needed to be clarified to specify which produce was covered by the Code. The Delegation proposed to delete the words “and are intended to be consumed raw”, as the Code should cover all fruits and vegetables sold in the raw form whether or not they were consumed raw. After some discussion, the Committee agreed on the need for further deliberation on this matter.
81. In Section 3.1 Environmental Hygiene, it was agreed to add the words “where possible” at the beginning of the first and second paragraphs concerning the identification of sources of contamination and to delete reference to adjoining sites. In Section 3.2.1.2 it was also agreed to insert “where possible” at the beginning of para. 3 concerning the need for documentation on manure, sewage sludge and other fertilizers.
82. The Delegation of France proposed to separate clearly the issues related to manure and to sewage sludge, in view of the specific problems associated with the latter.
83. The Delegation of Sweden proposed to include a sentence on biological control of pests by applying microorganisms, which were especially used in organic production, and the associated hazards and also expressed its concern regarding the use of antibiotics for the production of fresh fruits and vegetables. The Delegation of the United States pointed out that issues related to pest control were not within the scope of the Code. The Committee did not come to a conclusion on this question.
84. The Delegation of Japan and many other delegations emphasized the importance of the annex for sprouts. The Committee reconfirmed the decision of the previous Session to include an annex on sprouts and asked the Delegations of Japan, Denmark, the Netherlands and USA to prepare a working document for consideration at next meeting.
85. Although several delegations supported the advancement of the text to Step 5, the Committee recognized that there were many other issues that could not be fully addressed during the Session, including those comments submitted in CX/FH Add-1 and CRDs. The Committee agreed that the drafting group should further consider those issues.
Status of the Proposed Draft Code of Hygienic Practice for the Primary Production, Harvesting and Packing of Fresh Fruits and Vegetables
86. The Committee returned the Proposed Draft Code to Step 3 and agreed that the drafting group led by Canada would redraft the Code on the basis of the comments received and discussions held during the session, for circulation at Step 3 and consideration by the next session.
