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DISCUSSION PAPER ON THE APPLICATION OF RISK ANALYSIS PRINCIPLES FOR FOOD ADDITIVES AND CONTAMINANTS (AGENDA ITEM 5)[9]

20. The 31st CCFAC agreed that the discussion paper should be revised in light of comments received and the Committee's discussions, in cooperation with the JECFA Secretariat, for consideration at its current meeting.[10] In discussing principles of risk analysis, the 23rd Session of the Codex Alimentarius Commission adopted[11] several recommendations to be applied in the framework of Codex, including:

21. In introducing the discussion paper, the delegation of the United States noted that the document had been revised on the basis of input provided by the 31st CCFAC, the 23rd CAC and the 53rd JECFA meeting. The delegation informed the Committee that the purpose of the document was to strengthen the standard setting activities of the CCFAC by clarifying its risk management role and the risk assessment role of JECFA and to improve risk communication between the two bodies. The United States was of the opinion that these goals might be achieved through the further elaboration of the proposed Risk Assessment Policy Statement (Annex II of CL 1999/22-FAC).

22. The delegation of Portugal, speaking on behalf of the Member States of the European Union, stated that broadly assuming naturally occurring toxicants were contaminants was somewhat misleading, as some naturally occurring toxicants at lower doses could also be beneficial. The delegation also agreed that the CCFAC and JECFA needed to establish clear priorities and routes of communication but the means to do so needed to be further considered, i.e., lists of risk assessment groups further developed by JECFA on the basis of CCFAC priorities should be agreed to by the CCFAC; other interests, including qualitative factors, should be considered in risk assessment outputs; and, the selection of JECFA experts should be further examined. In regard to the proposed Risk Assessment Policy, the delegation was of the opinion that decision making for the application of such policies should be ultimately directed to the CAC; that the Committee should take the "As Low as Reasonably Achievable" (ALARA) principle into account in the context of the General Standard on Contaminants and Toxins in Foods; and, that the use of the term "non-science based factors" should instead refer to "other legitimate factors".

23. Several delegations, and the representative of Consumers International, agreed with the opinion of the delegation of Norway that the paper should also clearly explain the procedure and criteria for the selection of JECFA experts; risk communication between assessors and managers; the role of national governments; other legitimate factors; the precautionary principle; and, the consideration of hypersensitivity and intolerance by JECFA. It was also suggested that the document should focus on food additive risk analysis only and that Codex should develop a program for the application of risk analysis in developing countries.

24. The representative of FAO reiterated the fact that JECFA was not a subsidiary body of Codex and that JECFA reported directly to the Directors-General of FAO and WHO, who were responsible for establishing the agenda of each meeting, taking into account the advice of the CCFAC.

Status of the Discussion Paper on the Application of Risk Analysis Principles for Food Additives and Contaminants

25. The delegation of the United States agreed to revise the document, with the assistance of the original drafting group (Australia, the Netherlands, Sweden, Thailand and the United Kingdom) on the basis of written comments submitted and the above discussions for circulation, comment and further consideration at its next session. In the interest of promoting common risk analysis principles throughout Codex, the Committee also requested the Codex Secretariat to verbally report on its deliberations concerning this issue to the forthcoming 15th Session of the Codex Committee on General Principles. The Committee further agreed that its deliberations should be reported to the forthcoming 47th CCEXEC in order to clarify the intended status of the CCFAC document in the context of the general consideration of a uniform and consistent approach to the application of risk analyses in different committees. It also agreed that the 24th Session of the Commission should be provided with a report on this issue after its further consideration by the 33rd CCFAC.


[9] CL 1999/22-FAC and comments submitted by Denmark, Consumers International (CX/FAC 00/4); Canada, EC (CRD 4); JECFA (CRD 5); India, EC-revised (CRD 6).
[10] ALINORM 99/12A, paras. 14-17.
[11] ALINORM 99/37, paras. 47-58.

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