TITLE
INTRODUCTION
GENERAL REQUIREMENTS (GENERAL PRINCIPLES)
RAW MATERIALS
MINERALS, VITAMINS AND OTHER ADDITIVES
GENERAL MANAGEMENT OF FEEDS
GOOD ANIMAL FEEDING PRACTICES AND ON-FARM PRODUCTION OF ANIMAL FEED
PERSONNEL
20. The Chairperson noted that, subsequent to the Commission's decision to establish the Task Force, Codex Circular Letter CL 1999/28-AF had been issued requesting proposals for additions or amendments to the Proposed Draft Code of Practice on Good Animal Feeding and comments in relation to the food safety issues identified by the Codex Alimentarius Commission in the Terms of Reference establishing the Task Force. He noted that substantial comments had been received and that these had been compiled as annotations to the Proposed Draft Code (Documents CX/AF 00/4 and CX/AF 00/4-Add.1, Revised). In addition, the Chairperson had prepared a revised text of the Proposed Draft Code based on the comments received (CX/AF 00/4-Add.2)
21. Several delegations requested clarification as to which document should be used as a basis for discussion under the present Agenda Item. Questions were raised as to the use of the Chairperson's text stating that this was not a usual procedure in Codex and concerns were expressed that this could set a precedent for future Codex discussions. It was also noted that it was usual for Codex bodies to discuss comments submitted by Member governments on their merit. On the other hand, some delegations pointed out that parts of the material in the Chairperson's text resolved some of the problems of the initial text, especially since the Chairperson's text contained additional detail in some important areas.
22. The Task Force agreed to base its discussion on the original version of the Proposed Draft Code and with the comments received and presented in CX/AF 00/4, CX/AF 00/4-Add.1, Revised and CRD 1, at the same time taking into account such material from the Chairperson's text as it was relevant and useful to the further elaboration of the Code.
23. The Task Force noted several proposals to amend the Title of the Proposed Draft Code. It agreed that the Title should reflect the content of the Code and that as the scope and content had not yet been considered and agreed, it was premature to agree upon a Title.
OBJECTIVES AND SCOPE
OTHER SPECIFIC ISSUES
STRUCTURE OF THE CODE
DEFINITIONS
24. The Task Force noted that the first paragraph of the Introduction was in fact a brief statement of the objectives and scope of the Code and agreed to discuss it in this context with a view to a possible rearrangement in later drafts.
25. Many delegations drew attention to the two-fold nature of the Code, since it dealt with both animal feeding practices at the farm level, as well as good manufacturing practice for the production of animal feedingstuffs. Several delegations stressed the need to take into account pasture feeding and free-range feeding of animals, especially where supplemental feeding in addition to pasture feeding was practiced. Reference was also made to manufactured feed and feeding practices used in aquaculture.
26. The Task Force recognized that the issues to be considered in relation to the production, distribution and storage of manufactured feedingstuffs were different from those related to animal feeding practices. There was, however a degree of overlap when on-farm production of feedingstuffs was considered. It also noted that issues in relation to manufactured feedingstuffs could probably be treated internationally, but that many specific issues relating to animal feeding and on-farm practices had to be treated regionally or even locally. Several delegations and observers stressed that priority should be given to compound feedingstuffs and ingredients moving in international trade.
27. The Task Force agreed that the scope of the Code should cover the entire feed chain and should include provisions for grazing or free-range feeding and for on-farm production in addition to provisions for processing, distribution, storage and use of compound feedingstuffs.
28. Among the issues to be taken into account, the Task Force agreed that the primary purpose of the Code was the protection of consumers' health, in particular food safety issues. The Task Force also agreed that issues of animal health relating to food safety were of significant importance and noted the linkages that existed with other Codex Codes of Practice in the area of meat hygiene[7], aquaculture, food hygiene[8] and application of the Hazard Analysis and Critical Control Point (HACCP) System and the work of the OIE on zoonoses. On the other hand, the Task Force noted that issues relating to animal welfare (other than food safety related animal health issues) did not fall within the mandate of the Commission and hence not within the Terms of Reference of the Task Force. It was however proposed that issues relating to the quality of feedingstuffs in terms of compliance with standards for composition would fall within the mandate of the Task Force.
29. The Task Force discussed a proposal to make explicit reference to environmental considerations. It was informed that this had been considered on several occasions by the Commission and that it had been confirmed that the Commission's mandate was limited by its Statutes to "protecting consumers' health and ensuring fair practices in the food trade". Nevertheless, the Commission had previously taken environmental considerations into account where necessary for the establishment of standards for the protection of consumers' health. Such a requirement was explicit in Section 3.1 of the Codex General Principles on Food Hygiene.
30. The Task Force noted that the Codex Committee on General Principles in its debate on other legitimate factors other than science used in the Codex decision-making process had requested input from other relevant Committees on such factors taken into account in establishing Codex standards, guidelines and other recommendations. The purpose of this exercise was to allow for a better-informed debate in the Codex Committee on General Principles.
31. The Task Force considered the question of "traceability" in reference to the control of feedingstuffs and the ability to take corrective measures in case of emergency situations or when there was an indication of non-compliance with established standards or procedures. It was noted that this issue was also being debated in other Codex bodies including the Ad Hoc Intergovernmental Codex Task Force on Foods Derived from Biotechnology and that the Codex Committee on Food Import and Export Inspection and Certification Systems had developed a number of relevant Guidelines that could be used[9].
32. The Task Force agreed that special provisions relating to "traceability" should be included in the Code especially in reference to good manufacturing practices for the production, distribution and use of feedingstuffs. It also proposed that reference may need to be made to other Codex texts and to standards developed by ISO for this purpose. It was suggested that general requirements in relation to traceability might be included in the Code, leaving specific provisions for application to Member governments.
33. The Task Force also agreed that the Code should include provisions for the labelling of feedingstuffs as part of good manufacturing practice and risk management in view of the need for adequate labelling within the framework of traceability. Moreover, it was stressed that labelling should be clear and informative so as to allow the farmer to handle and use feedingstuffs correctly.
34. The Task Force agreed that references should be made to official inspection and control procedures and self-regulation (auto control), taking into account recommendations already adopted and published by the Commission. References to HACCP principles should also be included. The Task Force agreed however that specific reference to legislative requirements would not be appropriate for inclusion in the Code.
35. The Task Force was of the opinion that the structure of the Proposed Draft Code as outlined in CX/AF 00/4 and CX/AF 00/4-Add.1-Revised was inadequate for the purposes of Task Force.
36. Taking into account the discussion above on Objectives and Scope and the need to develop separate advice for Good Manufacturing Practices and for Good Animal Feeding Practices, the Task Force agreed to base the structure of the current text as follows;
Title
1. Introduction37. The Task Force noted that further revision might be necessary in the light of future discussions.
2. Purpose and Scope
3. Definitions
4. General Principles/Requirements including
- Traceability
- Possibility of negative list or a list of substances presenting risks to food safety
- Labelling
- Principles for the use of additives
- Inspection and control procedures
5. Guidance for Good Manufacturing Practice including HACCP
6. Guidance for Good Animal Feeding Practice including HACCP
38. Many delegations stressed the crucial need for clear and unambiguous definitions of terms used in the Code. Several delegations underlined the fact that these definitions should be consistent where appropriate with other Codex definitions adopted by the Commission or else that they should be complemented with additional information specific to animal feeding. Specific attention was drawn to the question of the term "additive" which, when commonly used in relation to animal feedingstuffs could include substances used to meet the nutritional needs of animals whereas the definition applied to additives used for food destined to human consumption excluded substances used for improving nutritional characteristics[10].
39. The Ad Hoc Task Force agreed that the proposed definitions contained in the Chairperson's text should be included in the next draft of the Code as a point of departure, and to add other relevant definitions already developed by Codex or in the report of the FAO Expert Consultation, and relevant definitions elaborated by other international standardization bodies such as the ISO. These definitions would be submitted to Members for comments.
ADDITIVES
CONSIDERATION OF "POSITIVE" AND "NEGATIVE" LISTS
GENERAL MANAGEMENT
40. The Task Force agreed that certain matters were common to consideration of the production of animal feedingstuffs whether or not they were produced commercially or on-farm.
41. Many delegations expressed the need to avoid duplication and to make linkages with existing Codex documentation and the work of other Codex Committees that had dealt with animal feeding matters. The Codex Secretariat noted that several bodies of the Commission had worked or were working on animal feeding matters. These included the work of the Codex Committee on Pesticide Residues in establishing Maximum Residue Limits for forages and feedingstuffs; the Codex Committee on Residues of Veterinary Drugs in Foods in establishing Maximum Residue Limits for veterinary drugs including those that entered into food by means of animal feeding; and the Codex Committee on Food Additives and Contaminants in relation to contamination from environmental or industrial sources. The Task Force requested the Codex Secretariat to provide a paper for its next session with comprehensive information of the work already completed or underway in Codex.
42. The Task Force noted that principles for the use of additives in animal feedingstuffs would be of crucial importance in the final Code. As this matter had not been addressed fully in the Proposed Draft Code contained in CX/AF 00/4, it used the text contained in the Chairperson's draft (CX/AF 00/4-Add.2, Section 3.2.3) as a basis for discussion.
43. The Task Force noted that one of the issues complicating the discussions on the use of additives was the lack of suitable definitions that were applicable in the context of animal feeding. It noted that definitions existed in the Codex Alimentarius for "food additives" and for "veterinary drugs".
44. The Task Force agreed that the Code should contain a provision to the effect that "additives should be assessed for safety and approved under stated conditions of use". It was also agreed that there should be a delineation between feed materials and additives and between additives and veterinary medicines so as to avoid misuse.
45. The Task Force addressed the issue of antibiotics used for growth promotion purposes. Opinions varied between those delegations that supported a statement in the Code that would prohibit such uses and those delegations that were of the opinion that antibiotics should not be used in the absence of a public health safety risk assessment. Attention was drawn to the report of the Representative of WHO on the outcome of the WHO Consultation on Global Principles for the Containment of Antimicrobial Resistance and it was agreed that further discussion of this issue should be undertaken in the light of the report and recommendations of the Consultation, as well as the reports and guidance of other groups such as OIE, CCFH and CCRVDF. It was agreed that the revised draft text of the Code would need to indicate that this was the case and that the several options discussed would be presented as alternatives.
46. Several delegations proposed the inclusion of references to either positive lists of permitted substances to be used in the preparation of animal feedingstuffs, or negative lists of prohibited substances as well as lists of "undesirable substances" subject to maximum limits or tolerances. Other delegations and observers were of the opinion that the first priority should be paid to the establishment of good practices and that in all cases the focus should be on the objective of ensuring the safety and quality of foods of animal origin, as stated in the Terms of Reference of the Task Force.
47. Several delegations and observers were of the opinion that the establishment of positive and negative lists would be very difficult, as such lists would be determined by the nature of animal production in different countries and therefore subject to national and even local conditions, especially in developing countries and to the species or classes of animals. It was further suggested that a general statement be included in the Code providing for the establishment of such lists under national conditions.
48. The difficulty of the lack of clear definitions for additives, contaminants, by-products, wastes, and other substances provisions that might be considered as prohibited or "undesirable" substances was also seen as impeding progress in establishing a negative list. The Task Force also agreed that there was a need for further information from OIE and from governments in relation to substances that were subject to official controls and that the prior work of other Codex Committees such as CCFAC, CCPR, CCRVDF would need to be taken into account. Attention was also drawn to the Code of Ante-Mortem and Post-Mortem Inspection of Slaughter animals and for Ante-Mortem and Post-Mortem Judgement of Slaughter Animals and Meat[11] which described the conditions for disposal of meat products deemed to be unsuitable for human consumption.
49. The Task Force agreed to request, by means of a Circular Letter to Member countries, information on lists established by different governments to control the use of prohibited and undesirable substances in animal feedingstuffs or other approaches. The Task Force also accepted the offer of FAO to establish an Internet Conference site on the FAO Website to further develop the debate on this issue, based initially on the comments received to the Circular Letter. It was agreed that an open-ended meeting would be convened immediately before the next Session of the Task Force to consider the replies to the Circular Letter and the outcome of the Internet Conference, and report its findings to the Task Force.
50. It was proposed that a working group to be established to assist in assessing possibilities for drawing up a list of materials that should be prohibited from animal feedingstuffs and consider compiling a list of contaminants and other undesirable substances whose presence in feeds should be controlled but the Task Force did not come to the conclusion with this matter.
51. It was noted that this section would contain the main common provisions relating to Good Manufacturing Practice (GMP).
52. In addition to the points raised in written comments, delegations recommended that attention be paid to the following issues in the redrafting of this section:
53. The Task Force considered the application of the HACCP system in relation to GMP under this section and also under Section 5 of the text (see paras 61-62 below).
54. The Task Force agreed that the outcome of applying GMPs should be safe production of foods of animal origin, whether the feed was prepared industrially or on-farm or in farmers' cooperatives and whether or not HACCP principles were applied. Doubts were expressed about the applicability of the use of HACCP system at farm level in all cases.
55. The Task Force agreed that the section should refer to all raw material, whether of plant, animal or marine origin, and amended the Title of this section accordingly. It was also noted that the same provisions should apply to the use of fermentation products as raw materials.
56. The Task Force noted that several international organizations specializing in methods of analysis and sampling, including the AOAC and the ISO, had established both standard methods and validated methods for the examination of feedingstuffs. It was suggested that reference be made to these internationally accepted methods and to sampling procedures at an appropriate point in the revised Code. It was further agreed to request the Secretariat to compile a list of internationally available standard and validated methods for the examination of feedingstuffs. As it was also noted that the Codex Committee on Methods of Analysis and Sampling had established criteria for the use of such methods internationally (although only methods for the examination of foods), the Task Force agreed to inform this Committee of its present debate.
57. Questions were raised about the suitability of reference to "supplier warranty" in the proposed Draft Code. It was noted that this was related to the question of quality and safety guarantees. The Task Force noted the efforts of some trade groups to develop voluntary codes of practice and general conditions for delivery of raw material to assist in this area.
58. It was noted that the reference in this section to standards for maximum levels for contaminants, etc, was linked to the consideration of the work of other Codex Committees on residues and contaminants and that these should be taken into account.
59. The question of the scarcity of suitable raw materials was raised in relation to the need for more research into alternative safe sources of protein and fat, together with the evaluation of these sources on a sound scientific basis with a view to establishing their safety for human and animal health and optimal use of natural global resources.
60. The Task Force recalled the problems related to the definitions for these substances, which in turn created problems for their treatment in the Code. It was agreed that the general principles relating to the control of "Raw materials" applied equally to the control of other ingredients and that therefore that the two sections could be combined and transferred to the Section on General Principles.
61. Many delegations pointed out that this section of the Code was the main section dealing with good manufacturing practice (GMP) for the production of animal feedingstuffs. It was noted that several of the statements made in the proposed Draft Code were overly explicit and not always based on risk assessment; for example, the requirement to flush equipment with clean feed between batches (Section 5.4). Provisions relating to the labelling, transport, record keeping, recall of defective product were also noted as needing further elaboration. It was also noted that the provisions of this section needed to be adapted to the conditions applying in different countries with emphasis on the control of hazards and management of risks to human health.
62. Several delegations drew attention to the Codex Recommended International Code of Practice - General Principles of Food Hygiene[16] and the Annex in that Code outlining the application of HACCP principles, where many of these problems had been addressed in relation to overall food safety, including primary production. It was agreed to redraft the Section taking into account the structure of the General Principles with special attention being paid to measures required for food safety.
63. In the course of this and other discussions, several delegations drew attention to the need to provide better guidance of the definition of "waste", including the various types of waste and how they should be handled or disposed of. Attention was drawn to the negative environmental effects of rejecting materials that could otherwise be safely processed and used. The modes of re-use of animal products and by-products in the food chain were also indicated as requiring consideration.
64. The Task Force noted that in accordance with the structure of the revised draft Code, there would be a section dealing with Good Animal Feeding Practices and On-Farm Production of Animal Feed. It considered the necessity and appropriateness of establishing an informal working group to expedite the discussion and development of an appropriate text.
65. The Task Force discussed possible Terms of Reference of the working group including manufacturing of feedingstuffs on farm level, forage crop production, feeding practices, pasture and free-range feeding.
66. Several delegations requested clarification as to whether or not forage crop production would be within the mandate of the Task Force, and some delegations were of the opinion that the exact nature and necessity of this working group should be clarified first and the presence of any types of hazard arising from practices at the farm level should be identified. Some delegations supported that related existing Codex texts should be referenced in developing the Good Animal Feeding Practices on a farm level.
67. In view of the diverse opinions expressed in relation to the proposed terms of reference of the working group, the Task Force agreed that it was premature to establish an informal working group.
68. The Representative from FAO informed the Task Force that FAO could provide assistance in facilitating the discussion process by means of an electronic conference on the Internet.
69. It was agreed that this Section would be incorporated into the section on General Requirements.
