Previous Page Table of Contents Next Page


Risk Analysis (Agenda Item 3)[3]


a) Proposed Draft Working Principles for Risk Analysis (Item 3.A)
b) The Application of Risk Analysis in the Elaboration of Codex Standards (Agenda Item 3.b)

a) Proposed Draft Working Principles for Risk Analysis (Item 3.A)


Working Principles for Risk Analysis (except the Aplication of Precaution in Risk Management - paras. 34 - 35)
Working Principles for Risk Analysis of Precaution in Risk Management - paras. 34 - 35)

Working Principles for Risk Analysis (except the Aplication of Precaution in Risk Management - paras. 34 - 35)[4]

16. The Committee recalled that the elaboration of the Working Principles had been undertaken following the recommendations of the 22nd Session of the Commission concerning the use of risk analysis in Codex. The Committee recalled that its 15th session had returned the Proposed Draft Principles to Step 3 for further comments and consideration by the 16th Session, with the exception of the section on "precaution in risk management" (see paras. 49 to 69. A number of Delegations expressed their preference for the draft text tabled by the Delegation of Australia, stating that the Chairperson's text still retained elements of ambiguity as to the work of Codex and the work of Member governments. These Delegations stated that it was inappropriate to suggest that Codex should develop standards, guidelines or recommendations by recourse to the "precautionary principle" when data were inadequate, even though it was recognized that precaution was an essential element in the Codex normal decision-making process. These Delegations also noted the linkages with the general statement on the application of precaution in risk analysis as contained in the Section on General Aspects (paragraph 5) of the draft document (see also paras. 32-34, above)., below).

General aspects

17. The Delegation of New Zealand pointed out that the Principles should take into account the evolution in risk analysis concepts and the progress made in specific areas, especially microbiological risk assessment and management. In particular, the document should make it clear that the elements of risk analysis were not applied separately but within an overarching risk management framework; the use of terminology should also be reviewed to ensure consistency throughout Codex.

18. Several delegations expressed the view that the recommendations made in the framework of Codex in relation to risk analysis should not affect the rights and obligations of Member countries under WTO and especially the SPS Agreement.

19. The Delegation of Canada proposed to indicate that the principles were not intended as international standards, guidelines or recommendations as described in the SPS Agreement nor as a standard as defined under the TBT Agreement. The Representative of WTO recalled that the SPS Agreement did not establish any distinction between different types of Codex texts directed to governments, and referred to the reply from the SPS Committee to the question from the Commission on the status of Codex texts in 1998, in which it was indicated that " how a text would be applied depended on its substantive content"[5]. Any statement in a Codex text regarding the intended use of that text would be taken into consideration in the case of a WTO dispute.

20. The Committee agreed that to facilitate a better comprehension of the text, a Glossary of the terms used should be annexed to the document.

Scope

21. The Committee had an extensive discussion on the Scope of the document to determine whether the principles should apply only within Codex or to member governments.

22. The Delegation of the United States expressed the view that the scope of the Principles should be limited to Codex, as this was the original mandate given to the Committee by the Commission. As the current scope referred both to Codex and to governments, this created considerable confusion throughout the text and the interpretation of several sections was not clear, including those addressing precaution. The Delegation indicated that the development of risk analysis principles for application by governments could be considered at a later date but the development of principles for application in Codex was the highest priority. This position was supported by several delegations.

23. Several other delegations expressed the view that the current scope should be retained, and that the last session had achieved significant progress on recommendations directed both to Codex committees and to governments. These delegations also pointed out that it was the role of Codex to provide advice to governments on risk analysis, as recognized by the Commission.

24. Several delegations stressed the need to clarify the scope of the document before proceeding with a detailed discussion of the text, as this lack of clarity would cause difficulties with several sections. Other delegations proposed to discuss the text in detail in order to identify the sections where further clarification was required. The Committee, recognizing that there was no consensus on the scope at this stage, agreed that the first paragraph should be retained in square brackets, and that other references to the application of the principles would be subject to further discussion. The Committee agreed to ask the Commission whether it should develop principles for application within Codex only, or principles that would be applicable both within Codex and to governments, with the necessary clarification where necessary (see also para. 71. The Committee agreed to request the Commission for a clarification of the intended scope and application of the document; i.e., whether it was a text exclusively for application within the Codex framework, or by Member governments, or both (bearing in mind that some paragraphs then might need to be singled out as being for specific application either by Codex or by Member governments)., below).

25. Some delegations pointed out that the section should describe only the scope of the document and therefore proposed to delete paragraphs 2 and 3 as they referred to the objectives of Codex. The Committee did not come to a conclusion on this proposal. The Committee noted a proposal to refer to "food safety aspects" of Codex standards to establish a distinction with other health related issues, especially in the area of nutrition. The Delegation of Australia, supported by the Delegation of Brazil proposed to indicate in paragraph 2 that the purpose of the text was "providing an objective basis for measures to protect the health of consumers".

26. As regards paragraph 4 on risk analysis in Codex, the Secretariat noted that while the Commission and its subsidiary bodies might consider some elements of risk assessment, they were mainly responsible for providing advice on risk management and that normally risk assessment was the responsibility of FAO/WHO expert committees and consultations. The text was therefore amended to reflect that Codex was providing advice rather than undertaking risk management itself.

Risk Analysis - General Aspects

27. The Delegation of Malaysia, supported by several delegations and observers, proposed to delete the reference to risk analysis being "soundly based on science" as the risk management and risk communication components took into account other aspects (paragraph 1). Other delegations supported the reference to science since the risk analysis process as a whole was based on scientific risk assessment.

28. The Committee had an exchange of views on this question and agreed that risk analysis "should be consistent with the Statements of Principles Concerning the Role of Science and the Extent to which Other Factors are Taken into Account", rather than "soundly based on science", as this covered both the need for a scientific basis and the consideration of other legitimate factors where appropriate. The recommendations in the paragraph were amended accordingly and rearranged for clarification purposes.

29. The Committee discussed a proposal to clarify that only "publicly available" documentation should be made accessible to all interested parties, as proprietary information was confidential. The Secretariat indicated that the CCFICS had addressed this issue in the Principles for Food Import and Export Inspection and Certification, where both confidentiality and the need for scrutiny by consumers and their representative organizations and other interested parties were covered in the section on Transparency (para. 14), and the Committee agreed to use a similar wording.

30. The Committee agreed to indicate at the beginning of paragraph 4 that "the three components of risk analysis should be applied in an overarching framework of strategies and policies to manage risk", in order to reflect the integrated approach to risk analysis.

31. The Committee recognized that the separation between risk assessment and risk management was also intended to avoid confusion about the functions to be performed by risk assessors and risk managers, in addition to the need to avoid conflicts of interest, and amended the text of paragraph 4 accordingly.

32. The Delegation of Australia proposed an amendment to paragraph 5 to provide further clarification on the use of precaution in risk assessment and its importance in the selection of risk management options. The Delegation proposed to delete the second sentence and to add a new sentence as follows: "Precaution should be exercised through the use of appropriate assumptions in the risk assessment and the choice of risk management options that reflect the confidence in the available scientific information". The Committee agreed to retain the second sentence and to add the new sentence proposed by Australia. Some delegations expressed their reservation on the use of the term "precaution" and the Committee agreed to place the entire paragraph in square brackets.

33. The Delegation of Australia also proposed to add further explanations concerning the relationship between the degree of uncertainty in risk assessment and risk management options, and noted that clarification at this stage might facilitate the debate concerning precaution in risk management (paras. 34-35), although this was a separate issue. It was suggested that the additional paragraph should be transferred to the section on precaution in risk management (paras. 34-35) but the Committee agreed to retain it for the time being under General Aspects as paragraph 5b.

Working Principles for Risk Analysis of Precaution in Risk Management - paras. 34 - 35)[6]

34. Some delegations expressed their concern with this addition. Other delegations proposed to discuss it further and to consider how it might relate to the discussion on precaution in risk management and in particular the use of precaution in routine and exceptional circumstances. The Committee could not discuss this proposal in detail and agreed that it would require further consideration at the next session. The proposals for the revised text of paras. 5 and 5b are included in Appendix V.

35. The Committee had an exchange of views on the need to amend paragraph 6 on the needs and situation of developing countries.. The Delegation of Morocco expressed the view that clarification was needed on the reference to "responsible bodies" and that explicit reference should be made to the specific bodies concerned at the international and government level. The Delegation of Sweden, speaking on behalf of the EC, proposed to add at the end of the paragraph that "however, that should not compromise the level of consumer protection". However, the Delegation of India, supported by other delegations, opposed the inclusion of this linkage. The Delegation of Bolivia stated that the level of consumer protection was already covered in paragraph 2 of the Scope. The Committee therefore agreed to retain the original text as agreed at the last session.

Risk Assessment

36. Some delegations pointed out that the references to the Statements of Principle Relating to the Role of Food Safety Risk Assessment throughout the text were not always consistent with the exact wording of the Statements, and a footnote referring to the Statements was added to the heading of this section.

37. In order to clarify paragraph 9 on the selection of experts, the Committee agreed with the proposal of the Delegation of Sweden to add a reference to their "experience and expertise", in addition to the current text.

38. The Committee agreed to delete paragraph 11 and to replace it with the following: "Explicit consideration should be given to variability and other sources of uncertainty at each step in the risk assessment process". The paragraphs concerning the data used in risk assessment were grouped and reordered to follow a more logical sequence (10,13, 16 and 15). Paragraph 13 was amended to reflect more precisely the use of quantitative and qualitative information in risk assessment.

39. The Committee noted some proposals to amend paragraph 15 (developing countries and the use of global data) but left the text unchanged because, as pointed out by the Delegation of India, it repeated a specific recommendation of the Commission. The Delegation of the United States pointed out that the use of global data did not apply to national governments, and a reference to Codex was added accordingly. A reference to "storage" was added in paragraph 16 (food chain) to make it consistent with para. 26 in the Risk Management section, as agreed at the last session.

Risk Assessment Policy

40. The Committee recognized that the establishment of risk assessment policy affected the risk analysis process as a whole and agreed to transfer paragraphs 19 to 23 to the end of the section on General Aspects.

41. The Committee noted that paragraph 20 provided a definition of Risk Assessment Policy and the Committee agreed that it could be used in the Glossary of Terms (see para. 20 above). In paragraph 21, the Committee agreed that risk assessment policy should be established "preferably" in advance of risk assessment and amended the text accordingly.

42. The Committee recognized that it was not always possible to determine in advance whether the mandate given to risk assessors was "achievable" and agreed that it should be "as clear as possible". The square brackets in paragraph 22 were therefore deleted.

43. The Delegation of the United States proposed to consider paragraph 23 (risk management option) in conjunction with paragraph 28 (risk reduction) under Risk Management. Following the discussion on paragraph 28 (see para. 45. An alternative wording was added in paragraph 28 indicating that risk management options should be "assessed" or " evaluated". The Committee had an exchange of views on the notion of risk reduction, as some delegations felt it that it was too narrow and that risk management options should be considered in relation to the level of consumer protection. The Committee agreed to replace "risk reduction" with a reference to "the scope and purpose of risk analysis and the ability to achieve the required level of consumer protection", and to include an assessment of the option of "doing nothing" in the risk management options., below) the Committee agreed to retain paragraph 23 in the current section as it addressed a different issue.

Risk Management

44. The Committee agreed to use the wording of the Statement of Principles to describe "other legitimate factors" in paragraph 25, and to delete the square brackets. The Committee recalled that the description of the components of risk management reflected the recommendations of the Joint FAO/WHO Expert Consultation on Risk Management and Food Safety concerning the structured approach and agreed to retain the current text. The Committee agreed that the description of "risk evaluation" proposed by the Consultation should be included in the Glossary of terms mentioned above, in order to prevent confusion on that term; it was also noted that translation difficulties would need to be addressed.

45. An alternative wording was added in paragraph 28 indicating that risk management options should be "assessed" or " evaluated". The Committee had an exchange of views on the notion of risk reduction, as some delegations felt it that it was too narrow and that risk management options should be considered in relation to the level of consumer protection. The Committee agreed to replace "risk reduction" with a reference to "the scope and purpose of risk analysis and the ability to achieve the required level of consumer protection", and to include an assessment of the option of "doing nothing" in the risk management options.

46. The Committee agreed to simplify paragraph 31 by deleting the superfluous reference to legitimate factors. The Delegation of Canada proposed to amend this paragraph to stress the need for consistency in the decisions taken under similar circumstances, in addition to the current recommendations on transparency. The Committee did not discuss this question in detail and could not come to a conclusion at this stage.

47. The Committee amended paragraph 33 to reflect that standards and related texts should be updated as necessary to reflect new scientific knowledge.

Risk Communication

48. The Committee noted some proposals for amendments to that section, as mentioned in the written comments of the EC and CI. However it was not possible to consider this section in detail due to time constraints and the current text was retained, with the understanding that there would be an opportunity to examine it in more detail later.

Background

49. At the 15th Session of the Committee it was agreed that a drafting group co-ordinated by the French Secretariat would work by electronic mail in order to propose a revised draft text of these paragraphs. Comments were also requested from Member governments and interested international organizations by means of Circular Letter CL 2000/12-GP. In the light of comments received the French Secretariat prepared a revised text (CX/GP 01/3) which was distributed for further comments. A Working Group was then convened immediately preceding the present Session to discuss this proposal in the light of the comments received. Professor Chevassus-au-Louis, Chairman of the Working Group, presented the following report to the Committee[7]:

Report of the Working Group

50. "The Working Group had considered the proposed wording of paragraphs 34 and 35 of the Proposed Draft Working Principles for Risk Analysis in document CX/GP 01/3. The main changes introduced to document CX/GP 01/3 were the following:

51. The Working Group agreed to delete footnote 1 ("It is recognized that hazard identification is a crucial step in this process") and to replace it by the following phrase "from a preliminary risk assessment" coming after "reasonable evidence". It was recalled that hazard identification is defined in the Procedural Manual. On the other hand, the working group wished to recall that the application of precaution should be exercised following a preliminary risk assessment.

52. The Working Group discussed at length the scope for the application of precaution. It wondered whether precaution had to be applied by governments, by Codex or by both. It concluded that the situation described was the same but that precautionary measures could take different forms according to whether they are taken within the Codex framework or by governments. Consequently it suggested a text comprising:

- A general paragraph intended for risk managers and describing the situation.

- Two specific paragraphs, one intended for Codex and the other for governments, which define the action likely to be undertaken.

53. The Working Group agreed that there was a link between paragraph 34 and elements of paragraph 35, in particular on the issue of proportionality but it did not have time for a full discussion to determine which elements applied to Codex and which applied to governments.

54. The Working Group had no time to consider footnote 2 ("Some members refer to this concept as the "precautionary principle"). This discussion would have to take place during the plenary session.

55. Finally the Working Group agreed on the appended wording which it proposed to submit to the plenary session of the CCGP (see Appendix V).

56. The following reservations were expressed in relation to this wording (in the Working Group):

- Although recognizing that clarifications had been made, the Delegation of the United States expressed a general reservation on the whole text.

- The Delegation of Brazil stated that the paragraph intended for governments should be put in square brackets.

- Some delegations, including Japan and the European Union wished to discuss further the wording of the last sub-paragraph of paragraph 34 by comparison with the wording initially proposed."

Discussion of the Working Group's "Compromise Text"

57. Following the presentation of the Working Group report, there was a general debate in the Committee.

58. Several delegations including Argentina, Bolivia, Paraguay and Uruguay asked for the deletion of paras. 35-35 as in their view there was a question of the legitimacy of referring to precaution as a principle of international law. The Delegation of Uruguay expressed the view that paragraphs 34 and 35 in the Working Principles should be deleted since the confusion created by these paragraphs as regards terminology and legal aspects could result in measures that would adversely affect the protection of consumers' health and fair trade practices.

59. The Committee expressed its appreciation to the Working Group and its Chairman for their efforts to find a solution to the problems raised in relation to paragraphs 34-35. In particular, delegations stated that some progress had been made towards a clearer definition of the means by which Codex on one hand, and Member governments on the other hand, applied precaution in their respective areas of competence. Nevertheless, several delegations stated that without a clarification of the Scope of the Working Principles as a whole, the situation would remain confused. At different points in the discussion, Delegations made reference to differences in the perceived mandate of the Committee as set down by the Commission. One Delegation drew attention to the goals in reference to risk analysis set out by the Commission in 1999 in its Medium-Term Plan 1998-2003.[8] Reference was also made to the initial mandate of the Commission in 1997 to draft "integrated principles for risk management and assessment policy setting, risk communication and documentation for inclusion in the Procedural Manual".[9] However, attention was also drawn to the Commission's statement that "governments should be encouraged to integrate risk analysis in their legislation".[10]

60. There was general agreement that governments had the right to take interim measures to protect the heath of consumers as set out in Article 5.7 of the SPS Agreement. However, agreement could not be reached about the actions that Codex should take in situations where there was uncertainty and/or lack of scientific information including adverse effects on human health, as some delegations were of the opinion that Codex should not develop international standards, guidelines or recommendations under such conditions. Other delegations stated that Codex did, and should, prepare guidance, as appropriate, under such circumstances.

61. Some delegations requested the removal of any explicit reference to "precaution", claiming that all necessary measures to protect consumers' health when scientific evidence was insufficient were covered by the SPS Agreement and that any additional reference could foster the use of precaution for the purpose of trade protection, and that reference to a "precautionary principle" could allow governments to deviate from the disciplines of the SPS Agreement. The Delegation of Argentina, referring to its written comments, stated that it did not recognize any legal status for a so-called "precautionary principle" and therefore requested to delete any reference to such a principle. Other delegations stated that for the purpose of understanding and the fostering of consumer confidence in the risk analysis process, a reference to "precaution" was essential, and stated that this could be a reference to a "precautionary principle" as well as to a "precautionary approach". In the opinion of these delegations the use of either expression would indicate to consumers that a high level of protection was being sought, and that precaution was not being used only in acute situations.

62. Several delegations, referring to the International FAO Conference on International Food Trade beyond 2000 (Melbourne 11-15 October 1999), expressed the view that precaution was an essential element of risk analysis. There was a difference of opinion as to whether Codex should be encouraged to develop standards, guidelines or recommendations exclusively on this basis, without comprehensive scientific information and evidence.

63. On the basis of this debate and several explicit proposals for amendment to the Working Group's compromise text, the Chairperson of the Committee tabled a revised text for the consideration of the Committee. The Delegation of Australia also circulated a revised text for consideration.

Consideration of the Chairperson's Text

64. The Committee expressed its appreciation to the Chairperson for her efforts in drawing together many of the diverse opinions expressed during the discussion of the Working Group draft.

65. The Representative of WHO stated that the issue of food safety had been recognized as one of high significance by the World Health Assembly. He reported that the Director-General of WHO had recently referred to the use of risk analysis as the "third wave" of strategies that were being used to improve the food safety status of countries around the world, the first and second "waves" being the use of Good Manufacturing Practices and the application of HACCP. However, risk analysis gave developing countries the opportunity to make even more significant advances than the developed countries in food safety. The Representative stated that risk analysis had to be considered as a health issue with trade implications and not as a trade issue with health implications, and that the debate on precaution should be viewed in this light.

66. Some Delegations stated that explicit reference to the use of precaution in Codex decision-making would reinforce the view that protecting consumers' health was the primary purpose of risk analysis over and above any trade concerns. The Observer from Consumers International expressed concern with the trend, within Codex and at the present meeting, to emphasize trade concerns over and above those of protecting the health of consumers. This view was supported by the Delegations of the United Kingdom and Norway. The Delegation of Argentina referred to the objectives of Codex of protecting consumers' health and ensuring fair practices in food trade.

67. Several Delegations stated that there was a need for a single document for use within Codex that described the application of precaution and also guidance for governments on how to apply precaution. These Delegations stated that they could accept most of the Chairperson's text, including the footnote which made explicit reference to "precautionary principle/precautionary approach". In the opinion of most of these Delegations, reference to the application of precaution was essential to maintain consumer confidence in the ability of food control authorities to ensure the safety of the food supply.

68. Several other Delegations expressed their preference for a complete deletion of paragraphs 34 and 35 as they should not apply to the work of Codex. Some of these delegations proposed however that, if the Chairperson's text was to be retained, reference to "precaution" should be deleted along with reference to actions to be undertaken by governments. Several delegations were also of the opinion that the footnote that referred explicitly to "precautionary principle/precautionary approach" should be deleted. The Delegation of Bolivia supported deleting the note because the precautionary principle could be used as a justification for trade protectionism. Some delegations also expressed their concern about the proposal to equate "precautionary principle" with "precautionary approach". The Delegation of Uruguay stated that the measures referred to in paras. 34 and 35 should only be applied by governments, in accordance with the WTO Agreements.

69. A number of Delegations expressed their preference for the draft text tabled by the Delegation of Australia, stating that the Chairperson's text still retained elements of ambiguity as to the work of Codex and the work of Member governments. These Delegations stated that it was inappropriate to suggest that Codex should develop standards, guidelines or recommendations by recourse to the "precautionary principle" when data were inadequate, even though it was recognized that precaution was an essential element in the Codex normal decision-making process. These Delegations also noted the linkages with the general statement on the application of precaution in risk analysis as contained in the Section on General Aspects (paragraph 5) of the draft document (see also paras. 32-34, above).

STATUS OF THE PROPOSED DRAFT WORKING PRINCIPLES FOR RISK ANALYSIS

70. The Committee noted that it had reviewed the complete text of the Working Principles now for the second time, and that progress had been made on a number of points although it had not been possible to achieve consensus on all of the text, in particular on the paragraphs dealing with Scope (paragraph 1) and precaution (paragraphs 5, 34 and 35). In relation to paragraph 34, the Committee agreed that all of the current alternative proposals, as presented in Appendix V of the present report, would be included in any revised text in square brackets.

71. The Committee agreed to request the Commission for a clarification of the intended scope and application of the document; i.e., whether it was a text exclusively for application within the Codex framework, or by Member governments, or both (bearing in mind that some paragraphs then might need to be singled out as being for specific application either by Codex or by Member governments).

72. The Committee also agreed to request the advice of the Commission on how Codex should react when scientific data were insufficient or incomplete and evidence of a risk to human health existed, in particular whether it should proceed to elaborate a standard or related text or whether it should refrain from such action.

73. In order to assist in the interpretation of the manner in which precaution was being used by Codex, the Committee invited the Chairpersons of relevant Codex Committees as well as governments and interested international organizations, to forward examples to the Secretariat in time to be available for discussion of this matter by the Commission (see para. 60, above).

74. On the basis of the Commission's advice, the Committee noted that it should be possible to proceed with the development of a text that would incorporate the decisions made at the present session. It requested the Secretariat to prepare such a revised text for circulation at Step 3 and consideration at the Committee's next session. It also requested the Secretariat to review the editorial presentation of the text, to remove duplication or repetition where possible while ensuring that the consensus decisions of the Committee remained as a they had been agreed.

75. The Delegation of Australia stressed the importance of an effective mechanism to ensure progress between the sessions and offered to lead a small working group to redraft the Working Principles for Risk Analysis. Several delegations supported this proposal. The Committee agreed that there was a need for the Host Country to convene an open-ended working group (open to all members and observer organizations) between sessions to review the document and the comments received so as to facilitate the discussion of the text at the Committee's next session. The Delegation of Bolivia expressed the view that this working group should be open to developing countries and be provided with interpretation. The Chairperson confirmed that, as had been the case before the present session, the Working Group would be open to all countries and provided with interpretation into French and Spanish.

b) The Application of Risk Analysis in the Elaboration of Codex Standards (Agenda Item 3.b)[11]

76. The Delegation of India presented the document and stated that it had been prepared in the light of a number of decisions taken in the recent past by Codex Committees which demonstrated that scientific information from only a limited number of countries had been used as a basis for the decision-making and that draft standards had been advanced in some cases before completion of the risk assessment. The Delegation particularly addressed the discussions concerning Aflatoxin M1 in Milk and Lead (Pb) in various foods as examples where global data, in particular data from developing countries, had not been taken into account. The paper contained proposals for specific guidelines that might be used to ensure that Codex standards were indeed based on global data.

77. The Delegation proposed that in addition to the proposals contained in the working paper, consideration should be given by FAO and WHO to the identification of collaborating centres and/or sentinel sites that could develop the necessary epidemiological and exposure data in order that global information be used in the Codex Risk analysis process.

78. The Committee expressed its appreciation of the paper prepared by the Delegation of India and many delegations expressed the view that the paper identified issues requiring serious consideration.

79. The Delegation of the United States expressed its support for many of the recommendations contained in the proposals, but noted that some of them had already been included in the Draft Working Principles. The Delegation proposed that for the moment the elaboration of separate Guidelines appeared to be premature, and that the proposals be forwarded to the relevant Codex Committees for consideration. The view that many of the specific proposed Guidelines should be incorporated into the Working Principles was supported by other Delegations including Australia, Malaysia, Sweden and United Kingdom. The Delegation of Uganda also noted the problems of developing and verifying data used in risk analysis. The Delegation of Chile referred to the recommendation of the 23rd Session of the Commission on risk analysis and especially (para. 56 f)) that a co-author from a developing country should be appointed for position papers where the main author was from a developed country, and proposed that this should be taken into account if a drafting group was established for the Working Principles for Risk Analysis.

80. The Representative of FAO stated that there was a great need for capacity building for developing countries in developing the necessary data for risk analysis both at the national and global levels. FAO was giving consideration to the establishment of a Global Facility for Capacity Building in Food Safety and Quality that would address this issue among others, and welcomed the initiative announced by the French Minister of Agriculture in his opening address. The Representative also pointed out that capacity-building workshops on risk analysis had been held in most regions, including recently in the Near East and South-Asian regions. Workshops on exposure assessment had been held in association with Codex Regional Coordinating Committees in the past biennium.

81. The Chairperson of Committee on Pesticide Residues (Dr. van Eck, the Netherlands) noted that the lack of relevant data from developing countries had been recognised as a constraint in that Committee's work. The Committee had recommended to strengthen regional cooperation to develop data. Similarly, the Delegation of Denmark supported the objective of providing means to improve developing country participation in Codex work, but stated that emphasis should be placed on support to develop more complete food safety systems; the question was not only about participation in Codex meetings. The Delegations of Dominican Republic, Norway and Swaziland also drew attention to the need for addressing the issue of capacity building. The Observer from Consumers International stressed the need to use global data, particularly on epidemiological surveillance and exposure studies; and the need to develop capacity building, particularly in developing countries.

82. The Representative of WHO stated that new procedures for the identification of experts by FAO and WHO and for obtaining data, especially in the area of microbiological risk assessment and the risk assessment of foods derived from biotechnology, gave the opportunity for developing countries to use the Internet or the Codex-L distribution list to contribute to the early stages of the risk analysis process. The Representative noted that participants in expert meeting were selected in their personal capacities and not as representatives of their countries; nevertheless considerable efforts were made to ensure that the membership of expert committees and consultations reflected the global membership of the parent organizations.

83. The Committee thanked the Delegation of India for its thoughtful paper and agreed that the recommendations should be considered together with the Working Principles as appropriate. The Committee also agreed to send the paper to the relevant Codex Committees for their consideration of the specific issues raised. It also agreed to circulate the recommendations contained in the paper for government comments and to consider these recommendations in the light of comments at its next session.


[3] ALINORM 01/33, Appendix III; CX/GP 01/3-Add.2 (comments of Australia, Canada, Malaysia, Thailand, United States, CI, EC, IACFO); CX/GP 01/3-Add. 4 (comments of New Zealand); CRD 1 (comments of Thailand); CRD 6b (India)
[4] CX/GP 01/3 ; CX/GP 01/3-Add.1 (Comments of Australia, Malaysia, Thailand, United States, Uruguay, CI, CRN, CIAA, EFLA/AEDA, GCPF, IASDA, IACFO, ICGMA) ; CX/GP 01/3-Add.3 (Argentina, Costa Rica, Malaysia, Norway, Uruguay, United States, CI, COMISA, EC, GCPF, IAFCO) ; CX/GP 01/3-Add.3 (New Zealand, ALA); CRD5 and 7 (CRN) ; CRD 6 bis (India) ; CRD 11 (Australia – compromise text).
[5] ALINORM 99/33, paras. 50-52
[6] CX/GP 01/3 ; CX/GP 01/3-Add.1 (Comments of Australia, Malaysia, Thailand, United States, Uruguay, CI, CRN, CIAA, EFLA/AEDA, GCPF, IASDA, IACFO, ICGMA) ; CX/GP 01/3-Add.3 (Argentina, Costa Rica, Malaysia, Norway, Uruguay, United States, CI, COMISA, EC, GCPF, IAFCO) ; CX/GP 01/3-Add.3 (New Zealand, ALA); CRD5 and 7 (CRN) ; CRD 6 bis (India) ; CRD 11 (Australia – compromise text).
[7] Unnumbered CRD: “Report of the Working Group – 21 April 2001. The Application of Precaution in Risk Management”
[8] ALINORM 99/37, Appendix II, para.3.
[9] ALINORM 97/37, Paragraph 164 (ii).
[10] ALINORM 99/37, Paragraph 49.
[11] CX/GP 01/4

Previous Page Top of Page Next Page