| Module 7 National Food Control Systems: Components and OperationFood Quality and Standards Service Food and Nutrition Division |
The objective of this module is to explain the basic components of a national food control system and how these components can and should be operated for maximum efficiency. Common pitfalls are identified and benefits of an efficient system are described. Up-to-date management approaches are introduced. The importance of government, industry and consumer partnerships in achieving national goals of enhanced consumer protection and economic advancement through trade in safe and quality food is emphasized.
7.1 Introduction and historical background
7.2 The importance of food control
7.3 What is food control?
7.4 Developing a national food control strategy
7.5 Current situation
7.6 International food trade
7.7 Impact of the World Trade Organization
7.8 Future directions for food control
Food control is an ancient activity...
Access to safe, reliable and nutritious food supplies is a basic need for all people. Governments have an obligation to ensure this need is met. Producing safe and good quality food is also a prerequisite to successful and sustainable development of national agricultural resources and of domestic and international food trade.
Food standards for consumer protection and trade have a long tradition. Laws were laid down by Moses to prevent the consumption of meat from unclean animals, especially animals that had died from causes other than supervised slaughter. Assyrian writing tablets provided descriptions of how to determine correct weights and measures for foodgrains. The Egyptians were the first known culture to prescribe requirements for labelling on certain foods. In ancient Athens, beer and wines were inspected to ensure their purity and soundness. The Romans provided a well-organized state-controlled food control system to protect consumers from being defrauded. In the European Middle Ages individual countries passed laws concerning the quality and safety of eggs, sausages, cheese, beer, wine and bread. Some of these ancient statutes are still in operation today. The Industrial Revolution, which began in Europe in the late eighteenth century, gave technological and economic impetus to trade in foods across and between continents. Food chemistry, as a science, dates from the mid-1800s. Most early food standards and basic food control systems also date from about the same time.
From the Middle Ages onwards, consumer protection measures continued to evolve and expand to provide a greater degree of protection and to deal with the increased levels of sophistication of the problems associated with food quality, safety and trade practices. This was particularly true following the introduction of mass production technology and the emergence of populated urbanized centres in the late eighteenth and early nineteenth century. New and different approaches were required to address public concerns for food problems emerging from these dramatic changes. The response of most countries undergoing these changes was to enact food laws and regulations, and to establish official organizations and institutions to administer food control activities. This approach laid the foundation and became the forerunner of today's food control.
...but food safety and fraud concerns are no less relevant today
Food control plays an important role in assuring a high quality, safe and nutritious food supply for the public, for their good health and for the economic benefits derived from trade in safe and high quality food. However, recent events are sufficiently alarming to have created some concerns about the effectiveness of the food control systems. Every year, nearly 800 million people all over the world suffer from widespread malnutrition, most of them in developing countries. Malnutrition is not only the result of insufficient food supplies; it is also caused by the consumption of a limited variety of foods and poor quality and unsafe foods. Also, every year, three million children die from diarrhoeal diseases (including dysentery) brought about by consumption of poor quality food and unsafe drinking water.
If we examine the basic food safety concerns of most people throughout the world, we will find that consumers are concerned about chemical contaminants in the food supply, in particular: mycotoxins, including aflatoxins; industrial chemicals such as polychlorinated bi-phenols and toxic heavy metals; use of agricultural chemicals, such as pesticides and fertilizers; the presence of residues of drugs administered to animals and the safety of colours and various types of additives added to the food supply. Recently, biological contamination has surfaced as one of the most important concerns of consumers, particularly in developed countries, in light of the media's coverage on major foodborne disease outbreaks stemming from imported and domestically produced products in the United States, the United Kingdom, and in Europe (Table 1).
| Contaminant | Food Vector | Origin and year | Number of people affected | Economic consequences |
| Cyclospora | Strawberries and raspberries | Guatemala 1996 |
1 000 cases (US) | Exporting country lost millions of dollars in trade. |
| Salmonella | Ice cream mix | US1994 | 240 000 cases | Financial loss to producer and a significant cost in reputation and marketability of its product. |
| Escherichia coliO157 | Fast food hamburgers | US1993 | 4 deaths | Loss of consumer confidence in the product. |
| Escherichia coliO157 | White radish | Japan1996 | Approximately 9 000 school children affected | Financial loss to producer and significant cost on reputation and marketability of product. Cost of patient treatment. |
There are increasing concerns about pathogenic organisms that also exhibit antibiotic resistance. Also, considerable concern has been expressed by some consumers and scientists over the use of new technologies, such as the use of biotechnology in food product development. Consumers continue to resist purchasing food that has been irradiated, despite the fact that this technology has received considerable scrutiny and has been considered safe for a number of years provided it is used in accordance with the proper control measures. Other technologies of concern include the use of packaging innovations such as modified atmosphere packaging, as well as food fortification as a means of overcoming micronutrient deficiencies.
In light of these concerns an effective food control system is needed to assure consumers about the safety and quality of the food supply and to promote and facilitate trade both domestically and externally. Internal food trade would benefit due to value addition of products, protection of careful and scrupulous producers and processors against unlawful competitors, and in the development of industry and trade. External food trade would be facilitated due to better international market access and foreign exchange earnings and avoidance of dumping of inferior quality products.
Although there are many different definitions of Official Food Control, the one accepted by FAO is "All mandatory activities necessary to assure the quality and safety of food". This definition was published by FAO in the Food and Nutrition Paper (FNP) series on Food Quality Control - Manual 14/11 entitled "Management of Food Control Programmes". Food control is applicable throughout the entire food system. The three basic characteristics of a food control infrastructure include food law and accompanying regulations, a food inspectorate, analytical services and compliance unit, and supporting services (education, information, training and advisory support).
Official food control has its foundation in law. Without the legal framework of the government, there is no credibility for official activities or for those who carry them out. Furthermore, there is no incentive for others to comply with any directive issued by the "unauthorized" agency. While this defines the role of the government in food control, other partners, namely the food industry and the consumer, are also involved.
Food control cannot operate without adequate food law
As a first step in improving food control, the legal framework on which it is based should be reviewed and revised, and up-dated where necessary. Food legislation is an expression of the will of the government to assure food quality and safety and to carry out consumer protection measures as a matter of public policy. The terms used in the law should be clearly defined, along with procedures for administration of the law, including the authority to promulgate rules, regulations, and codes of practice and quality and safety standards. Procedures for food handling, processing, storage, shipping and sale should also be laid out. The law should define the role and authority of the competent government agency, as well as the powers granted to its personnel. It should define the role and responsibility of the private sector and other institutions such as industry, academic institutions, scientific committees, and consumers, in relation to food quality and safety. Any effort to revise food law should incorporate the input of the other partners in food control, the food industry and the consumers.
General regulations issued under authority of the law should also involve the input of all affected sectors. They should be specific, clear and in plain language so as to be understood by non-technical people. Occasionally, regulations that are sensitive from a regulatory point of view may be issued without outside agency input. In either case, they should clearly state the requirements, limits or other restrictions.
It is good policy to follow up the issuance of any regulation with information designed to provide explanations and answers to anticipated questions and, where possible, organize education and training seminars and workshops to facilitate understanding of and compliance with the regulation.
Food control functions rest on three pillars...
The primary functional units of a food control system, at the basic and minimal level, include an inspectorate, an analytical service, and a regulatory compliance unit. The inspectorate inspects and investigates an industry's performance in complying with official control requirements. The analytical service tests and examines products to determine compliance with mandatory requirements of law and regulations, including food standards, established quality and safety limits for chemical and biological contaminants, packaging requirements and other factors for which testing is required. The compliance unit serves as the enforcement function to oversee the bringing of legal cases when warranted. Other functional units support these activities including administrative, planning, programming, research and information, and education and training support, to assist both internal agency units and, when resources permit, affected external sectors.
A primary functional unit of official food control is an adequately staffed and trained inspectorate. The role of the inspectorate is to inspect domestic food manufacturing, processing and handling facilities, import/export foods and a company's facilities for compliance with the national legal and regulatory requirements. The inspector normally collects samples for all types of food analysis to demonstrate the compliance level of any suspected foods, as well as market samples for monitoring and surveillance purposes. In many countries, the inspectors also conduct investigations of suspected food poisoning or injury, fraudulent marketing and handling practices, complaints by consumers or industry and illegal importation or exportation of food products.
...a trained inspectorate...
It is important that the inspectors be trained in the latest investigative techniques and are fully educated in the latest food safety and quality assurance methods. They should receive up-to-date training in the new technologies used in processing and manufacturing, including what is required for the control of these technologies for them to function at maximum effectiveness and to assure proper performance. They must also be able to evaluate the performance of equipment and instruments used in production to assure they are appropriately controlled and monitored. In short, they must be well trained and understand the importance of Good Manufacturing Practices (GMPs), recognize deviations from GMPs and know the impact on product quality and safety. Finally, the inspector should understand the utilization and application of Hazard Analysis and Critical Control Point (HACCP) based systems as a means of enhancing the existing quality assurance and control measures used by the food industry.
...credibility of analytical results...
The laboratory function is critical to food control. The laboratory personnel serve to either confirm or not confirm the suspicion of the inspector that the food products sampled do not comply with regulations. It also confirms the quality and safety of the food by determining if mandatory levels or limits of contaminants, additives, or other restricted materials are met and if the product complies with mandatory food standards. The laboratory gathers analytical data related to monitoring activities such as those for food contaminants, microbiological contamination, meeting quality and safety standards, etc. Laboratories deal with very complex analytical problems caused by product composition interference. The problems can only be overcome by using the latest in analytical instruments and sophisticated methods of analysis. This also requires up to date technical knowledge acquired only through a continuous personnel-training programme.
Because the analytical results may serve as the basis for legal action against a food producer, methods and techniques used must be accurate and validated. In the legal system of most countries, these matters come under careful scrutiny, with the laboratory analyst frequently forced to defend his technical abilities, the method and techniques used in the analysis, the accuracy of the instruments used and finally, the results of the analysis. Official food control laboratories must maintain an internal quality assurance programme to assure their credibility under such circumstances.
...and pursuit of violations
Compliance functions in food control vary from country to country. Usually it is the responsibility of a legal unit in the Ministry of Justice to carry out court actions. However, the food control unit is usually the unit that recommends penalty actions or sanctions for violations encountered during the course of its investigative activities. If this is the case, the food control unit then should have a compliance unit. This unit would then ensure that the recommendations for legal action are appropriate; supported by sufficient and supportable evidence, and are worthy of the time and effort it will take in the courts to achieve a successful enforcement outcome.
The compliance unit would be responsible for those actions that are considered regulatory in nature, such as court actions, and for programmes intended to achieve compliance through voluntary means. Most businesses will comply with reasonable rules and laws provided they understand what they must do and believe it is in their best interest to do so. Consequently, keeping the industry informed about the requirements and working with them to assist in achieving these requirements will go a long way in assuring that food is safe and of suitable quality without having to resort to penalty actions.
Food control systems must also work with industry and consumers
Some of the supporting functions to food control activities include information, education and training services. These may be the direct responsibility of other government agencies, which act in a horizontal manner across government agency lines in a variety of areas, such as health education, trade and industries information services, consumer information services, etc. In any case, it is an important element of the food control process since industry and consumers alike need to have information to make decisions in the business world and market place. Food control officials must recognize the need for the development of information in a useable format to keep people informed about important aspects of the food supply.
The information and training services can conduct workshops and seminars on timely subjects of concern to industry or the consumers, or can develop informational materials to be used for public distribution. Communication through public media announcements, published brochures, information bulletins, even the development of an Internet home page can go a long way in keeping people informed. Programmes of education and training can be arranged directly or through educational institutions. A consumer affairs unit would relate to consumer issues, and work with consumer groups and the media and public in general to describe the food control programmes, get input and provide information that is useful and informative. The unit can also assist in getting important food quality and safety messages to the public, particularly during emergency situations when public involvement is required in providing protection against health threatening hazards related to the food supply.
Science and technology services provide backup in research planning and support, or for the review of the latest technologies in food control or food processing. They can liaise with academia on technology transfer, to assist in solving technical problems. Scientific advisory services are absolutely necessary for a food control system. Using a risk based programmed approach to food control requires an understanding of food hazards and how to control, reduce or eliminate these hazards to decrease consumer health risks. The scientific community plays a vital role in food control, developing methods, conducting research and defining the severity of the risk to consumers. They can assist in solving technical problems and providing sound scientific information to support and defend actions taken. They can provide risk assessment estimates on additives to food, and contaminants and residues when necessary, particularly in circumstances when a higher level of protection is needed for the public than international standards provide, or where international standards do not exist.
The food industry shares responsibility with the governmental agencies in achieving the objectives of a national food control strategy. It is responsible for the implementation of codes of good agricultural practices (primary production) and good manufacturing practices (secondary production) and a food quality and safety system e.g. HACCP. The role of the industry can also include the education and training of all employees in the areas of food handling and a general food quality and safety system. The industry may also be involved in research into developing technologies for food control. It can also provide information to consumers through food labelling and advertising. Ensuring that the industry is included in national food control activities can be instrumental in overcoming potential problems.
Consumers have rights and responsibilities; this means they also have a role in food control. While they have the right to high quality and safe food, they also need to understand there is no such thing as an absolutely safe food supply. They must understand how they can protect food in the household, during the handling, preparation and serving and storage of food and leftovers to prevent this food from becoming a health hazard. Consumers are also a valuable source of information but need a focal point in the food control system to let their dissatisfactions be known, to complain about product deception and poor quality and to report injury and illness caused by food. Consumer organizations can play an important role in representing the consumer in the development of a national food control strategy and bringing the concerns of consumers to the attention of the policy makers and the industry.
National strategy should begin with a baseline review
Official Food Control requires commitment and resources. It is important to obtain this commitment and the resources through developing an appropriate strategy as to what is to be achieved, how it will be done and who will do it and in what time frame. The development of a national strategy is a national endeavour and should include all those sectors involved in food quality and safety. It is recommended that a working committee make a review of the existing situation. The committee would be made up of individuals with technical (academic, science, legal and industrial), social/cultural and economic skills and knowledge from as many of the affected sectors as possible. The committee should be under the guidance and direction of a well-known skilful civic or government leader with good credentials and reputation. A review would include an examination of the legal framework, the type of food products produced for domestic and export markets, the processing methods, conditions and practices involved, and storage, transport and other handling practices. In addition, it would be important to know what health risks are involved with the food, the processes, handling and storage practices and to have information on past foodborne or related outbreaks of illness or injury, and what are the known causes. Finally, it is also important to know if there are any cultural, social, religious, economic or other factors which may have an impact of the quality and safety of food or on the activities necessary to implement an effective food control system.
The information gathered from the review can then be compared with the review of present staffing, resource allocations, the functions of competent organizational units, performance levels of personnel and organizations, and strengths and weaknesses of the existing food control system. An assessment must also be made of industries' willingness and ability to accept the responsibility for enhancing the quality and safety of their products and how well they are doing at the time. The role of academia and research institutions in the food industry (technical problem solving, product development, and advisory consultations) should also be assessed.
Analysis of the information allows for debate and discussion on possible short and long-term goals, management action to overcome gaps and overlaps in the system, strengthening weaknesses and developing a programmatic approach to solving the existing problems using risk based methods. A national workshop of experts and interested parties from all sectors can provide an opportunity for input in the development of the overall strategy. Resource allocations and organizational adjustments may be necessary over time to create the efficiencies and effectiveness desired.
Weaknesses in many food control systems...
If we take a good look at the food control capabilities of the world community, we will find that most countries in the world are still classified as developing countries. This means that at the national level, without technical assistance and resources, little progress can be made in solving and managing the risks associated with unsafe foods. Emerging food safety issues are becoming more complex and as a result it will be even more difficult for developing countries to deal with them in the future.
If we were to profile the food control abilities of most of the countries of the world, we would find that most countries have failed to develop and implement any type of national strategy for establishing a food control system. Such a system would have to be designed to protect the health of the consumers and promote the active trade in quality and safe food. In some countries where strategies do exist, there is a failure to establish reasonable goals, support the achievement of these goals or involve those who have the greatest interest in the success of such a strategy, namely the industry and the consumers.
We would also find that the majority of countries do not have a system of management to develop and implement effective and efficiently managed food control programmes. Programmes, which do exist, are not evaluated against established goals and objectives. Programme performance is not monitored and evaluated. Resources are wasted on non-productive or redundant activities, and activities are often the easy thing to do rather than the important thing to do. Employee performance is not evaluated in terms of achievement or production. Quality of performance is not measured nor is there a system of continuing education and training for up-grading skills and knowledge of operational employees.
Almost all countries, including the industrialized countries, need to up-date their food laws and regulations to reflect rapidly developing changes that are coming about in the implementation of modern food control methods. Modern food law and regulations should reflect the changes in international trading rules and reflect the respective responsibilities and roles of government, industry and the consumers in assuring food safety. Many countries have no food law but function on directives issued by various ministers, sometimes in conflict with each other. Most countries with food legislation have laws that have been in effect for 30 to 40 years. These laws have either not been updated, or have been amended bit by bit creating a complex maze of rules which are not understood by the regulators or the industry and the consumer. In many cases, laws that focus on one subject area contain clauses or sections of laws intended to regulate food as well. For example, public health legislation or agriculture legislation may contain a few brief paragraphs or general statements intended to regulate food. Many laws are written with so much prescriptive language that they become barriers to technology advances, restrict industry innovation and prevent or hinder trade.
Because of limited resources, food control officials are poorly equipped to perform their respective functions. Inspection Services are ill equipped to perform the type of in-plant activity associated with the traditional inspection process. Factors necessary for assessing and verifying more sophisticated quality and safety control systems such as elements of a HACCP system are not taken into consideration in this case.
Laboratories in many countries lack analytical instruments to test food products appropriately. Frequently, they cannot obtain supplies of necessary reagents, standards, solvents and other analytical supplies, and do not have the methods and technical capability to perform the required tests to assess quality and safety attributes.
In many countries, the most important food control official is the inspector at the municipal or local authority level. This inspector generally has less education and training qualifications than any other food control official does in the control chain. As this inspector is not provided with much training on a continuing basis, he cannot gain or maintain proficiency. Yet he is responsible for assuring that food being sold or served in major urban centres is safe, wholesome and nutritious. Also, this inspector is generally the lowest paid official working in the food control chain. And to complete the scenario, the inspector may also be responsible for other health-related duties, such as waste control, vector control, nuisance management, communicable disease control, water safety and a host of other public health activities. The point here is that food control personnel are generally inadequately trained and often lack the technical information needed to perform their functions.
In the case of laboratory personnel, extremes are seen from country to country. Many countries place their food control emphasis on laboratory analysis of finished food products and consequently, laboratory personnel have graduate level university degrees. These highly qualified employees carry out routine chemical and biological analysis of food products and may be considered significantly underemployed. In many other countries the opposite situation prevails; laboratory employees have only a basic level of education and cannot perform complex food analyses with the result that they are not carried out.
Another serious deficiency is the lack of co-ordination between government organizations and agencies with food control responsibilities to work together and to involve those other sectors (industry, academia and consumers) which can provide meaningful input into the process. In some countries, agencies with authority to perform various aspects of food control are in competition with one another. In some cases, unclear lines of authority or poorly written laws or overlapping responsibilities cause confusion for the food industry, for consumers, and for the agencies themselves. In many cases, government agencies compete with one another for authority and jurisdiction, at times performing the same tasks, issuing conflicting rules and regulations on the same subject or initiating programmes which conflict with the existing programmes of another agency, wasting the limited resources available.
... are being addressed through improved legislation...
Changes are taking place in relation to issues associated with general concerns for the quality and safety of the food supply and the new directions in food trade. Among the first of these changes are the efforts being made by most countries to up-date their food laws, rules and regulations.
Over the past decade, there has been a concerted effort in many countries to review and up-date food law and regulations. The European Community countries have enacted or are making the necessary changes to harmonize national laws and regulations with requirements set out by the European Commission. The former centrally planned economies of Eastern and Central Europe with the help of FAO have prepared new food laws where they previously did not exist and have put aside the old Soviet GOST standards. In their place, new Codex based standards are being adopted. Laws and regulations are being developed which apply more to a market oriented economy. Nearly all of these countries have aspirations to join the European Community and are in the process of meeting accession requirements. Harmonization of laws and regulations will be necessary to achieve membership.
In Asia, where industry traditionally relied on government for quality and safety control approval, new approaches are being incorporated into provisions of the food law defining the greater role of industry to accept their responsibilities regarding food quality and safety. In Latin America, the use of certification and/or registration procedures is being utilized as a means of assuring food control, often utilizing third party, non government institutions to carry out these functions.
Most developed countries with systems in place to review laws and regulations on a routine and frequent basis have been carrying out this process with a view toward strengthening the food safety provisions.
...and re-organized structures
Another development is the reorientation of the direction of food control. The reorientation has its roots in two concepts. First, there is considerable concern expressed by the public in relation to foodborne hazards and the subsequent risk. However, official food control agencies are required to use a risk ranking system as a means of establishing the priority areas in which their limited resources should be devoted. Resources consequently are not available for other non-risk or safety-related problems and the industry is encouraged to tackle problems using their internal quality assurance programmes. In addition to this, the new integrated approach to food control requires the collaboration between government and all segments of the food industry.
Most food control agencies, as well as other government agencies, generally suffer from decreasing budget allocations and are being asked to do more with less. They are asked to find more efficient means to do their work without sacrificing either control or protection. These challenges have resulted in some innovative approaches being tried and some dramatic changes in traditional food control procedures.
In the case of New Zealand and Australia, they decided to establish one food safety agency that will serve the needs of both countries and share the resources available for common activities, now known as the Australian-New Zealand Food Authority (ANZFA).
In Japan, nearly 3000 inspector positions were eliminated from the government payroll by contracting inspection services out to a third party private inspection service. In Asia, the role of government has been redefined to serve as monitors of the industry's efforts to assure food quality and safety, rather then perform these quality assurance services as they have in the past.
In Latin America, third party certification of quality and safety measures are being put in place, while in Europe there is a concerted effort to reduce the number of agencies involved in food control and consolidate authority in only one or two organizations of government.
Growing international trade in food...
There are some factors related to international trade that must be taken into account because of their importance to and their impact on food control and the fair trade of food. Trade in food at the international level is growing at a rapid rate with continued growth anticipated in the years to come. WTO statistics indicate international trade in food to be worth US$380 billion (1997). Although the liberalization of trade practices and reduction of tariff and non-tariff trade barriers can account for some of this growth, there are a number of other reasons which should be taken into consideration for food control reasons.
Consumers are demanding cheaper food products and a greater variety of foods to be available on an all year round basis. Over the past several decades or more, there has been mass migration from country to country and shifts in populations from the rural areas to growing urban centres. This migration has increased demand for ethnic and traditional foods by people who want access to the food from their native country, mostly available only through importation. Increases in tourist travel to nearly every part of the world have created the awareness and taste for exotic foods only available through importation. The liberalization of the international trading rules that permit free passage without tariffs and non-tariff trade barriers, including technical barriers, has had the impact of opening up markets that were previously protected by importation quotas and national protectionist policies.
Technical innovations have made a lot of this possible. Packaging and packing technologies have been introduced which have extended the shelf life of many food products which formerly could not "go the distance". This means that, without the packaging technologies, the product would spoil before it ever reached the intended destination and therefore could not be exported to faraway countries.
...reinforces the need for adequate food control systems
Rapid production, handling practices and transportation methods allow food produced by one country to be shipped to another country thousands of miles away. Methods such as containerized and palletized shipments, refrigerated and freezer compartments, at sea fish processing, and air cargo provide the opportunity for a variety of fresh and nutritious products to be available almost all year around. They also allow contaminated products to be in the hands of consumers in other countries within hours or days, increasing the risk.
US experience with control of food imports
There are a few countries in the world that monitor the importation of food products to the degree that they know what products are rejected or detained and for what reasons. Although many countries are beginning to gather this information, the United States is the only country that has tracked this information for some time and makes this information available to the public and anyone who has an interest in such matters. Over a period of time, FAO has been tracking the US statistics as a means of identifying the type of problems encountered in the food trade at the international level. The figure below provides an indication of the most prevalent problem areas over the past four years.
The World Trade Organization (WTO) has had a dramatic impact on food trade. The introduction of the disciplines and requirements of the Agreements on SPS and TBT could also set the stage for equally dramatic changes in food control.
WTO rules emphasize the role of international standards
As indicated earlier, the Codex safety and quality standards have become the benchmark for compliance with the SPS Agreement. All trading countries will need to reconcile this fact. By definition this includes any measure applied to protect human, animal and plant life and health. As it relates specifically to food, it includes the control of food additives, food contaminants, toxins, and disease causing organisms.
The important elements of this Agreement include a statement of the Basic Rights of all WTO Member countries to establish sanitary measures for the protection of health and life of their human, animal and plant population. However, it must be either based on international standards (Codex, IPPC or OIE), or be justified using risk assessment methods, established or acceptable at the international level, and based on sound science.
All WTO Member countries are to harmonize their procedures and standards by participating in the standards setting process of Codex, IPPC and OIE, and accept the principle of equivalence, i.e. the outcome of the measure is the same regardless of the method used to achieve it. Transparency is required and the availability of information, notifications and openness in the decision making and handling procedures in the administration of the terms of the Agreement will satisfy this requirement when handled appropriately. The SPS enquiry point helps to serve that purpose. Developed countries are encouraged to provide technical assistance to their developing country trading partners and particularly those that are having difficulty in meeting the terms of the Agreement.
As was discussed earlier, the Codex objectives are based on a legal framework of laws and regulations that protect consumers and prevent unfair trading practices while at the same time facilitating international trade. The basic purpose of food control is to do the same thing and the SPS Agreement effectively does the same through the mutual agreement of its Member countries at the international level.
It must be emphasized, however, that the SPS makes it clear that technical rules will be allowed, but only when it is justified, and it can only be justified by sound scientific evidence utilizing internationally acceptable risk assessment procedures. This effectively establishes the need for a risk based food control system for national governments to be utilized for international compliance with trading requirements.
International standards can be used by countries where the capacity to independently develop national standards does not yet exist
In this case, many developing countries do not have either the technically qualified personnel nor the financial resources to contract an expert medical toxicologist to do the intense review necessary to evaluate the safety of substances proposed to be used in foods as food additives. The best way to handle these matters is to look and see what the Joint FAO/WHO Expert Committee on Food Additives (JECFA), the Joint FAO/WHO Meeting on Pesticide Residues (JMPR) or other ad-hoc international expert groups have already done or would recommend. In relation to the JECFA and JMPR, their recommendations have almost universally been accepted by interested parties including national governments, regional standard setting bodies and the Codex in relation to Acceptable Daily Intakes (ADIs) and Maximum Residue Limits (MRLs) on additive safety, and contaminant and residues of veterinary drugs and pesticides respectively.
Over the past 100 years, food control has evolved in a slow and methodical manner taking one step at a time and dealing with the problems brought about by changes in consumer demands, technology advances, abuses in the environment which affected food and new and intense approaches in agriculture and production. The latest challenges are just a continuation of this process, except that there is a greater sense of urgency for those countries whose systems have been slower in the evolutionary process. A liberalized trading system could bring many benefits especially at a time when demand is high and new opportunities exist. Missing out on this chance simply because food control systems are lacking is likely to be at great cost to economic growth.
At the international level, there are some dramatic changes taking place in food control, driven in part by the changes in international food trade. These changes are having both a positive and negative impact worldwide. Most economies of the developing world rely heavily on agriculture. Since many developing countries are also exporting countries, there are prospects that additional resources resulting from increased trade can improve food control activities, resulting in improved food quality and safety for both domestic and export trade for the exporting country. This is a most welcome outcome of these changes.
However, the negative side of these changes, particularly for developing countries, is in relation to the increased emphasis on food safety. This is not well managed or controlled by developing countries, although the performance in this area is better for exported products than for domestic products. The introduction of poor quality or unsafe food into the international market increases consumer risk in a broader context - on a worldwide basis. Each report of an episode of foodborne disease from an exported food product weakens trade and consumer confidence in the safety of all imported food products, regardless of the exporting country responsible for the outbreak. The quality and safety problems of the exporting country can become the quality and safety problems of a distant importing country almost overnight. An example is the case of Cyclospora contamination of strawberries and raspberries.
Technical assistance to improve food control systems is built into WTO rules
Recent developments at the international level mean that assistance is available to countries in the area of food control. As a result of the SPS and TBT Agreements, technical assistance is the obligation of every Member of WTO if they are capable of providing it. It has nothing to do with development levels. Developing countries can help other developing countries in some matters in which they have had experience. Members should inform the Secretariat of the SPS and TBT Committees of the type and reason for required technical assistance when requesting such assistance during meetings at the WTO through the country delegation. Food control will be most important in the years to come particularly when new rounds of negotiations begin on new Agreements or on revisions to old Agreements. It takes years to build up a food control system that is reliable, complete, effective and efficient. It is important to start now in order to be up to date when new requirements come into play in the future.
A country cannot go wrong by using Codex standards. Full participation within the limits of a country's resources is suggested so that the Codex standards reflect the inputs of Codex Members and each Member has the chance to make a difference. By following Codex and adopting its standards, a country is presumed to comply with the terms of the SPS Agreement. Compliance is a tough requirement and it will take an adequately administered and effective food control system to give countries the type of assurance they will need to convince and establish the confidence of their trading partners.
An important FAO activity
Technical assistance can be provided by FAO. Since 1975, 400 projects have been implemented all over the world and numerous workshops, seminars and training courses have been organized. Manuals and guidelines covering various different aspects of food control have been prepared and an advisory service on specific issues is provided on request.
FAO. 1999. FAO trade-related technical assistance and information. Rome.
FAO. 1998. FAO Technical Assistance Programme: Food Quality and Safety. (ESN internal publication). Rome.
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