57. The Delegation of Australia, in introducing the working document, noted that the Guideline was being developed in response to the mandate set out by the Commission in the Committee’s Terms of Reference. The Delegation noted that the drafting group had attempted to indicate the way in which quality assurance systems used by commercial enterprises could also be used by the competent authorities in the process of food inspection and certification, while delineating elements of quality assurance systems which should be considered by industry and how HACCP could be integrated into such systems. It was noted that written comments suggested that the approach followed may not have given appropriate emphasis to matters of concern to governments and this aspect should be a focus of discussions for the Committee.
58. The Delegation of the United States stated that the document as drafted contained a considerable amount of material directed to industry, particularly Sections 5 and 6, which was not appropriate. This material should therefore be placed in an Annex. The Delegation stated that, if the Guidelines were to be of use to governments and official bodies, they must have a clear and narrow scope. It also expressed concern at the proposals contained in the proposed draft guidelines regarding the use of industry experts to carry out official audits.
59. The Delegation of France, speaking on behalf of the Members of the European Union present at the Session[17], stated that too much emphasis had been placed on the systems of quality assurance considered as an end in themselves and not as a tool for the competent authorities who remain responsible for food control in international trade. In the opinion of the Delegation the text required clarification and should concentrate of three points:
60. The Delegation of New Zealand stated that the sections dealing with the elements of quality assurance systems, their implementation and maintenance, would be better placed elsewhere, perhaps in an annex to the document. The text related to the application of HACCP principles within a quality assurance system could also be minimized by using a footnote reference to the Codex HACCP Guidelines. The section on official assessment and certification required expansion.
61. The Delegation of Canada expressed concern at problems in the use of terminology and stated that the emphasis on HACCP masked the provisions of the guidelines on the use of quality assurance by importing food industries.
62. The Delegation of Brazil stated that it could agree to the continued development of the guidelines for use on a voluntary basis; that the terminology should be harmonized with internationally accepted terms; and, that the quality assurance systems applied should be internationally recognized.
63. The Delegation of India noted that HACCP was only one of several food safety systems that could be used under the Codex General Principles of Food Hygiene and that this fact was not reflected in the Guidelines. In general, there was too much emphasis on HACCP.
64. The Delegation of Thailand, supported by those of China and Malaysia, reiterated the reservation made at previous sessions of the Committee. It stated that the introduction of good manufacturing practices and HACCP allowed enterprises to meet the ALOP and was concerned that the guidelines could be interpreted in a manner that would make the use of quality assurance systems compulsory. The Delegation noted that food-exporting countries may decide to use any world-wide recognized quality control systems in their production processes as they deem appropriate.
65. The Delegation of Japan asked whether there might be linkages between the contents of this document and the issue of “traceability” to be discussed under Item 10. The delegation of Japan also enquired as to how traceability related to the work of other Codex committees.
66. The Delegation of Germany noted that the ISO 9000 standards for quality assurance were under revision.
67. The Committee noted that the objective of the guidelines was to provide advice to governments and their official and officially-recognized inspection and certification bodies in the case that an enterprise had established a quality assurance system. It further noted the views expressed above, as well as those submitted in writing, and decided that the Proposed Draft Guidelines required further work. It requested the drafting group to revise the Proposed Draft Guidelines in the light of the above discussion.
68. The drafting group led by Australia was reconstituted to include Canada, Denmark, France, India, Japan, Morocco, the Netherlands, New Zealand, South Africa, Switzerland, United States and European Commission.
STATUS OF THE PROPOSED DRAFT GUIDELINES FOR THE UTILIZATION AND PROMOTION OF QUALITY ASSURANCE SYSTEMS TO MEET REQUIREMENTS IN RELATION TO FOOD
69. The Committee returned the Proposed Draft Guidelines to Step 2 for further revision, comment, and discussion at its next session.
