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Discussion Paper on the Application of Risk Analysis Principles for Food Additives and Contaminants (Agenda Item 5)[6]

21. The 32nd CCFAC agreed that the document should be revised by a drafting group led by the United States on the basis of written comments submitted and on the Committee’s discussions and circulated for comment and further consideration at its next meeting[7]. The revised document was presented by the United States.

22. The Delegation of Sweden, speaking on behalf of the member countries of the EU, highlighted the proposals presented in the EC comments, including that some paragraphs should be reworded to clarify the requirements concerning the availability and submission of data; to indicate that priority setting was a risk management task and therefore the responsibility of the CCFAC; to recognize that JECFA should not recommend ALARA levels to CCFAC as this was a risk management option; and, to eliminate the definition of “risk profile”.

23. The Delegation of Morocco expressed the view that several questions required further consideration, including risk communication with the public; the independence and geographical selection of experts; consumer protection in relation to fair trade practices (in addition to health concerns); the relationship between priority setting in the CCFAC and the work of JECFA; the need to take into account geographical differences in diets when setting the ADI; and, how to ensure that data from developing countries were available in the risk assessment process, as recommended by the Commission.

24. The Delegation of Brazil proposed to amend the recommendations in Annex II to reflect that the Committee should only endorse additives for which specifications of identity and purity had been established by JECFA, as this was necessary to carry out risk assessment.

25. The delegation of Norway pointed out that although the title of the paper referred to Risk Assessment Policy, this aspect was not sufficiently developed, and the issue of risk communication should be further elaborated.

26. The Delegation of India, supported by some delegations, proposed to delete the reference to “other legitimate factors” in the recommendations in Annex II, while noting that it was mentioned as background in other parts of the document. Other delegations and the Observer from CI stressed the importance of addressing other factors and noted that this question was currently under discussion in the Codex Committee on General Principles (CCGP).

27. The Committee noted that the general Working Principles for Risk Analysis and the consideration of “other legitimate factors” were the responsibility of the CCGP, as decided by the Commission. In addition, the Executive Committee had confirmed that no further action was required from other committees in relation to the current discussion in the CCGP. The Secretariat recalled that relevant Codex Committees had been required by the Commission to identify the elements of risk analysis used in the decision process and that the Commission would consider a progress report on risk analysis in Codex work.

28. The JECFA Secretariat recalled that JECFA provided risk assessment and scientific advice in the areas of food additives and contaminants, residues of veterinary drugs and allergens to relevant Codex Committees (CCFAC, CCRVDF, CCFL). As regards the selection of experts, the roster of FAO JECFA experts was published on the FAO website and a call for experts had been issued to member countries for the last JECFA meeting on mycotoxins. The JECFA Secretariat stressed that experts were selected on the basis of their competence and independence, taking into account geographical representation to ensure that all regions were represented. Experts were also requested to present a declaration of interest. The availability of data in developing countries was an important concern recognized by FAO and WHO and both organizations have technical assistance programmes that could contribute to the development of national capacity for risk assessment.

29. The Committee agreed that the Delegation of the United States, with the assistance of Australia, the Netherlands, Norway, Sweden, Thailand, and the United Kingdom, would, in view of the comments received and based on the above discussion, revise the paper (Discussion Paper on the Application of Risk Analysis Principles for Food Additives and Contaminants) for circulation, additional comment and further consideration at the next session.


[6] CL 2000/40-FAC and comments submitted by Indonesia, New Zealand (CX/FAC 01/4) and Argentina, Uruguay (CRD 12)
[7] ALINORM 01/12, para. 25

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