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Food Safety Act: A New Regulatory Approach

The document discusses the importance of effective national food control systems to ensure food safety and quality, particularly in the context of international trade and consumer protection. It outlines challenges faced by food control authorities, including increasing foodborne illnesses and the need for harmonized standards. The document emphasizes the role of organizations like FAO and WHO in promoting scientific principles in food laws and standards, and highlights the necessity for comprehensive food control systems that integrate regulatory, preventive, and educational strategies.

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0% found this document useful (0 votes)
41 views28 pages

Food Safety Act: A New Regulatory Approach

The document discusses the importance of effective national food control systems to ensure food safety and quality, particularly in the context of international trade and consumer protection. It outlines challenges faced by food control authorities, including increasing foodborne illnesses and the need for harmonized standards. The document emphasizes the role of organizations like FAO and WHO in promoting scientific principles in food laws and standards, and highlights the necessity for comprehensive food control systems that integrate regulatory, preventive, and educational strategies.

Uploaded by

21125880
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

Dr.

Nguyen Minh Xuan Hong

Chapter 1
FOOD LAWS &
Introduction to
FOOD STANDARDS Food Laws &
Dr. NGUYỄN MINH XUÂN HỒNG
nmxhong@[Link]
Food Standards

1 2

• Effective national food control • The new global environment for food trade places
systems are essential to protect
considerable obligations on both importing and
the health and safety of
Food Law domestic consumers. exporting countries to strengthen their food control
systems and to implement and enforce risk-based
Or Food • They are also critical in
food control strategies.
enabling countries to:
Control • Consumers are taking unprecedented interest in the
– Assure the safety and quality of
System their foods entering international way food is produced, processed and marketed, and
trade; and are increasingly calling for their Governments to
– Ensure that imported foods accept greater responsibility for food safety and
conform to national requirements.
consumer protection.

3 4
Dr. Nguyen Minh Xuan Hong

• The Food and Agriculture Organization of the • This is particularly important for developing
countries as they seek to achieve improved food
United Nations (FAO) and the World Health
safety, quality and nutrition, but will require a high
Organization (WHO) have a strong interest in
level of political and policy commitment.
promoting national food control systems that are
based upon scientific principles and guidelines, • In many countries, effective food control is
undermined by the existence of fragmented
and which address all sectors of the food chain.
legislation, multiple jurisdictions, and weaknesses
in surveillance, monitoring and enforcement.

5 6

Chapter outline
1. Challenges for food control authorities 1.
2. Important food issues CHALLENGES FOR FOOD
3. Elements of a national food control system
CONTROL AUTHORITIES
4. Strengthening national food control systems
5. Specific issues of developing countries

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Dr. Nguyen Minh Xuan Hong

• Globally, the incidence of food borne diseases is increasing


The challenges for food control authorities: and international food trade is disrupted by frequent
• Increasing burden of food borne illness and new and disputes over food safety and quality requirements.
emerging food borne hazards; • The modern concept of risk assessment provides guidelines
with important information on the principles and practices
• Rapidly changing technologies in food production,
of food control and the trend away from a merely punitive to
processing and marketing; a preventive approach to food control.
• Developing science-based food control systems with a • Responsibility for food control in most countries is shared
focus on consumer protection; between different agencies or ministries with duplication of
• International food trade and need for harmonization of regulatory activity, fragmented surveillance and a lack of
food safety and quality standards; coordination are common resulting in wide variations in
• Changes in lifestyles, including rapid urbanization; expertise and resources between the different agencies and
the responsibility for protecting public health may conflict
• Growing consumer awareness of food safety and quality with obligations to facilitate trade or develop an industry or
issues and increasing demand for better information. sector.

9 10

2.1. Food Safety, Quality and Consumer


Protection
• Food safety: all hazards, whether chronic or acute, that may
make food injurious to the health of the consumer.
2. • Food quality includes all other attributes that influence a
product’s value to the consumer, including:
IMPORTANT FOOD ISSUES – Negative attributes such as spoilage, contamination with filth,
discoloration, off-odors
– Positive attributes such as the origin, colour, flavour, texture and
processing method of the food.
 This distinction between safety and quality has
implications for public policy and influences the nature and
content of the food control system most suited to meet
predetermined national objectives.

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Dr. Nguyen Minh Xuan Hong

2.2. Food control


• Confidence in the safety and integrity of the food
supply is an important requirement for consumers.
• Is a mandatory regulatory activity of enforcement by
national or local authorities to provide consumer • Food borne disease outbreaks involving agents
protection and ensure that all foods during production, such as Escherichia coli, Salmonella and chemical
handling, storage, processing, and distribution are contaminants highlight problems with food safety
safe, wholesome and fit for human consumption; and increase public anxiety that modern farming
conform to safety and quality requirements; and are systems, food processing and marketing do not
honestly and accurately labelled as prescribed by law. provide adequate safeguards for public health.
• To enforce the food law(s) protecting the consumer
against unsafe, impure and fraudulently presented
food by prohibiting the sale of food not of the nature,
substance or quality demanded by the purchaser.

13 14

• Factors contribute to potential hazards in foods: Specific concerns about food hazards have
– improper agricultural practices; usually focused on:
– poor hygiene at all stages of the food chain;
• Microbiological hazards;
– lack of preventive controls in food processing
and preparation operations; • Pesticide residues;
– misuse of chemicals; • Misuse of food additives;
– contaminated raw materials, ingredients and • Chemical contaminants, including biological toxins;
water; • Adulteration.
– inadequate or improper storage,
–…

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Dr. Nguyen Minh Xuan Hong

• Thus an ideal food control system should include


• The list has been further extended to cover genetically modified
effective enforcement of mandatory requirements,
organisms, allergens, veterinary drugs residues and growth
promoting hormones used in the production of animal products. along with training and education, community
• Consumers expect protection from hazards occurring along the outreach programs and promotion of voluntary
entire food chain, from primary producer through consumer compliance.
(often described as the farm-to-table continuum). • The introduction of preventive approaches such as the
• Protection will only occur if all sectors in the chain operate in an Hazard Analysis Critical Control Point System (HACCP),
integrated way, and food control systems address all stages of have resulted in industry taking greater responsibility
this chain. As no mandatory activity of this nature can achieve its
for and control of food safety risks.
objectives fully without the cooperation and active participation
of all stakeholders e.g. farmers, industry, and consumers, the • Such an integrated approach facilitates improved
term Food Control System is used in these Guidelines to describe consumer protection, effectively stimulates agriculture
the integration of a mandatory regulatory approach with and the food processing industry, and promotes
preventive and educational strategies that protect the whole domestic and international food trade.
food chain.

17 18

2.3.1. International Trade


2.3. Global Considerations • Expanding world economy
• Liberalization of food trade
• Growing consumer demand
2.3.1. International Trade • Developments in food science and technology
2.3.2. Codex Alimentarius Commission (CAC) • Improvements in transport and communication

2.3.3. SPS and TBT Agreements  International trade in fresh and processed food will
continue to increase.
 Access of countries to food export markets will continue
to depend on their capacity to meet the regulatory
requirements of importing countries.

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Dr. Nguyen Minh Xuan Hong

2.3.2. Codex Alimentarius Commission (CAC)


Codex Alimentarius Commission (cont.)
• CAC is an intergovernmental body that coordinates food
standards at the international level. • Codex has embarked on a series of activities based on
• Objectives: to protect the health of consumers and risk assessment to address microbiological hazards in
ensure fair practices in food trade. foods.
 Created worldwide awareness of food safety, quality and
• It has formulated international standards for a wide range consumer protection issues
of food products and specific requirements covering
 Achieved international consensus on how to deal with them
pesticide residues, food additives, veterinary drug scientifically, through a risk-based approach.
residues, hygiene, food contaminants, labelling, etc.
 Continuous appraisal of the principles of food safety
 These Codex recommendations are used by governments and quality at the international level
to determine and refine policies and programs under
 Increasing pressure for the adoption of these principles
their national food control system.
at the national level.

21 22

2.3.3. SPS and TBT Agreements SPS Agreements


• Confirms the right of WTO member countries to apply
• The conclusion of the Uruguay Round of Multilateral measures to protect human, animal and plant life and
Trade Negotiations in Marrakech health.
Establishment of the WTO on 1 January 1995 • Covers all relevant laws, decrees, regulations; testing,
inspection, certification and approval procedures; and
The Agreement on the Application of Sanitary and
packaging and labelling requirements directly related to
Phytosanitary Measures (SPS)
food safety.
 The Agreement on Technical Barriers to Trade (TBT).
• Member States are asked to apply only those measures
• Both these Agreements are relevant in understanding for protection that are based on scientific principles, only
the requirements for food protection measures at the to the extent necessary, and not in a manner which may
national level, and the rules under which food is traded constitute a disguised restriction on international trade.
internationally.

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Dr. Nguyen Minh Xuan Hong

SPS Agreements (cont.) TBT Agreements


• Encourages use of international standards, guidelines or
recommendations where they exist, and identifies those • Requires that technical regulations on traditional
from Codex (relating to food additives, veterinary drugs quality factors, fraudulent practices, packaging,
and pesticide residues, contaminants, methods of analysis labelling etc imposed by countries will not be more
and sampling, and codes and guidelines of hygienic restrictive on imported products than they are on
practices), to be consistent with provisions of SPS. products produced domestically and encourages use
 Codex standards serve as a benchmark for comparison of of international standards.
national sanitary and phytosanitary measures.
• While it is not compulsory for Member States to apply
Codex Standards, it is in their best interests to harmonize
their national food standards with those elaborated by
Codex.

25 26

Objectives of national food


control systems
3. • Protecting public health by reducing the risk
of food borne illness;
ELEMENTS OF A NATIONAL • Protecting consumers from unsanitary,

FOOD CONTROL SYSTEM unwholesome, mislabelled or adulterated food;


• Contributing to economic development by
maintaining consumer confidence in the food
system and providing a sound regulatory
foundation for domestic and international trade
in food.

29

27 29
Dr. Nguyen Minh Xuan Hong

Scope Building Blocks


• Food control systems should cover all food (a) Food Law and Regulations
produced, processed and marketed within the (b) Food Control Management
country, including imported food. (c) Inspection Services
• Such systems should have a statutory basis (d) Laboratory Service : Food Monitoring and
and be mandatory in nature. Epidemiological Data
(e) Information, Education, Communication and
Training

32 33

32 33

(a) Food Law and Regulations Traditional food laws Modern food laws

• The development of relevant and enforceable - Legal definitions of - Necessary legal powers
food laws and regulations is an essential unsafe food and prescriptions to ensure
- Prescription of food safety
component of a modern food control system.
enforcement tools for - Allow the competent food
• Inadequate food legislation will impact on the removing unsafe food authority or authorities to
effectiveness of all food control activities carried from commerce and build preventive approaches
out in the country. punishing responsible into the system.
parties after the fact.  preventive and holistic in
 reactive and their approach to reducing
enforcement-oriented the risk of food borne illness

34 35

34 35
Dr. Nguyen Minh Xuan Hong

• include provisions for the right of consumers to


Aspects of food legislation access to accurate and sufficient information;
– provide a high level of health protection; • provide for tracing of food products and for their
recall in case of problems;
– include clear definitions to increase consistency
and legal security; • include clear provisions indicating that primary
responsibility for food safety and quality rests
– based on high quality, transparent, and independent
with producers and processors;
scientific advice following risk assessment, risk
management and risk communication; • include obligation to ensure that only safe and
fairly presented food is placed on the market;
– include provision for the use of precaution and the
adoption of provisional measures where an • recognize the country's international obligations
unacceptable level of risk to health has been particularly in relation to trade;
identified and where full risk assessment could not • ensure transparency in the development of food
be performed; 36
law and access to information.
37

36 37

• In addition to legislation, governments need updated


food standards. In recent years, many highly (b) Food Control Management
prescriptive standards have been replaced by
horizontal standards that address the broad issues
• Effective food control systems require policy and
involved in achieving food safety objectives.
operational coordination at the national level.
• In preparing food regulations and standards,
• Determined by the national legislation
countries should take full advantage of Codex
standards and food safety lessons learned in other
countries to develop a modern regulatory framework
that will both satisfy national needs and meet the
demands of the SPS Agreement and trading
partners.
38 39

38 39
Dr. Nguyen Minh Xuan Hong

(c) Inspection Services


Responsibilities of food control
management • The administration and implementation of food laws
require a qualified, trained, efficient and honest food
• Establishment of regulatory measures
inspection service.
• Monitoring system performance
• The food inspector is the key functionary who has
• Facilitating continuous improvement day-to-day contact with the food industry, trade and
often the public.
• Providing overall policy guidance.
• The reputation and integrity of the food control
system depends on their integrity and skill.

40 41

40 41

Responsibilities of the inspection services:


– Recognizing, collecting and transmitting evidence
– Inspecting premises and processes for compliance when breaches of law occur, and appearing in court
with hygienic and other requirements of standards and to assist prosecution;
regulations;
– Evaluating HACCP plans and their implementation; – Encouraging voluntary compliance in particular by
– Sampling food during harvest, processing, means of quality assurance procedures;
storage, transport, or sale to establish compliance,
– Carrying out inspection, sampling and certification of
to contribute data for risk assessments and to identify
food for import/export inspection purposes when
offenders;
required;
– Recognizing food decomposition, food which is
unfit for human consumption, or food which is – In establishments working under safety assurance
otherwise deceptively sold to the consumer; and programs such as HACCP, conduct risk-based
taking the necessary remedial action; audits.
42 43

42 43
Dr. Nguyen Minh Xuan Hong

Proper training of food inspectors:


 Training in food science and technology to (d) Laboratory Service:
understand industrial processes, identify potential Food Monitoring and Epidemiological Data
safety and quality problems, and have the skill and
experience to inspect the premises, collect food • Establishment of laboratories: requires considerable
samples and carry out an overall evaluation. capital investment, expensive to maintain and operate.
 Understanding relevant food laws and regulations,  careful planning is necessary to achieve optimum
their powers under those laws, and obligations such results.
laws impose on the food sector. • All food analysis laboratories may not be under the
 Being conversant with procedures for collecting control of one agency or ministry, and a number could
evidence, writing inspection reports, collecting be under the jurisdiction of the states, provinces and
samples and sending them to a laboratory for analysis. local authorities.
 Training HACCP systems to handle HACCP audit
responsibilities. 44
45

44 45

• The Food Control Management should lay down the


norms for food control laboratories and monitor • The introduction of analytical quality assurance
their performance. programs and accreditation of the laboratory by
an appropriate accreditation agency within the
• The laboratories should have adequate facilities for
country or from outside, enables the laboratory to
physical, microbiological and chemical analyses.
improve its performance and to ensure reliability,
• The analytical results of a food control laboratory are accuracy and repeatability of its results. Prescription
often used as evidence in a court of law to determine of official methods of sampling and analysis also
compliance with regulations or standards of the support this effort.
country  utmost care must be taken to ensure the
efficient and effective performance of the laboratory.

46 47

46 47
Dr. Nguyen Minh Xuan Hong

(e) Information, Education,


Communication and Training
• Food control agencies should address the
• Provision of balanced factual information to specific training needs of their food inspectors
consumers; and laboratory analysts as a high priority.
• Provision of information packages and
educational programs for key officials and workers • These activities provide an important means of
in the food industry; building food control expertise and skills in all
• Development of train-the-trainer programs; interested parties, and thereby serve an
essential preventive function.
• Provision of reference literature to extension
workers in the agriculture and health sectors.
48
49

48 49

Summary

Food Law
and 4.
Regulations
Information,
STRENGTHENING
Food
Control
Management Food
Education,
Communication
and Training
NATIONAL FOOD
control
system CONTROL SYSTEMS
Inspection Laboratory
Services Service

50

50 51
Dr. Nguyen Minh Xuan Hong

4.1. Principles of Food Control


• Maximizing risk reduction by applying the principle Certain key principles and related issues:
of prevention as fully as possible throughout the
food chain;
(a) Integrated farm-to-table concept
• Addressing the farm-to-table continuum;
• Establishing emergency procedures for dealing with (b) Risk Analysis
particular hazards (e.g. recall of products);
• Developing science-based food control strategies; (c) Transparency
• Establishing priorities based on risk analysis and (d) Regulatory Impact Assessment
efficacy in risk management;
• Recognizing that food control is a widely shared
responsibility that requires positive interaction
between all stakeholders.
52 53

(a) Integrated farm-to-table concept


• The objective of reduced risk can be achieved most (b) Risk Analysis
effectively by the principle of prevention throughout the
production, processing and marketing chain. To achieve
maximum consumer protection it is essential that The Codex Alimentarius Commission defines risk
safety and quality be built into food products from analysis as a process composed of three
production through to consumption. components:
• The introduction of preventive measures at all stages  Risk assessment
of the food production and distribution chain, rather
than only inspection and rejection at the final stage,  Risk management
makes better economic sense, because unsuitable  Risk communication
products can be identified earlier along the chain.
• Government regulators are then responsible for
auditing performance of the food system through
monitoring and surveillance activities and for enforcing
legal and regulatory requirements.
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Dr. Nguyen Minh Xuan Hong

• Risk assessment - a scientifically based process


consisting of the following steps: (i) hazard identification;
(ii) hazard characterization; (iii) exposure assessment;
and (iv) risk characterization.
• Risk management - the process of weighing policy
alternatives, in consultation with all interested parties,
considering risk assessment and other factors relevant
for the health protection of consumers and for the
promotion of fair-trade practices, and, if needed selecting
appropriate prevention and control options.
• Risk communication - the interactive exchange of
information and opinions throughout the risk analysis
process concerning hazards and risks, risk related
factors and risk perceptions, among risk assessors, risk
Relationship between the three components
managers, consumers, industry, the academic
of risk analysis
community and other interested parties.

56 57

• Risk analysis is well established for chemical hazards,


and FAO and WHO are now extending the experience
and expertise developed from risk analysis of chemical
hazards to that of microbiological hazards. Risk
analysis must be the foundation on which food control
policy and consumer protection measures are based.
• Codex standards take into account risk assessments
carried out at the international level and are accepted
as scientifically valid under the SPS Agreement. Hence
their adoption and implementation within national food
control systems is encouraged.
• Risk management should take into account the economic
consequences and feasibility of risk management options
and recognizes the need for flexibility consistent with
consumer protection requirements.

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Dr. Nguyen Minh Xuan Hong

(c) Transparency
GAP VS. GMP • A food control system must be developed and
implemented in a transparent manner.
• GOOD AGRICULTURAL PRACTICES • The confidence of consumers in the safety and
• GOOD MANUFACTURAL PRACTICES quality of the food supply depends on their
perception of the integrity and effectiveness of
food control operations and activities.
• This will encourage cooperation from all
concerned parties and improve the efficiency and
rate of compliance.

62 63

(d) Regulatory Impact Assessment


• Food control authorities should also examine the
manner in which they communicate food safety
information to the public. • When planning and implementing food control
measures, consideration must be given to the
• This may take the form of scientific opinion on food costs of compliance (resources, personnel, and
safety matters, overviews of inspection activity, and financial implications) to the food industry, as these
findings on foods implicated in food borne illnesses, costs are ultimately passed onto consumers.
food poisoning episodes, or gross adulteration.
• The important questions are:
• All this could be considered as a part of risk
communication to enable consumers to better  Do the benefits of regulation justify the costs?
understand the risks and their responsibilities for  What is the most efficient management option?
minimizing the impact of food borne hazards.

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Dr. Nguyen Minh Xuan Hong

• Export inspection systems designed to assure


the safety and quality of exported foods, will • Two approaches have been suggested for
protect international markets, generate business determining cost/benefit of regulatory measures
and secure returns. in food safety:
• Regulatory impact assessments (RIA) are of  Theoretical models can be developed to
increasing importance in determining priorities estimate willingness to pay (WTP) for reduced
and assist food control agencies in adjusting or risk of morbidity and mortality;
revising their strategies to achieve the most  Cost of illness (COI) covering lifetime medical
beneficial effect. They are, however, difficult to costs and lost productivity.
carry out.

66 67

4.2. Developing a National Food Control


Strategy
• Both approaches require considerable data for
interpretation. • Requires knowledge of the current situation and the
development of a national food control strategy.
 COI estimates are perhaps easier for policy • Tend to be country-specific.
makers to understand and have been widely
• Influenced by current or emerging food safety and
used to justify measures for food control, even
quality issues.
though they do not measure the full value of
risk reduction. • Need to consider international perceptions of food
risks, international standards, and any international
 Not surprisingly, it is easier to perform a RIA commitments in the food protection area.
for an export inspection intervention, than for  When establishing a food control system, it is
regulatory policy which achieves a public necessary to systematically examine all factors that
health outcome. may impinge upon the objectives and performance of
the system and develop a national strategy.
68 69
Dr. Nguyen Minh Xuan Hong

(a) Collection of Information


• The profile should permit a review of health and
• This is achieved through the collection and collation of socioeconomic issues impacting on food borne
relevant data in the form of a Country Profile. hazards, consumers concerns, and the growth
of industry and trade, as well as identification of
• This data underpins strategy development, with
stakeholders reaching consensus on objectives, the functions of all sectors which are directly
priorities, policies, roles of different ministries/ and indirectly involved in ensuring food safety
agencies, industry responsibilities, and timeframe for and quality and consumer protection.
implementation. • The collection of epidemiological data on food
• In particular, major problems associated with the borne illness is an indispensable component of
control and prevention of food borne diseases is a country profile and should be done whenever
identified so that effective strategies for the resolution possible.
of these problems can be implemented.

70 71

(b) Development of Strategy • The final strategy should include:


 A national strategy for food control with defined
• Aim: to develop an integrated, coherent, effective objectives, a plan of action for its implementation, and
milestones;
and dynamic food control system, and to
determine priorities which ensure consumer  Development of appropriate food legislation, or
protection and promote the country’s economic revision of the existing legislation to achieve the
development. objectives defined by the national strategy;
 Development or revision of food regulations,
• The strategy should be based on multi-sectoral
standards and codes of practice as well as
inputs and focus on the need for food security, harmonizing these with international requirements;
and consumer protection from unsafe
adulterated or misbranded food.  A program for strengthening food surveillance and
control systems;

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Dr. Nguyen Minh Xuan Hong

• The final strategy should include (cont.): 4.3. Strengthening Organizational


Structures for National Food Control
 Promotion of systems for improving food safety and
Systems
quality along the food chain (i.e. HACCP-based food • During the preparation of a national food control
control programs);
strategy, it is important to consider the type and
 Development and organization of training programs for size of the organization(s) that are necessary to
food handlers and processors, food inspectors, and implement the strategy.
analysts;
• Three common types of organizational
 Enhanced inputs into research, food borne disease arrangements at the national level:
surveillance, and data collection, as well as creating
increased scientific capacity within the system; • Multiple Agency System
 Promotion of consumer education and other community • Single Agency System
outreach initiatives.
• Integrated System

75 76

(a) Multiple Agency System


• While food safety is the foremost objective, food
control systems also have an important economic
objective of creating and maintaining sustainable food
production and processing systems.
• In this context, food control systems play a significant
role in the following:
 Ensuring fair practices in trade;
 Developing the food sector on a professional and
A system based A system based on A system based on scientific basis;
on a single, multiple agencies a national  Preventing avoidable losses and conserving natural
unified agency responsible for integrated approach resources;
for food control food control  Promoting the country’s export trade.

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Dr. Nguyen Minh Xuan Hong

• The systems that deal specifically with these objectives


• Specific commodity inspection regulations, such as for
can be sectoral i.e. based upon the need for
fish and fish products, meat and meat products, or fruit
development of the particular sector such as fisheries,
and vegetable products which are implemented by
meat and meat products, fruit and vegetables, milk and
different agencies or ministries given this mandate
milk products.
under relevant law(s).
• These systems can be mandatory or voluntary, and put
• Regulated systems for grading and marking of fresh
into effect either through a general food law or a
agricultural produce which go directly for sale to the
sectoral regulation.
consumer or as raw material for industry.
Ex: An export inspection law that identifies foods to be
• They are mostly confined to quality characteristics so
covered for mandatory export inspection prior to export;
that the producer gets a fair return for his produce and
or offers facilities for voluntary inspection and
the buyer is not cheated.
certification for exporters.

79 80

• Drawbacks of multiple food control agencies :


• Where sectoral initiatives have resulted in the
 Lack of overall coordination at national level;
establishment of separate food control activities, the
 Frequent confusion over jurisdiction and resultant
outcome has been the creation of multiple agencies
inefficiencies in performance;
with responsibilities for food control.
 Differences in levels of expertise and resources and
• Food control systems may also be fragmented hence uneven implementation;
between national, state and local bodies, and the  Conflict between public health objectives and the
thoroughness of implementation depends upon the facilitation of trade and industry development;
capacity and the efficiency of the agency responsible  Limited capacity for appropriate scientific inputs in
at each level. decision-making processes;
• Thus, consumers may not receive the same level of  Lack of coherence leading to over-regulation or time
protection throughout the country, and it may become gaps in adequate regulatory activity;
difficult to properly evaluate the effectiveness of  Reductions in the confidence of domestic consumers
interventions by national, state or local authorities. and foreign buyers in the credibility of the system.

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Dr. Nguyen Minh Xuan Hong

• The benefits that result from a single agency


(b) Single Agency System approach to food control include:
 Uniform application of protection measures;
• The consolidation of all responsibility for protecting
public health and food safety into a single food  Ability to act quickly to protect consumers;
control agency with clearly defined terms of  Improved cost efficiency and more effective use of
reference has considerable merit. resources and expertise;
• It acknowledges the high priority that Government  Harmonization of food standards;
places in food safety initiatives and a commitment  Capacity to quickly respond to emerging
to reducing the risk of food borne disease. challenges and the demands of the domestic and
international marketplace;
 The provision of more streamlined and efficient
services, benefiting industry and promoting trade.

83 84

• While a national strategy helps to influence both the (c) Integrated System
legislation and the organizational structure for
enforcement, it is not possible to recommend a
single organizational structure that will universally • Integrated food control systems warrant
meet the requirements and resources of every consideration where there is desire and
country’s socioeconomic and political environment. determination to achieve effective collaboration
• The decision has to be country specific, and all and coordination between agencies across the
stakeholders should have the opportunity to farm-to-table continuum.
provide inputs into the development process.
• Unfortunately, there are often few opportunities for
countries to build a new food control system based
on a single agency.

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Dr. Nguyen Minh Xuan Hong

• Advantages of integrated system:


(c) Integrated System  Provides coherence in the national food control system;
 Politically more acceptable as it does not disturb the day-to-day
• Typically, the organization of an integrated food control inspection and enforcement role of other agencies;
system would have several levels of operation:  Promotes uniform application of control measures across the
whole food chain throughout the country;
 Level 1: Formulation of policy, risk assessment and
 Separates risk assessment and risk management functions,
management, and development of standards and resulting in objective consumer protection measures with
regulations. resultant confidence among domestic consumers and credibility
with foreign buyers;
 Level 2: Coordination of food control activity,  Better equipped to deal with international dimensions of food
monitoring, and auditing. control such as participation in work of Codex, follow-up on
SPS/TBT Agreements, etc;
 Level 3: Inspection, and enforcement.
 Encourages transparency in decision-making processes, and
 Level 4: Education and training. accountability in implementation;
 Is more cost-effective in the long term.

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• Some other functions of such a body at the national


level may include: • An integrated National Food Control Agency
 Revising and updating the national food control strategy should address the entire food chain from farm-to-
as needed; table and should have the mandate to move
 Advising relevant ministerial officials on policy matters, resources to high priority areas and to address
including determination of priorities and use of resources; important sources of risk.
 Drafting regulations, standards and codes of practice and
promoting their implementation; • The establishment of such an agency should not
involve day-to-day food inspection responsibilities.
 Coordinating the activity of the various inspection
agencies, and monitoring performance;
 Developing consumer education and community outreach
initiatives and promoting their implementation;
 Supporting research and development;
 Establishing quality assurance schemes for industry and
supporting their implementation.

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4.4. Funding National Food Control Systems


• The funds and resources required for reorganizing and
strengthening food control systems would normally be
made available from the national government. 5.
• In countries where food control responsibilities are
spread across many government agencies it may be
SPECIFIC ISSUES OF
necessary to negotiate a revised funding structure and
establish transition arrangements to ensure continuity of DEVELOPING COUNTRIES
funds and resources.
• For this to occur, it is essential there is full commitment
by the government for establishing appropriate
structures and developing policies to deliver the
optimum level of consumer protection.

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Food Systems (cont.)


5.1. Food Systems
• Food production, processing, and marketing • Problems occur as a result of poor postharvest
systems are complex. handling, processing and storage of food and also
due to inadequate facilities and infrastructure such
• In many developing countries they are also highly as the absence or shortage of safe water supply,
fragmented and dependent upon a large number of electricity, storage facilities including cold stores,
small producers. and transport facilities and networks, etc.
• While this may have socioeconomic benefits, as • A majority of food producers and handlers lack
large quantities of food pass through a multitude of appropriate knowledge and expertise in the
food handlers and middlemen, the risk of exposing application of modern agricultural practices, food
food to unhygienic environments, contamination hygiene, and good food handling practices.
and adulteration increases.

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Dr. Nguyen Minh Xuan Hong

5.2. Food Processing Industry


5.2. Food Processing Industry
• The food processing industry in developing countries
ranges from sophisticated state-of-art facilities to
small artisanal operations producing traditional foods • Governments often support these small units as
for the local community. they provide employment and generate income for
• The size of these processing units is quite variable – their operators.
from a few large plants to a majority of small and • The challenge for developing countries is to
cottage scale units with very limited resources for provide incentives for the effective expansion of
effective technological inputs. these small units so they may absorb better
• At the least developed end of this continuum, these technology.
premises are ill equipped to deal with the
maintenance of food safety and quality in a scientific
and sustained manner.

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5.3. Street Foods


• Studies in developing countries have shown that up • Food safety is a major concern with street foods.
to 20-25% of household food expenditure is incurred • These foods are generally prepared and sold
outside the home, and some segments of the under unhygienic conditions, with limited access
population depend entirely on street foods.
to safe water, sanitary services, or garbage
• This has been one of the consequences of rapid disposal facilities.
urbanization, with millions of people having no
access to a kitchen or other cooking facilities. • Hence street foods pose a high risk of food
poisoning due to microbial contamination, as well
• There are millions of single workers without families as improper use of food additives, adulteration
and a large floating population who move in and out
and environmental contamination.
of the city for work, and these people largely depend
upon street foods for their daily sustenance from
places of work, schools, hospitals, railway stations,
and bus terminals.

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Dr. Nguyen Minh Xuan Hong

5.4. Food Control Infrastructure and


Resources
• Food control infrastructure in many developing • Food control systems may also suffer from
countries tends to be inadequate, due to limited poorly or inadequately developed compliance
resources and often poor management. policies.
• Food control laboratories are frequently poorly • Food control authorities need to better
equipped and lack suitably trained analytical staff. appreciate the role of science in the risk-based
This is accentuated where multiple agencies are approach, and to take advantage of scientific
involved in food control. resources in the international community.
• A lack of overall strategic direction means that
limited resources are not properly utilized.

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5.5. Technical Assistance: Role


of International Agencies • FAO assistance in food control and food standards
is a major activity and is delivered at global,
regional, and country levels.
• The need for technical assistance in strengthening
food control systems in developing countries is well • Published manuals of food quality control cover a
recognized. range of different aspects of food control systems
and are used internationally.
• FAO and WHO are the two main specialized agencies
of the United Nations involved in food quality and
safety technical cooperation programmes with
developing countries.

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Dr. Nguyen Minh Xuan Hong

• Technical assistance is provided in many areas such as:


• WHO has in recent years substantially increased the
 Establishing or strengthening national food control systems
priority of its food safety activities at international
and infrastructure;
and regional levels.
 Assistance in preparation of food law and regulations;
• It also provides technical assistance at international,
 Workshops on developing national strategies for food
control; regional, and country level for providing assistance
 Assistance in establishing or improving food analysis
to Member States in developing and strengthening
capabilities; their National Food Safety Programs.
 Assessing the implications of SPS and TBT Agreements;
 Providing training in food inspection, analysis and food
handling;
 Providing training of trainers in HACCP;
 Providing training in management of food control systems;
 Assistance in strengthening National Codex Committees.

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• The nature and extent of these activities is influenced


• Both the SPS Agreement and TBT Agreement
by available resources, including:
specifically refer to the need to provide technical
 Developing regional and national food safety policy and
strategies; assistance to developing countries.
 Preparation of food legislation, food regulations and • Such assistance may be in areas of processing
standards, and codes of hygienic practice; technologies, research and infrastructure, establishment
 Implementation of food inspection programs; of national regulatory bodies, etc.
 Promoting methods and technologies designed to prevent
food borne diseases, including the application of the
• In particular, developed countries which import food
HACCP system; from developing nations are required, upon request, to
 Developing or enhancing food analysis capability; provide technical assistance to the developing exporting
 Development and delivery of hygiene training and countries to enable these countries to meet their SPS or
education programs; TBT obligations in international food trade.
 Establishing healthy markets and enhancing the safety of • This new opportunity to access technical assistance
street food; under the WTO Agreements has not yet been fully
 Promoting the establishment of food borne disease utilized by developing countries.
surveillance activity.
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Dr. Nguyen Minh Xuan Hong

A few definitions as given by FAO / WHO:


• Technical assistance in the food control area may • Audit: A systematic examination to determine whether what
also be obtained through the World Bank, other is actually happening complies with documented
development banks, and from bilateral donor procedures.
agencies. • Codex Alimentarius Commission (CAC): It is a subsidiary
body of the Food and Agriculture Organization of the United
• Access to such funds is dependent upon the Nations and the World Health Organization. The
priority that developing countries attach to Commission is entrusted with the elaboration of
strengthening their food control systems as international standards of food to protect the health of
reflected in their national development plans. consumers and to ensure fair practices in the food trade.
• Codex Committees: These subsidiary bodies of the Codex
Alimentarius Commission include nine general subject
committees, fifteen specific commodity committees, six
regional coordinating committees and time-limited ad-hoc
Intergovernmental Task Forces on specific subjects.

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• Critical Control Point: A step at which control is essential • Food Control: A mandatory regulatory activity of
to prevent or eliminate a food safety hazard or reduce it to enforcement by national or local authorities to provide
an acceptable level. consumer protection and ensure that all foods during
production, handling, storage, processing and distribution are
• Equivalence: The process of recognition that enables the safe, wholesome and fit for human consumption; conform to
sanitary and phytosanitary measures employed in one quality and safety requirements; and are honestly and
country to be deemed equivalent to those of a second accurately labelled as prescribed by law.
country, trading in the same product, although different
• Food Hygiene: All conditions and measures necessary to
control measures are being practiced.
ensure the safety and suitability of food at all stages of the
• Farm-to-Table: Includes all steps involved in the food chain.
production, storage, handling, distribution and preparation • Food Inspection: The examination, by an agency
of a food product. empowered to perform regulatory and/or enforcement
• Food Contaminant: Any biological or chemical agent, functions, of food products or systems for the control of raw
foreign matter, or other substance not intentionally added materials, processing, and distribution. This includes in-
to food which may compromise food safety or suitability. process and finished product testing to verify that they
conform to regulatory requirements.

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Dr. Nguyen Minh Xuan Hong

• Food Surveillance: The continuous monitoring of the food


supply to ensure consumers are not exposed to • GMO: Genetically modified organism.
components in foods, such as chemical contaminants or • HACCP Plan: A document prepared in accordance with the
biological hazards, which pose a risk to health. principles of HACCP to ensure control of hazards which are
• Good Agricultural Practices (GAP): Practices of primary significant for food safety in the segment of the food chain
food producers (such as farmers and fishermen) that are under consideration.
necessary to produce safe and wholesome agricultural • HACCP System: The hazard analysis critical control point
food products conforming to food laws and regulations. system (HACCP) is a scientific and systematic way of
• Good Manufacturing Practices (GMP): Conformance enhancing the safety of foods from primary production to
with codes of practice, industry standards, regulations and final consumption through the identification and evaluation
laws concerning production, processing, handling, labelling of specific hazards and measures for their control to ensure
and sale of foods decreed by industry, local, state, national the safety of food. HACCP is a tool to assess hazards and
and international bodies with the intention of protecting the establish control systems that focus on prevention rather
public from illness, product adulteration and fraud. than relying mainly on end-product testing.

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• Hazard: A biological, chemical or physical agent in, or


condition of, food with the potential to cause harm. • RIA: Regulatory impact assessment.

• Hazard Analysis: The process of collecting and • Risk Analysis: A process consisting of three components:
interpreting information on hazards and conditions leading risk assessment, risk management and risk communication.
to their presence to decide which are significant for food • Risk Assessment: A scientifically based process consisting
safety and therefore should be addressed in the HACCP of the following steps: hazard identification, hazard
plan. characterization, exposure assessment, and risk
• JECFA: Joint FAO/WHO Expert Committee on Food characterization.
Additives. • Risk Characterization: The qualitative and/or quantitative
• JMPR: Joint FAO/WHO Meeting on Pesticide Residues. estimation, including attendant uncertainties, of the
probability of occurrence and severity of known or potential
• Monitoring: In a HACCP plan, the act of conducting a adverse health effects in a given population based on hazard
planned sequence of observations or measurements of identification, hazard characterization and exposure
control parameters to assess whether a critical control point assessment.
is under control.

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Dr. Nguyen Minh Xuan Hong

• Verification: In HACCP, the use of methods, procedures,


• Risk Communication: The interactive exchange of
or tests in addition to those used in monitoring to determine
information and opinions concerning risks among risk
compliance with the HACCP plan, and/or whether the
assessors, risk managers, consumers and other interested
HACCP plan needs modification in order to enhance food
parties.
safety.
• Risk Management: The process of weighing policy
• WTO: The World Trade Organization is the international
alternatives in the light of results of risk assessment, and, if
organization that establishes the rules of trade between
required, selecting and implementing appropriate control
nations. At its heart are the WTO agreements, negotiated
options, including regulatory measures.
and signed by the bulk of the world‟s trading nations and
• SPS: Sanitary and Phytosanitary Agreement of the World ratified in their parliaments. The goal is to help producers
Trade Organization (WTO). of goods and services, exporters, and importers conduct
their business.
• TBT: Technical Barriers to Trade Agreement of the World
Trade Organization (WTO).

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References
FAO/WHO, 2003. Assuring food safety and
quality - Guidelines for strengthening
national food control systems. FAO and
Nutrition Paper, 76. ISSN 0254-4725
[Link]

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