OIE 12th Conference of the OIE Regional Commission for the Middle East Harmonizing national legislation on Food Safety Alberto Mancuso Amman (Jordan) 23 September 2013
CONTENTS Evolution of food safety legislation Harmonisation of legislation in the framework of a Food Safety Strategy Suggested approach and possible solutions 2
FOOD SAFETY LEGISLATION: Objective of harmonisation A coherent legal framework is the foundation of an effective food control system, providing the necessary legal powers and prescriptions to ensure food safety and allowing the competent authorities to build preventive approaches into the system 3
FOOD SAFETY LEGISLATION: THE PAST Legislation particularly detailed Command and control approach Basic importance: premises and equipment Basic importance: traditional controls 4
LEGISLATIVE EVOLUTION Crisis BSE Crisis Dioxin Consumer s loss of confidence Definitive cause of the change Inadequacy of food safety legislation 1. Fragmentation of controls 2. legislation focused on final products control 3. Direct implication of the Competent Authorities in providing food safety 4. Lack of controls on animals feeding 5. Deficiencies in risk analysis 5
THE NEW LEGISLATION: PRINCIPLES Horizontal approach for all the food Introduction of stable to table principle Important to achieve objectives, not the way you obtain them Risk based approach to food safety The responsible for food safety is the food business operator Traceability: essential element 6
NEW LEGISLATION 1. Legislation: general goals and minimum requirements 2. Official controls to check food business operators compliance 3. Food business operators implement food safety programs and procedures 7
FOOD SAFETY SYSTEMS IN THE WORLD Food control systems show considerable similarities Food safety policy based on integrated approach Food safety responsibility transferred to the food business operator Implementation of the farm to table policy Stressing the importance of HACCP Risk based food safety policy 8
IMPACT OF THE FOOD SAFETY LEGISLATION Upgrading agri food establishments Re organisation of control systems Establisment of a Rapid Alert System Implement risk analysis principles Ensure of foodstuffs traceability Introduce the Farm to Fork Principle 9
IMPACT OF THE FOOD SAFETY LEGISLATION Competent authorities are called upon to verify systems applied by the food business operators: extensive training of inspectors Food Business Operators become directly part of the system, through the implementation of food safety programmes in the companies 10
HARMONISATION: WHICH STANDARDS? Basic framework: Codex Alimentarius Principles to be respected: included in SPS AGREEMENT In case of export: legislation of the importing Country Reference documents Codex Alimentarius «Principles and guidelines for National food control systems (CAC/GL 82 2013) FAO/WHO Guidelines for strengthening national food control systems (2003) Annex 6: Guidelines for developing a National Food Law 11
EU FOOD HYGIENE PACKAGE Regulation (EC) No. 178/2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority Food business operators Regulation (EC) No. 852/2004: hygiene of foodstuffs General Competent authorities Regulations (EC) No. 882/2004: official controls Regulation (EC) No. 853/2004: hygiene rules for foodstuffs of animal origin Specific 12 Regulation (EC) No. 854/2004: official controls on products of animal origin
HARMONISATION OF LEGISLATION IN THE FRAMEWORK OF A FOOD SAFETY STRATEGY The preparation of a national food control strategy enables the country to develop an integrated, coherent, effective and dynamic food control system, and to determine priorities which ensure consumer protection and promote the country s economic development 13
FOOD SAFETY STRATEGY BASIC BUILDING BLOCKS 1. Legislation Food Laws and Regulations 2. Food Control Management 3. Official control Inspection Services 4. Laboratory system 5. Training 14
FOOD SAFETY STRATEGY ADDITIONAL BUILDING BLOCKS 6. Surveillance system Foodborne disease surveillance 7. Risk assessment reinforcement 8. Information, education, communication 9. Facilitation of GHP and HACCP principles implementation 10.Plan for upgrading of establishments 15
FOOD SAFETY STRATEGY For each building block Rationale Current situation Actions to be taken Annexes Action plan Timetable objectives and goals, activities responsibilities expected results/indicators 16
REINFORCING OFFICIAL CONTROL ON FOODSTUFFS PRELIMINARY AUDIT INSPECTION SERVICES LABORATORY DRAFTING A COUNTRY PROFILE PREPARATION OF A FOOD SAFETY STRATEGY LEGISLATION COMPETENT AUTHORITY INSPECTION SERVICES LABORATORY SHORT TERM Gap analysis Preparation procedures need assessment MEDIUM TERM drafting primary legislation training training LONG TERM drafting secondary legislation reorganisation proposal preparation of the official control plan support toward accreditation
AN EXAMPLE OBJECTIVES Competent Authorities roles definition 2. FOOD CONTROL MANAGEMENT Establishment of a leadership function and administrative structures with clearly defined responsibilities Separation between risk assessment and risk management Effective horizontal and vertical coordination Introduction of Audit principles Creation of an effective data management system Adequate management of crisis 18
AN EXAMPLE 2. FOOD CONTROL MANAGEMENT 2.5. Data management system, control plans and reporting RATIONALE Official controls shall be carried out according to control plans, which shall be drafted on the basis of comprehensive and reliable data A basic step to organize an efficient food control system is therefore the establishment of a data management system 19
AN EXAMPLE 2.5. Data management system, control plans and reporting ACTIONS TO BE TAKEN a. Development of a data management system for record keeping, collection, storage, analysis and distribution of data b. Development of a software for laboratories c. Development of a software for collecting data at Counties d. Preparation of a national official control program e. Implementation of a reporting system f. Preparation of a multiannual integrated control plan 20
AN EXAMPLE 3.1. Harmonisation of official controls ACTIONS TO BE TAKEN a. Preparation of a national plan for supervision, including number of controls, procedures, forms, documentation, action to be taken b. Development of procedures and guidelines for the supervision of inspectors and veterinarians c. Development of guidelines, procedures, check list, reporting rules for food inspectors d. Development of a specific tool for prioritization of controls 21
HARMONISATION OF LEGISLATION IN THE FRAMEWORK OF THE FOOD SAFETY STRATEGY ACTIONS TO BE TAKEN 1. Appointment of Working Group(s) 2. Training on international food safety standards and legislation 3. Review of the National Legal Framework 4. Identification of Harmonisation priorities 5. Identification of legislative instruments most suitable 6. Drafting and harmonisation plan (time table) 7. Preparation of gap analyses 8. Drafting new legislation (primary and secondary)
SUGGESTED APPROACH Avoid a desk approach and take carefully into consideration the situation in the field Evaluate the impact of new legislation implementation, establishing realistic deadlines Adopt specific strategies aimed at the implementation of the legislation: enforcement is essential, transposition is only the first step toward harmonisation Proactive involvement of stakeholders Avoid, as much as possible, to have a double level in food production: National consumer should have the same rights; at least: establish a framework for reaching the same standards
POSSIBLE SOLUTION Implementation of a multilateral TWINNING PROJECT Tool of collaboration between Institutions peer collaboration, not a one way assistance 24
THANK YOU! E-mail a.mancuso@izs.it 25