FAO/WHO Global Forum of Food Safety Regulators
Marrakesh, Morocco, 28 - 30 January 2002
The Current Status of Consumer Participation in Food Safety Risk Analysis,
and Opportunities for Improvements
24 Highbury Crescent, London N5 1RX, UK
Tel: (+44) 20 7226 6663
Fax: (+44) 20 7354 0607
Email: [email protected]
SUMMARY
Consumers International has participated in Codex work as an observer for three decades, and notes the importance of ongoing efforts by the Codex Commission to improve the participation of consumers in its activities. Sound goals have been established, but the details of implementation have yet to be worked out. Data need to be collected at regular intervals on objective measures to track progress in consumer participation at the national and international level. Some governments are more advanced than others in terms of the extent and mechanisms through which they facilitate consumer participation in their food safety risk analysis. Through forums such as this one and Codex Regional Coordinating Committees, successful experiences can be shared and perhaps, more widely adopted. In order to improve the quality of consumer participation, consumer NGOs should be given opportunities to take part in risk analysis training and similar workshops carried out by international agencies and national governments. The risk assessment process, which has traditionally been closed to observers, should also be more open and transparent; bringing invited consumer participants into that process could both improve the results and add to the credibility of risk assessments.
INTRODUCTION
Consumers International has actively participated in international food safety risk analysis, as an observer at meetings of the Codex Alimentarius Commission and its committees, and as an invited participant at other international events, since about 1970. Member organisations of CI, which now number over 270 in more than 120 countries, have been active voices for consumers in their own national food safety processes for even longer, in many cases. Throughout that long and active history, a central focus of CI and its members has been to ensure that consumers have appropriate roles and that the consumer voice is heard in the food safety risk analysis process.
The Codex Alimentarius Commission has commendably and effectively committed itself to creating an open and inclusive process, in which consumer participation is solicited and welcomed. Over the years, Codex relations with observer INGOs, including those from the consumer sector, have been a model for other international bodies. Codex's parent agencies, the FAO and WHO, have also worked very hard to ensure that the consumer voice is heard and have tried to include consumer participants in many high-level expert consultations and conferences. Consumers International thanks the agencies and their member governments for these efforts.
Nevertheless, we see some opportunities to expand and improve both the amount and the quality of consumer participation in food safety risk analysis.
OPPORTUNITIES FOR FURTHER PROGRESS AT THE INTERNATIONAL LEVEL
At its 23rd session, in 1999, the Codex Commission adopted a far-reaching set of goals and resolutions aimed at improving consumer participation in Codex. The vision there articulated was sound; much of the implementation, however, still lies ahead.
Among the goals identified by the Commission in 1999 were the establishment of some benchmarks to measure the state of consumer participation in Codex and track progress from year to year. A "check list" was to be developed, covering items such as numbers of countries that have established a National Codex Contact Point, number of countries whose National Codex Committees include representatives of consumer organisations, and other objective indices of consumer participation in the process. Details of where, how and by whom these data were to be collected and a "baseline" report on the current status were expected to be discussed at the 2001 Codex Commission meeting. But the agenda for that meeting was crowded, and the Commission was unable to devote time to discussion of consumer participation.
Consumers International hopes the Commission and its member governments will not lose track of this task, which is an important issue for consumers. A reporting system for tracking progress still needs to be set up, probably at the Regional Codex Coordinating Committee level. Such a tracking system will enable progress to be measured, and can also provide examples of successes that can be shared with other regions.
To improve the quality of consumer participation in food safety risk analysis, national consumer organisations should be invited to participate in Codex training and related workshops, organised by FAO, WHO and other agencies, from time to time in various regions of the world. This was recommended by the Codex Commission in 1999, and endorsed by a resolution at the World Congress of Consumers International, held in November 2000. Despite general agreement on the desirability of such training, few instances have occurred yet in which it has been offered to consumers. Consumers International urges host governments and international agencies to seek ways to include consumer NGOs in future training sessions. Consumers International offers to assist in identifying and contacting candidate organisations for such training.
Another step that would help improve consumer participation at the international level would be to make the risk assessment components of Codex work more open and transparent. At present, expert bodies that provide risk assessments for Codex meet in closed sessions that recognized FAO and WHO observer INGOs are not allowed to attend. Opening this process up to observers would enhance the credibility of the resulting risk assessments with the public, and could improve the quality of the risk assessments. Some countries, including the U.S. and the U.K., have included consumer representatives on scientific advisory committees and expert bodies, with beneficial results. We hope those countries will share their experiences at this forum, and that this healthy approach will be more widely followed by national and international risk assessment authorities.
OPPORTUNITIES FOR FURTHER PROGRESS AT THE NATIONAL LEVEL
Based on surveys of Consumers International's members in various regions of the world, consumers' ability to participate in food safety risk management at the national level varies considerably from country to country. This variability is due both to the differing capabilities of CI members in different countries, and to wide differences in national food safety legislation and government practices. The Codex Commission has reached similar conclusions. Many, but not all, member governments have established a functioning national Codex Contact Point, have set up a National Codex Committee, routinely hold public meetings at which national positions on issues pending before Codex bodies are discussed with consumers and other interested parties, and have taken other steps recommended by the Codex Commission to encourage public participation in national Codex work. In short, governments are at different stages in developing their national and international food safety risk management systems, and in building public participation into their process.
Consumers International sees the effort by Codex to keep track of progress in consumer participation in its work as also an important means for encouraging governments that still need to improve their structures and processes for consumer participation. That is one reason why we consider it so important that the Codex Commission earnestly pursues this item on its work agenda, fully recognizing that this is but one of many issues on Codex's agenda that are important to consumers.
We also believe that forums such as this one offer an invaluable opportunity for nations to share experiences and discuss successful and perhaps not-so-successful approaches to improving consumer participation in their food safety work. We look forward to hearing the paper presented by Brazil. We also bring participants' attention to some recent developments in New Zealand, and hope officials from New Zealand will be present to discuss them.1 We applaud the willingness of national governments to experiment and explore new mechanisms for including consumer voices in the food safety policymaking process, and hope that through forums such as this one, some positive new approaches will be shared and applied more widely.
A CONCLUDING GENERAL OBSERVATION
The session at this Forum devoted to Risk Management included a discussion of ways to integrate food safety approaches "throughout the food chain." Consumers are mindful of the role they play as risk managers, through careful shopping, proper cooking, attention to hygiene in the kitchen, and other activities. Indeed, for some relatively small risks, governments may decide that the foods involved are "safe enough" to be marketed, and in effect delegate risk-management responsibility to consumers, by allowing the foods to be sold and leaving it up to consumers to decide whether to eat them or not.
While most consumers might prefer that there be no safety questions about any foods on the market, many are willing to take the responsibility to act as their own risk managers for certain food safety issues. However, when that is the case, consumers cannot fulfill their role properly unless foods are fully and accurately labelled in ways that will support informed consumer choices.
Consumers International expects governments that elect to delegate risk-management responsibility to consumers, for example on issues such as the acceptability of genetically modified foods, to require mandatory labelling in such cases, so that the consumer's right and ability to choose to accept risks is preserved.
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