Agenda Item 4.3 b) | GF 01/12 | |||||||||||||||
FAO/WHO Global Forum of Food Safety Regulators Capacity Building and Technical Assistance
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Scientific Institutions |
Professional Association and their Chapter |
Trade Bodies |
National Institute of Nutrition (NIN) |
Nutrition Society |
FICCI/CII |
Central Food Technology Research Institute,CFTRI |
Association of Food Scientists & Technologists |
CIFTI |
Indian Toxicology Research Centre, ITRC |
Indian Dietetic Association |
Hotel Associations |
Home Science College |
Association of Catering Professionals |
Sectoral Bodies Eg. Halwais Association. |
There is certainly a much greater recognition now in developing countries of the importance of food safety. The initiation stage appears to have begun, if both individual countries and international agencies commit more funds and proper and systematic planning is done. But it is clear that our discussion in this Global Forum on Capacity Building will become meaningful only if there is an external commitment to pledge sufficient resources. We suggest the setting up of a Global Food Safety Fund which will have a much wider agenda and provide the wherewithal to WHO/FAO to provide that kind of assistance which will make a difference.
We now come to some priority specific areas for action based on the WHO draft Global Strategy for Food Safety Document and the ten-point Regional strategy for the South-East Asian Region.
The absence of reliable data on the burden of food borne disease impedes understanding about its public health importance and prevents the development of risk-based solutions to its management. Structures and systems must therefore be developed at Sub-national and national (and regional and international) levels to survey food borne disease and at national level to conduct risk assessments and implementation of risk management strategies. This is a new area requiring assistance. WHO should help in the preparation of a project for selected countries on a regional basis and for the setting up of regional sentinel sites. India already has institutions looking into disease surveillance. We are also approaching the World Bank for a Disease Surveillance Project. Therefore, additional assistance in India would be minimal. Countries could be assisted bilaterally too. Successful Projects could be replicated elsewhere.
For an effective foodborne disease surveillance system and, as a necessary foundation for good regulatory systems, it is essential to have a good laboratory structure. Unfortunately, this is a weak area in most developing countries. The Regional Strategy Document has identified the causes thus;
Over the years, WHO, FAO and other agencies have provided a lot of assistance in this area in India by way of supply of equipment to labs and training public analysts and chemists. In many labs these have been well utilized. In many not.
Here also the problem is multi-dimensional and needs to be accordingly addressed. One view is that there has been un co-ordinated external assistance for selective labs largely in the export sector. However, instruments supplied are too sophisticated, difficult to work and maintain in local conditions and require expensive external help. Therefore, it has been suggested that a needs analysis is required covering the appropriateness of the type of instruments, models, post-purchase maintenance, consumable use pattern etc. One way forward is to strengthen a few laboratories which are of international standard at minimal cost and use them as Regional Resource Centres for upgrading the quality of laboratories within a country or countries of a Region. They would also supply equipment, help in its maintenance, provide reference standards, consumables etc. to a selected network of labs. These centres could be both domestically funded and multilaterally assisted. They could also be used for Analytical Quality Assurance Programmes, as well as training programmes in analytical methods including GLP. A good example of optimum resource utilization through building networks of existing labs in the country, region and international level is the recent initiative of the IAEA, Vienna, (jointly funded by FAO and WHO) for various environmental contaminants.
At a more prosaic level, we are preparing to upgrade infrastructure in our labs through the Capacity Building Project. We are also trying to audit selected labs and prepare a plan for upgrades to lead to accreditation by our National Board. This programme could be assisted by donors and applied in many countries. Further, in times when instrumentation cycles are getting shorter, assistance for replacements must be considered, as well as introducing services for a fee principles.
Finally, special help is required for the upgrade of entire systems of certain labs for microbiological analysis in each country.
Another view is that developed importing countries increasingly require more sophisticated instruments and test methods. Therefore, there is a need to identify test methods which are practical and acceptable and do not require great sophistication in instrumentation. Once this is done, appropriate commodity assistance in kind could be given, apart from required software assistance in calibration, QA systems, SOPs, etc.
Traditionally, food safety has been checked through end product testing and culprits punished. This has numerous difficulties as the number of personnel available simply cannot police the market and punishment through complicated and time taking judicial procedures often comes to nothing. Increasingly, therefore, emphasis is on the preventive approach and to adopt HACCP principles and GMP, GHP etc. But for most developing countries these have been new concepts.
WHO/FAO have been generously providing technical assistance for training under HACCP. Both have carried out the training for trainers programme. This conceptually has much more sustainability. Consultants have also held HACCP Seminars during their visits. This appears to be an ad hoc exercise without much lasting benefit. Some countries like US/EU have also supported HACCP training activities, largely addressed to export areas. The EU is currently starting a programme with the Quality Forum of an important Industry Association. This will provide trained quality professionals but work is going to be restricted, to 20-25 SME's. They have built an institutional relationship with a well known HACCP training organization in UK. These partnerships through bilateral means is the kind of 'alliance building' which needs to be encouraged. Many Indian organizations both in private and public and export sector have also followed through, particularly the dairy, marine products, fruit and vegetable processing sectors. The problem is the huge and dispersed small and medium business sector and the larger unorganized tiny sector.
The approach has been seminar driven. Training has been the basic activity. We really do not know how much we have covered across and within sectors and with what success and depth. Clearly also activities are not integrated. We are convinced, therefore, that a National HACCP Training and Implementation Plan be formulated. This would involve survey of needs of different sectors; identification of the current status of trainers, trained personnel. Sectors of industry/units already having undergone training, evaluation of implementation and an analysis of feedback; preparation of a series of Manuals, Industry wise on HACCP principles; revision of course/training materials etc. Simultaneously, basic GMP GAP and GHP norms need to be prepared for all sectors (big, medium, small and tiny) and they need to be incorporated in some form as guidelines in the National Food legislation. Preparation of these generic, and later more specific, norms are of great priority.
This brings us to the problem of dissemination. One of the ways we are planning to do this is to develop a network of Institutes to adopt street food projects, as well as innovative ways of local dissemination of information through meetings of representatives of retailers and consumers etc. Further, all this should enter the course design of all academic and vocational institutes, teaching/training food service providers. This will immediately make this much more accessible and spread knowledge down stream. A recent analysis concluded that Universities having regular teaching programmes could play an active role in speeding HACCP in the country. On the fisheries side alone there are 8 Agricultural Universities/Fisheries colleges in the country.
Whether it is addressing HACCP or training requirements of regulatory officials, or teachers and students in the network mentioned above, there are huge communication needs as there are thousands of widely varying recipients. To ensure standardization, quality and easy reach, it is time that modern communication technology is utilized. How many Seminars will take place? Therefore, we must organize distance education courses, both through the traditional way and through the Web. This is a promising new area for future work of FAO/WHO. I am sure India can play an important role in helping prepare such courses.
A necessary simultaneous activity would be conducting regular investigational surveys to monitor levels and nature of contaminants in food products. These have been largely laboratory based in the past and used for standard formulation. They now need to be more market-based and results utilized for all the activities mentioned above. Further, not only food inspectors but students of the institutions mentioned could be involved in this exercise. We are working on preparation of a plan of action in this direction. This could be easily supported.
In many countries many excellent institutions exist who individually, and together, have a huge store of human, technical and financial resources available. These need to be brought into the system. It is not easy to build an all embracing food agency. Therefore, we have to strengthen these existing institutions so that each can play an important role in an identified sector or nature of activity. The only exercise required when the National Plan is prepared is to identify what strengthening is actually required. Assistance required may not be very substantial. This would also lead to development of intra and inter-country institutional networks. In fact, there is great potential for South-South co-operation in this area, which can obtain much greater value from a given amount of assistance. People in government departments come and go. These institutions as resource centres will remain. Institutional strengthening is crucial for sustainability. They will also then play an important role in Codex matters too.
The last decade has seen rapidly increasing global food trade and increased exports from developing countries. SPS measures have enabled many to access exacting markets and helped retain market access when entry requirements have changed. However, perhaps there is cause for concern. Lowering of tariffs and other barriers in developing countries are being accompanied by high standards and stringent requirements for food products in developed countries. So while their exports are threatened, those of developed countries are facilitated.
Since Codex standards are now benchmarks for international food trade, the standard setting process becomes critically important, particularly for developing countries. Most standards are being set based on requirements and information provided by developed countries. Technological developments are leading to detection of progressively lesser amounts of a contaminant. There is pressure to lower standards to those levels. Sometimes, these have no relationship with epidemiological impact and risk. Exposure assessment data is not always fully taken account of. Most importantly, such data from developing countries is rarely considered, yet standards become Global Standards. Doubts arise further when developed countries are seeking 'highest levels of protection' casting away the traditional concept of 'appropriate levels of protection'. This leads to the feeling that they are becoming non-tariff barriers and are adding great costs to developing country exports. The UN Secretary General had publicly referred to the cost to African exports of nuts to Europe because of the totally unrealistic existence of levels of aflatoxin of the EU.
Necessarily then questions arise whether developing countries are having their due say in the setting of standards and how can this be ensured. The other issue which arises is what is required to be done to ensure that these countries are able to meet standards where already set. This becomes the other context in which issues of capacity building and technical assistance have to be seen.
Over the last few years there has been talk of increasing participation of developing countries in the Codex process, but almost wholly restricted to increasing their physical participation in Codex meetings. India has been arguing that while this is important, though largely symbolic, much more important is to address their ability to take part fully in the standard setting process, the greatest constraint to which is lack of effective infrastructure at national levels for evaluation of draft standards. No doubt the extent, manner and quality of developing country participation has greatly increased, but much more needs to be done. A recurring contradiction in the approach of developed countries is that while the problems of effective participation are being recognized, and only partially addressed or remedied, the agenda is growing every day with increased sophistication and simultaneously attempted to push through on fast track basis. This is an important aspect of Capacity Building which requires assistance.
If countries are to be involved in the standard setting, data from developing countries and different regions has to be collected and incorporated. India has been repeatedly arguing this stand and Codex has accepted this in principle. The World Health Assembly had resolved in its 53rd Session in May 2000 that WHO make the largest possible use of information from developing countries in risk assessment for international standard setting. We, therefore, strongly welcome the statement incorporated in the draft WHO Global Food Safety Document which says:
"WHO will improve the methods of risk assessment for chemicals and microbiological hazards in food in order to provide accurate, Globally representative bases for standard setting by Codex. In regard to GEMS/Food databases, it will strive to obtain better data on food intake and on the level of contamination of food in developing countries to ensure that the risk characterizations provided to Codex are of Global significance."
This action brooks no delay. FAO/WHO's 'call for Data' or 'call for Experts' will not suffice. Data has to be collected if available somewhere in the system or otherwise generated. Assistance would also be required in identifying types of data, collection mechanism and documentation of data bases of both national and international standards formulation. This whole exercise, along with the risk assessment process, would itself be a capacity building exercise apart from generating the data.
We urge WHO/FAO to set up a Working Group of experts and representatives of some developing countries to explore what efforts at Capacity Building and financial assistance for generation of such data are required. The ideal mechanism is to identify Institutions in different regions, which will act as collaborating Institutions and become nodal points. These will be the same which we are proposing to strengthen in relation to domestic food safety systems. And it is experts of these Institutions which should be represented in the Group of Experts such as JECFA/JMPR etc. Transparency of experts lies in their being independent of any manufacturing interest not in involvement with generation of national-level data.
A necessary part of this exercise, as we collect the data, is a good hands on training on both qualitative and quantitative risk assessment covering chemical and microbiological hazards. Risk analysis remains an area of urgent assistance for Capacity Building. More seminars is not the answer. Dr. Rios had mentioned establishment of risk analysis units. We say put these in identified institutions. In addition Universities could be utilized. Training methodologies would need to change too - expert-supported practical applications.
This becomes an obvious area of action. India is currently implementing an FAO sponsored Project. This has the following elements:
This project is well designed and is expected to lead to measurable outcomes; strengthen Capacity and capability to respond to Codex issues; identify collaborative institutes; identify and address needs /gaps in this area; and draw up a long-term HACCP education Plan. This Project is expected to give sustainable benefits. It is hoped evaluation of its successes could lead to introduction of more Projects in other countries. In so far as South Asia is concerned, these local experts and expertise gained could be used to help other countries too.
The SPS and TBT Agreements have completely changed the environment of international food trade. The first requirement is for developing countries to fully understand their provisions and implications. Over the years, WTO has held many seminars and training programmes helping in substantial improvement in this understanding. However, not many know the nuances of how it is operating in practice in different areas, or in what manner advantages can accrue to developing countries. Therefore, there continues to be a case for more detailed dissemination of the Agreements and their working. It is also to be recognized that there is a continuous turnover of personnel dealing with this subject in different countries. Therefore, this training must be institutionalized at National and Regional levels. Secondly, training methodology needs to change to include hands on exercises based on actual examples and prepared case studies. If developing countries are not taking recourse to this assistance then there seems to be some fundamental lack in communication. Explicit possibilities with some specificity of issues of different kinds need to be developed by some experts. Perhaps a consumer friendly Web based course for these Agreements such as the WIPO Patents course, would be of great use. A large number of people in bureaucracy, in institutions and in the industry and elsewhere can directly access and become familiar with this subject. We recommend action on this immediately.
Capacity of countries to respond effectively could also improve by collection and dissemination of information of the kind of technical assistance which has or has not been provided by developed countries under Clause 9 of the SPS agreement. There is too little information, or perhaps too little assistance. In this regard, it is a general perception that this Clause has remained at best an endeavor clause without being fully operationalised. India spent about US$ 25m in adjusting to a country's requirements on marine products without any assistance. The experience of India's Export Inspection Council of trying to incorporate such provisions in Equivalence Agreements has not elicited much positive response. We are also told that there are many cases of rejections even when processing units follow GHP/HACCP and inspections and certifications are done. This area needs to be separately studied and required assistance identified.
Data is essential regarding individual import requirements for different products or sectors, or of individual importing countries, or specific international standards which are creating problems for developing countries. Data on standards; methods of sampling, inspections and tests; appeal procedures etc, could be readily made available on computerized databases. Further studies could suggest:
There are many experts or Institutions in many developing countries which can do this individually or in collaboration.
Another area is assistance in getting Equivalence Agreements on board. There is a serious difficulty in this area and little progress is being made in the direction of signing Equivalence Agreements. Equivalence determination is of great importance to trade facilitation. Therefore, some detailed attention has to be paid as to who can give what kind of assistance in this area. This is also desirable as it will directly link concerned institutions in both countries.
It is not easy to comment because of absence of information. The US/EU have provided a list of activities supported in different countries. They mostly relate to seminars by experts and some training. The EU has also indicated some activities which seem to go beyond workshops and actually are involved with introduction of SPS measures in different sectors. In both cases it appears that the primary emphasis is on seafood and fisheries and there are fruits and vegetables areas also. Therefore, these efforts perhaps directly relate to import of items of concern to these countries.
Discussions in the SPS Committee have shown that assistance:
The first step, therefore, must be diagnosis of the national situation to identify existing capacities and problems thereby identifying the best forms and medium of technical assistance which could be given by different agencies in a co-ordinated manner. This brings us back to the need for a National Action Plan whose part any Aid Project would then necessarily become.
The discussion in this paper leads us to the following conclusions: