Delegate's Report, 19th Session, Codex Committee on Food Import and Export Inspection and Certification Systems
The United States is pleased with the outcome of the 19th Session of the Codex Committee on Food Import and Export Inspection and Certification Systems (CCFICS). The Committee made good progress in progressing a key document, Proposed Draft Principles and Guidelines for National Food Control Systems. The Committee also:
- Requested the United States to develop a Discussion Paper on performance metrics for assessment of national food control systems.
- Agreed to further develop a proposal to revise the existing Codex Principles and Guidelines for the Exchange of Information in Food Safety Emergency Situations (CAC/GL 19-1995) with a Discussion Paper to be developed by the United States.
- Considered undertaking new work to establish a harmonized questionnaire for importing countries to use when undertaking an audit of an exporting country's food control system (or component parts thereof).
The 19thSession of CCFICS was attended by approximately 200 delegates from approximately 55 Member countries, one Member organization (the European Union), and five international intergovernmental and non-governmental organizations. The United States was represented by: the U.S. Delegate, Mary Stanley, USDA Food Safety and Inspection Service; the U.S. Alternate Delegate, Michael Wehr, U.S. Food and Drug Administration; two governmental advisors; and one non-governmental advisor.
A detailed summary of the discussions on both of these items and on other matters considered by the Committee is presented below. The full report of the Session can be found in REP 12/FICS on the Codex website, www.codexalimentarius.org.
Principles and Guidelines for National Food Control Systems
At its 17th Session, CCFICS agreed to undertake new work to develop a set of principles and guidelines for national food control systems. Prior work included significant discussion on the document at the Committee's 18th (2010) Session and a physical working group held in Brazil in March, 2011. Those efforts resulted in a document containing a relatively well-developed set of principles, initial general agreement on sections relating to design and implementation of a national food control system, and substantial delineation of the elements for these sections. The document was submitted for country comments with countries and observer organizations submitting over 90 pages of comments on both the technical content and basic structure of the document.
This session of CCFICS spent considerable time reaching a consensus on the introductory information, objective, and principles as well as reaching agreement on the structure and elements that will be included as practical guidance to assist national governments on the development, operation, evaluation, and improvement of national food control systems. It was emphasized that the guidance is intended both for developed and developing countries and that its content would relate both to policy and technical/operational components.
The Committee considered in-depth the proposed principles and reached agreement on principles previously incorporated into the text: protection of consumers; whole food chain approach; transparency; roles and responsibilities; consistency and impartiality; use of risk-based, science-based, and evidence based decision-making; cooperation between multiple authorities; use of preventative measures; self-assessment and review; and recognition of systems. The Committee agreed to add three other principles: legal foundation, harmonization, and sufficient resources.
The Committee considered the basic framework for the design and operation of a national food control system. CCFICS agreed that the framework should consist of four main elements: policy-setting; system design; implementation; and monitoring and system review. The Committee agreed to a diagrammatic means to reflect this framework. Subsequently, the Committee spent a substantial amount of time reviewing the current document and the lengthy comments received, restructuring the document as needed and reaching general agreement as to the likely content of each section.
Recognizing that consensus had been reached on the introduction, objective, and principles, the Committee forwarded these sections for adoption at Step 5 by the Codex Alimentarius Commission at its 2012 Session. The remaining sections (policy-setting, system design, implementation, monitoring/review) were returned to Step 2 for redrafting. CCFICS will hold a physical working group tentatively scheduled for the second quarter of 2012 to carry out the redrafting.
Among other things, the Committee considered specific proposals originating from an electronic working group of the Codex Ad-Hoc Intergovernmental Task Force on Animal Feeding to take "feed" and "feeding" into account in the scope and content of two Codex texts, the Principles and Guidelines for the Exchange of Information in Food Safety Emergency Situations (CAC/GL 19-1995) and the Guidelines for the Exchange of Information Between Countries on Rejections of Imported Foods (CAC/GL 25-1997). CCFICS agreed that further thought regarding the proposals was needed before the inclusion of feed into these two documents and referred the matter to work to be led by the United States to develop a Discussion Paper considering broader revisions to these two documents (see Proposed New Work below).
The Committee considered a proposal from the Codex Committee on Fish and Fishery Products to amend the Codex Generic Model Official Certificate to incorporate attestations directly related to fish/fishery products. The Committee referred the issue to a discussion relating to attestations (see below).
Proposed New Work
An APEC Export Certificate Roundtable, held prior to the last (18th) Session of CCFICS, suggested that it may be helpful for CCFICS to consider expanding the extent of guidance on attestations contained in the Codex Guidelines for Design, Production, Issuance and Use of Generic Official Certificates (CAC/GL 38-2001). The United States prepared a Discussion Paper for this Session of CCFICS. The paper requested CCFICS to consider four specific questions:
- Are principles relating to attestations sufficient or should CCFICS develop additional guidance?
- If additional guidance is needed, what would be the nature of this guidance?
- With respect to principles, is there a need for additional principles relating to attestations beyond that provided in Note 16 of the Annex to the Codex Guidelines for Design, Production, Issuance and use of Generic Official Certificates (CAC/GL 38-2001)?
- How should knowledge, experience, and confidence influence the need for attestations?
The Committee generally agreed that new work on attestations was not needed at this time.
The Committee, in the context of this agenda item, also considered the issue of the Codex Committee on Fish and Fishery Products recommendation for additional guidance relating to fish/fishery product attestations (see Other Matters above). CCFICS concluded that it was premature to consider the inclusion of the CCFFP proposals into the Codex Generic Model Official Certificate.
Costa Rica submitted a proposal to establish a harmonized questionnaire for use by an importing country when undertaking an audit of an exporting country. The Committee generally agreed to the need for this work but requested Costa Rica to further develop the subject in a Discussion Paper for consideration by the next Session of CCFICS.
The United States submitted a Discussion Paper on Performance Measures to Evaluate National Food Control Systems. Two types of indicators were proposed: regulatory performance indicators to determine the effectiveness of the national food control system in achieving food safety, food suitability and technical outcomes; and operational performance measures to demonstrate that inspection activities were carried out according to established policy. Several delegations supported the proposal; other delegations, while not opposing the concept and need for the work, indicated that it should wait until the National Food Control System document was complete or at least further along. The committee agreed that the proposed work was premature and requested the United States to revise the Discussion Paper, providing greater detail and examples of performance metrics and taking into account responses to a questionnaire that would be prepared by the United States and circulated to countries requesting information on how metrics are used to assess and manage their national food control systems. The subject will be reconsidered at the next Session of CCFICS.
Revision of Principles and Guidelines for the Exchange of Information in Food Safety Emergency Situations (CAC/GL 19-1995)
The International Dairy Federation submitted a proposal for new work that would revise the existing Codex Principles and Guidelines for the Exchange of Information in Food Safety Emergency Situations (CAC/GL 19-1995) to provide additional guidance on: (1) roles and responsibilities of the various parties involved in food safety emergency situations (governments, industry, consumers); (2) the processes used in investigating and resolving food safety emergency situations; and (3) communications required during food safety emergency situations. Many delegations supported the work but noted that the proposal lacked clarity and needed revision. The Committee agreed that the United States would revise the paper for reconsideration at the next Session of CCFICS. Additionally the committee agreed that the revision would include: (a) consideration of whether the Codex Guidelines for the Exchange of Information Between Countries on Rejections of Imported Foods should be included in the revision, perhaps combining the two documents (handling both rejections and food safety emergency situations); and (b) consideration of the incorporation of "feed" and "feeding" into the Principles and Guidelines for the Exchange of Information in Food Safety Emergency Situations and the Guidelines for the Exchange of Information Between Countries on Rejections of Imported Foods (see Other Matters above).
Next Session of CCFICS
The 20th Session of CCFICs is tentatively scheduled for February 18-22, 2013.