Delegate's Report, 41st Session, Codex Committee on Food Hygiene
The United States believes the 41st Session of the Codex Committee on Food Hygiene (CCFH) was a productive Session with the Committee completing work on several items and initiating important new work items. The Committee:
- Completed work on development of an Annex to the Code of Hygienic Practice for Fresh Fruits and Vegetables on Leafy Green Vegetables Including Leafy Herbs, recommending adoption by the Codex Alimentarius Commission (CAC) at Steps 5/8.
- Completed work on development of a Code of Hygienic Practice for Pathogenic Vibrio Species in Seafood, recommending adoption by the CAC at Steps 5/8.
- Completed work on development of an Annex to Code of Hygienic Practice for Pathogenic Vibrio Species in Seafood on Control Measures for Vibrio Parahaemolyticus and Vibrio Vulnificus in Molluscan Shellfish, recommending adoption by the CAC at Steps 5/8.
- Agreed to a set of Proposed Draft Risk Analysis Principles and Procedures Applied by the Codex Committee on Food Hygiene and forwarded them to the Codex Committee on General Principles for review and likely subsequent adoption by the CAC.
- Continued work on the Draft Guidelines for the Control of Campylobacter and Salmonella Spp. in Chicken Meat
- Continued work on the Proposed Draft Code of Hygienic Practice for Control of Viruses in Foods.
- Agreed to new work on revision to the Code of Hygienic Practice for Collecting, Processing and Marketing of Natural Mineral Water.
- Agreed to new work on the revision to the Principles for the Establishment and Application of Microbiological Criteria for Foods.
The 41st Session of CCFH was attended by 205 participants representing 79 Member countries, one Member organization (the European Community (EC)), and eleven international intergovernmental and non-governmental organizations. The United States was represented by: the Delegate, Dr. Donald Zink, FDA Center for Food Safety and Applied Nutrition; Co-Alternate Delegates Dr. Kerry Dearfield, USDA Food Safety and Inspection Service, and Mr. Jack Mowbray, FDA Center for Food Safety and Applied Nutrition; eleven government advisors; and, two non-government advisors.
A summary of the results of the 41st Session of CCFH is given below. The full report of the Session can be found in ALINORM 10/33/13 on the Codex Website, www.codexalimentarius.net.
ANNEX ON LEAFY GREEN VEGETABLES INCLUDING LEAFY HERBS TO THE CODE OF HYGIENIC PRACTICE FOR FRESH FRUITS AND VEGETABLES
Prior to the 41st Session, in June, 2009, an electronic working group was held to review and discuss the leafy vegetables annex document line by line. The working group identified five recommendations that needed further discussion by the Committee, as follows:
- Remove "including herbs" from the annex title
- Encourage employees to notice and report symptoms of foodborne illness;
- Use the term "recirculated" rather than "recycled" to refer to post-harvest water that is reused and continually moving through a system;
- Develop and maintain a written food safety plan; and
- Rank irrigation water sources from lowest to highest risk.
The Committee carried out a paragraph-by-paragraph review of the document and made a number of technical changes to the document.
With respect to the five recommendations made by the Working Group, items 1-4 above were accepted by the Committee.
Regarding recommendation 5, ranking irrigation water sources in terms of risk, one Delegation asked that the ranking be moved from water for irrigation 184.108.40.206.1 to water for primary production, 220.127.116.11 since the quality of the water source for any primary production activity is important. The Delegation noted that the quality of the water source is important for all primary production activities. Several countries disagreed with ranking the water sources. Based on the work of an intra-session working group, the Committee reached a compromise new text for Section 18.104.22.168 (see Appendix II of the Report of the 41st Session which presents both the old and new texts).
Brazil requested that the scope of the annex be limited to bagged ready-to-eat leafy vegetables. The Committee disagreed and kept the scope as is. The remainder of the changes to the annex were generally to clarify specific provisions of the document.
The Committee completed work on the document and recommended its adoption by the Commission at Steps 5/8.
CODE OF HYGIENIC PRACTICE FOR PATHOGENIC VIBRIO SPECIES IN SEAFOOD
The Committee considered a document that had been well-developed by two physical working groups held since the last session of CCFH, including a working group held immediately prior to this Session of the Committee. At the physical working group held immediately prior to the Session, the U.S. made a presentation on "risk calculators" similar to the ones that are used in the U.S.
The working groups resolved the technical issues associated with the text. The Committee carried out a paragraph by paragraph review of the document in which only a few additional changes were made to the document. The Committee:
- Amended the text to indicate that a sodium chloride concentration of more than 10% could minimize growth or reduce levels of Vibrio spp.
- Clarified that food processing practices could used singly or in combination to control the growth of Vibrio spp.
- Clarified the labelling section to indicate that seafood at high risk of being contaminated with high levels of Vibrio spp. should be labeled to alert at-risk consumers.
- Clarified text in the labelling section directed to susceptible populations to indicate that seafood should be thoroughly cooked, rather than heated.
CCFH requested FAO and WHO to convene an Expert meeting to validate risk assessment models developed by the U.S. including growth rates of V. parahaemolyticus and V. vulnificus and to also recommend appropriate methods to monitor their levels. It is likely that the US will be requested to take a leadership role in these activities.
The Committee completed its work on the document and agreed to recommend its adoption by the Codex Alimentarius Commission at Steps 5/8.
ANNEX ON CONTROL MEASURES FOR VIBRIO PARAHAEMOLYTICUS AND VIBRIO VULNIFICUS IN MOLLUSCAN SHELLFISH TO THE CODE OF HYGIENIC PRACTICE FOR PATHOGENIC VIBRIO SPECIES IN SEAFOOD
This document on Control Measures for Vibrio Parahaemolyticus and Vibrio Vulnificus in Molluscan Shellfish, an Annex to the above noted document, Code of Hygienic Practice for Pathogenic Vibrio Species in Seafood, was also well developed through the same two physical working groups.
The working group meeting just prior to the Session resolved concerns regarding Part II of the Annex that created categories of "partially treated" bivalve mollusks. The Working Group agreed to remove sections of the Guideline indicating that consumers would be responsible for partial treatments to address the hazards posed by these pathogens.
The Committee carried out a paragraph-by-paragraph review of the Annex and made a few additional changes including the following:
- Modified the Scope section to clarify that bivalve molluscs consumed after a vibriocidal treatment were not covered by the document.
- Amended the definition of "post-harvesting process" to recognize that post-harvest treatment technologies might be developed, which can achieve reduction of V. parahaemolyticus and V. vulnificus to non-detectable levels while retaining the sensory characteristics of live bivalve molluscs.
- Deleted a table which included growth rates of V. parahaemolyticus and V. vulnificus populations in raw oysters in specific environmental conditions as it related to only certain regions of the world and, if applied to other regions, might provide inaccurate information.
The Committee completed its work on the Annex and agreed to recommend its adoption by the Codex Alimentarius Commission at Steps 5/8.
PROPOSED DRAFT GUIDELINES FOR THE CONTROL OF CAMPYLOBACTER AND SALMONELLA SPP. IN CHICKEN MEAT
The proposed draft guidelines were presented for consideration of advancing the document to Step 5 or Steps 5/8. The physical working group had last met in September 2009 and had agreed to a draft that reflected advice provided by a FAO/WHO technical expert group. At CCFH, there was general support for the document to date as well as the accompanying FAO/WHO (JEMRA) web-based risk management decision support tool.
However, during the general comment period, the European Commission (EC) stated they could not support a document including chemical interventions and proposed the document be returned to Step 2 until the FAO/WHO report on active chlorine became available and then reevaluated at the 42nd CCFH session. A lengthy discussion was held on this issue. The US delegation and delegations from many other countries opposed the EC position stating there was sufficient documentation and expert opinion to support forward movement of the document.
The committee, acknowledging a consensus would not be reached on this point, agreed to end further discussion of the document at this Session and established an electronic working group to further develop the document. New Zealand and Sweden will lead the effort to revise the document based on comments received at the 41st session.
The document was returned to Step 2 for redrafting via an electronic working group with subsequent circulation at Step 3 for country comments.
RISK ANALYSIS PRINCIPLES AND PROCEDURES APPLIED BY THE CODEX COMMITTEE ON FOOD HYGIENE
Codex General Subject Committees involved in risk analysis had been asked by the Codex Alimentarius Commission to develop guidance relating specifically to how each individual committee should undertake its risk analysis work. Previously this guidance had been developed by several Codex Committees including committees responsible for work in the areas of food additives, contaminants, pesticide residues and veterinary drug residues.
Similarly CCFH undertook the development of Risk Analysis Principles and Procedures Applied by the Codex Committee on Food Hygiene. The document contains sections on: preliminary risk management activities; risk assessment; risk management; risk communication; and, interaction between the risk manager (CCFH) and risk assessor (JEMRA). An electronic working group led by India had developed the document. To enable completion of the work on the text, the Committee held an intra-session physical working group led by India.
The Committee considered the revised document and carried out a paragraph-by-paragraph review. Few changes were made to the document developed by the intra-session working group. A minor movement of two paragraphs was done to clarify at which point in the process certain activities were carried out, recognizing that the risk analysis process was flexible. Additionally, when referencing microbiological metrics (including microbiological criteria, performance objectives, process criteria and food safety objectives), it was clarified that while CCFH could recommend the inclusion of microbiological criteria in Codex texts as a risk management tool, any reference to other metrics should qualify these entities only as enabling tools as these tools are specific to national governments and should not necessarily be mandated on an international level.
With the inclusion of these adjustments, the Committee completed its work on the document and agreed to forward it to the Codex Committee on General Principles for review and subsequently its adoption by the Codex Alimentarius Commission.
PROPOSED DRAFT CODE OF HYGIENIC PRACTICE FOR CONTROL OF VIRUSES IN FOODS
The document produced by the working group in March 2009, had been circulated for comments prior to the 41st Session of CCFH. A new title was proposed by the Netherlands delegation to better reflect the content of the document: "Guidelines on the Application of General Principles of Food Hygiene to the Control of Viruses in Food".
Extensive comments on the document, both editorial and technical, were submitted. Based on the comments, which expressed concern regarding a number of key points, the Committee carried out only a general discussion on the document.
The issues and concerns raised by delegations, both in written comments and interventions focused on the following areas.
- The overall structure of the document;
- The need for additional more detailed and specific information relating to:
- Use of different types of water for different stages from farm-to-fork
- Cleaning and disinfection;
- Hand washing;
- Availability and efficiency of validated intervention procedures;
- Return of food workers to work after symptoms disappear;
- Better labeling regarding traceability of bivalve molluscs;
- Deletion of the annex on Ready-To-Eat foods as its limited additional information could be included in the main text;
- The need for additional information for the annex on bivalve molluscs
- The need to ensure the annex on fresh produce is consistent with the leafy green annex.
The Committee agreed to return the document to Step 2 for further work. The committee agreed to establish a physical working group led by the Netherlands to meet in the Netherlands March 25-26, 2010, to revise the document based on comments received. The document would then be circulated for comments at Step 3, and considered by the next session of the CCFH.
Endorsement of the Hygiene Provisions of Commodity Standards
The Committee endorsed the hygiene provision of the Draft Code of Practice for Fish Products (sections on Lobsters and Crabs) at Step 8, and Draft Standard for Sturgeon Caviar, also at Step 8.
The Committee did not endorse the hygiene provisions of the Proposed Draft Standard for Smoked Fish, Smoke-Flavored Fish and Smoke Dried Fish and Proposed Draft Standard for Fish Sauce, all at Step 5, noting concerns raised about the lower temperature at which Clostridium botulinum could produce toxin and about aerobic packaging as a safe control option. The Committee agreed to further consider this matter at its next Session, which would occur prior to the next Session of the Codex Committee on Fish and Fishery Products.
Inconsistencies Arising in Documents Elaborated by the CCFH and Adopted by the Commission
The Committee considered a document prepared by the Codex Secretariat which presented a number of recommended editorial changes to Codex texts previously developed by CCFH. The changes related primarily to correcting references, titles, or section headings to Codex texts included in the documents.
The Committee agreed to all editorial amendments which will be forwarded to the Codex Alimentarius Commission for approval.
While accepting all recommended editorial amendments, the Committee noted that there were inconsistencies in the way some Codex texts, in particular the General Principles of Food Hygiene, were referenced and agreed that it was not possible to take an affirmative decision on whether to reference by title or section only, and that this would be considered on a case-by-case basis.
Recommended New Work for CCFH
Based on the recommendations of Working Group for Establishment of CCFH Work Priorities, CCFH agreed to undertake two new items of work, as follows:
- Revision to the Code of Hygienic Practice for Collecting, Processing and Marketing of Natural Mineral Waters (CAC/RCP 33-1985). The Committee agreed to have Switzerland lead the work and a physical working group will be held to carry out the initial revision. The United States will be a participant in this work.
- Revision to the Principles for the Establishment and Application of Microbiological Criteria for Foods (CAC/GL 21-1997). The Committee agreed to have Finland and Japan serve as co-leads for this work with a physical working group established to carry out the initial revision. The United States will be a participant in this work.
Project documents were developed and approved for both new work items, and will be considered by the next Session of the Codex Alimentarius Commission.
NEXT SESSION OF CCFH
The 41st Session of CCFH is tentatively set for November 29 - December 3 in Uganda.