5. STRENGTHENING NATIONAL FOOD CONTROL SYSTEMS (2023)

5.1 Principles of Food Control: Issuesfor Consideration

When seeking to establish, update, strengthen or otherwiserevise food control systems, national authorities must take into consideration anumber of principles and values that underpin food control activities, includingthe following:

• Maximizing riskreduction by applying the principle of prevention as fully as possiblethroughout the food chain;

• Addressing the farm-to-tablecontinuum;

• Establishing emergency procedures for dealing with particular hazards (e.g.recall of products);

• Developing science-based foodcontrol strategies;

• Establishing priorities basedon risk analysis and efficacy in risk management;

• Establishing holistic, integrated initiatives which target risks and impact oneconomic well-being; and

• Recognizing that food control is a widely shared responsibility that requirespositive interaction between all stakeholders.

Certain key principles and related issues are discussedbelow.

(a) Integrated farm-to-tableconcept

The objective of reduced risk can be achieved most effectivelyby the principle of prevention throughout the production, processing andmarketing chain. To achieve maximum consumer protection it is essential thatsafety and quality be built into food products from production through toconsumption. This calls for a comprehensive and integratedfarm-to-table approach in which the producer, processor,transporter, vendor, and consumer all play a vital role in ensuring food safetyand quality.

It is impossible to provide adequate protection to theconsumer by merely sampling and analysing the final product. The introduction ofpreventive measures at all stages of the food production and distribution chain,rather than only inspection and rejection at the final stage, makes bettereconomic sense, because unsuitable products can be identified earlier along thechain. The more economic and effective strategy is to entrust food producers andoperators with primary responsibility for food safety and quality. Governmentregulators are then responsible for auditing performance of the food systemthrough monitoring and surveillance activities and for enforcing legal andregulatory requirements.

Food hazards and quality loss may occur at a variety of pointsin the food chain, and it is difficult and expensive to test for their presence.A well structured, preventive approach that controls processes is the preferredmethod for improving food safety and quality. Many but not all potential foodhazards can be controlled along the food chain through the application of goodpractices i.e. good agricultural practices (GAP), good manufacturingpractices (GMP), and good hygienic practices (GHP).

An important preventative approach that may be applied at allstages in the production, processing and handling of food products involves theHazard Analysis Critical Control Point system (HACCP). The principles of HACCPhave been formalised by the Codex Committee on FoodHygiene[1], and provide a systematic structure tothe identification and control of foodborne hazards. Governments shouldrecognize the application of a HACCP approach by the food industry as afundamental tool for improving the safety of food.

(b) Risk Analysis

The Codex Alimentarius Commission defines risk analysis as aprocess composed of three components:

• Riskassessment - a scientifically based process consisting of the followingsteps: (i) hazard identification; (ii) hazard characterization; (iii) exposureassessment; and (iv) risk characterization.

• Risk management - the process, distinct from risk assessment, ofweighing policy alternatives, in consultation with all interested parties,considering risk assessment and other factors relevant for the health protectionof consumers and for the promotion of fair trade practices, and, if neededselecting appropriate prevention and control options.

• Risk communication - the interactive exchange of information andopinions throughout the risk analysis process concerning hazards and risks, riskrelated factors and risk perceptions, among risk assessors, risk managers,consumers, industry, the academic community and other interested parties,including the explanation of risk assessment findings and the basis of riskmanagement decisions.

Risk analysis is well established for chemical hazards, andFAO and WHO are now extending the experience and expertise developed from riskanalysis of chemical hazards to that of microbiological hazards.

Risk analysis must be the foundation on which food controlpolicy and consumer protection measures are based. While not all countries mayhave sufficient scientific resources, capabilities, or data to carry out riskassessments, it may not even be necessary in all cases to generate local datafor this purpose. Instead countries should make full use of the internationaldata and expertise as well as data from other countries that are consistent withinternationally accepted approaches. Risk assessments carried out at theinternational level by JECFA, JMPR (See Annex 7), and other expert bodies areparticularly useful. Developing countries should take a pragmatic approach anddevelop a cadre of scientists to interpret such data and assessments, and to usethis information for the development of national food controlprogrammes.

Codex standards take into account risk assessments carried outat the international level and are accepted as scientifically valid under theSPS Agreement. Hence their adoption and implementation within national foodcontrol systems is encouraged.

Risk management should take into account the economicconsequences and feasibility of risk management options, and recognize the needfor flexibility consistent with consumer protection requirements.

(c) Transparency

A food control system must be developed and implemented in atransparent manner. The confidence of consumers in the safety and quality of thefood supply depends on their perception of the integrity and effectiveness offood control operations and activities. Accordingly, it is important that alldecision-making processes are transparent, allow all stakeholders in the foodchain to make effective contributions, and explain the basis for all decisions.This will encourage cooperation from all concerned parties and improve theefficiency and rate of compliance.

Food control authorities should also examine the manner inwhich they communicate food safety information to the public. This may take theform of scientific opinion on food safety matters, overviews of inspectionactivity, and findings on foods implicated in foodborne illnesses, foodpoisoning episodes, or gross adulteration. All this could be considered as apart of risk communication to enable consumers to better understand the risksand their responsibilities for minimizing the impact of foodbornehazards.

(d) Regulatory ImpactAssessment

When planning and implementing food control measures,consideration must be given to the costs of compliance (resources, personnel,and financial implications) to the food industry, as these costs are ultimatelypassed onto consumers. The important questions are: Do the benefits ofregulation justify the costs? What is the most efficient management option?Export inspection systems designed to assure the safety and quality of exportedfoods, will protect international markets, generate business and secure returns.Animal and plant health measures improve agricultural productivity. In contrast,food safety is an essential public health goal and may impose costs onproducers, yet investments in food safety may not be immediately rewarded in themarket place.

Regulatory impact assessments (RIA) are of increasingimportance in determining priorities and assist food control agencies inadjusting or revising their strategies to achieve the most beneficial effect.They are, however, difficult to carry out. Two approaches have been suggestedfor determining cost/benefit of regulatory measures in food safety:

• Theoretical modelscan be developed to estimate willingness to pay (WTP) for reduced risk ofmorbidity and mortality; and

• Cost of illness (COI)covering lifetime medical costs and lost productivity.

Both approaches require considerable data for interpretation.COI estimates are perhaps easier for policy makers to understand and have beenwidely used to justify measures for food control, even though they do notmeasure the full value of risk reduction. Not surprisingly, it is easier toperform a RIA for an export inspection intervention, than for regulatory policywhich achieves a public health outcome.

5.2 Developing a National Food ControlStrategy

The attainment of food control system objectives requiresknowledge of the current situation and the development of a national foodcontrol strategy. Programmes to achieve these objectives tend to be countryspecific. Like socioeconomic considerations, they are also influenced by currentor emerging food safety and quality issues. Such programmes also need toconsider international perceptions of food risks, international standards, andany international commitments in the food protection area. Therefore, whenestablishing a food control system it is necessary to systematically examine allfactors that may impinge upon the objectives and performance of the system, anddevelop a national strategy.

(a) Collection ofInformation

This is achieved through the collection and collation ofrelevant data in the form of a Country Profile (See Annex 8). This dataunderpins strategy development, with stakeholders reaching consensus onobjectives, priorities, policies, roles of different ministries/agencies,industry responsibilities, and timeframe for implementation. In particular,major problems associated with the control and prevention of foodborne diseasesare identified so that effective strategies for the resolution of these problemscan be implemented.

The profile should permit a review of health and socioeconomicissues impacting on foodborne hazards, consumers concerns, and the growth ofindustry and trade, as well as identification of the functions of all sectorswhich are directly and indirectly involved in ensuring food safety and qualityand consumer protection. The collection of epidemiological data on foodborneillness is an indispensable component of a country profile and should be donewhenever possible.

(b) Development ofStrategy

The preparation of a national food control strategy enablesthe country to develop an integrated, coherent, effective and dynamic foodcontrol system, and to determine priorities which ensure consumer protection andpromote the country's economic development. Such a strategy should providebetter coherence in situations where there are several food control agenciesinvolved with no existing national policy or overall coordinating mechanism. Insuch cases, it prevents confusion, duplication of effort, inefficiencies inperformance, and wastage of resources.

Devising strategies for food control with clearly definedobjectives is not simple, and the identification of priorities for publicinvestment in food control can be a challenging task. The strategy should bebased on multi-sectoral inputs and focus on the need for food security, andconsumer protection from unsafe adulterated or misbranded food. At the same timeit should take into consideration the economic interests of the country inregard to export/import trade, the development of the food industry, and theinterests of farmers and food producers. Strategies should use a risk basedapproach to determine priorities for action. Areas for voluntary compliance andmandatory action should be clearly identified, and timeframes determined. Theneed for human resource development and strengthening of infrastructure such aslaboratories should be also considered.

Certain types of food control interventions require largefixed capital investments in equipment and human resources. While it is easierto justify these costs for larger enterprises, imposing such costs on smallerfirms who may coexist with larger enterprises may not be appropriate. Thereforethe gradual phasing in of such interventions is desirable. For example,countries may allow small enterprises longer periods of time to introduceHACCP.

The strategy will be influenced by the country's stage ofdevelopment, the size of its economy, and the level of sophistication of itsfood industry. The final strategy should include:

• A nationalstrategy for food control with defined objectives, a plan of action for itsimplementation, and milestones;

• Development of appropriate food legislation, or revision of the existinglegislation to achieve the objectives defined by the nationalstrategy;

• Development or revision of food regulations, standards and codes of practice aswell as harmonizing these with international requirements;

• A programme for strengtheningfood surveillance and control systems;

• Promotionof systems for improving food safety and quality along the food chaini.e. introduction of HACCP-based food control programmes;

• Development and organization of training programmes for food handlers andprocessors, food inspectors, and analysts;

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• Enhancedinputs into research, foodborne disease surveillance, and data collection, aswell as creating increased scientific capacity within the system; and

• Promotion of consumereducation and other community outreach initiatives.

5.3 Strengthening OrganizationalStructures for National Food Control Systems

Given the wide scope of food control systems, there are atleast three types of organizational arrangements that may be appropriate at thenational level. These are:

• A system based onmultiple agencies responsible for food control - Multiple AgencySystem;

• A system based on a single,unified agency for food control - Single Agency System;

• A system based on a nationalintegrated approach - Integrated System.

(a) Multiple AgencySystem

While food safety is the foremost objective, food controlsystems also have an important economic objective of creating and maintainingsustainable food production and processing systems. In this context, foodcontrol systems play a significant role in the following:

• Ensuring fairpractices in trade;

• Developing the food sector ona professional and scientific basis;

• Preventing avoidable lossesand conserving natural resources; and

• Promoting the country's exporttrade.

The systems that deal specifically with these objectives canbe sectoral i.e. based upon the need for development of the particularsector such as fisheries, meat and meat products, fruit and vegetables, milk andmilk products. These systems can be mandatory or voluntary, and put into effecteither through a general food law or a sectoral regulation. Examplesinclude:

• An exportinspection law that identifies foods to be covered for mandatory exportinspection prior to export; or offers facilities for voluntary inspection andcertification for exporters.

• Specificcommodity inspection regulations, such as for fish and fish products, meat andmeat products, or fruit and vegetable products which are implemented bydifferent agencies or ministries given this mandate under relevantlaw(s).

• Regulatedsystems for grading and marking of fresh agricultural produce which go directlyfor sale to the consumer or as raw material for industry. They are mostlyconfined to quality characteristics so that the producer gets a fair return forhis produce and the buyer is not cheated.

Where sectoral initiatives have resulted in the establishmentof separate food control activities, the outcome has been the creation ofmultiple agencies with responsibilities for food control. Typically, under sucharrangements the food control responsibilities are shared between GovernmentMinistries such as Health, Agriculture, Commerce, Environment, Trade andIndustry, and Tourism, and the roles and responsibilities of each of theseagencies are specified but quite different. This sometimes leads to problemssuch as duplication of regulatory activity, increased bureaucracy,fragmentation, and a lack of coordination between the different bodies involvedin food policy, monitoring, and control of food safety. For example, theregulation and surveillance of meat and meat products may be separate from foodcontrol undertaken by a Ministry of Health. Meat inspection is often done byMinistry of Agriculture or primary industry personnel who undertake allveterinary activities, and the data generated may not be linked to public healthand food safety monitoring programmes.

Food control systems may also be fragmented between national,state and local bodies, and the thoroughness of implementation depends upon thecapacity and the efficiency of the agency responsible at each level. Thusconsumers may not receive the same level of protection throughout the countryand it may become difficult to properly evaluate the effectiveness ofinterventions by national, state or local authorities.

While multiple food control agencies may be the norm, theysuffer from serious drawbacks including:

• Lack of overallcoordination at national level;

• Frequent confusion overjurisdiction and resultant inefficiencies in performance;

• Differences in levels ofexpertise and resources and hence uneven implementation;

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• Conflictbetween public health objectives and the facilitation of trade and industrydevelopment;

• Limited capacity forappropriate scientific inputs in decision-making processes;

• Lack ofcoherence leading to over-regulation or time gaps in adequate regulatoryactivity; and

• Reductions in the confidence of domestic consumers and foreign buyers in thecredibility of the system.

During the preparation of a national food control strategy, itis important to consider the type and size of the organization(s) that arenecessary to implement the strategy. It is often not possible to have a singleunified structure or an integrated food control system, due to varioushistorical and political reasons. In such cases, it is necessary for thenational food control strategy to clearly identify the role of each agency toavoid duplication of effort and to bring about a measure of coherence amongthem. It should also identify areas or segments of the food chain which requirespecial attention and need additional resources for strengthening.

(b) Single Agency System

The consolidation of all responsibility for protecting publichealth and food safety into a single food control agency with clearly definedterms of reference has considerable merit. It acknowledges the high prioritythat Government places in food safety initiatives and a commitment to reducingthe risk of foodborne disease. The benefits that result from a single agencyapproach to food control include:

• Uniformapplication of protection measures;

• Ability to act quickly toprotect consumers;

• Improved cost efficiency andmore effective use of resources and expertise;

• Harmonization of foodstandards;

• Capacityto quickly respond to emerging challenges and the demands of the domestic andinternational marketplace; and

• Theprovision of more streamlined and efficient services, benefiting industry andpromoting trade.

While a national strategy helps to influence both thelegislation and the organizational structure for enforcement, it is not possibleto recommend a single organizational structure that will universally meet therequirements and resources of every country's socioeconomic and politicalenvironment. The decision has to be country specific and all stakeholders shouldhave the opportunity to provide inputs into the development process.Unfortunately, there are often few opportunities for countries to build a newfood control system based on a single agency.

(c) Integrated System

Integrated food control systems warrant consideration wherethere is desire and determination to achieve effective collaboration andcoordination between agencies across the farm-to-table continuum. Typically, theorganization of an integrated food control system would have several levels ofoperation:

Level 1: Formulation of policy, risk assessment andmanagement, and development of standards and regulations.

Level 2: Coordination of food control activity,monitoring, and auditing.

Level 3: Inspection, and enforcement.

Level 4: Education and training.

In reviewing and revising their food control systems,governments may wish to consider a model which calls for the establishment of anautonomous national food agency which is responsible for activities at Levels 1and 2, with existing multi-sectoral agencies retaining responsibility for Level3 and 4 activities. The advantages of such a system include:

• Provides coherencein the national food control system;

• Politically more acceptable as it does not disturb the day to day inspection andenforcement role of other agencies;

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• Promotesuniform application of control measures across the whole food chain throughoutthe country;

• Separatesrisk assessment and risk management functions, resulting in objective consumerprotection measures with resultant confidence among domestic consumers andcredibility with foreign buyers;

• Betterequipped to deal with international dimensions of food control such asparticipation in work of Codex, follow-up on SPS/TBT Agreements, etc;

• Encourages transparency in decision-making processes, and accountability inimplementation; and

• Is more cost-effective in thelong term.

Responding to these benefits, several countries haveestablished or are in the process of creating such a policy making andcoordinating mechanism at the national level. Case studies demonstratingnational food control systems in selected countries are presented in Annex9.

By placing management of the food supply chain under acompetent, autonomous agency, it is possible to fundamentally change the wayfood control is managed. The role of such an agency is to establish nationalfood control goals, and put into effect the strategic and operational activitiesnecessary to achieve those goals. Other functions of such a body at the nationallevel may include:

• Revising andupdating the national food control strategy as needed;

• Advisingrelevant ministerial officials on policy matters, including determination ofpriorities and use of resources;

• Drafting regulations,standards and codes of practice and promoting their implementation;

• Coordinating the activity ofthe various inspection agencies, and monitoring performance;

• Developing consumer education and community outreach initiatives and promotingtheir implementation;

• Supporting research anddevelopment; and

• Establishing quality assuranceschemes for industry and supporting their implementation.

An integrated National Food Control Agency should address theentire food chain from farm-to-table, and should have the mandate to moveresources to high priority areas and to address important sources of risk. Theestablishment of such an agency should not involve day-to-day food inspectionresponsibilities. These should continue to lie with existing agencies atnational, state/provincial, and local levels. The agency should also considerthe role of private analytical, inspection, and certification servicesparticularly for export trade.

See Annex 10 for further details on selected organizationalcomponents of a National Food Control Agency.

See Annex 11 for details on possible activities to beundertaken during the establishment and initial operation of a National FoodControl Agency.

5.4 Funding National Food ControlSystems

The funds and resources required for reorganizing andstrengthening food control systems would normally be made available from thenational government. In countries where food control responsibilities are spreadacross many government agencies it may be necessary to negotiate a revisedfunding structure and establish transition arrangements to ensure continuity offunds and resources. For this to occur, it is essential there is full commitmentby the government for establishing appropriate structures and developingpolicies to deliver the optimum level of consumer protection.

Securing sufficient resources may be a problem, as the trendtowards reduced public sector spending is influencing governments to reviewtheir priorities and funding arrangements. Cost recovery is practised in manycountries. It is important that this is managed carefully as any costs passeddirectly onto the food industry will ultimately be passed onto consumers as anindirect tax on food. This falls disproportionately on the poorer sectors ofsociety. Cost recovery options include fees for licensing, inspection activity,and food analysis. In some countries the trend towards smaller governments hasresulted in the contracting of food control services from the private sector.This involves private providers contracted to undertake specific food controlactivities such as food inspection and surveillance.

[1] Codex Alimentarius (1997).Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for itsApplication. Annex to CAC/RCP 1-1969, Rev. 3 (1997)