Food and Chemical Safety

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10-point Regional Strategy for Food Safety in the South-East Asia Region

Introduction

The South-East Asia Region of the World Health Organization comprises ten member states, viz., Bangladesh, Bhutan, India, Indonesia, Democratic People's Republic of Korea, Maldives, Myanmar, Nepal, Sri Lanka and Thailand. In recent years, the countries of the Region have made significant achievements in improving the health of, and services to their ever-growing populations.

In spite of these achievements and the very considerable financial and technical investment by national governments, international organizations, including the World Health Organization, the Food and Agriculture Organization, bilateral aid agencies and nongovernmental organizations, protein-energy malnutrition, micronutrient deficiencies and diarrhoeal diseases remain major causes of morbidity and mortality. Many hundreds of millions of diarrhoeal disease cases are reported annually and many more individuals are exposed to diarrhoeal disease but do not report their suffering. Of particular concern is the extent and life-threatening nature of such diseases in the young. Of these, international organizations estimate that approximately 30% die from diarrhoeal diseases.

The problem is aggravated by the rapid population increases in most countries, particularly in the urban environment. This population explosion in the urban environment is compounded by migration from the rural areas. Perhaps up to 50% of the urban population living in major cities in the Region live in conditions of extreme poverty, filth, overcrowding and poor sanitation. Slum conditions are to be found in nearly all major urban areas. In addition, a significant number of people including large numbers of children are homeless. Urbanization has also impacted on social structures. This in turn results in a heavier emphasis on the purchase and consumption of food outside the family home. Street food vendors and food service premises are an essential and increasing part of the food supply system in nearly all countries of the Region but, without strict control of food preparation, storage and display practices, may become a major source of foodborne disease.

The interacting factors leading to ongoing malnutrition and an increasing incidence of foodborne disease are many and their inter-relationship extremely complex. The WHO Regional Consultation on the Development of a Strategic Plan for Food Safety in the South-East Asia Region was held at WHO/SEARO, New Delhi, from 27-30 October 1998 to enable Member States to address this complex issue and develop a Regional Strategic Plan for food safety improvement.

Nineteen participants from ten Member Countries participated in the Consultation along with two representatives from the Food and Agriculture Organization (FAO) and fiveTen-Point Regional Strategy for Food Safety in the South-East Asia Regionobservers from other agencies [International Council for Control of Iodine Deficiency Disorders (ICCIDD), International Life Sciences Institute (ILSI-India) and Voluntary Organization in Interest of Consumer Education (VOICE)]. The Secretariat comprised experts from WHO headquarters (HQ) and the South-East Asia Regional Office, a WHO short-term Consultant and WHO technical officers from five countries.

As a result of group work and plenary discussions, the participants developed a ten-point strategy for enhancing food safety in the South-East Asia Region.

Food Safety Policy

     Despite the probable extent of foodborne disease, many governments have no clearly articulated written policy on food safety, nor, in several countries, is there any one authority with a clear mandate as the responsible authority for all activities in relation to food safety. National Plans of Action for Nutrition (NPAN) are said to have been drawn up by all the ten countries of the Region. in a number of countries however, they are seen as policies and plans predominantly relevant to the development of food security programmes. This may be a result of a self-sufficiency first approach, a consequence of the pressures exerted by a hungry population or simply political expediency. In addition, these programmes have of course been aimed at the prevention and anagement of nutritional diseases. In most of these countries, however, such programmes are not yet seen as key policy statements of relevance to food control authorities. The reluctance to establish documented policies and plans of action relevant to all participants in food safety is an indication of the failure of consumers, politicians and governments to recognize the true extent of the health and economic consequences of foodborne disease. Again, many possible causes exist for this failure, including ineffective communication, lack of awareness, inadequate data on the costs of foodborne disease, cultural habits, differing social values, traditions and taboos as examples.

     WHO has provided direction for the better integration of food safety policy in a number of initiatives, including its integration in National Plans of Action for Nutrition and in Health and Environment Plans established as part of the Region's Health and Environment Initiatives. Each of these approaches offers the concept of and mechanisms for an intersectoral approach to issues such as food safety.

Strategy 1: Countries should develop their food safety policy integration with policies addressing food security, quality and nutrition, and consistent with international requirements for participation in international trade.

Related Actions

     Health authorities should promote the need For a multi-sectoral group at the highest level of government (possibly a single agency) to be established to review existing policies regarding their compatibility, relevance to society and appropriateness to protect the health of the population.

     International organizations, such as WHO and FAO, should continue to facilitate awareness of the social and economic costs of foodborne disease through national fora in order to increase political pressure for the establishment of such a multi-sectoral group.

     A multi-sectoral group (involving sectors such as health, agriculture, rural and urban development; food processors, food analysis, nutrition, commerce,hospitality, tourism, environment education, consumers, women's affairs) should be established to undertake such a review at the national level.

     The review should initially identify a focal agency to drive policy change and to monitor the effectiveness of such an agency in achieving change. In the review, consideration must be given to the benefits of having the key ministry capable of drawing support from other ministries as the focal agency.

     Governments should provide the necessary resources to establish and support the secretariat of the focal agency and/or muld sectoral group.

     Such a group must develop a harmonised plan of action for food safety and quality, food security and nutrition

     In the immediate term, governments should establish a mechanism for the development, adoption and enforcement of sanitary and phytosanitary measures in order to meet the requirements of the SPS and TBT Agreements.

     To facilitate international trade in safe food, those countries which are either importers or exporters of food should establish mechanisms for the sharing of information, for the harmonization of regulations (outlined later) and for the development and application of risk assessment in the enforcement of food regulations.

     In the longer term, such a multi-sectoral group should also consider the economic and social costs and benefits of privatising elements of the national food safety and quality programme.

Food Legislation

Food legislation provides the foundation for national food safety programmes. it plays a pivotal role in directing the food control efforts of food inspectors. It informs producers' and  processors of requirements regarding production, processing methods and product standards and provides the consumer expectations of a given food.

     Much of the law addressing food safety in the Region has not been evaluated as to its relevance and effectiveness. As a consequence, in some countries' the basic food law has not been revised significantly (amendments excluded) since the 1950s. Food regulations and food standards too have stagnated in some countries of the Region. In contrast, a few governments' commitment to modernising their societies and to improved food safety for their populations has led to a comprehensive revision of laws, regulations and standards and a commitment to the guidelines of the Codex Alimentarius Commission (Codex).

     In a Region where the vast majority of consumers rely on foods that have undergone little or no processing prior to purchase (fresh produce, household food, products of family scale or small industries and street-vended food), legislation must focus on the hazards associated with such foods. Legislation must also, however, address the hazards associated with food processed for domestic consumption, food for export and imported food.

Strategy 2: Governments should regularly evaluate and revise their food legislation to ensure it best protects their populations and facilitates international trade in safe food.

Related Actions

     The governments' focal agency (as identified i n 2.2.4) should, in collaboration with all interested parties including industry and consumers, regularly evaluate and revise food safety and quality legislation. To facilitate this, governments should make available sufficient resources for the task.

     The harmonisation of a country's legislation with other countries in the Region and globally should be facilitated by becoming a member of Codex, establishment of a national Codex Contact Point and Committee and participation in relevant Codex meetings. For such participation, both national and international support should be sought.

     Where appropriate, trading partners or countries with common borders should hold bilateral or multilateral meetings to harmonise legislation so that safe food can pass across borders with only the minimum delays necessary and so unsafe food is prevented from exportation.

Food Control and Inspection

     Food control systems are reliant on food inspectorate and public health inspectors to provide the main manpower. Generally, these inspectors are appointed at a number of levels of government. National food control and inspection staff are usually appointed under the Ministries of Health. In addition, inspectors are appointed under ministries such as agriculture, industry and commerce, to inspect raw materials and products to determine compliance with standards. Generally, these divisions/units are grossly under-resourced in terms of both personnel and equipment.

     Other levels of government that employ inspectors include provincial, state, union territory, district and municipal authorities. In some areas, this leads to duplication of responsibilities and a lack of accountability which, in an atmosphere of gross understaffing, can result in no one taking responsibility. With insufficient numbers of inspectors to undertake inspection duties, unscrupulous businesses have a high likelihood of going without detection. This is aggravated by the knowledge that food safety is often just a part of the duty of inspectors.

Strategy 3: Food inspection activities should be prioritised according to consumer risk, -facilitated-by the provision of training and guidelines and supported adequateIy by appropriate government resources.

Related Actions

     The frequency of food inspection activities should be prioritised according to risk, with high-risk foods being the priority.

     Governments should lay more emphasis on regulatory assessment with the objective of obtaining evidence that the seven principles of HACCP have been applied, the HACCP plan and pre-requisites are correctly implemented and that the system has been maintained.

     Enforcement agencies responsible for food inspection activities should prepare and disseminate a code of practice for inspectors as well as prepare materials for and train inspectors in the code of practice, modern inspection techniques based upon HACCP principles and sampling procedures in accordance with Codex.

     Enforcement agencies should identify the appropriate minimum curriculum that is required for inspectors to be either considered competent to undertake their regulatory role or to be accredited by the responsible authority.

     Authorities should establish, for inspectors, training commensurate with their responsibilities and potential earnings (e.g. Indonesia's three-tier training programme ).

     Governments should be made aware of the community cost benefits of employing adequate inspectors (government or government accredited) to provide ad equate coverage of communities. Subsequently, governments should make available at least the minimum resources necessary to assure the safety of food.

     Governments should consider a diversity of approaches for the mobilization of resources to strengthen inspection capabilities. Such approaches may include the establishment of licensing and analysis fees and the realization of fines.

     Governments should establish an effective management information system to enhance the flow of information regarding food inspection activities.

Analytical Capability

     Contaminant monitoring is an essential element of a national food safety programme. Its implementation provides the community reassurance of the safety of the food supply and identification of potential risks before programmes to provide the necessary data, regulatory authorities must have access to laboratories with the capacity to analyse for the common causes of foodborne disease. While in many countries outside the Region, governments are more recently using accredited privatised laboratories for these purposes, most countries in this Region maintain government laboratories for food analysis.resourced. However, in a number of countries, even the central nationl food laboratories are inadequately resourced with respect to funding, equipment and personnel.

     Even central national laboratories sometimes only have the capacity to perform basic wet chemistry on food samples. Some central national laboratories have the necessary equipment for more advanced chemical analyses but may often lack the recurrent funds to purchase or replace materials such as reagents, columns, tubes etc. Consequently, essential equipment may be in a state of disrepair.

     The historical focus of food control systems on adulteration for the purposes of fraud and the origin of most as laboratories focused on drug analysis has meant that laboratories have much stronger chemical analysis sections than microbiological. Consequently, even central national laboratories are commonly not set up to test for emerging pathogens such as Campylobacter and Escherichia coli 0157. Provincial, district and municipal laboratories are even more under-funded.

     Furthermore, many laboratories in the Region do not apply adequate quality assurance procedures, do not participate in inter-laboratory testing and are not accredited.

Strategy 4: National analytical capacity should be strengthened by appropriate training, resources and establishment of quality assurance protocol and procedures.

Related Actions

     In the short term, governments should ensure that the central or national official food control laboratory has the capacity to precisely carry out those microbiological, chemical and physical tests necessary to detect and quantify, where possible, the hazards most likely to affect the health of the nation's population. To achieve this, international organizations, such as WHO and  FAO, should be requested to initiate a regional activity focused on quality assurance in the food laboratory and the development and initial implementation of a protocol for regional proficiency testing.

     Subsequently, the national, central laboratory or a neighbouring (where there is only one laboratory in the country) country's central laboratory (employing ISO 25 guidelines) should be established by the government as a key quality assurance centre, evaluating, training and accrediting provincial, district and municipal laboratories.

     Where appropriate, governments should consider both the consequences and cost effectiveness of accrediting private laboratories to undertake analysis for regulatory purposes.

     Where governments remain committed to the concept of maintaining government owned and operated laboratories, adequate resources (including manpower and equipment) must be made available to ensure the ongoing Successful operations of such laboratories.

     Countries should conduct routine monitoring of their food supplies to identify and assess trends in regard to food contamination. Countries should consider participation in the WHO Food contamination Monitoring Programme to take advantage of the quality assurance and control services provided.

     Governments should, in undertaking such programmes, apply a methodology consistent with that recommended by the Codex Alimentarius Commission.