THE CODEX COMMITTEE ON CONTAMINANTS IN FOODS, RISK MANAGEMENT OF CONTAMINANTS IN THE FOOD CHAIN

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1 THE CODEX COMMITTEE ON CONTAMINANTS IN FOODS, RISK MANAGEMENT OF CONTAMINANTS IN THE FOOD CHAIN OBSERVATIONS OF THE CHAIR Martijn Weijtens (Chair) and Rob Theelen (Chair s assistant)

2 HISTORY OF CCCF The Codex Committee on Food Additives and Contaminants (CCFAC) was established in 1964, being one of the first general subject Committees of the Codex Alimentarius. At that time, the Netherlands were the host of CCFAC. The CCFAC was responsible for the risk management of additives and contaminants. The agendas of the meetings were split in two parts: food additives related issues, and contaminant related issues. The workload of these meetings was substantial; ad-hoc working groups were planned for Friday and Saturday, and then the plenary meeting took place from Monday to Friday The Codex Committee on Contaminants in Foods (CCCF) is established in Then the CCFAC was split in two committees, separating additives from contaminants. The host of this new committee on contaminants was appointed to the Netherlands. So, the Netherlands has a long history of chairing Codex Committee meetings dealing with contaminants. 2

3 THE CODEX COMMITTEE ON CONTAMINANTS IN FOODS According to the Procedural Manual, CCCF is (a) to establish maximum levels for contaminants and naturally occurring toxicants in food and feed; (b) to prepare priority lists of contaminants for risk assessment by the JECFA (c) to elaborate methods of analysis and sampling for the contaminants and naturally occurring toxicants; (d) elaborate standards or codes of practice; and (e) to consider other matters in relation to contaminants and naturally occurring toxicants in food and feed 3

4 SETTING STANDARDS The precautionary principle is the fundament of setting standards for contaminants. The MLs are to be set at feasible levels according to ALARA: As Low As Reasonably Achievable. Feasible means in this respect that the production of foodstuffs and feeding stuffs must be carried out according to good agricultural practices. Setting MLs is not the only way to produce safe food. MLs control by rejection of foods that contain too high levels of a contamination. In a world that can not feed all its inhabitants yet, rejection and destruction of foods is not preferred. Therefore, there is much attention in the CCCF for prevention and reduction of contamination, by the development of Codes of Practice. In the list of standards (2014) there are 24 Codes of Practice; 18 were developed by the CCCF. 4

5 GENERAL OUTLINE OF CCCF WORK PROCEDURE In the CCCF there is much attention for the work of JECFA. As there are many contaminants and toxins, the Priority list of contaminants and naturally occurring toxicants proposed for evaluation by JECFA is essential for CCCF. It is prepared by an ad-hoc working group in every meeting. Many delegates participate in these working groups. In the CCCF a special meeting was introduced, chaired by JECFA, in which the outcome of the JECFA meetings are being presented and discussed. This creates more awareness by the risk managers in CCCF. If it is decided to take up new work, CCCF members will start with a Discussion Paper. An electronic working group will prepare this paper, in which the arguments are given why a new Code of Practice or new ML is to be considered needed. When decided by the CCCF on the basis of the Discussion Paper that new work should be done, the Drafts are being prepared according to the Step procedure described in the Procedural Manual. But, as the major difficulties in the discussions have already been addressed in the Discussion Paper, the Steps can be short. In many cases, the Draft goes through Step 3 directly to Step 5/8. 5

6 POLITICS IN THE CCCF? MLs have impact on the export of foods and feed. This is especially true for contaminants, as they are hard to control during the production. E.g. concentrations of mycotoxins depend on the climate and storage conditions. The first can not be controlled, the second can by means of a Code of Practice. With regard to the ML, importing countries like to see concentrations of contaminants as low as possible, whereas the exporting countries prefer a ML that is feasible for them. So the discussion on the ML is prone to economic motives. This issue can be solved by demonstrating of the feasibility of a standard. The producing countries need to generate data on concentrations of the contaminants. This is a costly procedure, while many producers lack the money. It should become clear that food safety is the responsibility of both producers ánd importers, and accordingly the more wealthy countries must support the developing countries in the regard. Thus capacity building and Trust Fund are of interest for áll Codex Alimentarius members. 6

7 CO-HOSTING The CCCF gives much importance to the participation of the less developed countries. This is underlined by co-hosting of the CCCF meetings. The CCCF started already many years ago to have meeting co-hosted by other countries. These meetings were in the Philippines, Tanzania, China, Turkey, and the Russian Federation. For 2015 the meeting is planned in India. The Netherlands have learned that co-hosting needs more effort and costs than the meeting in the host country. Even so, we consider co-hosting essential for improving the participation of less developed countries. So CCCF is a strong supporter of co-hosting of Codex meetings and the Netherlands will continue to support co-hosting meetings of the CCCF. 7

8 TIME A complaint that is often heard is, that setting standards in the Codex Alimentarius is a time consuming process. CCCF objects to this statement. It is demonstrated in the CCCF that standards can be set in a fast way, still being careful. If the need for a standard is considered essential in international trade, there is much involvement and things can go quick. A striking example is the standard for melamine in food and feed, set by CCCF within two years, using information from other meetings and risk assessments of other bodies. Another lesson learned with regard to time, is the use of discussion papers in the CCCF. The effort made are paying back, as it is decided whether or not there is a real need for a standard and consequently new work. CCCF is of the opinion that it is better to remove the issue from the agenda in an early stage than at the end of the Step procedure after the conclusion that consensus can not be reached. 8

9 DELEGATES Looking back in time from the early meetings up to the meetings in the present days, it can be concluded that the contribution of the delegations is changing. In former days, the discussions in the meetings were influenced by a rather small group of delegations, that were familiar with the Codex procedures. These people had a long track record of Codex meetings. New delegates were most oft impressed by these experienced participants, and consequently the outcome of these meetings could be based on the opinions of these experienced delegates only. A change in time is, that the delegates are now looking for more support within its region. In CCCF the regional groups like CCAFRICA and CCLAC are becoming more important. Experienced participants of the region support and help the new delegates, and opinions are more oft harmonized between the members of the region. Consequently it can be expected that the discussions between regions in the CCCF will become harder, but at the same time better representing the differences between the regions. 9

10 FUTURE 10 It is difficult to predict the future, but on the basis of the observations of the chair a few signals can be noted. The relevance of Codex Alimentarius standards in the international trade of foods and feed is increasing. The world is becoming smaller, and international trade of foods is essential for feeding the world population. JECFA is important for the CCCF. The Committees depend on the outcome of JECFA. It is therefore in the interest of the Committees to keep supporting JECFA, both by finances and providing national experts. Co-hosting is very helpful to create more involvement of the codex members. It can be costly, but it is worthwhile. Co-hosting should become more custom (also for the other Committees). The world regions show growing expertise and knowledge, and act with more confidence in the Codex Committee meetings. Discussion will become broader and harder. Reaching consensus might become more difficult. Here is the challenge for the Codex Secretariat ánd the Chair. In contract to most believe, time needed to set standards is not the issue in the Codex Alimentarius. Setting standards need for careful planning of the different steps, thorough preparation of a delegate s position and fallback options. Then the Chair and delegates can judge what can be achieved. Needs finally a Chair who controls the meeting, dares to conclude, and knows when to stop.