| NAW/WFA Working Paper No 10 |
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NAW/WFA Working Paper No 10 Joint Food and Agriculture Organisation/ World Health Organisation Food Standards Programme-Codex Committee on Food Hygiene Our Comments on 29 November - 4 December 1999 Codex Alimentarius is the set of rules for international food standards. The Codex process must be opened up to give real influence to consumers and workers in the food chain industries. All existing rules should be reviewed. We have been aware of the HACCPS issue for some time. It has particular relevance to Wales in terms of the Welsh public health agenda, and the transitional use of European Commissions Objective 1 and 3 SPD funds. NAW/WFA Working Papers 4 and 5 considered these matters (see our web site). In September we wrote to the NAW Health and Social Services Secretary, and spoke with John Barnes (Department of Health, London), and David Worthington (Cardiff) requesting access to Codex discussion papers, which have now obtained from WHO. The FAO/WHO discussion paper is the critical first phase of a process for SME's and other food operations. These will eventually be incorporated in European Commission food law reform. The two key issues are: A second order issue concerns the regulatory cost implications for hard pressed Welsh SME's. It is therefore particularly important that the cost implications of trade rules and actions do not disadvantage small businesses, with systems that have their origins in the USA space programme, and Fordist production methods. How future consumer benefits and business cost can be eased either through, for example, Objective 1 funding of the WDA's agribusiness strategy could affect the future viability of SME's diversifying into new added value production activities. Below we provide suggested amendments to recommendations and conclusions to page 19 of the above FAO/WHO discussion paper (CX/FH 99/9). Proposed amendments to the text are underlined. These comments are directed at-. » Health, Agriculture, and Economic Development Departments in Wales The reasons for these amendments are fairly straight forward, and well rehearsed in other fora. Clearly a wider range of stakeholders will need to be involved in this process if Codex is to command public confidence. We now take the FAO/WHO text, at page 19, and underline our proposed amendments. Conclusions and Recommendations 1. The Codex Committee on Food Hygiene should consider the development and adoption of separate Guidelines for Application of HACCP in SLDBs as part of the general principles document, following wider public consultation. 2. Given the barriers to implementation of HACCP by SLDBS, governments, consumer, public health,, worker organisations, and trade/industry associations should develop strategies to facilitate its implementation. 3. Special attention is needed regarding implementation strategies for SLDBs with very limited means and expertise in the areas of food hygiene. 4. When implementing HACCP in SLBDs attention should be paid to the strategies identified and guidelines developed by the WHO Consultation, following wider public consultation. 5. Recognising the important role that sector specific guides play in implementing HACCP in SLDBS, every effort should be made prepare and disseminate such documents to ensure that consumer, worker and public health organisations are involved at local, regional, and national levels. 6. It is recommended that international organisations such as FAO and WHO, set up a central data base of existing guides including information on their scope, language and intended use, indicating the extent to which consumer and worker organisations are involved in the implementation process at local, regional, and national levels, and make it accessible through a web site. 7. In order to assist in developing countries, international organisations, such as FAO and WHO, should explore ways and means of providing support to governments and industries, as well as consumer, worker. and public health NGOS, on an ongoing basis". David Smith 25 November 1999 |