Comments and Correspondence
ICGMA COMMENTS ON THE WORK OF JOINT FAO/WHO FOOD STANDARDS PROGRAMME
May 15, 2002
WHO Department of Budget and Management Reform
1211 Geneva 27, Switzerland
Dear Evaluation Team:
The International Council of Grocery Manufacturers Associations
(ICGMA) is pleased to provide our comments on the work of the Joint
FAO/WHO Food Standards Programme, including the Codex Alimentarius
Commission as requested by your office.
ICGMA, a recognized INGO before the Codex Alimentarius Commission,
represents the interests of national and regional associations who
collaborate with all sectors of the consumer packaged goods industry.
ICGMA promotes the harmonization of scientific standards and policies
concerned with health, safety, packaging, and labeling, of foods,
beverages and other consumer packaged goods. ICGMA also works to
facilitate international trade in the sector by eliminating or preventing
artificial barriers to trade. ICGMA actively participates in all
horizontal Codex Alimentarius Committee Meetings and in many vertical
Meetings, as well.
General:
Over the course of the past several years, Codex has shown a steady
and perhaps dangerous inclination to move away from its fundamental
principle of using sound science in its standard setting process.
Numerous proposals by INGO's, led largely by consumer and/ or environmental
activists, have led to new work in Codex even though these proposals
fail the threshold test of relevance: they lack any compelling scientific
purpose related to the fundamental objectives of Codex, which are
the protection of the health of consumers and fair practices in
food trade.
Scientifically supportable standards that protect the health of
consumers will ensure consumer confidence in the global food supply.
Codex achieves nothing if, to allay the "concerns" of
one group or another, it expends its energies and wisdom on the
agenda of outside groups at the expense of real and lasting food
safety standards. The problem will only be compounded when, as is
inevitable, member states begin promulgating regulations in an effort
to follow Codex's lead, and both the public and private sectors
waste resources trying to comply with laws that do nothing to make
food safer. What is needed is a return to the disciplined and sometimes
difficult work of science-based standard-setting, focused on the
mission of Codex for the past four decades: the guarantee of safe
food for people the world over. Refocusing Codex in this regard
will do more to ensure consumer confidence and restore the integrity
and efficiency of the Codex process, than will pursuing agendas
based on highly subjective assumptions about non-health and safety-related
consumer information issues.
Specific:
1. The relevance and adequacy of Codex and other food standards
as a basis for consumer health protection, trade and economic development:
Codex can only be relevant and effective when it focuses its resources
on the establishment of quantifiable, science-based standards aimed
at enhancing food safety, rather than on social activism that does
not affect the safety of the global food supply. If Codex has fallen
short of late, it is because too much time is spent on sociopolitical
debates and too little time on safety. Generally, the more technically
oriented is a committee, the more tangible results are delivered.
It is no coincidence that the least progress has been made on contentious
"social issues" before the CCFL and the CCGP.
2. The adequacy of governance structures and decision-making processes
in Codex and other food standards work:
Although generally these processes function well, the system does
tend to slow down in search of consensus, which can be almost impossible
to achieve because some of the Chairs are not as effective as others
in sensing the trend at a meeting, and leading toward a decision.
Committee Chairpersons should take a more neutral and stronger lead
in controlling the debate, identifying the areas of agreements/
disagreement, and determining whether a viable path forward exists.
It is possible to hear all views and yet impose reasonable time
limits on plenary presentations. The Committee of Chairs can also
be useful to maintain consistency among committees and to avoid
duplication of work or debate. Chairs must be vigilant to assure
regional consensus is not mistaken for international consensus (e.g.
solely based on number of interventions) and that INGO views are
not weighted equally with member governments.
The Commission and the Executive Committee function far more effectively.
The Secretariat is in need of additional experience and resources.
3. The efficiency and transparency of the Codex process, including
the independence of Codex bodies and of scientific advice given
to Codex and avoidance of conflict of interest:
Despite the calls from a number of activist groups, Codex is more
transparent now than at any time in its recent history. There is
no evidence that any of the scientific bodies on which Codex depends
is biased or subject to any conflict of interest. As to efficiency,
as noted in point one, efficiency is directly related to the scientific
validity of the work on which Codex embarks. Attempting to promulgate
international scientific standards based upon philosophical or regional
consumer preferences inherently creates inefficiencies, lack of
consensus and delays. This critical flaw of today's Codex can be
remedied by a return to Codex's original brief. JECFA (Joint Expert
Committee on Food Additives and Contaminants) must remain independent
from Codex, science-based, and focused on rigorous risk assessment.
This independence will ensure that risk management decisions are
valid and science based.
4. Opportunities to participate in the Codex process:
While there has been a marked increase in the level of participation
in the Codex process by international NGOs, there has been a decline
in attendance by developing countries because of the prohibitive
cost. The integrity of the process depends on maximum member country
participation, and this should be vigorously encouraged and facilitated,
as soon as possible.
5. Implications for future international systems of food safety
and food standards development relative to public health, food trade
and economic development in a broad sense:
Functioning properly, Codex can be a tremendous force for the development
of effective and beneficial regulatory templates for developing
countries, as well as a constructive force for constructive mechanism
for harmonizing food regulations throughout the world. Codex is
the primary reference agency for the WTO in trade disputes involving
food. A continuance of recent trends in Codex could easily result
in more rather than fewer non-tariff trade barriers, with no concomitant
increase in global food safety.
ICGMA appreciates the opportunity to provide these comments. Should
you have any questions or need additional information, please do
not hesitant to contact me.
Sincerely,
Mari Stull
Executive Secretariat
International Council of Grocery Manufacturers Associations
cc. FAO Secretariat
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