Comments and Correspondence
ICGMA LETTER TO FAO/WHO ON RISK ANALYSIS PRINCIPLES
January, 2001
Secretary
Joint FAO/WHO Food Standards
Programme – FAO
Viale delle Terme di Caracalla
00100 Rome, Italy
Fax: +39 (06) 5705 4593
RE: Request for Comments on CL 2001/24-GP
Dear Secretary:
The International Council of Grocery Manufacturers Associations
(ICGMA) is an international non-governmental organization (INGO)
with official recognition before the Codex Alimentarius Commission
and other international fora. ICGMA 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. It is in this context that ICGMA submits the following comments
to the CL 2001/24-GP as requested by your office.
The ICGMA commends the Secretariat in their diligent efforts in
developing the Draft Working Principles for Risk Analysis (Draft)
and believe that it fairly reflects the decisions and amendments
made during the 24th Session of the Codex Alimentarius Commission.
ICGMA offers the following specific comments and recommendations
to the Draft.
Comments are provided to specific paragraphs as numbered:
Scope:
1. This statement accurately reflects the decision of the Commission
that principles of risk analysis be applied to the framework of
Codex.
2. Insert the word, “scientific” after second “objective.”
7. Replace “consumers and their representative organizations,
and other interested parties” with “all interested
parties” for consistency with paragraph 8.
Risk Analysis- General Aspects:
10. Delete bracketed text. Precaution should be used when negative
effects on health are identified – not when those effects
“are difficult to evaluate.”
11. Delete the bracketed text.
12. We agree with the premise, but questions how all needs and
situations for developing countries can be identified. We suggest
paragraph 38 verbiage.
16. Delete this paragraph and combine the concept with paragraph
as indicated in our suggested new paragraph 17.
17. We suggest, “The mandate given by risk managers to
risk assessors should be as clear as possible, taking into account
available scientific evidence and any constraints affecting the
risk assessment process. Risk managers should evaluate human health
and safety risk reductions resulting from different risk management
options."
Risk Assessment:
18. Suggest combining this paragraph with paragraph 19 as follows,
“Science based risk assessments should form the basis of
Codex standards, guidelines and recommendations. The scope and
purpose of each risk assessment should be clearly stated and the
outputs of the risk assessment should be defined.”
20. For clarity, suggest, “Experts responsible for risk
assessment should be selected in a transparent manner on the basis
of their expertise and their independence with regard to the interests
involved. The procedures used to select these experts should be
documented, including details of their expertise and experience
and a declaration of any potential conflict of interest."
26. Suggest second sentence, “Any expression of uncertainty
or variability in risk estimates should be quantified to the extent
it is scientifically achievable.”
Risk Management: As these principles are “intended
for application in the framework of the Codex Alimentarius,”
we request clarification as to the role of Codex Alimentarius in
risk management.
30. In accordance with the scope of the document and for consistency
we suggest using language in paragraph. 2, “The basis of
risk management decisions should be to protect the health of consumers
while not unjustly hinder fair practices in food trade.”
31. Suggest, “…as identified in Criteria for
the Consideration of Other Factors Referred to in the Second Statement
of Principles.” after OLF.
34. Suggest, “Risk management options should be evaluated/assessed
in terms of the objective outcomes of risk assessment and risk
characterization, as well as the overall scope and purpose of
risk analysis considering the risk of taking no action.
35. Suggest, “The outcome of the risk evaluation process
should derive from the appropriate exercise of objective and scientific
standards, weighing risks against benefits, with protection of
consumer health and safety the primary consideration, and the
standard of proof based on that articulated in Article 5.7 of
the Sanitary and Phytosanitary (SPS) Agreements.
36. Agree with deletion.
37. Suggest, “Risk management should ensure transparency
in the decision making process. Decisions should ensure consistency
in similar circumstances to avoid unjustified trade barriers.
Risk Communication: As these principles are “intended
for application in the framework of the Codex Alimentarius,”
we request clarification as to the role of Codex Alimentarius in
risk communication.
ICGMA appreciates this opportunity to present our comments and
views on the Draft. We welcome the opportunity to participate in
further deliberations on this issue to ensure the adoption of a
document that satisfies the mandate of the Codex Alimentarius Commission:
to protect health of consumers, and to facilitate fair practices
in food trade.
Sincerely,
Mari Stull
Executive Secretariat
International Council of Grocery Manufacturers Associations
1010 Wisconsin Avenue, Suite 900
Washington, DC 20007
USA
CC: CIAA
Codex Contact Point for France
SGCI/CODEX
Carré Austerlitz, 2 Boulevard Diderot
75703 Paris Cedex 12
Fax. 33 (0)1 4487 16 04
Email: sgci-codex-fr@sgci.finances.gouv.fr
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