Comments and Correspondence
ICGMA COMMENTS SUBMITTED TO HEALTH CANADA ON THE GENERAL STANDARD
FOR THE LABELING OF PREPACKAGED FOODS: QUANTITATIVE DECLARATION
OF INGREDIENTS (QUID)
January 25, 2002
Codex Contact Point for France
SGCI/CODEX
Carre Austerlitz
2 Bouevard Diderot
75703 Paris Cedex 12
Fax: +33 1 4487 1604
Re: Request for Comments on the Proposed Draft Working Principles
for Risk Analysis (CX/GP02/3)
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 specific standards and policies concerned with the health, safety,
packaging, and labeling of foods, beverages and other consumer packaged
goods. ICGMA also works to facilitate international trade in this
sector by elimination or preventing artificial barriers to trade.
The ICGMA would like to express our appreciation for the efforts
of the Working Group members in the revision of the Proposed Draft
Working Principles for Risk Analysis (Draft Document). We would
also like to note the absence of members from developing countries
at the Working Group meeting, but point out that we support the
views of those few representative developing countries that did
participate in the meeting.
ICGMA submits the following comments to the Draft Document as
requested by your office.
Comments are provided to specific paragraphs, as numbered:
Title
The revised title accurately reflects the decision of the Commission
that principles of risk analysis be applied to the framework of
Codex. Accordingly, we support the revision.
Scope
3. We support the revisions to this paragraph as important clarifications
that the principles contained within the document are intended to
apply to the committees of Codex and the appropriate expert bodies
in the conduct of risk assessment, management and communication.
We support the acknowledgement that the Draft Document does not
take as its goal the elaboration or implementation of risk analysis
procedures for governments of member nations. This distinction is
important in that it removes, in part, the relevance of national
arguments regarding the essential factors forming the basis for
risk analysis from any discussion of the guiding principles of an
international standards-setting body such as Codex. The elimination
of a discussion regarding national implementation of risk assessment,
management, and communication from the scope of the documents permits
the concept of scientific justification to once again move to the
forefront of Codex decision-making.
Risk Analysis - General Aspects
9. We suggest revision of the last sentence to read, "However,
it is recognized that risk management decisions are based on a risk
assessment." This wording strengthens the relationship of risk
management and risk assessment and is in accordance with Article
5.1 of the WTO Agreement on the Application of Sanitary and Phytosanitary
Measures Agreement.
10. We support the insertion of former paragraph 40 at paragraph
10.
11. The representatives from the few participating developing countries
strongly urged the deletion of this paragraph. We support the deletion.
Legitimate application of precaution in risk analysis and the right
to take provisional measures in situations of uncertainty is defined
in article 5.7 of the WTO SPS Agreement. ICGMA cautions on the elaboration
of precaution in a Codex document which is not wholly in accordance
with this article.
Risk Management
Although we support the modifications to the text of the Working
Draft regarding risk management, we continue to request clarification
of the role of Codex in risk management. Specifically, the Draft
Document does not sufficiently clarify the fact that Codex does
not implement risk management options or create risk management
measures, as this role belongs properly to the governments of member
nations. We believe that Codex's role in generating guiding principles
and recommendations for risk management to be used by the governments
of member nations should be underscored.
27. We recommend light amendment to final sentence to read "Where
relevant, acute, chronic, (including long-term), cumultative and/or
combined adverse health effects should be taken into account."
28. We recommend replacing the term "minority opinions"
with "where appropriate" and the word "conclusions"
with "results."
31. We support the changes made to this paragraph. The addition
of the reference to the Criteria for the Consideration of the Other
Factors Referred to in the Second Statement of Principles highlights
the role of these criteria in underscoring the role of Codex as
a science-based international standards-setting organization whose
primary aim is to protect consumer health.
37. We support the revisions to this paragraph as consistent with
our understanding of the definition of "fair practices in food
trade" and the consideration of these practices in conjunction
with the protection of consumer health.
Risk Communication
41 - 44: We support the changes made to paragraphs 41 through 44
regarding risk communication. In particular, we support the clarification
in paragraph 41 of the two types of risk communication at issue
within Codex: 1) communication amongst risk assessors (expert bodies
and consultations) and risk managers (Codex Committees); and 2)
communication amongst Codex and all interested parties (member governments,
industry, citizens).
43. While the revisions to paragraph 43 are helpful in outlining
the concrete goals of risk communication, and elaborating the importance
of transparent, documented risk communication with all interested
parties, this section still lacks any elaboration of suggested mechanisms
for interactive risk communication between any of these groups.
We would suggest that the Committee discuss in greater detail the
currently available processes for risk communication between these
three groups and make a determination as to whether new avenues
for interactive risk communication, particularly with interested
parties, should be developed.
ICGMA appreciates this opportunity to present our comments and views
on the Draft Document and welcome the opportunity to participate
in further deliberations on this issue.
Sincerely,
Mari Stull
Executive Secretariat
International Council of Grocery Manufacturers Associations
cc. Secretary Joint FAO/WHO Food Standards Fax: +39 (06) 5705 4593
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