Comments and Correspondence
ICGMA COMMENTS ON JMPR
June 12, 2003
Secretary, Codex Alimentarius Commission
Joint FAO/WHO Food Standards Programme
FAO
Viale delle Terme di Caracalla, 00100
Rome, Italy
Dear Dr Randall:
The International Council of Grocery Manufacturers Associations
(ICGMA) appreciates the opportunity to provide input on the following
issues from the Codex Committee on Pesticide Residues: (1) the proposed
procedure of the elaboration on Interim MRLs and (2) the reduction
of extraneous burden from the workload of JMPR.
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 these sectors by elimination or
preventing artificial barriers to trade.
Proposed procedure of the elaboration on Interim MRLs
GMA strongly supports this proposed procedure. At present, it takes
up to 8 years from nomination to establishment of a Codex MRL for
pesticides. During this period, growers cannot use the newer, often
safer alternatives on crops destined for export to countries that
rely on Codex standards. The alternative approach proposed by CCPR
is the use of national MRLs as interim food standards for a fixed
period of time until a Codex standard becomes available. The interim
standard would be set at Step 8 of the Codex process. In the meantime,
JMPR would consider the standard and consequently advance it through
the standard procedures and ultimately supplant the interim standard.
The CCPR has sought advice from the Commission to initiate a pilot
project towards this end.
ICGMA supports consideration by the Commission of this novel approach
not only for pesticides but other relevant Codex standards. The
approach would permit new standards to be used within 2 years of
nomination as opposed to the current process that typically requires
8 years. Safer standards, many of which are substitutes for existing
ones with more serious health concerns, could be made available
for use in traded commodities in a relatively shorter interval after
adoption at the national level.
In line with the concern raised by some delegations to the CCPR,
ICGMA also supports the recommendation that the Commission consider
the legal status of interim standards within the Codex system and
the implications of these interim standards for other Codex Committees.
It would also be worthwhile for the Commission to initiate contact
with the WTO to ascertain likely status of interim MRLs in context
of the SPS and TBT agreements.
Reduction of extraneous burden from the workload of JMPR
ICGMA supports limiting data requirements to those relevant to
the establishment of an MRL and to the assessment of dietary exposures,
thus allowing JMPR to spend more time in reviewing more compounds
for standard setting purposes.
Again, ICGMA appreciates the opportunity to provide comments on
these issues.
Respectively,
Mari Stull,
Executive Secretariat
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