Comments and Correspondence
ICGMA COMMENTS ON PROPOSED DRAFT PRINCIPLES AND GUIDELINES FOR THE
CONDUCT OF MICROBIAL RISK MANAGEMENT
December 20, 2002
Mr. S. Amjad Ali, Staff Officer
Food Safety and Inspection Service
U.S. Department of Agriculture
Room 4861
1400 Independence Avenue, SW
Washington, D.C. 20250, USA
Dear Mr. Ali:
Re: Comments on CX/FH 02/7, Proposed Draft Principles and
Guidelines for the Conduct of Microbiological Risk Management, at
Step 3
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 CX/FH 02/7 per your request.
ICGMA appreciates the opportunity to comment on the Proposed
Draft Principles and Guidelines for the Conduct of Microbiological
Risk Management. We commend the working group led by France
on the revision of this document, which provides a framework for
the management of risks arising from the occurrence of microbiological
hazards in foods.
ICGMA offers comments on the following Sections of the document:
Section 2. Definitions
"Food Safety Objective": ICGMA recommends removing the
brackets around the word "microbiological", deleting the
words "at the time of consumption", and deleting the brackets
and the term (ALOP) at the end of the definition,; so that
the definition would read:
"Food Safety Objective – The maximum frequency and/or
concentration of a microbiological hazard in a food, when produced,
that provides the appropriate level of health protection.
Example of FSO: 100 Listeria monocytogenes per gram of ready-to-eat
food."
ICGMA believes that microbiological hazards should be specified
because these principles and guidelines relate to microbiological
risk management. We further believe that a food safety objective
should be able to be measured practically, and this would usually
not be possible at the time of consumption.
In the above definition for Food Safety Objective, ICGMA believes
that microbiological hazards should be specified because these principles
and guidelines relate to microbiological risk management. We further
believe that a food safety objective should be able to be measured
practically, and this would usually not be possible at the time
of consumption.
"Product tracing/traceability": ICGMA agrees with the
working group that this any definition should follow the work undertaken
by CCFICS and other Committees in this area. Product tracing should
be limited to one step forward and one step back and implemented
for purposes of health and safety.
Section 3. General Principles
ICGMA believes that Principle 7, which is bracketed, [PRINCIPLE
7: In the case where scientific knowledge of the risk is insufficient,
it may be appropriate for risk managers to apply a precautionary
approach, through interim measures.], should be removed. We believe
that Principle 6, which states "Risk managers should take into
account the uncertainty of the risk estimate when making risk management
decisions." addresses uncertainty in microbiological risk management.
Further, with respect to the use of precaution, ICGMA notes that
the 24th Session of the Commission, July 2001, adopted the position,
in regards to the consideration of precaution, that “When
there is evidence that a risk to human health exists but scientific
data are insufficient or incomplete, the Commission should not proceed
to elaborate a standard but should consider elaborating a related
text, such as a code of practice, provided that such a text would
be supported by the available scientific evidence”.
Section 5.1.2 Identification of a microbiological food
safety issue
ICGMA agrees with the proposition of the USA that "a key step
in microbiological risk management is determining the available
resources (human, financial, time) for addressing the food safety
issue." A management plan will be implemented more effectively
when appropriate resources have been incorporated into the plan.
Section 5.2.1 Determining the appropriate level of protection
(ALOP)
ICGMA believes that sanitary measures used to establish an ALOP
should be based on scientific criteria. To this end we support the
removal of brackets from the words "scientifically justifiable
and" in the third para in this section, so that the para reads:
"The ALOP/ALR applies equally to both domestic and imported
food. The ALOP/ALR should be scientifically justifiable and clearly
conveyed to the exporting country."
The seventh para in this section contains examples of other factors
that may be involved in determination of ALOP. ICGMA believes that
the inclusion of the fifth bullet point (public risk reduction preferences,
public values) in the list of examples is problematic because these
factors could serve as trade barriers. . This example should also
be removed from 5.2.2.3, Other factors. If these
factors are considered in establishing a country's ALOP, they should
be based on objective criteria and should not be used as trade barriers.
5.2.2 Identification of available options
ICGMA supports deleting the last sentence, which is bracketed,
from this section.
(For information to the Int'l Working Group and ICGMA members:,
this sentence reads: [For countries, in that case, it may be appropriate
to adopt a precautionary approach in the microbiological risk management.])
Section 5.2.4 Final management decision - For national
purposes
ICGMA does not believe that the subsection, "For National
Purposes", should be included in the document. Risk management
advice at the national level is outside of the scope of this Committee,.
as it is being addressed by the Committee on General Principles
in its risk analysis document. We therefore suggest removal of this
subsection.
Section 6.3 Role of Product Tracing/Traceability
ICGMA supports the role of product tracing to facilitate the rapid
withdrawal of unsafe food products and food ingredients from the
market place when there is a public health threat, and supports
its incorporation into microbiological risk management programs,
specifically as a component of food recall systems.
Section 7.1 Monitoring
ICGMA agrees that monitoring is used to provide information on
risks to human health from specific hazards and/or foods, and that
surveillance of human populations includes investigation of food-borne
disease outbreaks and product tracing to the source of the likely
causal pathogen.
Again, ICGMA appreciates the opportunity to comment on the Proposed
Draft Guidelines for the Control of Listeria monocytogenes in Foods.
Respectively,
Mari Stull
Executive Director
International Council of Grocery Manufacturers Associations
cc: Secretary, Codex Alimentarius Commission
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