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Comments and Correspondence
IGCMA COMMENTS ADDRESSING PROPOSALS TO INTRODUCE THE "PRECAUTIONARY
PRINCIPLE" INTO THE DELIBERATIVE PROCESS OF THE CODEX ALIMENTARIUS
COMMISSION
September, 2001
My name is Mari Stull and I am speaking on behalf of the International
Council of Grocery Manufacturers Associations (ICGMA). ICGMA represents
the interests of national and regional associations representing
all sectors of the grocery industry and serves to facilitate harmonization
of standards and policies concerned with health, safety, packaging,
labeling, advertising and marketing of foods, beverages and other
grocery products.
We do not believe that Codex Alimentarius should debate formalization
of the "precautionary principle." Doing so would only
give the misguided principle credibility. There are four reasons
why it should not be debated within Codex:
- Precaution is already a part of decision making.
- It could undermine the scientific objectivity and integrity
of Codex
- It would send a clear message that current Codex standards
are insufficient to assure safety – even when applied correctly
and with diligence. In those cases where food safety has been
at issue in recent memory, the cause was not the absence of an
all-encompassing Codex standard of precaution, but rather the
human failure of national regulatory bodies, which had at their
disposal the necessary precautionary mechanisms but failed to
use them.
By giving credence to this debate, Codex would take a momentous
step back from the challenge set for it by the World Trade Organization
- that it serve as a basis for expeditiously and fairly resolving
questions that impede the free and safe flow of food products between
nations.
Summary
Member states presently apply, on a daily basis, precaution
in the exercise of their responsibilities in ensuring food safety; A so-called "precautionary principle," prescribed
by states or regions and imposed on the whole of the world community
in the form of Codex standards and subsequent amendments to the
Sanitary and Phytosanitary Agreements, would be redundant, impractical
and worse, a potential trade barrier; Such an outcome is inconsistent with the principles
and objectives of the Codex Alimentarius Commission and the World
Trade Organization;
Codex must remain consistent with its mission, working to ensure
that member countries are better able to apply recognized, existing
standards in their risk analysis and risk management processes,
and not expend time and resources on the definition and development
of a “precautionary principle” that will not contribute
to the objective of providing for safe and universally accessible
food to all nations.
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