Position Paper
STATEMENTS OF PRINCIPLES ON THE ROLE OF SCIENCE AND THE EXTENT TO
WHICH OTHER FACTORS ARE TAKEN INTO ACCOUNT: ROLE OF SCIENCE AND
OTHER FACTORS IN RELATION TO RISK ANALYSIS
May, 2001
At the 16th session of the Codex Committee on General Principles
(CCGP) in April 2000, the Secretariat introduced a document on the
consideration of other legitimate factors. CCGP agreed that it should
provide general guidance on the use of such factors taking into
account views of the other Committees who are also involved in risk
assessment.
At the 17th session CCGP considered a revised document but could
not reach consensus on two bullet points. Those points remain in
square brackets and were advanced to the CAC to:
- Resolve the issues within the square brackets and
- Consider the criteria for inclusion in the procedural manual
as an explanation of the Statements of Principle.
Current Status of bullets in question:
* [albeit not within the mandate of Codex, certain factors may
be taken into account, if recommendations of relevant multilateral
intergovernmental organization exist. Codex standards should avoid
having a negative impact on the application of such internationally
agreed recommendations.]
The International Council of Grocery Manufacturers Associations
(ICGMA) believes that the inclusion of language allowing "certain
factors" to be taken into account in Codex's deliberations,
even thought these "factors" are admittedly "not
within the mandate of Codex," is fundamentally inconsistent
on its face.
Codex's brief is the development of standards and guidelines in
the area of food safety, based on the application of sound scientific
principles. The specific insistence on the inclusion of "other,"
non-science factors, or factors unrelated to food safety "not
within the mandate of Codex" in the discussion of standard
and guideline setting can only reflect a desire to broaden Codex's
criteria in the interest of promoting agendas other than food safety.
The idea that Codex standards should "avoid having a negative
impact in the application of internationally agreed recommendations"
in other functional areas also places at risk the integrity of the
scientific deliberative process. Based on this conceptual framework,
Codex would cede its authority to other bodies, even when those
bodies have improperly extended their own mandate to encompass functional
areas properly within the ambit of Codex.
Such a construction not only subverts the independence and scientific
integrity of the Codex deliberative process, it improperly and unnecessarily
subordinates Codex to other deliberative bodies with less competence
in the critical areas of food safety and health.
At the same time, it threatens the integrity and independence of
all international organizations by removing any lines of demarcation
based on competence and prescribed mandate, in the interest of social,
cultural and political objectives.
For all these reasons, the language at issue should be excised
in its entirety from the Statements of Principles on the Role of
Science and the Extent to Which Other Factors are Taken Into Account.
The International Council of Grocery Manufacturers Associations
is an international non-governmental organization (NGO) officially
recognized by the Codex Alimentarius. 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.
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