Agenda Item 3a) - CRD Final March 12, 2002  

JOINT FAO/WHO FOOD STANDARDS PROGRAMME

CODEX COMMITTEE ON GENERAL PRINCIPLES

Seventeenth Session

Paris, France, 15 - 19 April 2002

IFAH COMMENTS ON

PROPOSED DRAFT WORKING PRINCIPLES FOR RISK ANALYSIS

CX/GP 02/3

With regard to the revised text at Step 3 of the procedure following the working group held 5-7 December 2001, IFAH wishes to emphasise the following points:

Paragraph 7)

IFAH continues to have concerns that there is potential conflict between preservation of confidentiality and “documentation should be accessible to all interested parties”. We note that there is no definition provided yet as to what constitutes “confidentiality” and IFAH awaits further clarification.

Paragraph 11)

IFAH prefers to amend the first sentence to “Precaution is an inherent element of risk management”. We believe that the final word of this paragraph should read “risk” rather than “hazard”.

Paragraph 12)

“Specifically identified” for developing countries is placing a burdensome requirement and IFAH recommends deletion of this phrase to read “… should be taken into account …”

Paragraph 15)

IFAH suggests the following modification: “Risk assessment policy should be established in advance of risk assessment through consultation with risk managers, risk assessors and other interested parties in order to ensure that the risk assessment process is transparent, systematic, unbiased and complete.”

Paragraph 27)

IFAH recommends insertion of “Where relevant” at the beginning of this final sentence. We believe that the qualifying language is very important in this sentence.

Paragraph 43)

IFAH suggests inserting the phrase “where appropriate” after the final phrase “minority opinions”. This should not be mandatory but at the discretion of the risk managers/ communicators).