Final - 30 August 2001
Agenda Item 7 CX/FH 01/7
JOINT FAO/WHO FOOD STANDARDS PROGRAMME
CODEX COMMITTEE ON FOOD HYGIENE
Thirty-fourth Session
Bangkok, Thailand, 8-13 October 2001
PROPOSED DRAFT PRINCIPLES AND GUIDELINES FOR THE CONDUCT OF MICROBIOLOGICAL RISK MANAGEMENT
INTERNATIONAL FEDERATION FOR ANIMAL HEALTH (IFAH) COMMENTS
Introduction
Since this is a document concerning aspects of Risk Management, it seems appropriate that there should be some cross- reference to the equivalent document for Risk Assessment. Because of the close iterative linkage between these two steps, there should be some commentary on the preceding steps taken for Risk Assessment.
Similarly, one would expect some discussion on the subsequent stage of Risk Communication in accordance with the principles and guidelines for risk analysis as discussed by the CAC in July 2001.
In the first sentence of the document, it seems inappropriate to state that "risks from microbiological hazards are of immediate and serious concern to human health".
This is contrary to the whole basis of the principles of risk analysis, whereby the whole purpose of the process is to determine the level of risk in order to determine whether indeed there is any negative impact on human health. Therefore, we suggest that the sentence is amended to state that " risks from microbiological hazards may be of immediate etc…"
4. INVOLVEMENT OF STAKEHOLDERS
We agree that there is a requirement to include stakeholders in the process. However, there appears to be some confusion here as to how for all stakeholders are involved in the Risk Management process and the importance of their role at the stage of Risk Communication. Is it intended to have a separate document to discuss the Risk Communication steps? Without these steps, it would seem to be partially complete.
5.1.1 Identification of risk managers
IFAH would prefer to use the phrase "At the outset of a microbiological risk analysis activity, etc…" in the first sentence. The risk assessment process would be expected to proceed in advance of the risk management step.
5.1.2 Identification of a food safety issue
We suggest the insertion of the word microbiological between "a" and "food". There is a range of contaminants that can create a food safety issue but this document refers very specifically to those of microbiological origin.
5.1.7 Consideration of the process and the results of the microbiological risk assessment
Recent experiences of the review process for the use of Fluoroquinolones in the US in relation to microbiological hazards in food suggest that the brackets be removed from Bullet point number 4. IFAH supports the concept that the risk assessment is subject to peer review.
5.2.1 Identification of available options
Following discussions at the CAC July 2001 IFAH proposes the deletion of the final sentence in brackets at the end of this section. Precaution is a fundamental component of risk management.
For the same reason, 5.2.1.3 Precautionary principle can be deleted and cross-reference made to the CAC position adopted at its 24th Session in July 2001.
6. GUIDELINES FOR IMPLEMENTATION OF MICROBIOLOGICAL RISK MANAGEMENT DECISIONS
A fundamental component of implementation is the Risk Communication procedure and IFAH is surprised that there is no reference to this in this section.
7. MONITORING AND REVIEW
The Risk Analysis procedures call for an iterative and ongoing process of all the steps in the chain and the role of Risk Assessors and Risk Communicators are of ongoing and critical importance in this process. It would be useful to see some direct reference to this process in this section which covers some of these points in detail. It should be recognised that all stakeholders are relevant in the monitoring process and can provide significant inputs to the Risk Managers in the ongoing evaluation of hazards that may be identified in a review.
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