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Food Inspection & Certification Systems Based on Codex
By Shashi Sareen, Director, Export Inspection Council of India
Official and officially recognised inspection and certification systems are fundamentally important and a very widely used means of food control. With increase in global trade in foods, it is important that the food products exported are of the right quality and safe for consumption. Quality and safety can be assured through application of proper or well-designed inspection and certification systems.

Inspection of food may be done at any stage of production and distribution process or right through the food chain to include harvesting, storage, transport or even at retail level. Inspection systems may be focused in the food stuffs themselves or the procedures and facilities in the transport and distribution chain, on the substance and materials which can be incorporated into or contaminate foodstuffs.

To ensure that fair inspection and certification systems implemented by countries ensure consumer products and facilitation of trade, it is necessary that these are designed and implemented following certain basis principles.

With this in view, the Codex Alimentarius Commission, in its 19th meeting in 1991, decided to establish the Codex Committee on Food Import & Export Inspection & Certification Systems (CCFICS). The terms of reference of this Committee are as follows:
To develop principles and guidelines for food import and export inspection and certification systems with a view to harmonizing methods and procedures which protect the health of consumers, ensure fair trading practices and facilitate international trade in food stuffs;
To develop principles and guidelines for the application of measures by competent authorities of exporting and importing countries to provide assurance, where necessary, that foodstuff comply with requirements, especially statutory health requirements;
To develop guidelines for the utilization as and when appropriate, of quality assurance systems to ensure that foodstuffs conform with requirements and promote the recognition of these systems in facilitating trade in food products under bilateral/multilateral arrangements by countries;
To develop guidelines and criteria with respect to format, declarations and languages of such official certificates as countries may require with a view towards international harmonization;
To make recommendations for information exchange in relation to food import/export control;
To consult, as necessary, with other international groups working on matters related to food inspection and certification systems; and
To consider other matters assigned to it by the Commission in relation to food inspection and certification systems.

Activities of CCFICS
CCFICS has met 12 times since its establishment, the last meeting being in December 2003 in Brisbane, Australia and has developed the following documents;
Principles for Food Import & Export Inspection & Certification (CAC/GL 20-1995).
Guidelines for the Design, Operation, Assessment and Accreditation of Food Import and Export Inspection & Certification Systems (CAC/GL-26-1997).
Guidelines for the development of Equivalence Agreements regarding Food Control and Export Inspection & Certification Systems (CAC/GL 34-1999).
Guidelines for the Exchange of Information in Food Control in Emergency Situations (CAC/GL 19-1995).
Guidelines for Exchange of Information between countries on Rejection of Imported Food (CAC/GL 25-1997).
Guidelines for Generic Official Certificate Format and Production and Issuance of Certificates.

These documents are important and useful not only for import and export but also in designing food control systems for internal or domestic purposes.

Principles for Food Inspection & Certification
For design and implementation of any inspection and certification system, it would be necessary that certain basic principles are followed, which would ensure that foods and their production systems meet the requirements in order to protect consumers against food borne hazards and deceptive marketing practices. These principles are laid down in document CAC/GL 20-1995 and include the following;
Fitness for purpose,
Risk assessment,
Special and differential treatment,
Control and inspection procedures, and
Certification validity.

Components of an Inspection & Certification System
Design of food inspection and certification systems has been laid down in the guideline document for design, operation, assessment and accreditation of food import & export inspection certification systems – Document CAC/GL 26-1997. These guidelines provide a framework for the development of such inspection and certification systems consistent with the principles for food import & export inspection and certification as highlighted above. The requirements laid down should help and maintain necessary confidence in the inspection and certification systems, facilitate fair trade and take account of the expectations of the consumer for an appropriate level of protection both in domestic and international trade.

The basic components of food inspection certification systems are highlighted below:

Basic infrastructure
The basic infrastructure would include aspects such as potable water supply, continuous power supply, cold chain facilities and facilities at farm level such as wash rooms, laboratories etc. In most of the developing nations, many of these are not upto the mark and would require upgradation and investments. Developments in such areas may be a pre-requisite for addressing food safety and quality problems.

National Food Control Policy and Strategy
Food control activity is a multi disciplinary activity covering a number of aspects. A number of agencies would normally be involved in any country including government, research institutions, agricultural institutions, non-governmental organizations (NGOs), consumers etc. Their needs to be a suitable documented food strategy with clear objectives, well designed plan of action with role clarity provided for different players and clear networking within the organization.

Legislative framework
Food legislation includes Acts, regulations, and requirements or procedures prescribed by the government relating to food stuffs and covering the protection of public health, protection of consumers and conditions of fair trade. The food control needs to be simple, complete, covering all aspects of food chain and address issues of safety and not to be unduly prescriptive. It should provide authority to carry out controls at all stages of the food chain including production, manufacture, importation, process, storage, transportation, distribution and trade. It should, further, be flexible to allow taking into account new technologies, developments and changing trade needs. It also needs to be WTO compatible and as far as possible, be based on Codex standards, guidelines and recommendations. Legislation may also include provisions for registration of establishments or listing of certified processing plants, establishment approval, licensing or registration of traders, equipment design approval, penalties in the event of non-compliance, coding requirements and charging of fees. Necessary provisions need to be included for ensuring integrity, impartiality and independence of the official and officially recognized inspection and certification systems.

Control programmes and operations
Inspection services should draw up control programmes based on precise objective and appropriate risk analysis. HACCP approach in which there is a shift from end point inspection to a Quality & Safety Assurance & Management System Based approach should be encouraged. Under this system, the responsibility of meeting the food quality and safety regulatory requirements lies with the food industry with all segment of food chains having responsibility for establishing food safety and quality controls. The responsibility of food control regulators is to ensure, through a systems of surveillance of industry and various other components of the food chain that they meet the requirements that have been specified.

Elements of a control programme should include the following:
Sampling and analysis
Checks on hygiene, including personal cleanliness and clothing
Examination of routine and other records
Examination of the results of any verification systems operated by the establishment
Audit of establishments by the national competent authority
National audit and verification of the control programme

The administrative procedure should be in place to ensure that controls by the inspection systems are carried out regularly proportionate to degree of risk, where non-compliance is suspected and in a coordinated manner between different authorities (if several exist).

Control should also cover, as appropriate, the establishment, installations, means of transport, equipment and material; raw materials and ingredients for preparation and production of food stuffs; semi-finished and finished products; cleaning and maintenance products; processes for manufacture or processing of food stuffs; preservation methods; labelling integrity and claims etc. Formal documentation of control programmes is also necessary.

Decisions criteria and action
Control programmes should target at the appropriate stages of operation depending on specific objectives. The frequency and intensity of controls should be designed to take into account the risk as well as reliability of controls already carried out by those handling the products at various other stages i.e. production, manufacturing, import etc. The checks applied to imported products should also be based on risk and reliability of controls of the exporting country. In case the imported product does not conform to requirements, the resulting measures should be proportionate to degree of public health risk, potential fraud or deception of consumer. In case of rejected product, information should be exchanged as per the guidelines CAC/GL 25-1997 – Guidelines for the Exchange of information between countries on rejection of imported foods. Such information on rejections should be provided immediately to the importer, exporter, and food control authority of the exporting country covering identification of food concerns; importation details; rejection decisions and reasons for the same and the action taken.

Facilities, equipment, transportation and communication
Adequate facilities including equipment, transportation and communication facilities should be available to ensure delivery of inspection and certification services.

Laboratories are the backbone of the inspection and certification activity. The capabilities in terms of equipment and manpower should be such as to test to requirements prescribed not only in domestic legislation but also to cater to the requirements of importing countries. The laboratories should have state-of-the-art equipment and manpower that is qualified and trained to operate such equipment. The laboratories used by the inspection and certification services need to be accredited under officially recognized programmes to ensure that adequate quality controls are in place to provide for reliability of test results. Internationally accepted quality assurance techniques should be implemented to ensure reliability of analytical results.

Manpower is one of the most significant resources that need to be constantly developed and empowered with the latest knowledge and skills to be able to understand the needs of food quality and safety controls and implement the same. Official inspection and certification services should have access to sufficient number of qualified personnel as appropriate in areas related to food science, technology, chemistry, biochemistry, microbiology etc. The personnel should not only be capable, but appropriately trained in areas of inspection and certification systems, audit techniques, risk analysis techniques, testing, technological aspects etc. and should have a status that ensures impartiality and have no direct commercial interest in the products or establishments being inspected or certified.

Certification systems
Certification should provide assurance of conformity of a product or a batch of products or that a food inspection system conforms to specified requirements and should be based as appropriate on regular checks by the inspection service; analytical results; evaluation of quality assurance procedures linked to compliance with specified requirements; any inspection specifically required for the issuance of a certificate. The competent authorities should take all necessary steps to ensure the integrity, impartiality and independence of official or officially recognized certification systems.

Official accreditation
Inspection or certification bodies may be officially accredited to provide services on behalf of official agencies. These bodies shall comply with criteria laid down in International standards such as ISO/IEC 17020, Guide 62 and 65 as well as Codex Guidelines for the Design, Operation, Assessment and Accreditation of Food Import & Export Inspection & Certification Systems especially in relation to competence, independence and impartiality of personnel. The performance of these inspection and certification bodies should be regularly assessed by the competent authority. 
Assessment and verification of inspection and certification systems
The national system should be subject to audit separate from routine inspection, may be self-evaluation or by third parties. Internationally recognized assessment and verification procedures should be used. Guidelines for conducting assessment and verification of an exporting country by an importing country have been given in the Annex to CAC/GL 26-1997, which may also be useful during audit at the national level. An importing country may take a review of the exporting country, if agreed to.

For any decisions relating to food control systems, both developmental as well as implementation, there is a need to have information as well as data that is scientifically collected, shared with decision makers and implementers as well as processors. This would include information on regulatory requirements not only in the domestic sector and international market but also that of importing countries; data on residues and other parameters which would help in framing regulatory requirements as well as be used for decision making on implementation actions to prevent food borne hazards, planning food control activities etc. It may be mentioned that while ensuring transparency, any constraint of professional and commercial confidentiality should be respected.

Other factors
In addition to the design of inspection and certification systems based on Codex, certain other additional components would need to be addressed. Of specific relevance would be the guidelines for food import control systems that have been specified in the other guideline documents of this Committee. These guidelines provide a framework for development and operation of an import control system keeping in line with objectives of Codex i.e. to protect consumers and facilitate fair practices in food trade while ensuring that unjustified technical barriers are not introduced. Some of the important components of food import control systems include requirements for imported foods which are consistent with requirements for domestic foods; clearly defining responsibilities of the imported food control authorities and transparent legislation and operating procedures; and provision for recognition of food controls applied by an exporting country’s competent authority. These would also clearly need to be taken into account while designing a food control system.

Participation in the work of Codex and other international organizations is also a very important factor to ensure that the viewpoint of the countries is taken into account in international standards setting. It is also necessary that sufficient data is generated in the country and presented at various fora.

The international trade in food is growing rapidly as countries rely on each other to provide adequate and varied food supply through import and export of food products. With globalisation, countries are having improved access into the export markets, but this access is leading to greater competition and the need to ensure confidence in the safety of the food supply. While the onus is on the food industry to produce food that is safe and of high quality, governments are responsible not only for ensuring that the industry is providing safe food which meets the health requirements of the consumers as well as the regulatory requirements of the governments, but also to ensure that the importing country allows entry of such foods without unnecessary restrictions. This would be achievable if the design of inspection and certification systems are based on international standards and accepted as equivalent by the importing country.

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