August 7, 2012

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Re: GMA Comments on Proposed Draft Principles and Guidelines for National Food Control Systems at Step 6

Dear Mary and Mike:

Thank you for considering these informal comments on behalf of the Grocery Manufacturers Association (GMA). GMA is a strong supporter of the work of the Codex Committee on Food Import Export Inspection and Certification Systems (CCFICS) and believes that the proposed Principles and Guidelines for National Food Control Systems will be a valuable tool both to assist developing countries in designing and implementing national control systems, but also to bring some consistency and harmonization globally. GMA believes great progress has been made on the document but improvements can still be made for clarity. To derive the best value, the document needs to be very clear and user friendly.

While, this document addresses National Food Control Systems “sale of foods within national borders,” GMA underscores that all national systems are dependent upon a global supply chain and suggests that within the context of this document, stronger linkages to the responsibilities and relationships to import and export control should be made. The introduction references appropriate Codex texts but is not clear on why these are relevant or are important pieces of the national control system. The framework and policies of the national control system do need to include policies related to interaction with trading partners and products in trade. GMA believes that this is a significant gap in the text which could be corrected by clarifying introductory remarks or new text within the appropriate sections that either reference appropriate Codex text or includes new language clarifying the global interaction (for example, Section 4.1 would clarify that policy goals must take into account international obligations and that control programmes would be established for import and export control reference to Codex text).

The following comments are primarily editorial in nature:

Recognizing, the Principles and Introduction have already been adopted at Step 5, GMA believes some editing would still be helpful. Generally, throughout the document, there are far too many “where relevant,” “as appropriates” and similar language. This language undermines the substance of the text and is generally unnecessary.

Introduction: Delete “as appropriate” in paragraph 1 and “where appropriate” in paragraph 4.

Paragraph 1: “Various approaches may be used to achieve an effective national food control system.” - “As appropriate” is redundant.

Paragraph 4: “Competent authorities may apply these principles and guidelines in designing and implementing national food control systems.” - The “where appropriate to particular situations” is unnecessary as there is nothing mandatory about this guidance and this language comes very close to deferring to national circumstances which is inappropriate in an international standard.

Paragraph 8: Delete “in the event of a conflict.” This language actually weakens the statement. If this priority needs to be underscored, perhaps the anticipated “conflict” should be identified specifically.

Paragraph 13: “…to ensure effective operation of the national food control system,” It may be helpful to add “provide oversight and ensure….”

Paragraph 14: Delete “where relevant...” It is always relevant for consumers to manage risks under their controls and be provided with information with “relevant” information to do so.

Paragraph 18 could use some editing or reordering.

Paragraph 23: Do we want to “facilitate” consumer confidence or facilitate trade and enhance consumer confidence?

Section 4 Framework. This section looks really good and reads well and does reference supporting trade.

Section 4.1: Policy Setting

Paragraph 30: Is “consumer demands” the appropriate terminology? Suggest alternatives: “consumer expectations,” “consumer needs.”

Paragraph 34: Edit

Paragraph 36 does not flow well – tenses in the bullets are not aligned well with the chapeau. In bullet 5, include legislation “and regulation.”

Section 4.2: System Design. The substance is all here but this section is not “reader friendly.” It is in this section, that confusion arises between the “system” and “the control programme,” “control programmes,””control programs” “compliance and enforcement programmes” and “control measures” and how they interrelate. It may help somewhat to refer to programmes either in the singular or plural but not both and to reorder the paragraphs so that 47, 48 and 50 are brought forward within the section. It may also be helpful to consider subtitles or groupings based around the “programmes” such as “compliance and enforcement programmes,” “food recall programmes” “communication programmes” …

Paragraph 47: Reorder to a more logical flow, food safety factors first.

Section 4.3 Implementation: This section generally looks quite good but may also benefit by highlighting or subheading sections such as, “training,” “third party providers,” “laboratories.” I am generally pleased with the consistent references to stakeholder engagement throughout this text and note that paragraph 67 includes a bullet point on stakeholder engagement. However, there is no further reference to stakeholder engagement within the implementation section – no “how to” advice. Being sensitive to discussions in other negotiating for a about stakeholder engagement, GMA strongly encourages the addition of some basic guidance on how to engage stakeholders.

Suggested paragraph 79bis: In order to promote consumer confidence, the competent authority should have in place a program for engagement with stakeholders including the food industry, consumers and other interested parties. Such program should include: public meetings, education or outreach events and dissemination of information through electronic or other means.

Section 4.4 Monitoring and System Review: It seems that this section should include a role for third party auditing and review. While the parties engaged or responsible for this review are not very clear, the specific recommendations on mechanisms (e.g. information on foodborne illness, non-compliance incidents) are very good.

Thank you for consideration of these comments. I would be pleased to talk with you further.

Sincerely,

Peggy S. Rochette

Sr. Director of International Affairs