CODEX: International Guidelines for Monitoring the Performance of National Food Control Systems

CODEX is continuing to pursue initiatives with the Committee on Food Import and Export Inspection and Certification Systems (CCFICS) and the Guidance for Monitoring the Performance of National Food Control Systems(NFCS) 

What do or should these CODEX initiatives mean for international food trade? What should these initiatives mean for local and international food businesses?

Benefits to Participating Countries

The U.S. is a key contributor to the CODEX National Food Control Systems (NFCS) initiative, yet FDA appears to be ignoring it in the Foreign Supplier Verification Programs (FSVP) under FSMA - http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm361902.htm. Little is said about NFCS in the proposed FSVP rule if it has even been mentioned or considered.

In the Globe and Mail report of Mar. 01, 2016, the U.S Agriculture Department gave the Canadian Food Inspection Agency until mid-March to fix significant food safety and sanitation concerns found during an audit of Canada’s meat, poultry and egg inspection systems.

In a news release as far back as November 20, 2014, Canada was said to rank first out of 17 countries (including the U.S.) on food safety performance. So which observation is correct, or what has gone wrong?

With a common frame of reference that CODEX will be able to provide for assessing the acceptability of food shipments among countries, one can immediately see the value of the CODEX Guidelines for Monitoring the Performance of National Food Control Systems. Even in the example of the spat between the U.S and Canada, the usefulness can be seen. The U.S. and Canada are identified as participants in the CODEX initiatives. The benefits will predictably spill over to local and international food businesses within the participating countries.

Re-direction of Focus and Elimination of Wasted Resources for Food Businesses

While the kinds of wrangling between nations as reported between the U.S. and Canada take place, food businesses that cannot avoid being caught in the crossfire remain buried in the redundancy of private certification schemes. Clearly, food companies need to wake up and smell the coffee. The real battles are being fought on fronts where private certification schemes have little if any effect beyond forced and fictitious claims.

The truth cannot be more clearly exposed. Private certification schemes do not carry the force of law nor do they currently serve any arbitrator role in resolving cross-border trade wrangling as exemplified in the Canada-U.S. example. In fact, the respective country’s regulations rightly grant only a limited credence or acceptability to private certification schemes as presented in the FDA FSMA comments on GFSI  and the CFIA policy on private certification.

Where it really matters, private certification schemes also do not seem to have any quantifiable and verifiable results that show any significant reduction of product failures. They certainly do not provide litigation reprieve when illness is the onlyproof required.

The argument about the acceptability of private certification schemes as the savior of international trade is getting further weakened as CODEX pursues its initiatives with the CCFICS  and the NFCS.  Empty claims are frequently made about the superiority of private certification. In reality, the certification process distracts and places the burden of wasted resources on food businesses due to the unnecessary duplication of requirements already imposed by regulations. This reality belies any assumptive conclusions about the synergy that exists between regulations and private certification schemes.

It has been reported that private certification will grow to $19 billion plus by 2019. This makes it very attractive to prospectors who would almost defend the merits of certification with their lives. Given the demonstrated redundancy of certificates, one can easily see the gains to be made if the $19 billion were to be used for fortification programs instead of certification schemes.

Conclusion:

A common ground for monitoring the performance of national food control systems provided by CODEX, a body that is internationally recognized, and with the direct participation of the nations involved is much needed. It should prevent unproductive and often baseless international wrangling.

Food businesses also have much to gain from the CODEX initiatives. They will suffer less cross-fire casualties. Besides, the initiatives provide the opportunities for food businesses to optimize the use of their resources in pursuing profitable regulatory and scientific solutions instead of wasting such resources in pursuing superficial certificates. It is not s secrete that current certification schemes merely regurgitate CODEX guidelines anyway. They may use other sources that are also already available to food businesses. Information from these sources are merely put together by the schemes and used for their pre-occupation with offering no more than criticisms. These schemes (under the guise of avoiding conflict of interest) refuse to get involved in providing real and practical solutions. 

Food businesses need to simply focus on fortifying their food control systems according to the emerging CODEX guidelines and the applicable national regulations. These, along with the specific scientific and technical knowledge that applies to each operation, provide adequate technical and management information to make private certification redundant.

Private certification is already of little to no consequence in less privileged parts of the world. Yet food comes to the more affluent part from these less privileged regions. This calls for a different mobilization in addition to the Codex CCFICS and NFCS initiatives. It is the mobilization against inequality. It is the mobilization of collaboration where more affluent nations provide financial and technical assistance to the less privileged.

Posted by Felix Amiri

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Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.