Food safety

White Paper On Food Safety

Principles of food safety
The German food industry welcomes the principle that food safety must be based on a comprehensive, unified concept covering the entire food chain, from the agricultural producer and his suppliers to shops and restaurants. Everybody involved in the food chain is responsible for food safety in his own particular province, i.e. the individual processing stages can only be held liable for the production steps under their control. A further important factor comes at the end of this chain: a responsible attitude on the part of the consumer.

Where safety is concerned, an integrated approach to a policy on food law must in our view cover all preliminary stages. The special aspects of the products must receive due consideration when assessing safety matters in the various preliminary stages. In the first instance the White Paper addresses questions of animal-feed law, but it does not link these to questions of the law covering pesticides, fertilisers, veterinary medicine; there are no indications of a unifying, integrative approach.

In this connection an important role could be played by the basic or framework directive on Food Law, which should contain definitions and principles of European food law and for which there is such a pressing need. The definitions in accordance with Community law which were mentioned in the Green Paper are of considerable practical importance here. This is particularly true with regard to standard definitions for foods, whereby it must be recognised that keeping the food sector distinct from the extremely broad-ranging definition of pharmaceuticals as set out in Directive 65/65 may prove problematic, particularly in the case of new products (e.g. functional foods, dietary supplements). Measures should be undertaken to establish a narrower definition of the term "pharmaceuticals", as the decisions taken by the European Court of Justice also point in this direction (emphasis on functions).

Further matters of urgency are general regulations to protect public health, the stipulation of defined areas of responsibility for those involved in the food manufacturing and marketing process (from stable to the table), Community legislation stipulating the provisions for mutual recognition with due regard to the decisions taken by the European Court of Justice and, finally, provisions regulating the non-applicability of the substantive regulations contained in the Product Safety Directive to Community food law in view of the latter's comparatively more specific, higher standard of safety.

Furthermore it will be necessary to provide for concrete crisis-management measures. In the event of a crisis there will be an overriding need for all those affected - plus the decision-makers - to be involved in its resolution. With regard to this we propose the formation of a European crisis centre involving the industry as well as the regulatory decision-makers. We naturally still believe that a national crisis centre should be established.

An important matter in this connection is the traceability of food and animal feed, together with their additives. Account must be taken of the fact that the food industry has already made considerable efforts with regard to traceability in order to make sure the right decisions are taken in a crisis. But it must be stated that in a number of fields product type and production methods set limits to traceability that can only be overcome with disproportionate effort, if at all.

We emphasise the need for an efficient application of the principle of mutual recognition in fields where no harmonisation has taken place.
We especially welcome the application of the internationally-acknowledged basic principles of risk analysis in the process of taking legislative and administrative food-policy decisions. Thus risk assessment and risk management must be strictly separated, as this is the only way to ensure the independent scientific evaluation that is a sine qua non for the creation of consumer confidence.

With regard to the application of the precautionary principle to the taking of risk-management decisions, it is our opinion that this must be subject to precisely-defined conditions. Only in cases where there is substantial health risk, and scientific findings - when risk assessment is complete - give adequate grounds for intervention, should time-limited measures based on the precautionary principle be taken. The precautionary principle must not be misused as a fig-leaf for political decisions that lack any scientific basis. We reserve the right to make a detailed statement on this, particularly with regard to the Commission's announcement of 2 February 2000 on the applicability of the precautionary principle.

Care must also be taken when applying other legitimate factors that these are of significance to the question of food safety and consumer protection. In the final analysis this field, too, requires the application of objective criteria in order to prevent abuse. An agreement at international level in accordance with the Codex Alimentarius is first of all required in this connection. In our view, only the internationally recognised factors should apply.
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