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Food safety

White Paper On Food Safety

The European Food Authority
The German food industry is of the opinion that a European Food Authority may contribute to the creation of confidence in the European legislative system on the part of consumers and industry. It will be necessary to restrict the duties of this authority to risk assessment and communication.

Against the background of the principles of food safety specified in Part I of our statement, the authority can play a useful role in the restoration and maintenance of confidence on the part of consumers and industry.

Principles of risk analysis


We particularly welcome the fact that the establishment of the European food authority is to observe the principle of separating risk assessment from risk management. It is of paramount importance for consumers` and industry's confidence in scientific risk assessment that internationally-acknowledged risk-analysis rules are complied with.

Tasks


The list of the tasks of a food authority seems to us to be extremely long, though most of them are necessary. It will not be possible, however, entirely to exclude certain aspects of risk management from its work. This applies to the operation of the "early-warning system" and to "communication" with the public. However, if discussions about "communication" should lead to the conclusion that in this connection it ought to be among the responsibilities of the food authority, then the authority must set itself clear guidelines defining what information is given to whom, on what conditions, and when. Committed supporters of the principle of transparency though we are, we must still ensure that the principle of confidentiality is preserved and that of proportionality applied.

The list of tasks should also expressly include providing the Commission and member states with scientific advice on contentious questions of the free movement of goods, as well as on solving conflicts in the field of world trade. Such an authority is particularly well-placed to play a major role in cases where there are diverging views in the internal market about the scientific assessment regarding certain questions that may result in threatening the principle of mutual recognition.

We also argue that the authority should concern itself with all scientific questions of food safety, wherever they may arise along the food chain. It should particularly undertake scientific assessments necessary in the preliminary agricultural stages, e.g. in animal-feed production, whenever these may affect food safety.

Principles


The fundamental principles of a European food authority must be independence, the utmost scientific competence and transparency.

We support the view of the Commission that the European food authority must be independent of current EU institutions.

On no account may the work of such an authority be financed by involved parties - the industry, for example - as this might call its independence into question. It is important for it to be financed exclusively by the European Union.

Scientific community


It should have access to first-class expertise in all important branches of science in the EU and beyond. Maximum advantage must be taken of specialist knowledge, information and expertise already available in national organisations concerned with food safety.

Crisis management


We welcome the White Paper's proposals for the role of the authority in cases of crisis management. Here a unit operating at the highest scientific level can play a significant role in advising the Commission and member states.

Product safety directive


The proposal for revision of the directive on "General product safety" submitted by the Commission at the beginning of April will require critical examination, in view of the aim of expanding the early warning system and establishing guidelines for its mode of functioning and the appurtenant procedures. The system is to be expanded on the basis of "voluntary measures initiated by or agreed with the authorities"; participation by non-EU countries or international organisations is also to be possible.

If manufacturers or traders are to be required to notify the competent authorities forthwith of unsafe products in the future, the question arises as to whether "tacit recalls" will then also be subject to such notification requirements.

Early-warning system


We are receptive to the idea of giving the authority responsibility for the early-warning system. We wish to emphasise once more, however, the crucial importance of making it work better.

Such an information system constitutes an indispensable instrument to safeguard consumer protection; it is precisely for this reason that it should be operated with special care, so as to ensure that the recipients of the information do not become inured to its warnings. The current system which is operated by the Commission suffers from the fact that it is cluttered with communications containing incomplete or trivial information. The form and manner in which the communications are dispatched means that they are always received as urgent "warnings", which are often unfounded and which may, in isolated cases, cause great damage to companies.

A much clearer distinction is required between "warnings" (rapid alert notifications), i.e. occurrences which necessitate urgent information measures and counter-action "informational communications" (non-alert notifications). It is sufficient to discuss the latter in a separate information exchange process, as all the necessary measures have already been undertaken.

According to the White Paper, the European Food Authority is to "operate the early warning system" and, where appropriate, carry out further observation measures. In principle, the BLL is in favour of the rapid alert system being operated by a technically competent body which is also capable of carrying out scientific risk assessment in individual cases ("expert filter").

The Commission's proposals in the White Book regarding expansion of the rapid alert system, which to date has been limited to official objections, is to be seen in a more critical light: Companies are to be obliged to provide "notification" of internal events, i.e. "tacit recalls" will be subject to official notification. This would breach fundamental principles of individual responsibility and confidentiality for the food industry.

It is essential to focus this information system on really important instances of food safety, separating it completely from the mere forwarding of other information of a non-urgent nature.

Relationship with the Scientific Committees


As we understand it the White Paper makes no clear statement about the relationship between the authority and the existing scientific committees. We wish to say at the outset that we have in the past had no occasion to criticise the content of the work of these bodies and their highly competent members - but the same can most definitely not be said of the obvious shortcomings in their organisation, and hence ultimately in the efficiency of their activities.

We can imagine the authority, for example, acting as a sort of "secretariat" of the committees, providing preparatory and organisational scientific support and thus enabling the scientists to concentrate on their real work. Careful consideration must be given to the question of who issues a scientific assessment: the committees or the authority.

When the details of the collaboration are being worked out, account should be taken of the recommendations of the December 1999 study "The Future of Scientific Advice in the EU" by Professors James, Kemper and Pascal.

Network


We especially wish to emphasise the need for close cooperation between the European food authority and the national scientific authorities and other institutions concerned with food safety. One question in particular must be resolved: that of differing or even contradictory assessments within the EU. This is what makes it so important to involve national experts, so that the findings of a European authority cannot be called into question.

Expert involvement


The White Paper is very vague on the subject of the involvement of experts by the so-called "circles concerned".. To avoid any misunderstanding we wish to state explicitly that independence must be one of the fundamental principles of the work of the authority. However, independence must not preclude experts in the circles concerned from playing any part in the authority's deliberations. On the contrary: it should make maximum use of specialist knowledge at every stage of the food chain. Clear structures must be created enabling the "circles concerned" to make an input without compromising the authority's independence. In this connection we would once more refer to the study by Professors James, Kemper and Pascal.

In conclusion we should like to emphasise once again that a European food authority could fulfil an important role in matters of risk assessment and risk management. It will be crucially important to create an authority at the highest possible scientific level and of impeccable reputation, which will inspire both consumer and industry confidence by providing irrefutable scientific advice to serve as the basis for responsible political decision-making.
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