Transcript of Dr Richard J.

Dawson’s Presentation

Thank you Dr Hedley, that was a tremendous introduction from my point of view. I only know of one better introduction and that was recently, when I was in Beijing, the Chairman was ill and I had to introduce myself. Now, that was an introduction.

I am very pleased to be here with you all this afternoon. The Director General of FAO, Dr Jacques Diouf has asked me to express his kind appreciation for inviting FAO to participate in this very important seminar. What I am going to do this afternoon, if I may – I just have to learn how to use computers; I do have a degree in criminology but that doesn’t make me computer literate – I want to talk about the control of food safety, and my title “Is That Enough?”. I think you may have a copy of my planned presentation. If you do, disregard it because I am going to give you another presentation. Because when the organisers asked me to come and speak on this subject they gave me a whole long yardstick of items that they want me to discuss, so I thought I’d put one in a paper and discuss the other with you here today. What I really want to talk about is, I want to talk a little bit about food quality, food safety; I want to talk about the international perspective and the importance that this plays to an organisation, to a country, to an administration, in controlling their food quality and safety. In some instances, cities, governments, say that international aspects don’t have any bearing on them and that they will take care of their own activities. Unfortunately, that is not the case any more, especially in food and the way that food is being traded today. So, what I am going to talk about, I am going to talk about food safety, food quality, problems encountered in this. I want to talk about the Codex Alimentarius. Has anybody heard about the Codex Alimentarius? Anybody raise their hand if they have. Not many people – one. Well, I’m going to try to explain what the Codex Alimentarius is and what it does for you, and hopefully I am more successful than I am with my mother. My mother is 96 years old – 97 now – she is very healthy, and when I left the FDA in 1980, to join the FAO, I told her I was joining the Codex Alimentarius. Whenever I’m back in the USA I try to explain what I do. She still, today, thinks I’m a travel agent


because of all the postcards that I get and she does not understand Codex. When I talk about FAO, she thinks I’m talking about FAO Schwartz – but that’s a different operation. So let’s get into the presentation, if I can.
When I was getting ready to do this presentation, I saw a piece in the paper that appeared in Bangkok, and it is on “Counterfeit ‘Del Monte’ Corn Creeps into Hong Kong Stores” and I said to myself, the title of the presentation you are talking on is ‘Food Safety’ but how many people have forgotten the aspects of food quality. And it appears today in the world that more and more people are only looking at the aspects of food safety and forgetting the very important things of food quality. And the counterfeit Del Monte corn that you people had here in Hong Kong, certainly falls under the aspect of adulteration and not really under a food safety problem because the product was repackaged, and probably to the temperature necessary, so the safety was not an aspect, it was the other aspects of filth and things that really don’t fall under food safety terms.

So, we know that food is a source of health for one thing, it provides the substance to do our jobs and to live. It’s our life. It’s a pleasant thing. Especially, just before I came here I was fortunate enough to fill my stomach with some very good food which I liked very much. So it’s an enjoyment, it’s a necessary evil. You have to have food. Now look at what I call and what the UN calls food quality. It’s total features and characteristics of a product or service that bear on its ability to satisfy the stated or implied needs. Not I must stress “total”. Food quality includes safety as well as the quality aspects. It includes them both, safety and quality. The UN talks about food control or food quality, and we always refer to that, that it means both: the quality aspects as well as the safety aspects. Food safety - the specific definition: All conditions and measures that are necessary during the production, processing, storage, distribution and preparation of food to ensure that, when ingested, it does not represent an appreciable risk to health – appreciable risk to health. That is the official definition that we will talk about on food safety. Food control - now what does that encompass? It means assuring both food quality and food safety, both aspects. Now, let’s look at food trade for a minute. I said I wanted to get into the

aspects and the dimensions of trade. Is it a big business today? I’d say so. Three hundred billion US dollars a year, plus, in trade. Very, very important and very important to the countries of Asia because it earns money. That means over 475 million metric tons. A lot of food is being traded. We now talk about the globalization of food or the internationalization of food. Food, really, isn’t any more – it’s not regional, where it was at one time. I can go to San Francisco and find the same foods on the shelf that you find here in Hong Kong. I can go down in Latin America and Brazil and find the same foods. Likewise, you can find many other foods from these countries. So, trade has become a real big business and to ensure the safety and quality of these foods is a very important item. It is also, I think, from a perspective of living in Hong Kong that you people realise, and you probably already do, that 61% of the world’s population lives in Asia. Sixty-one per cent. That means a tremendous market, not only for exports for food but also for food imports. Now let’s look at some of the food problems. We have microbiological problems. You’ve heard, I guess, about some of the problems that the US has been having on microbiological problems. Some of the problems encountered with E-coli 157, in Japan. I understand it has been found here also in Hong Kong. To our knowledge it has not been found yet in a tropical climate country – subtropical, yes. Chemical problems - pesticide residues; other chemicals - food additives that we look at. We do find a problem around the world about excess of residue contamination. Natural occurring toxins – and these are the mycotoxins or the aflatoxins, which I’m very sure that you people understand the aflatoxin problem of contamination. You know when Chernobyl blew up in Russia several years ago, there was a problem with radio-nucleides, and everybody was worried about the problem


of radio-nucleides and I remember, at a Codex meeting, at an international meeting, we were discussing trying to set the levels of acceptable radionucleides. The Asians all came to that meeting and said it should be zero residue level in any food product. Fine. The next meeting we had, it was on mycotoxins, aflatoxins. The Asians came in and said the limit should be very high. So you see, there is a difference between what part of the world is affected and what part of the world is not affected. The Chernobyl problem did not affect Asia, so Asia wasn’t interested in setting any limits. Aflatoxins certainly cost a lot of money to the Asians and therefore they want a higher limit. So our job is to try to settle the dispute and come up with something that is acceptable between all countries. Adulteration - this is something where we also get involved in quality as well as the safety aspects of food. And another very big important one is misbranding. Not many people look at misbranding any more but it is a serious problem and an economic cheat that should not be permitted. Short weight is another problem that we encounter throughout the world. If you can see this slide, it shows from one country, the USA, the detentions, in 1996, from Asia – and I am only including Asia and I’m not including Hong Kong - but you see that the highest percent of detentions by the US Food and Drug Administration on products from Asia, was actually filth, where most people think that the problem of food trade is microbiological problems or chemical problems. Not so. The second one was on low-acid canned food, and this is against the violations of the US Government. Decomposition and microbiological contamination were also high, as was labelling. This is information that is useful to many organisations and governments in trying to determine where they should set their priorities within their limited resources. I was going to bring with me the latest detention list of products shipped from Hong Kong to the US, but I thought it might be insulting. It’s quite large. And you are having a lot of your products that are shipped from Hong Kong, probably trans-shipped out of China Mainland, to the USA, and it is worth for authorities and industry to take a look at that information. It is very valuable and useful.

Now let’s talk a little bit about the Codex Alimentarius, and obviously there is not much knowledge of the Codex Alimentarius here today. It is an intergovermental organisation that was established in 1962 by FAO, the Food and Agricultural Organisation of the UN, and by WHO. It currently has a membership of 163 member countries. That covers 98% of the world’s population. Codex Alimentarius – what is its purpose? The main purpose is consumer protection, and we are only talking, now, about food. The protection of the consumer from unfit or unsafe food. Also, we talk about the facilitation of trade, that is another main purpose, to ensure that there are fair trading practices between countries and that we don’t have trade disputes between the countries. And the last primary objective is that it co-ordinates. Its purpose is to coordinate all the work on food standards throughout the world. And this is talking about work with ISO, and talking of work with any other regional or national standards body doing work on food standards. Now, what is Codex? Codex, if you translate it, it starts out from the Latin word that translates into ‘Food Code’ or ‘Food Law’. Very simple and very basic – food law or food code. It is intergovernmental with national representatives from governments. This means that anyone that goes to a Codex meeting, the ones that speak are the intergovernmental representatives – representatives from governments. In addition, it includes advisers or observers from industry, consumers and academia. The work programme – it prepares food standards, it prepares guidelines on food, and it also prepares codes of practice. Now, I mentioned that the membership currently of Codex is 163 countries and that means we have to get agreement amongst the 163 countries, to pass one of these laws, regulations, guidelines or codes of practice, and that is very, very difficult, but it does work. I know when I worked for the US Government, we could not even get agreements within our own administration. But here we are getting agreements throughout for the 163 member countries. The budget - very small, for a big organisation, US$5 million every two years.


It only has six professional employees to handle all the work throughout the world. One thing about Codex Alimentarius is that it dictates that each member country, 163 member countries, must have a Codex contact point for the purpose of exchanging information and receiving information about food standards, food safety issues, food quality issues, so we have 163 contact points throughout the world. I was going to ask you if you knew where the Chinese National Codex contact point is located. It is located in the Ministry of Agriculture in Beijing. However, in actuality, in China, the Ministry of Health does most of the work on Codex and food standards and codes of practice and what-have-you, and there has to be good co-ordination between the two. Codex decisions are all science based. That is a very important issue, that it isn’t based on the public opinion, it is based on a science issue. If science cannot support the discussion, the discussion is closed. The issues and decisions must be all science based. Controlling Food Quality: Now, there are very, very many methods of ensuring the food quality and safety of foods but one of the simplest ones and probably one of the best ones is good hygiene practices. Following that, you have what we call GMP’s, the Good Manufacturing Practices, and this is guidelines not only for the industry, whether it be a restaurant industry or a big food industry, but it is also guidelines for the food control officials to go and do their work, to do their inspections, and to make their analysis correctly. We have what we call HACCP (Hazard Analysis Critical Control Point) technique, and that followed the work by NASA in the USA, on zero defects, and it’s a hazard analysis type of system where you analyse what the hazards are and try to correct the control points in the system. And the last one which has come forward now, a very important new one, is what they call risk analysis, and it will be in vogue, it will be the way that food control officials do their inspections for the next several years, and the way that

administrations set their rules and regulations. Risk analysis, basically, covers three areas, with the first being risk assessment where you go out and assess what the risk is and bring back the information for the managers. Following that, the managers look at it and then they must make a management decision, and we call this risk management. And following that is a very, very important one, risk communication. How is the risk encountered? How is that communicated to not only the control officials, not only to industry, but also to the consumer. And it has to be done in a proper way, in a way that people understand, not only the industry but the consumers, as well as the control officials. FAO and WHO have recently held what we call expert consultations, on each of these subjects, and the reports are available for anyone. There is no charge for the information put out by Codex or by the FAO on these subjects, and as I say, the latest vogue, the latest way that control of food quality and safety will be carried out. Let’s quickly look at another organization. Everybody know the World Trade Organization? It formed from what they called GATT, the General Agreement on Tariffs and Trade, and it came into being in 1995, 1st January. It now has 123 member countries. Does anybody remember how many countries there are in Codex? Someone is listening. Yes, 163 in the Codex. 123 member countries in WTO. And, like Codex, the WTO says that countries must establish inquiry points. They don’t call them contact points, but call them whatever you want, there has to be a point of contact within the country. For each one of the agreements – and I think there are 20-some agreements in WTO - and certainly the Codex contact point in China, which is the Ministry of Agriculture, will not be the inquiry point for WTO, it will most likely be in the Ministry of Commerce. So this is where we talk about the need for coordination. Two major agreements under the WTO that affect all food and actually affect countries and administrations such as yourself, and one of them is the Application of Sanitary - Phytosanitary Measures, (SPS). The second agreement is on Technical Barriers to Trade. The SPS Agreement refers to food safety only. Only to food safety. The Technical Barriers to Trade Agreement


(TBT), refers only to food quality. So there is a break out under the World Trade Organization. It says, under the World Trade Organisation, that all food being traded internationally must be safe and must be of good quality, and all measures and decisions based on food quality and safety must be science based. So you are starting to see a comparison between the Codex and the WTO, the World Trade Organisation. Now, under the SPS Agreement, the Codex Alimentarius, their standards, their guidelines, their codes of practice, they are now the benchmark for all international trade. Prior to 1995, Codex was merely a voluntary organisation. You didn’t have to do what you agreed to. Under WTO, now you have to agree to follow the Codex rules for international trade. But, also, it mentions in the SPS, that all national legislation should be according to the Codex Alimentarius, should be based on what has been produced by the Codex Alimentarius. A very interesting aspect of the WTO and one that cities such as Hong Kong have to consider in making any legislation related to food quality and safety. Again, they talk about the three aspects of risk analysis. That’s risk assessment, risk management and risk communication and it is written right into the agreement now whereas before it was strictly a Codex issue. There are some words that are very important in the aspects of the WTO and the SPS Agreement and the first word is transparency, and I heard Dr Hedley talk about the aspects of transparency in the food industry. Now, any country, any organisation, that is setting up a food law or a change in their food law, has to notify the World Trade Organisation about their change and every other country that is a member, 123 countries, have the right to comment on the proposed legislation – transparency. Discrimination - discrimination is all your laws on national products must be the same for your imported products. That means you cannot treat an imported food product differently than you would one of your domestic products; that you can’t have a higher control quality for imported products than you do for domestic. So that means that there is a level playing ground for all products.

Equivalence: and this was a very, very important word in the negotiations that took place for about nine years and which I was personally involved in, in setting up this agreement. Equivalence is a very simple word but we can’t explain it today. Everybody was happy about it. It meant, really, you can do whatever you want any way you want to do it, as long as you came out with the same answer, the same level of protection of food quality and safety. But trying to get that understood by everybody, right now, is very difficult and very hard, and it is being looked at very closely by the Codex and next month, in Melbourne Australia, we will be reviewing that word again. Everybody was very happy and pleased to see it come into the agreement but now it is a very difficult thing to try to define and try to meet what we mean by it when we talk about equivalence. What is most important, probably, in the international agreement, are the words “Mutual Recognition”. You’ve heard, probably, for years, if you have been in the food quality control business, that harmonisation is the way to go. We haven’t harmonised in the 40 years that I have been working on food quality and safety and I don’t think we are going to see harmonisation in our day. Harmonisation will really mean one law for everybody and it is not the way that countries are going. So we are looking at these words “Mutual Recognition” that you recognise the laws in another country are different but that they give you the same level of protection and that trade can travel between the countries without having the same laws in each country. Let’s look, quickly, at the Technical Barriers to Trade issue, (TBT), we said that talks about food quality. Not food safety issues but food quality issues. And what are we talking about? We are talking about labelling, we are talking about adulteration – adding water to milk or sand to a product, or insects being in your product, or the Del Monte corn issue, as an example of adulteration – misbranding, and short weight. These are issues that are looked at under the TBT Agreement. And again, under the TBT Agreement, national legislation should go the same way as that for the international trade issues. WTO - as I mentioned, 123 member countries. China, not a member of the WTO. Hopefully, this year they will become a member. Interesting, Hong


Kong is a member of the WTO. This is a very strange situation where Hong Kong has a vote, a very important vote, in the role of the World Trade Organisation, in the effect that has on food quality and safety throughout the world. Whereas China does not have that vote. That should change this year, as I say. Now let’s quickly look at strengthening national food control legislation, and I understand there is work underway to strengthen the Hong Kong situation. And I have read the report, the review of the study that has been carried out here, but basically you have about three areas that you have to look at: inspection, laboratory work and administration. How you administer the laws, how you educate and how you train people. Food Control - there is a need for a co-ordinated approach, as we have said. A very big need for ministries to get together, for organisations to talk, for organizations to work together and not by themselves. At the same time, there is a tremendous need for consumer education. If consumers understand the law and what should be behind the safety and quality aspects, they can be an army for a control organisation; they can help you out. They can be a pain in the butt at the same time, but it is better to bring them into your side and have them help you and work with you because it can’t work without the participation of consumers. Another area that we have looked at very thoroughly, especially in Asia, is on street foods. It is a good supply of food, an excellent supply of food. It is a big business and it supplies a lot of vitamin M. Anybody know vitamin M? Vitamin M - Money. As an example, I was discussing this earlier today, we did a study in Calcutta, a city of 12 million people, and the police and the mayor thought, well, street foods is just a little thing, we don’t worry about it. We found out in our study that it produced US $1 million a day – US$365 million a year - to the industry that wasn’t taxed. The mayor and the police got very excited about that. Street foods, as you know, can also be a potential threat. Now, Hong Kong, you don’t have so-called street foods. However, walking around town last night, you do have street foods. You’ve got your hawkers. Whether you want

to call them a little store or a big store or whatever, you have got them out there, and unless they are controlled you are going to have some cases of foodborne outbreaks. But they are a tremendous source of income for people, they are a tremendous source of employment. And don’t throw them away, they are a wonderful thing. My wife and I eat street foods about every day in Bangkok. I live in Bangkok. What I want to leave you with is, you should think globally but certainly act locally. You have to think about your own aspects in taking your reviews of food control and working together. In some studies it sounds good, the concept that you want to do, but then implementation is a very difficult thing. We can get into discussion about that, about a single unit as control versus a multiple unit, different units of control, but change is very difficult but change is certainly necessary. And one of my Chinese co-operatives taught me this year that ‘sometimes you’re the pigeon, sometimes you’re the statue’. I hope that when you set up an organisation, that you set it up that you are not the statue but that you are the pigeon, and that you control things the proper way. Without it, you will be going, definitely, the wrong way and you won’t be offering protection to the public. Another old Chinese proverb that we use is: ‘It is better to dig the well now before you need the water’. And that‘s a good thing, to see what Hong Kong is doing now to get ready for the future in the next 20 years that we are talking about. One last thing I want to leave you with is that we are getting very busy, the FAO, the WTO and the World Health Organisation, to have an intergovernmental meeting down in Melbourne in October of next year. This is intergovernmental, it is not an invitation-only, it’s for government people, and we are going to be looking at all the agreements on the World Trade Organisation that affect food quality and safety, and also the Codex Alimentarius, to see where we should go and how we should change, especially how we deal with giving assistance and advice to developing countries. As I told the organisers earlier, that I have not spent much time in Hong Kong except for passing through but that is because FAO considered Hong Kong a


developed country and not a developing country. But certainly, FAO and WHO and the World Trade Organisation have a very big desire to see that people are protected and that foods are controlled in a proper and safe way, and we can give advice to anyone that is interested in receiving that. With that, I would like to say I have gone over time. I’ve heard bells, whistles and screams and I should close, but I want to thank you very, very much. I hope you have a better understanding of Codex than my mother had. And with that, I leave and I would like to hear some discussion later on, on exactly some concerns that you people might have at the local level and not so much at the international level. Thank you very much.

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