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Commentary

Investments in Food Safety Risk Assessment and Risk


Analysis as a Requirement for Robust Food Control
Systems: Calling for Regional Centers of Expertise

Samuel Benrejeb Godefroy*1, Rashed A. Abstract


Al Arfaj 2, Ahmed Tabarani 3, and Hussein
Risk Assessment is the scientifically-based process
Mansour 4
that characterizes the possible human health
1 Food Risk Analysis and Regulatory Excellence Platform implications of hazards found in food. This scientific
(PARERA), Department of Food Science and Institute of approach is part of the risk analysis paradigm that
Nutrition and functional Foods (INAF), Université Laval, governs the food decision-making process. It is a
Québec, QC, Canada. prerequisite for the development and execution of
2 Saudi Food and Drug Authority (SFDA), Riyadh, Kingdom robust and consistent food safety regulatory
of Saudi Arabia. decisions. This paper reviews food regulatory
decision-making scenarios where risk assessment
3 Risk Assessment Division, National Food Safety Bureau plays a key role. It discusses challenges associated
of Morocco (ONSSA), Avenue hadj Ahmed Cherkaoui, with the access to capacity and competencies from
Agdal-Rabat, Kingdom of Morocco.
various disciplines necessary to enable risk
4 National Food Safety Agency, Cairo, Arab Republic of assessment and overall risk analysis. The paper
Egypt. illustrates the urgent need for the provision of
additional support to capacity building initiatives in
this area by means of mutually beneficial resource-
sharing with the objective to establish regional
Keywords: food safety, risk assessment, regulations,
and/or sub-regional centres of food regulatory
food standards, capacity building, risk analysis,
Centres of Expertise, food regulatory science science, including expertise in risk assessment.
Regional Centres of Expertise may be the answer to
*Corresponding author: provide the needed competencies and up-to-date
tools to operationalize food regulatory systems,
Samuel Benrejeb Godefroy where food risk analysis is the foundation of decision-
Food Risk Analysis and Regulatory Excellence making, as advocated by the guidance of the Codex
Platform (PARERA), Tel: +1-418-656-2131, ext. Alimentarius commission. It may also be the response
4077562 , E-mail: parera@fsaa.ulaval.ca to support economic regional integration, where food
and agrifood trade needs to be supported by the
removal of Sanitary and Phytosanitary (SPS)
constraints and through achieving a more
coordinated and harmonious food safety standard
setting framework, at the regional level.

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Food safety continues to be a key public in turn drives the establishment of food safety
health issue for all countries and regions of the research priorities.
world(1) and an essential driver for the trade of
food and agri-food commodities. The Codex Importance of Risk Assessment
Alimentarius Commission (CAC) – the Risk Assessment is the science-based process
international food safety standard setting body – that characterizes the possible health
has recommended that food safety regulatory implications of a given hazard in food when
decisions be based on a structured science- consumed by humans(4). It can define a hazard’s
based decision-making process with three occurrence and transmission at various stages
distinct but closely interconnected components: from food production to consumption, is
Risk Assessment, Risk Management and Risk supportive of risk estimation and can account for
Communication (Figure 1)(2). the relative impact of food control measures
employed to mitigate such risks – this is
particularly applicable for microbial hazards.
Risk assessment can also represent a “safety
evaluation” – relevant, more specifically, to
chemical hazards – aimed at characterizing the
situation where consuming a food carrying such
hazards would pose no appreciable health
impact for the consumer. It is this scientific
approach, based on sound methodologies, when
executed correctly that supports both robust
Figure 1: Representation of the Food Risk Analysis and consistent food safety regulatory decisions.
Principle advocated by the Codex Alimentarius
Commission(3) Generally, a food safety competent authority
strives to be the most trusted organization
The CAC also called for “constant interactions within a given jurisdiction and is regarded by
between risk managers and risk assessors within other stakeholders, in particular consumers and
an environment characterized by risk food industry actors, to be the reference and
communication”. Risk analysis is in fact most focal point for food safety decisions. They offer
effective when all three components are advice, guidance and apply the required
successfully integrated as part of the food safety regulatory and non-regulatory measures with
decision-making framework. Application of the the objective to protect consumers and ensure a
risk analysis paradigm results in decisions that fair environment for food trade. Adopting a
are more likely to be consistent, and in decision-making framework based on the risk
proportion with the health risks being managed, analysis paradigm, with risk assessment as the
given that they are anchored in the analysis of foundation for the development of management
the scientific and other policy evidence, options, enables a food safety competent
according to agreed-upon methodologies. Risk authority: (1) to ensure consistent food safety
analysis also allows a country’s obligations under decisions within their district of oversight and in
the Sanitary and Phytosanitary Agreement (SPS) alignment with international partners; (2) to
to be met, supports the credibility of the food support cost effective measures that are justified
control system and contributes to identify gaps and commensurate with the risk being managed
and uncertainties in scientific knowledge, which and; (3) to provide a predictable food safety
regulatory environment that is more conducive

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FDRSJ JUN 24, 2019 Vol 2 No 1 (2019): (JANUARY-JUN), ISSN:1658-8002
to investments in the food and agri-food b. Development of Domestic and Regional
production sectors and is supportive of fair trade Food Safety Standards
in food and agri-food commodities. Reliance upon food safety standards anchored in
When is Risk Assessment Needed? a scientific assessment is paramount to ensure
their acceptability by domestic and international
A food safety competent authority will conduct a stakeholders, as well as to satisfy obligations of
risk assessment in response to, at minimum, two the SPS agreement regarding predictability,
situations: consistency and fairness as they relate to food
safety regulatory provisions. The development
a. Managing Food Safety Incidents and of these risk assessments is necessary whether
Foodborne Illness Outbreaks the intention is to adapt an international (Codex)
Food safety incidents associated with the standard before its adoption or to develop a new
occurrence of hazards in foods, regardless if they standard to address a country or region’s needs.
lead to illnesses and/or outbreaks, should be While scientific assessments to ensure the
managed on the basis of science-based risk adaptation of a given international standard to
assessments. The result of these assessments the national situation – accounting for domestic
should underpin food regulatory decisions on food exposure scenarios and food production
the ground, including but not limited to product practices – are more accessible to national
recall, product seizure, interruption of a food regulators, assessments required to derive a new
business operation and advice to consumers. A standard can be very resource intensive.
capacity is therefore needed to undertake such Capacity building programs and investments in
assessments on a regular basis and in a timely the development of risk assessment and food
manner in order to protect consumers’ health regulatory science competencies, tools and
and to avoid any unduly detrimental impact on procedures need to be envisaged in a realistic
food business operators. It is therefore and feasible manner such that they address
indispensable for food safety competent these needs. This is required to help propagate
authorities, tasked with the management of food risk analysis as the foundation of food
food safety incidents, to be equipped with a regulatory decisions and to strive towards the
skillfully trained human resource capacity to harmonization of food safety measures at the
carry out the function of rapid risk assessment, regional and international level.
which are assessments undertaken in a short
period of time, to address a given food safety Benefits and Consequences of Adopting Food
incident, based on the information available at a Safety Risk Assessment as Part of Competent
given time. It is also essential that internal Authorities’ Food Decision-Making Process
procedures and protocols be developed for this Producing food safety decisions that are
function to be exercised in a consistent fashion systematically anchored in a food safety
and synchronized with the occurrence and scientific assessment further enhances the
identification of the food safety incident. The acceptability of these decisions by all parties and
same methods and scientifically-based stakeholders. It strengthens the trust and
approaches should be applied for food safety confidence of consumers, food business
incidents involving both domestically produced
operators and international partners in the level
and imported food. Applying this overall of oversight exercised by a given competent
approach supports consistency of food safety authority. It also serves to protect the country or
management decisions and contributes to the the jurisdiction applying this practice from
predictability of each jurisdiction’s food challenges of legitimacy and fairness under the
regulatory environment.

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SPS agreement regarding decisions taken. decision-makers when considering additional
However, this approach includes accountabilities relevant factors during the formulation of their
that food regulators must accept and fulfill, in risk management recommendation(s).
particular, the systematic nature of the reliance
on risk assessments for decision-making should Calling for Regional Centres of Expertise in
be clearly demonstrated. A competent authority Food Risk Assessment and/or Food Regulatory
investing in food safety risk assessment should Science
not be witnessed issuing food safety decisions Developing food safety risk assessments and
independently from these risk assessments – formulating food standards require the
whether in the context of incident management availability of multi-disciplinary expertise and
or for standard setting. Similarly, decision- reliance on complex methodologies to be
making procedures and protocols should be developed and adopted by a highly skilled
amended to clearly reflect the “trigger” of a risk scientific workforce. This includes mastering
or a scientific assessment when a given food various food regulatory science disciplines (food
safety decision is required. Also, when toxicology, food microbiology, various aspects of
endorsing the dependence on food risk food science, chemistry, mathematical
assessments in support of food management modelling, etc.) and therefore requires
decisions, competent authorities must adopt important investments to be made by each food
certain key values that support the integrity and competent authority.
bolster the credibility of the outputs of the
decision-making process. In particular, Leveraging existing expertise in these scientific
embracing the principle of transparency in disciplines at the regional or sub-regional level to
documenting and making available the outputs create centres of expertise in food safety risk
of these scientific assessments, through assessment or food regulatory science may offer
publication or other means of dissemination, a suitable alternative. These Centres of Expertise
should be enshrined in the “day to day” routine (CE) could result from a mutualized scientific
practice of the authority. capacity, both in human skillsets and in tools,
data and their management systems from within
Once the question has been formulated to risk a given set of countries or jurisdictions that share
assessors, ensuring the independent nature of similar needs, economic situations, language or
the risk assessment is another factor that is food production and/or consumption practices.
critical to guarantee the credibility of the risk
assessment conclusion. Such independence A model could be envisaged in the form of Joint
should support the risk assessors in conducting Institutes of Food Regulatory Science, where
their work without interference by the decision- such institutes are linked to academic
makers that may influence the outcome of the organizations in a given region as well as being
assessment in a biased direction. This protection tied to and serving primarily the needs of food
from interference can be realized while ensuring competent authorities.
continued engagement and dialogue between These CEs can become the resource called upon
risk assessors and decision-makers. The manner by regulators in the given geographical area
in which uncertainty is managed, whether (e.g., region, sub-region) to address risk
related to limitations in the scientific assessment needs in support of standard
methodology or the lack of data, should be well setting(5).These CEs could also offer cost-
documented, clearly explained and well effective approaches to generate and maintain
communicated by risk assessors. Possessing the the scientific data needed as a foundation for
risk assessment’s full context is indispensable for food risk assessments, in particular food

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FDRSJ JUN 24, 2019 Vol 2 No 1 (2019): (JANUARY-JUN), ISSN:1658-8002
consumption information and food Training programs can be developed to
contaminants and nutrients occurrence data create cohorts of scientists from a given
collected through food surveys, whether a Total geography / set of jurisdictions to serve as the
Diet Study or targeted food commodity surveys. initial workforce of these joint regional centres
The validation of a risk assessment for the of expertise. The linkage with academic centres
purpose of formulating national standards as will support not only the initial training
well as functions related to rapid risk approach, but also the development of the
assessments in response to food safety incidents scientific infrastructure dedicated to this
and foodborne illness outbreaks, would still purpose.
remain within the prerogative and the oversight
of the national food competent authorities. As part of its commitment to propagate food risk
analysis training and competencies and in the
Figure 2 introduces a proposed operational context of the implementation of the Food
model to a Food Risk Assessment or Food Safety component of the workplan associated
Regulatory Science (Regional Centre of Expertise with the Memorandum of Understanding
or RCE). These RCEs can also become a hub for between the Food and Agriculture Organization
training, competency development, data of the United Nations (FAO) and University Laval
collection and gathering in support of food (UL)(6) , the Food Risk Analysis and Regulatory
regulatory functions, formulation and Excellence Platform (PARERA) of UL is setting up
assessment of food regulatory impacts and a trust fund to support multi-stakeholder
overall scientific expertise in food regulatory funding that could enable the design and
scientific disciplines. The operating model can implementation of such regional centres of
evolve from one that is supported by direct expertise.
funding from contributing jurisdictions
supplemented by food safety capacity Other initiatives have been recently announced
development programs to a self-sustaining and could support the operationalisation of this
approach, whereby services provided by the concept in various regions of the world. The
RCEs with respect to training, food data recent (April 2019) proposal examined by the
collection and/or provision of scientific and Food Safety Ministerial Committee of the Gulf
Cooperation Council (GCC) to create a GCC Food
regulatory opinions are cost-recovered. Costs
would be considered minimal for users of such Safety Risk Assessment Centre, based on the
services due to the economy of scale anticipated proposal of the executive leadership of the Saudi
as a result of sharing joint capacity. Food and Drug Authority (7) offers the
opportunity to mutualize expertise and
resources amongst countries of the GCC in food
risk assessment and risk analysis. GCC countries
are already integrated as far as their food
regulatory and standard setting requirements
go. A regional centre of expertise in food safety
risk assessment will provide additional
assurances that food decisions issued at the GCC
level are in line with international guidance and
best practices and are anchored in scientific
evidence.
Figure 2: Proposed Model of a Regional Centre of Similarly, the 2014 Malabo declaration and the
Expertise in Food Regulatory Science subsequent operational plans developed to

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address it(8), called for the “establishment and and more harmonious food safety standard
operationalization of a food safety coordination setting framework, contributing to the removal
mechanism for Africa”, including the possible of SPS constraints and as a booster to the trade
set-up of an African food safety agency. This goal of food and agri-food commodities in the
could be achieved though the incremental targeted regions.
development of one or more centres of expertise
at the sub-regional / regional level specializing in References
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