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Republic of the Philippines FBA,, Department of Health Food end Oran Ad FOOD AND DRUG ADMINISTRATION DATE: 23 August 2019 FOR: ALL CONCERNED STAKEHOLDERS FROM: PILAR MARILYN f PAGAYUNAN Director IV Center for Food Regulation and Research (CFRR) SUBJECT: Request for Comments on the draft Administrative Order (AQ) by the CFRR Please be informed that the CFRR is consolidating comments for the draft AO entitled “Guidelines for Food and Drug Administration (FDA) Certification of Food Safety Compliance Officer (FSCO). Comments may be submitted by e-mail to: ceduller@fda.gov.ph with ce to: mydpinion@fda.gov.ph_not later than 15 September 2019 in the format below: Name of Company or Organization: Contact Information Telephone: E-mi Title of draft policy: “Guidelines for Food and Drug Administration (FDA) Certification of Food Safety Compliance Officer (FSCO)” Section Comments Tnput/Recommendation/ __ Suggested text (if any) Thank you. Civie Drive, Filinvest Corporate City, Alabang 1781 Muntinlupa, Philippines Trunk Line +63 2.857 1900 Fax +632 807 0751 Website: www.fda.gov.ph Email: info@fda.gov.ph DRAFT FOR COMMENT ADMINISTRATIVE ORDER No. nL SUBJECT: — Guidelines for Food and Drug Administration (FDA) Certification of Food Safety Compliance Officer FSCO) RATIONALE Scetion 15, Article IT of the 1987 Philippine Constitution declares that the State shall protect and promote the right to health of the people and instil health consciousness among them. Furthermore, Section 9, Article XVI provides that the State shall protect consumers from trade malpractices and from substandard or hazardous products. Toward these ends, the State shall maintain a farm to fork food safety regulatory system that ensures high level of food safety; promotes fair trade; and advances the global competitiveness of Philippine food and food products. Pursuant to the Implementing Rules and Regulations (IRR) of Republic Act No. 10611, “An Act to Strengthen the Food Safety Regulatory System in the Country to Protect Consumer Health and Facilitate Market Access of Local Foods and Food Products, and for Other Purposes” otherwise known as ‘The “Food Safety Act of 2013” where SECTION 14 Rule 14 a.1 requires all food business operators (FBOs) to designate a Food Safety Compliance Officer (FSCO) who has passed the prescribed training course for FSCO recognized by the FDA-DOH, and SECTION 4 (p) requires all food safety regulatory agencies (FSRAs) and local government units (LGUs) to appoint food safety officers (FSO). Since the Food Safety Act of 2013 holds the FBOs responsible for ensuring food safety, having a certified FSCO in the food business will ensure FBO’s compliance to all the regulatory and food safety requirements. The FSCO will also provide confidence of producing good quality and safe food products. In time, the implementation of food safety practices and standards by food businesses under the supervision of a FDA certified FSCO will improve efficiency and productivity of the food business, and prevent cases of food-borne illnesses. This Order is therefore issued to provide guideline for certification of FSCO. OBJECTIVES This Order shall define the guidelines on certification of Food Safety Compliance Officers of food business establishments regulated by the FDA-DOH. DRAFT FOR COMMENT In particular, this guideline will establish a consistent and harmonized baseline for the certification of FSCO in compliance to the Food Safety Act and to censure equitable transparent process in certification of FSCOs. I. SCOPE This Order shall cover the certification of FSCOs for FDA regulated food business establishment with activity as manufacturer, distributor, and trader of processed and prepackaged food and food products. IV. DEFINITION OF TERMS For the purpose of this Order, the following terms shall have the following meanings: L. Certification refers 10 the provision by an independent body of written assurance (a certificate) that the product, service or system in question meets specific requirements. Certification of FSCO is administered by FSRAs or government agencies having jurisdiction, 2. Food-borne illnesses refer to diseases, usually either infectious or toxie in nature, caused by agents that enter the body through the ingestion of food. 3. Food business refers to any undertaking, whether public or private, that carries out any of the activities related to, or any of the stages of the food supply chain, 4. Food business operator (FBO) refers to a person engaged in the food business including one’s agents and is responsible for ensuring that the requirements of the Food Safety Act (in the context of this AO) are met by the food business under one’s control. For the purpose of this AO, it refers to the highest executive officer of the establishment (i.e, Owner/Proprietor, President, Authorized Office, General Manager, Factory/Plant Manager, Managing Director, Managing Partner). 5. FSCO refers to the Food Safety Compliance Off Business Operator. ‘er designated by the Food 6. Food safety regulatory agencies (FSRAs) refer to the following national government agencies: i, Under the Department of Agriculture (DA) ~ the Bureau of Animal Industry, the National Meat Inspection Service, the Bureau of Fisheries and Aquatic Resources, the Bureau of Plant Industry, the Fertilizer and Pesticide Authority, the Philippine Coconut Authority, the Sugar Regulatory Administration and the National Food Authority. 9, 10. 1. 12. DRAFT FOR COMMENT ‘Under the Department of Health (DOH) ~ the Food and Drug Administration, the Center for Food Regulation and Research, and the Bureau of Quarantine. Food safety officer refers to a professionally qualified and properly trained officer appointed by a food safety regulatory agency or by local government units (LGUs) in accordance with the appropriate civil service rules and regulations. Good manufacturing practices (GMP) refer to a quality assurance system aimed at ensuring that products are consistently manufactured, packed, repacked or held to quality standards appropriate for the intended use. It is thus concemed with both manufacturing and quality control procedure. Hazard reters to a biological, chemical or physical agent in food wit potential to cause adverse effect on health. Hazard Analysis and Critical Control Points (HACCP) refer to a scienc based system which identifies, evaluates and controls hazards which are significant for food safety at critical points during a given stage in the food supply chain, Large Enterprise, for the purpose of this Order, refers to any business activity or enterprise engaged in industry, agribusiness and/or services, whether single proprietorship, cooperative, partnership or corporation whose total assets, inclusive of those arising from loans but exclusive of the land on which the particular business entity's office, plant and equipment are situated, have value of more than Php 100,000,000 and/or with more than 199 employees. Micro, Small and Medium Enterprises (MSMEx) , pet Republic Act No. 9501 s. 2008 otherwise known as the Magna Carta for MSMEs, refer to any business activity or enterprise engaged in industry, agribusiness and/or services, whether single proprietorship, cooperative, partnership or corporation whose total assets, inclusive of those arising from loans but exclusive of the land on which the particular business entity's office, plant and equipment are situated, must have values under the following categories: Based on Number of Category Based on Size of Asset Reployest Micro ‘Not more than Php3,000,000 1-9 employees Small Php3,000,001 - Php13,000,000 10-99 employees Medium | Php15,000,001 - Php100,000,000 | 100 ~ 199 employees 13, DRAFT FOR COMMENT Qualified Person in Industry Regulatory Affairs (QPIRA) refers to the FDA accredited official liaison of the FBO to transact or file applications for authorization with the FDA. Risk refers to the likelihood of an adverse health effect and the severity of this effect following exposure to a hazard, Food safety standards refer to the formal documents containing the requirements that foods or food processors have to comply with to safeguard human health. They are implemented by authorities and enforced by law; and are usually developed and published under the auspices of a national standards body. Traceability refers to the ability to follow the movement of a food through specified stages of production, processing and distribution. Reealls mean actions taken to remove a product from the market. Risk Categorization refers to the classification of food businesses, food operations and/or food produets as high risk, medium risk or low risk based ‘on inherent and potential food safety risks in the production/processing system and/or on the possibility of the presence of microbiological and chemical hazards in the food produced; and history of compliance by the establishment with its quality and safety management systems and pertinent regulations. GENERAL GUIDELINES 1. ‘The FBO or his/her authorized representative of food business establishment shall designate a FSCO who has completed the prescribed training course recognized by the FDA- DOH and possesses the basic qualification and minimum competency requirement. FSCOs shall be certified by the FDA based on the risk categorization of the food business establishment (Low or High Risk). ‘The FBO or his/her authorized representative and designated FSCO shall ensure compliance with the requirements of Republic Act No. 9711 otherwise known as the “Food and Drug Administration Act of 2009" and Republic Act No. 10611 “Food Safety Act of 2013”, their respective IRRs, and other pertinent rules and regulations on processed and pre-packaged food/food products. ‘The certification shall be valid for three (3) years. Documentation of certification of FSCO shall be maintained at the food business establishment and shall be made available for inspection by the FDA at all times. DRAFT FOR COMMENT 5. The FDA-Regional Offices shall prepare a database of its certified FSCOs and shall furnish copy to FDA-CFRR for consolidation and documentation of all certified FSCOs in the country. VI. SPECIFIC GUIDELINES A. Risk Categorization of Food Business 1. Food businesses shall be categorized as follows based on the criteria provided in Table 1: Low Risk Micro Establishment Low Risk Small Establishment High Risk Micro Establishment High Risk Small Establishment High Risk Medium Establishment High Risk Large Establishment peep Table 1. Criteria for Risk Categorization of Food Business Criteria aay Asset/Size Product, Process, Category and Packaging System Low Micro Food products with: Small + high-acidity of pH 4.6 or below; and - «+ low water activity of 0.85 or below, including ne ee fermented foods, carbonated beverages, jams, jellies, and preserves, High | Micro ‘+ Thermally processed low-acid and acidified ‘Small foods/food products packaged in hermetically Medium | scaled containers, including aseptic Large processing and packaging systems 2. A food business establishment that covers both low risk and high risk products shall be categorized as High Risk Establishment. B. Qualifications Required for FSCO 1, The FSCO shall be classified for Low Risk Establishment or High Risk Establishment, regardless of establishment size, following the basic qualification and minimum competency requirement indicated in Table 2. DRAFT FOR COMMENT ‘Table 2. FSCO Basic Qualification and Minimum Competency Requirements A. Basic Qualification a. Filipino citizen of legal age, with good moral character, and mentally and physically healthy; b. Full-time employee of the establishment where he/she is being designated as FSCO; ©. The services of a part-time FSCO consultant may be employed, however, the owner or his/her representative full-time employee shall be certified as FSCO of the food business establishment; and c. Has completed at least thirty (30) hours of training courses listed in Annex C from any FDA recognized training institution within the last three (3) years. Minimum Competency Requirement Low Risk establ igh Risk establishment Any of the following: Any of the following: ‘* Graduate of any technical course, | ¢ Graduate of Bachelor of Science in Food preferably food related Technology ‘© Has completed third year in | ¢ Licensed chemical engincerichemist or tertiary level education in food | microbiologist with at least two (2) years related course (food technology, | relevant experience in food manufacture, food and nutrition, chemistry, | quality and safety or equivalent microbiology, chemical/sanitary | experience in teachit engineering, veterinary medicine, fisheries, agriculture) | ¢ Graduate of other fields related to food science and technology (nutrition and ‘© Has been with the establishment | dietetics, chemical/sanitary engineering, for at least three (3) years in a| veterinary medicine, —_fisheries, supervisory position responsible | agriculture) with at least three (3) years for food manufacture, quality | relevant experience in food manufacture, and safety or equivalent | quality control/assurance, food safety or experience. ‘equivalent experience in teaching. Graduate of other fields of discipline with at least five (5) years relevant experience in food manufacture, quality control/assurance, or food safety. 2. Low Risk Micro and Small Establishment shall require a FSCO possessing the basic qualification and minimum competency requirement for Low Risk Establishment. 3 C. Design: I 2. For food bi DRAFT FOR COMMENT High Risk Micro, Small, Medium, and Large Establishment shall require FSCO possessing basic qualification and minimum competency requirement for High Risk Establishment. ion of FSCO ‘The FBO of each licensed food business establishment shall designate a minimum of one FSCO possessing the basic qualification and minimum competeney requirements stated in Table 2 of Section VIB. ss with two or more facilities, each facility shall have a designated FSCO. 3. For low risk - micro and small food business, the owner may be designated as FSCO provided he/she possesses the minimum competency requirements for a low risk establishment in accordance with Table 2 of Section VLB. 4. For high risk - micro and small food business, the owner/manager may serve as the FSCO, provided the owner/manager possesses the basic qualification and minimum competency requirements for a high risk food business establishment in accordance with Table 2 of Section VIB. 5. Medium and large food business establishment shall designate their respective FSCO in accordance with Table 2 of Section VLB. 6. FSCO may or may not be the same as the FBO's QPIRA, as long as the basic qualification and minimum competency requirements of FSCO as provided in Table 2 of this Circular is complied with. 7. Incase of resignation or termination of FSCO, the FBO shall immediately assume the responsibilities as interim FSCO until such time that a new FSCO has been certified by FDA. 8. In case the FBO of the establishment is of foreign nationality, the next D. highest ranking Filipino Officer shall assume the responsibilities of the FSCO provided the basic qualification and minimum competency requirements in Table 2 of Section VIB are complied with, Certification of FSCO 1. Initial Certification of FSCO a. Within twenty-two (22) working days from the date of designation, the designated FSCO shall apply for FDA Certification at the FDA Action Center (FDAC) or FDA-Regional Office by complying with the following: DRAFT FOR COMMENT i. Notarized Designation of Food Safety Compliance Officer (FSCO) and Joint Undertaking in the format provided in Annex A; Information Sheet for FSCO Certification provided in Annex B; iii, Photocopy of the certificates of completion of at least thirty (30) hours of related training/workshop/seminar issued by any FDA- DOH recognized training institutions/organizations provided in Annex C; and iv. Payment of Php500.00 for certification. b. Within twenty-two (22) working days from receipt of the application, the FDA-CFRR Director or the FDA-Regional Director shall act on the application for certification of the designated FSCO. .. For approved applications, the FDA-CFRR Director or FDA-Regional Director shall issue the FSCO Certification. 4. However, for disapproved applications, the applicant will be officially informed of the grounds for disapproval through the applicant's given e- mail address, The FBO shall designate a new FSCO within owenty-two (22) working days from the date of notification of disapproval of application for FSCO certification ¢. Within twenty-two (22) working days from the date of disapproval of the application for certification, the FBO of establishments shall submit the required deficiencies or designate another FSCO. 2. Renewal of Certification of FSCO a, Within three (3) months prior to expiration of FSCO Certificate, the FSCO shall file for renewal of certification, at the FDA Action Center (FDAC) or FDA-Regional Office by complying with the following: i. Notarized Designation of Food Safety Compliance Officer (FSCO) and Joint Undertaking in the format provided in Annex A; ii, Information Sheet for FSCO Certification provided in Annex B; Photocopy of certificates of completion of at least twenty (20) hours of related training/workshop/seminar issued by any FDA- DOH recognized training institutions/organizations provided in Annex C, issued within 3 years prior to renewal of FSCO certification; and iv. Payment of Php500.00 for certification. DRAFT FOR COMMENT b. Application for renewal of FSCO certification shall be processed in accordance with Section VI.D.1,b to e. ¢. If the application for renewal of FSCO Certificate is filed a day after its validity, the application shall be considered initial and shall be processed in accordance to Section VLDI. ‘Change of Designated FSCO a. In case of resignation or termination of the services of the FSCO, the FBO shall inform the concerned FDA Office in writing and designate anew FSCO. b. Anew certification shall be secured from the concerned FDA Office if the FSCO transfers and assumes the FSCO position in another company, or if the FSCO transfers into another facility/location of the same company. ©. The new FSCO shall apply for certification within twenty-two (22) working days from the date of designation following the requirements under Section VLD. (Initial Certification of FSCO). 4. If the replacing FSCO is a former FSCO in another food business establishment of the same or higher risk category and possesses a valid FSCO Certificate, submission of the photocopy of his/her previous FSCO certificate shall be required in addition to the requirements under Section V1. D.2 (Renewal of FSCO Certification), €. If the replacing FSCO is a former FSCO in another food business establishment of lower risk category and possesses a valid FSCO Certificate, the requirements under Section VI D.1 (Initial Certification of FSCO) shall be submitted. £. The certification of the FSCO who has resigned or been terminated shall be considered automatically revoked. E. Duties and Responsibilities Along with the FBO, the FSCO shall attend the prescribed seminar covering the basic food laws and regulations and the duties and responsibilities of the FSCO. 2. Along with the FBO, the FSCO shall ensure compliance with the Republic Act No. 9711 otherwise known as the “Food and Drug Administration Act of 2009" and Republic Act No. 10611 “Food Safety 9 DRAFT FOR COMMENT Act of 2013”, their respective IRRs, and other pertinent rules and regulations on processed and pre-packaged food/food products. ‘As may be necessary, the FSCO shall also be responsible for the following: a. Lead the overall implementation of standardized food safety policies and procedures to ensure compliance with applicable laws and regulatory requirements; b. Assist in developing company policies, procedures or standards (i.e. GMP, HACCP, personnel hygiene) aimed at preventing foodborne illness and mitigating risks; ©. Manage the food business’ food safety program and supervise company staff in the correct implementation of said program while making sure that the program is updated with changes in food regulations: 4. Develop, maintain, and update all records, manuals, training procedures, ingredient’raw material and product specification books pertaining to food safety; ©. Conduct periodic in-house inspection of daily operations to verify if policies and procedures concerning food safety are being followed; £, Identify and report hazards in the day-to-day operation of a food establishment, including unsanitary conditions food preparation, processing, storage , packaging area, equipment, and tools, to be coordinated with manufacturing and quality control heads to implement corrective action as needed; g Coordinate and supervise in-house personnel training on food safety aspects covering manufacturing, packaging, handling and storage as needed to ensure that all personnel are adequately trained; h. Routinely coordinate with the warehouse/receiving teams to extract detailed information on safety and suitability of all ingredients/raw materials and lead in making collaborative decisions regarding acceptance or rejection; i, Manage and lead product recall activities from the start until completion; j. Assist in developing a packaging program and be responsible for oversight of packaging controls to ensure safety of pre-packaged products; 10 DRAFT FOR COMMENT k. Lead in the preparation for all internal and external food safety audits; 1. Communicate any changes in food safety policy and procedures, as well as, any findings related to food safety to all concerned employees; m. Serve as contact point for FSOs of government FSRAs and LGUs; and n. Perform other duties as may be required by the food business. F. Revocation of FSCO Certification Upon due process, the commission of any of the violations below shall result to revocation of the FDA certification for FSCO: a. Submission of false/tampered documents and/or reports; b. Misrepresentation of facts; c. Has received at least three (3) notices of non-conformance to food. safety standards, rules and regulations in one year; 4. Failure to notify the FDA regarding recall of unsafe products; and ¢. Connivance with food business operators which will result in food safety risks to the consumers. The FDA-CFRR or the FDA-Regional Director shall notify the FBO about the revocation of FSCO certification and the grounds for it. ‘The FBO or his/her representative shall submit a written action plan to rectify the violation(s) within seventy-two (72) hours, If the action plan is, acceptable to the FDA-CFRR Director or FDA-Regional Director the revocation shall be voided via official electronic mail and or mail. In the event that the certification of FSCO is revoked, the establishment shall designate a new FSCO within twenty-two (22) working days complying with the qualification in Section VIB and procedure in this Order. VII. TRANSITORY PROVISION All concemed food business establishment shall apply for certification of FSCO within six (6) months upon effectivity of this Order. VIII. SEPARABILITY CLAUSE 11 Ix. DRAFT FOR COMMENT If any provision in this Order, or application of such provision to any circumstances, is declared unauthorized or rendered invalid by any court of law ‘or competent authority, the remainder of its provisions not affected thereby shall remain valid and effective. REPEALING CLAUSE All provisions of existing administrative orders, circulars, and other issuances or parts thereof, inconsistent with this Order is hereby amended, modified or repealed accordingly. EFFECTIVITY ‘This Order shall take effect fifteen (15) days after its publication in a newspaper of general circulation and upon acknowledgment of receipt of a copy hereof by the Office of the National Administrative Register. FRANCISCO T. DUQUE III, MD, MSc Secretary of Health 12 DRAFT FOR COMMENT Annex A REPUBLIC OF THE PHILIPPINES ) CITY OF ) Ss Designation of Food Safety Compliance Officer (FSCO) and Joint Undertaking This is to officially designate (Complete name of FSCO) as the Food Safety Compliance Officer (FSCO) of __(Company name _as_in the LTO) located at __(Address_as_in_the LTO) with License to Operate Number The FSCO and the undersigned the Food Business Operator (FBO) are jointly responsible for ensuring food safety in the manufacture, storage, distribution, as may be applicable, of the company’s food product/s, among other specific duties and responsibilities stated in the FDA Guidelines for Certification of FSCO. IN WITNESS WHEREOF, we have hereto affixed our signatures this day of at (Name and Signature of FBO) (Name and Signature of FSCO) Date of Designation: SUBSCRIBED AND SWORN to before me this day of at by the above named person, showing his/her as proof of his/her identity. RY PUBLIC Doe. No. Page No. Book No. Series of 13 DRAFT FOR COMMENT Annex B Information Sheet for FSCO Certification DINNo. Typeof Ci Initial Change of FSCO Application Renewal Previous FSCO Name _ = Certificate No. __ Validity ‘Complete Name of FSCO - (Surname, Given Name, Mile Nome) Birthday Gender OMale 0 Female peste ueee (ex ANIONS) + Colored Photo Citizenship + Passport Size Peritanient + Taken within the Asareis last 6 months Contact Telephone Mobile Details E-mail Competency 1 Graduate of food related technical course, please specify (Tick applicable) 1 Has completed third year level in any food related course (food technology, food and nutrition, chemistry, microbiology, chemicalSanitary engineering, veterinary medicine, fisheries, agriculture), please specify (ex.BS Chemisty) Ci Has been with the establishment for atleast three (3) years in a supervisory eapacity responsible for food manufacture, quality controVassurance, food safety or equivalent Licensed chemical engineer/chemist or microbiologist with atleast two (2) years relevant ‘experience in food manufacture, quality control/assurance, and food safety Licensed Profession License/Registration No. Valid Until C1 Graduate of other fields of discipline related to food science and technology (nutrition and dietetics, chemical/sanitary engineering, veterinary medicine, fisheries, agriculture) with at least two (2) years relevant experience in food manufacture, quality control’assurance, and food safety, please specifies. BS Nutrion) 1 Graduate of other fields of discipline not related to food science and technology with at least five (5) years relevant experience in food manufacture, quality control/assurance, and fod safety, please specify field (ex. BS Accou Trainings Title of Training/ Training Institution Dates: ‘Number Attended Seminar/Workshop (Organization | (from-to) | of Hours (within the ben Total Number of Hours 14 DRAFT FOR COMMENT ‘Company Name as wen in the License peat. 10) ‘Company Address as wien inthe LTO LTO Number LTO Validity (eu cana03s) eNO Manufacturer — Repacker — Toll-Manufacturer (ck applicable Ci Importer of Raw Material for Own Use Exporter of Own Product Climporter Exporter Wholesaler C Trader Company Size Micro (Not more than Php3,000,000 with 1-9 employees) Chased on Assets and Numberof Employees) (1 Small (Php3,000,001 - Php15,000,000 with 10-99 employees) 1 Medium (Php15,000,001 - Php100,000,000 with 100-199 employees) OlLarge (more than Php100,000,000 with more than 199 employees) Product, Process 7 Food products with high-acidity of pH 4.6 or bel Se ‘ood products with high-acidity of pH 4.6 or below System 1 Food Products with low water activity of 0.85 or below, including fermented foods, carbonated beverages, jams, jellies, and preserves 1 Thermally processed low-acid and acidified foods/food products packaged in hermetically sealed containers, including aseptic processing and packaging systems Risk Category of O Micro — Low Risk O'sall — Low Risk Food Business 0 Micro ~ High Risk CO Small — High Risk Establishment 0 Medium — High Risk Large ~ High Risk Official Receipt Number “Amount Paid Date Paid (ex, 210N2019) Signature over printed name Signature over printed name of Designated FSCO of Food Business Operator or Date of Designation FBO Representative (ex. 02JUN2019) EVALUATION Approved FSCO Category Low Risk FSCO High Risk FSCO 1 Disapproved Reason for disapproval Evaluator’s Initial Date 15 DRAFT FOR COMMENT ‘Annex C Training Courses for FSCO and Training Institutions . Each FSCO is required to complete the following training courses: a. Qualified Person in Industry Regulatory Affairs (QPIRA) for Food b. Good Manufacturing Practices (GMP) ¢. Sanitation Standard Operating Procedures (SSOP) 4, Hazard Analysis and Critical Control Points (HACCP) ¢, Food Safety Management System (FSMS, ISO 22000) £. Food Safety System Certification (FSSC 22000) . In addition, other courses relevant to the products being manufactured by the company may be taken up as may be deemed necessary. . FDA-recognized institutions offering food safety related training courses a. Food and Drug Administration — Center for Food Regulation and Research; b. Food Safety Research and Development Institute (formerly Food Development Center); Philippine Trade Training Cente Department of Science and Technology and attached agencies; ¢. Department of Health and attached agencies; Department of Agriculture and attached agenci Academic institutions offering relevant courses; Food industry associations; and Other relevant government and private institutions, Department of Trade and Industry; 16

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