This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
11.0 MONITORING AND EVALUATION .................................................... 21 APPENDIX 1: CURRENT FOOD SAFETY LEGISLATION IN IRAQ .................................... 22
3
INTRODUCTION
The protection of human, animal and plant health in today’s global food market is an important
challenge that must be addressed through internationally recognised health and food safety
systems. Such systems must ensure that consumers are supplied with food that is safe to
consume, and that the country’s food sources are protected from pests and disease. This will be
accomplished by the establishment and maintenance of a rational, integrated farm-to-table
agricultural health and food safety system in Iraq that harmonises inter-agency efforts, minimises
inter-agency conflict and overlap, and ensures the protection of public safety in a manner
consistent with the Sanitary and Phytosanitary Agreement of the World Trade Organization
(WTO/SPS) and other international requirements.
Iraq need to establish Food Safety Agency (FSA) that will be responsible for the implementation
of a food safety programme for Iraq, and guide its ongoing administration. With a population of
30 million persons, and in excess of a million visitors each year, it is of paramount importance
that the quality of Iraqi’s food supply meets the highest standards to satisfy domestic demand, and
the requirements of our international trading partners. The Iraq, therefore, must put wide plan to
successful implementation of the food safety policy. The food safety policy that will support the
programme will complement several national policies in providing a framework for safe,
sustainable and ethical food production in Iraq.
A food safety programme is necessary in order to address food-related risks and to contribute to
the overall health and wellbeing of the population.
Furthermore, the health-related emphasis of the food safety policy cannot be understated when
the potential fall-out in the tourism industry from an outbreak of Travellers Diarrhoea is
contemplated. In addition, good food management practices will not only improve Iraq’s
international competitiveness, but also heighten awareness within the Iraqis population,
particularly when the link is made to lifestyle-related illnesses, and the community can share
responsibility for addressing such threats as
Microbial and chemical food safety hazards, such as Salmonella, Listeria and certain heavy
metals;
Pathogens emerging from the design of the food and agricultural systems, such as intensive
livestock operations and the globalisation of distribution and processing;
Hazards associated with technologies and their by-products, such as the use of pesticides,
heavy metals, growth promotions, antibiotics, fertilisers and genetically engineered crops and
foods;
Hazards associated with technologies introduced to solve other food safety and quality
problems, including additives and irradiation; and
Hazards associated with new approaches to food as health delivery agents, functional foods
and edible vaccines.
4
2.0 INTERNATIONAL BEST PRACTICES
In the development of the Food Safety Policy the Jamaican model was used as a base for current
Project due to similarities between the two countries at several aspects, also an evaluation of the
best practices of the European Union, Canada and United States were incorporated.1
European Union
The European Union has established a European Food Safety Authority which speaks to risk
analysis, protection of consumers’ interests and imported, exported food. The tasks and
composition of the Authority are clearly stated.
The mission of the Authority is to provide scientific advice and scientific and technical support
for the Community’s legislation and policies in all fields which have a direct or indirect impact on
food and feed safety. The Authority is comprised of a Management Board, an Executive Director
and his staff, Advisory Forum, Scientific Committee and Scientific Panels.
The tasks of the Authority include promoting and coordinating the development of uniform risk
assessment methodologies, providing scientific and technical support to the Commission and
ensuring that public and interested parties receive rapid, reliable, objective and comprehensible
information in the fields within its mission.
Canada
The Canadian Food Inspection Agency was established in 1997 by the Canadian Food Inspection
Agency (CFIA) Act. It is a departmental corporation with separate employer status. Its primary
responsibility is to enforce technical relations described in legislation pertaining to food safety
and to animal and plant health. It does this by providing inspection services such as registration of
processing plants, inspection of domestic and imported foods, certification of exports, and
quarantine. Prior to the creation of the CFIA, inspection and related services for food safety and
animal health were provided by Agriculture and Agri-food Canada, Health Canada and the
Department of Fisheries and Oceans. These three departments transferred about $330 million and
4,500 full-time staff equivalents.
The human resources implementation team developed criteria to identify those who move to the
Agency. Individuals who devoted 60% or more of their time to inspection services were
designated a dedicated resource and were transferred. In some cases, non-dedicated staff(those
devoting less than 60%of their time to inspection programs) were given the option to volunteer
for transfer to any vacant positions. In other cases, transfers of staff were not feasible from the
perspective of the parent department, and so dollars were transferred instead. This approach was
not used to identify staff when they belonged to largely self-contained inspection units. A
deliberate decision was made to leave the details of the financial transfers and the human resource
framework until after the launch of the new agency. This led to a phased-in approach. Issues and
details that could not be resolved before the legislation was passed and that were not crucial to the
legislation were deferred.
The accountability regime is a mix of new and traditional approaches to governance. The
Agency’s regime retains the principles of parliamentary accountability and ministerial
responsibility. Two ministers are responsible for implementing the federal food safety program.
1 Regulation (EC) No 178/2002 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 28
JANUARY 2002
5
The Minister of Agriculture is responsible for inspection activities; The Minister of Health sets
food safety policies and standards in the area of human health, and assess the effectiveness of the
Agency’s related activities. 2
United States of America
The three branches of government; executive, legislative and judicial all impact on the USA’s
Food Safety System. Federal, state, and local authorities have complementary and interdependent
food safety roles in regulating food and food processing facilities.
US food agencies are accountable to the President, the chief executive, who has constitutional
responsibility to assure that laws are faithfully executed; who appoints senior officials, and whose
Office of Management and budget clears significant regulations. Food agencies are accountable
to the Congress, the legislative branch of the US government, which provides the food agencies
their authority and budget. They are accountable to the courts, the judicial branch of the US
government, which review food agency regulations and enforcement actions. The agencies are
accountable to members of the public, who regularly exercise their right to participate in the
development of laws and regulations, such as commenting on proposed regulations whose
guidance is sought in frequent public meetings; and who provide strong support for food safety
regulation, the nutrition label, and other regulatory initiatives.3
3.0 CURRENT FOOD SAFETY SYSTEMS IN IRAQ
Iraqi food safety programme is currently managed by a number of entities and agencies distributed across
the ministries of Agriculture (MoA), Health (MoH) ,Planning (MoP) - Central organization for
standardization and quality control COSQC Baghdad federal(f) / KSQCA Erbil regional (r),environment (
MoE) for radiation ,MoT ministry of trade for ration card items and finally custom directorate at border.
However, there is a lack of coordination of these activities, as no one ministry or agency has overall
responsibility for ensuring safe food production and compliance with international agreements. As a result
of this uncoordinated approach, there are a number of areas in which there is unnecessary duplication of
effort and facilities. Some examples of duplication are in the areas of sampling, inspection, laboratory
testing facilities and training. These and other activities are set out in Table 1 below.
Table 1
Summary of Existing Food Safety Activities Showing Samples of Duplication
Food Safety Activities Ministries & Public Sector Agencies Involved
Inspection & Certification
Certification & Testing of Meat Products
for local consumption , export & import
Veterinary Services Division (VSD) –MoA
MoH – Public Health Department
COSQC_KSQCA /MoP
MoT
MoE
Inspection & certification of foods and
feeds at ports of entry, warehouses and
retailers
MoA
MoH
COSQC – KSQCA /MoP
MoT
MoE
Registration and inspection of all food MoA
2 1998 Report of the Auditor General of Canada
6
processing factories; sampling & testing of
raw materials and finished products
MoH
COSQC-KSQCA
Training
Training of Meat/Food Inspectors in
HACCP, general food safety and food
hygiene
MoH
MoP
Training & certification of farmers and
pest control operators in proper and safe
use of pesticides
Under establishments
Public Education
Public education & awareness on food
safety issues
MoH
COSQC -KSQCA
Laboratory Testing Facilities
Chemistry
Microbiology
Entomology
MoH
MoA
COSQC-KSQCA
MoT
MoE
As can be seen from this table, the responsibility for implementing the current food safety
programme is splintered across several agencies in the five (5) ministries named. It is
encouraging to note that there is some level of cooperation and collaboration between some
directorate and laboratory.
The current Food Safety Legislation also shows overlap and duplication, at present a total six
Acts cover food safety activities in Iraq that we can found (see Appendix). These Acts and their
attendant regulations are administered by the Ministries of Agriculture, Health, Commerce,
planning and Technology.
An examination of these acts will reveal that there is:
Evidence of overlap in the functions of the different Acts;
Most have quite strong powers to ensure compliance, although the penalties to be imposed
(weak) need to be upgraded in terms of current reality; and
Some of the Acts were promulgated many decades ago and so need to be modernised.
There is no clear separation between quality and sanitary requirements.
There is no sign to risk analysis, evaluation and managements. And how to benefit from the
scientific information on building the resolution to protect the consumer.
There is an urgent need for the modernisation of legislation related to food safety, and the
development of an Umbrella Legislation that would address the issues mentioned above.
Any plan for implementing an effective food safety programme, including the creation of a Food
Safety Agency, must take into consideration these gaps, limitations and unnecessary duplications.
Such a plan requires the formulation of an appropriate policy, the design of cost effective
institutional structures, programmes and activities and the creation of a comprehensive and
relevant legislative framework.
7
4.0 FOOD SAFETY POLICY AND DEVELOPMENT WORK
Iraqi Cabinet must approve the National Quality Policy which we are going to prepare, and after
a complete discus it with all Ministries and NGO’s through the corresponding and the workshop
meeting that well be held later ,The Policy will be reviewed by SWEDAC Consultants . The
policy calls for the “regulation of foods, food products and food safety which shall be integrated
through the establishment of a national food safety agency.” However, a comprehensive Food
Safety Policy and Programme needed to be developed. After discussions, the final policy submits
to Iraqi Parliament to approve as a law. .
5.0 FOOD SAFETY POLICY OBJECTIVES
1. To have a system in place that will enable traceability of food from producer to consumer.
2.To institute a system that will enhance Iraqi’s risk management capability.
3. To upgrade system for administering international agreements with respect to food safety.
4. To streamline institutional arrangements for efficiency and effectiveness.
5. To promulgate a modern food safety umbrella legislation.
6. To institute an appropriate institutional arrangement for accreditation.
7. To establish systems that will ensure food produced by farmers is safe for consumption.
8. To establish systems that will ensure imported food is safe for consumption
9. To establish systems that ensure that food sold to the public by vendors, restaurants and
processors is safe.
10. To establish a coordinating mechanism for food safety activities
6.0 POLICY ISSUES AND RECOMMENDATIONS
Issue #1. Traceability
Currently there is a lack of proper system to facilitate traceability in animal and plant products
from farm to fork.
Recommendation
The Government of Iraq shall establish systems that facilitate traceability from farm to fork.
Adequate procedures to facilitate the traceability of feed and food and their ingredients shall
be introduced. These include the obligation for feed and food businesses to ensure that
adequate procedures are in place to withdraw feed and food from the market where a risk to
the health of the consumer is posed. Operators shall keep adequate records of suppliers of
raw materials so that the source of a problem can be identified.
8
Issue #2. Risk Management System
There is a lack of proper infrastructures to facilitate risk management of food. Risk assessment
and risk management capabilities are required under the WTO/SPS Agreement to which Iraq is
try to be member in near future. The Agreement requires that SPS measures that are implemented
must be supported by appropriate competencies and skills in this area.
Recommendation
The Government of Iraq shall institute a formal risk analysis mechanism which shall include risk
assessment, risk management and risk components. In addition, there shall also be a Risk
Assessment Policy.
Issue #3. Attendance at International Meetings and the Implementation of Agreements
There is a need for Iraq to participate more in meetings in which international food safety
requirements are being discussed e.g. CODEX Alimentarius, WTO/ SPS Agreement. Also there
is a need for closer monitoring and follow-up of food safety matters covered under international
agreements. Currently there are several government as well as Private Sector Organizations that
monitor international agreements, however, a timely response and subsequent implementation is
lacking.
Recommendation
The Government of Iraq shall enhance participation in international meetings and the
implementation of agreements.
Issue #4. Overlapping of certain food safety functions Currently there are overlaps in food safety activities such as inspection, certification, training,
public education and laboratory testing facilities as shown in Table 1.
Recommendation
The government shall identify the rules and to streamline the relevant institutions.
Issue #5. Legislative gaps and overlaps
The implementation of the current Food legislation in Iraq is splintered across various Ministries
which leads to overlaps and in some cases gaps our team found that, “one of the main problems
with the current legislation is the lack of enforcement. This is due partly to the low level of fines,
the lack of trained persons to prosecute offences and the inadequate financial commitment given
to enforcement.
Recommendation
The government shall promulgate a modern food safety legislation that will rationalize the current
ones.
Issue # 6. Lack of local accredited laboratories for food safety analysis
Some trading agreements require that testing facilities used for food analysis must be accredited
by a recognized body. At present there are no local laboratories that are accredited. This situation
impacts on Iraqi’s ability to enter third country markets requiring this type of verification.
Recommendation
The government urgently needs to establish an accreditation body that will accredit labs,
inspection and certification bodies
Issue # 7 Food produced by farmers is not adequately monitored for safety
9
Farmers are producing and distributing food, which may have a high level of pesticide residue.
The current system does not allow for speedy assessment and implementation of corrective
measures.
Recommendation
Farmers shall be responsible for producing and selling safe food to the public. The government
shall institute a food safety monitoring system to ensure that only safe food is available to the
public.
Issue # 8. Ensuring that imported food is safe for consumption
Iraqais consume a large amount of imported food and currently the system of testing and
inspection on arrival in Iraq is inadequate.
Recommendation
Importers of food shall be responsible for the safety of food brought into the country for sale to
the public. The government shall strengthen the current system for monitoring the safety of
imported food and for enforcing the regulations covering this food.
Issue # 9. Need to ensure that food sold directly to the public is safe
Food is sold directly to the public by a variety of sources e.g. food vendors, restaurants, and
supermarkets and at times there is no guarantee that the food being bought is wholesome.
Recommendation
Retailers shall be responsible for ensuring that food sold directly to public is safe. The
government shall upgrade the current monitoring and enforcement system to ensure public safety.
Issue # 10. Difficulties exist in coordinating the food safety function.
At present there are many directorate and departments of government that are responsible for the
safety function along the food chain. This fragmented nature of the function has posed difficulty
for coordinating and streamlining activities and has resulted in overlaps and gaps in the country’s
food safety system.
Recommendation
The government shall establish a coordinating mechanism such as an agency which shall be
responsible for coordinating food safety activities.
7.0 STATEMENT OF SCOPE
In determining the scope of the food safety policy, it must be accepted that it has to be wide-
ranging and adopted by a number of sectors in the economy, each with their own issues to
resolve.
This policy shall, therefore, guide the operations of various scientific, technical, operational and
management agencies in the public and private sectors. These entities are concerned with:
Nutrition;
Food hygiene;
Public health;
Plant health;
Animal health; and
International trade (imports and exports).
10
An underlying expectation of such entities is to provide public education in their respective
discipline areas, and to deliver training within their area of competence.
8.0 DEFINITION OF FOOD AND STATEMENT OF PRINCIPLES
Definition of Food
For the purposes of this policy “Food” or “Foodstuff” means any substance or product whether
processed, partially processed, or unprocessed, intended to be, or reasonably expected to be
ingested by humans. “Food” also includes drink, chewing gum, and any substance, including
water, intentionally incorporated into the food during its manufacture, preparation or treatment.
Furthermore, Food, as defined for this policy, shall include food ingredients and derivatives, i.e.
o Genetically modified organisms (GMOs);
o Functional foods (foods which claim to have special properties valuable to health, but
which do not have a medicinal product license);
o Food additives; and Fortified foods (foods to which nutrients have been deliberately
added).
Food shall not include:
(a) feed
(b) live animals unless they are prepared for placing on the market for human consumption;
(c) plants prior to harvesting,
(d) medicinal products
(e) cosmetics
(f) tobacco and tobacco products
(g) narcotic or psychotropic substances within the meaning of the United Nations Single
Convention on Narcotic Drugs 1961, and the Nations Convention on Psychotropic Substances,
1971;
(h) residues and contaminants
Food Chain
In accordance with international practice the food safety management must take place throughout
the entire food chain. The Food Safety Policy shall therefore cover the entire food chain from
farm to fork. The Food Chain is referred to at various points in the policy statement and the
diagram below illustrates the stages of the Food Production Process (Figure 1).
11
Figure 1 – The Food Chain
All aspects of food safety and the principles guiding its management are covered by
internationally-accepted definitions. These are documented in the various references highlighted
in this policy paper with important definitions elaborated upon in Appendix 2. The principles
guiding the food safety policy are as follows:
Risk Analysis:
A formal risk analysis mechanism shall be instituted. This is a process consisting of three
components:
Risk Assessment, which is scientifically based process consisting of the following steps:
Commission of the European Communities: White Paper on Food Safety, January 2000 http://europa.eu.int/comm/dgs/health_consumer/library/pub/pub06_en.pdf