CFG
01/07 final
Letter dated 19 January
2007 from Foodaware to Bill Drennan, Food Law Policy Branch, Food
Standards Agency:
Dear Mr Drennan
Draft FSA Guidance Notes on general food law regulation (EC)
178/2002
The Guidance Notes relate specifically to Articles 14-16 and 18-20
of the General Food Law Regulation. They have been updated to take
account of those provisions which came in during 2005 and also following
consultation in 2005 on the EC Guidance. The Articles cover safety,
traceability, withdrawal and recall of products. As the Guidance is
intended to help producers and suppliers comply with the law, our
comments from a consumer perspective are brief. We fully understand
the industry’s desire to limit the guidance to requirements
under the law, and not to use it to promote best practice, so that
there is no possibility of confusion and the Guidance does not become
unwieldy. However, it is important for opportunities to be found to
continue to promote good practice and we urge the FSA to use all possible
opportunities, in conjunction with industry associations, to encourage
dissemination of best practice.
It is particularly disappointing that those commenting considered
that guidance on best practice in relation to traceability could result
in additional costs. Traceability of food products and their ingredients
is fundamental to ensure that the public can be protected from contamination,
and health and hygiene problems arising from a foodstuff or batch
of processed food. It is also essential to enable products which are
deemed unsafe to be withdrawn and action to be taken against those
who mislabel products or supply unsafe food. The role of regulatory
authorities is made considerably more difficult if products and ingredients
cannot be traced, and it becomes more difficult to prevent harm in
the face of a known hazard, if the product and its components cannot
be traced. We consider traceability to be an important requirement
for consumer protection and a necessary production cost for which
consumers are prepared to pay.
The section on traceability, therefore, is vague and unlikely to be
helpful to small businesses and farmers who may be unaware of the
requirements and necessity to comply. Leaving the length of time traceability
records should be kept to the discretion of the supplier is also unhelpful
to consumers. This is an area where more precise examples and good
practice guidance would be warranted.
The legislation applies to food produced for charitable events and
the FSA should ensure that schools and charities are aware of their
obligation to comply. The guidance is too technical to be of use to
such organisations, and simpler generic information should be available
through the website and in relevant publications to remind those who
produce food on an occasional basis of the legal obligations and risks.
Article 15 relates to the safety of animal feed at all stages of production,
storage, supply and sale, including one-off sales and supplies free
of charge. This article includes ensuring the safety of animal products
after the feed has been consumed by the animal. Given the ongoing
sensitivity of this issue, and the persistent risk from contaminated
animal feed and on-farm mixing, we would expect the FSA, in conjunction
with Defra, to provide dedicated advice on this issue to the farming
community in addition to the general guidance.
The document would benefit from the inclusion of some sample flow
diagrams indicating the questions which suppliers should ask of themselves
and the actions which would follow in a given set of circumstances,
e.g. a contamination incident resulting in a recall.
Yours sincerely
Susan Knox
Chairman
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