Preventive control key to ensuring food safety

When it comes to food and drinks, we are all food safety experts to some degree because of some common experiences. These experiences could range from legal or regulatory matters, about our daily meals and snacks, to fraud or unclear labelling, or even mild food poisoning. 

We all have certain levels of expectations about what our food should be like, whether that be organic, local, imported, non-GMO, or anything else. The public is very interested in news of food safety outbreaks or instances of heavy metal, pesticide residues, or antibiotics in food. 

The problem is that everyone in modern society depends on someone else to grow or prepare the vast majority of the food they eat. In the widest meaning, food law is set up to protect citizens from unhygienic and unsafe food. 

Since the food chain may be small, medium and long, it requires a proactive and systematic approach to control food safety issues because only end-product testing or inspection through reactive approach cannot remove the source of the problem. 

A preventive approach has been universally accepted and adopted throughout the world because it helps to identify the most important threats to food safety, rather than reacting to problems after they have arisen. 

Preventive control programs are designed to work in connection with and be supported by other relevant programs such as Good Manufacturing Practices (GMPs), Good Hygienic Practices (GHP), Good Agricultural Practices (GAP) and Good Distribution Practices as the foundation for food safety management. Application of preventive controls approach in identified steps helps to minimise the risk of producing products that can cause foodborne diseases for consumers. 

The history of preventive control can be traced back to risk‐based approaches of managing food safety as a very first initiative in the 1960s during the development of meals for the US space program. 

Finished‐product testing was the measure of quality control programs during this time, but that resulted in a shortage of food for space flights. This was commercially impractical, and as a result, NASA then worked with the Pillsbury company to prevent hazards through product formulation and process control. The method they developed was called the Hazard Analysis and Critical Control Point (HACCP). 

Based on their experiences, Pillsbury organised training programs for the US Food and Drug Administration (FDA) inspectors at that time. The FDA initiated HACCP principles in the development of low-acid canned food regulations in the 1970s. Then the US National Advisory Committee on Microbiological Criteria for Foods (NACMCF) and the Codex Alimentarius Commission (Codex) published the HACCP principles in the 1990s. 

The FDA has HACCP regulations for seafood and juice products, while the USDA has HACCP regulations for meat and poultry products. And HACCP is endorsed by many countries, including Australia, Canada, New Zealand and European Union countries. 

However, the preventive controls approach also includes controls for hazards related to food allergens, GMPs, sanitation, suppliers and others, such as food recalls and withdrawals, customs and border requirements, and licensing and registration of food establishments as regulatory compliance. 

The FDA has also started this preventive control approach for food and feed like Food Safety Preventive Control for Human Food (FSPCA for Human Food) and the Food Safety Preventive Control for Animal Feed (FSPCA for Animal Feed). 

In addition, the inspection and surveillance systems are very necessary for preventive food control. The US, Canada, Australia and New Zealand, many European countries, Japan, Thailand, Indonesia and our neighbouring country India have started inspections emphasising risks and introduced a surveillance system with a scientific approach. 

The government of Bangladesh has created the Bangladesh Food Safety Authority (BFSA) as an apex body for monitoring food safety through coordination among the existing Food Control Agencies (FCAs) by the enactment of Food Safety Act, 2013. 

With the help of development partner USAID and the Food and Agriculture Organization (FAO) of the United Nations, the Bangladesh Food Safety Authority (BFSA) once tried to initiate a risk-based inspection system through a scientific approach. Currently, JICA is supporting the BFSA for strengthening its capacity through a technical cooperation project. 

However, there are challenges to implementing the preventive food control system, which include: a lack of coordination among the FCAs; no monitoring of other FCAs to support and follow-up their activities; overlapping of roles and activities of FCAs and no clear jurisdiction; registration and licensing are done by other departments and authorities, but food safety and hygiene status are not considered during either processes.

Moreover, frequent transfers of senior officials and deputed officials without relevant backgrounds, in most cases, also pose a challenge for the FCAs. Fresh officers are not provided hands-on training on food safety either.

And the application of the Food Safety Act, 2013 through mobile courts is contradictory to a science-based approach.

To resolve this, it is necessary to conduct a regulatory gap analysis and arrange a high-level dialogue through the involvement of the Cabinet Division.

The Food Safety Act, 2013 needs to be amended with the provision of registration and licensing, revisiting the term sub-standard that is not related to food safety, and increasing the administrative authority to bring FCAs to court if they fail to comply with directives of the act. 

Other agencies' registration and licensing systems are obsolete if they are not relevant to food safety. Coordination among FCAs with demarcation of clear roles and responsibilities and regular monitoring of their activities through involvement of Cabinet Division is also required.

It is also necessary to rethink vertical quality standards because we cannot stop product diversification and customer demands according to their food choices and health needs unless there is any food safety issue. Is it required for SMEs?

It is also necessary to involve food industry experts in the development of rules and regulations and in high-level technical committees. 

The solution also entails a strategy for hands-on training and refresher training. At the minimum, a year of hands-on training through attachment in industry and regulatory activities for the entry level officers is required. In addition, refresher training is required after certain intervals. 

Senior officials should be posted for a sufficient time until the successors get ready to take the lead and deputed officials should come from relevant backgrounds to comply with the Food Safety Act. It is also better to recruit experienced individuals directly.

And finally, the government should introduce a preventive control system emphasising risk-based approaches, rather than reactive approaches like mobile court drives.

The author is the Senior Food Safety Consultant of the JICA STIRC Project