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Proceedings of 2nd

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Proceedings of 2nd

Workshop on

CODEX ALIMENTARIUS: PRINCIPLES & PROCEDURES

3rd

October, 2013

Kochi, Kerala

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WORKSHOP ON CODEX ALIMENTARIUS: PRINCIPLES & PROCEDURES

Background

1. Codex Alimentarius Commission is a joint FAO – WHO intergovernmental body

consisting of 185 Countries plus 1 European Union as members. There are a number of

organisations that have been granted Observer status. The mandate of Codex Alimentarius is

to ensure consumer health and fair practices in food trade through setting of standards for

food, Code of Hygienic practices and guidelines.

2. Food Safety and Standards Authority of India (FSSAI) being the National Codex Contact

Point of India is making efforts to create awareness about Codex Alimentarius; its importance

and procedures amongst the various stakeholders and strengthen their expertise for effective

participation in Codex Activities. As a first step towards this endeavour, the first regional

workshop was conducted on 2nd

August, 2013 in New Delhi. The second regional workshop

was conducted on “Codex Alimentarius: Principles and Procedures” on 3rd

October, 2013 at

Kochi.

Inaugural Session

While explaining the purpose of conducting the workshop, Ms Vinod Kotwal,

Director (Codex), informed the participants that Codex Alimentarius is a strong

intergovernmental body; whose mandate is health of the consumers. She further informed

that India became a member of Codex in 1964 and the NCCP was established in 1971 in

Ministry of Health and Family Welfare. With the establishment of FSSAI in 2008, the NCCP

of India is now located at FSSAI. NCCP through these workshops is trying to build a strong

network between the NCCP, Research Institutes, Industry and other stakeholders. Further

with the establishment of Codex Committee on Spices and Culinary Herbs (CCSCH), whose

host country is India, a greater responsibility has been entrusted on the country. It is a matter

of great pride that the Secretariat for CCSCH is with the Spices Board. Dr Jayathilak,

Chairman, Spices Board delivered a special address on the occasion and pointed out that as

a host country of CCSCH, India is in the centrestage. He thanked FSSAI for its continuous

support. Shri S. Dave, in the capacity of the Chairman, Codex Alimentarius Commission

delivered the key note address, acknowledging and appreciating the efforts of all those

involved in the establishment of CCSCH. A commodity committee has been established in

Codex after 25 years. Shri Chandramouli, Chairperson, FSSAI inaugurated the session

and reiterated that it was a matter of pride and honour for him to be a part of the Indian

delegation at the 36th

session of Codex Alimentarius Commission wherein the setting up of

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CCSCH was approved. With this opportunity, comes a great responsibility on the host

country to organize the meetings of the

Committee well and also play an active role. It is a long term commitment on behalf

of the host country and Spices Board should take note of this. He further mentioned that now

there is a need to build our expertise in the subject matter. He further touched upon the

activity pertaining to the harmonization of the national standards with Codex Standards being

taken up by FSSAI. Dr Thampi, Deputy Director (Publicity), Spices Board concluded the

session by extending his vote of thanks to all the speakers and participants.

TECHNICAL SESSION 1

10:30 A.M. – 01:00 P.M.

1. Shri S. Dave, Advisor, FSSAI - Codex Alimentarius Commission: Introduction

Shri S. Dave focussed on the basic information about Codex Alimentarius, its structure

and relevance. He mentioned that Codex is an intergovernmental body of the United Nations

with 185 member countries and 1 member organization. The function of Codex is to adopt

science based standards with the mandate of safety of health of consumers and fair practices

in trade. He mentioned that the Executive Committee of the Commission consists of

Chairperson, 3 Vice-Chairpersons, 6 Regional Co-ordinators and 6 Members from each

region. There are 10 General Subject Committees, 7 Commodity Committees, 6 Regional

Coordinating Committees and 2 Ad hoc Intergovernmental Task Forces. Further, the

scientific advice to Codex is provided by JECFA (Jt. Expert Committee on Food Additives),

JMPR (Jt. Meeting on Pesticide Residues), JEMRA (Jt. Expert Committee on

Microbiological Risk Assessment) and JEMNU (Jt. FAO/WHO Expert Meetings on

Nutrition).

The talk focussed on the issues that are relevant to developing countries and the issues

that are of particular importance to India such as:

Fresh Fruits and Vegetables : Okra, Pomegranates, Grapes, Potatoes, Onion

Spices, FFV

Tea, Coffee

Nutrition related issues

Marine, Dairy, Poultry, Meat Products

Additives / Contaminants / Veterinary Drugs / Labeling / Inspection / Methods of Analysis

/ Street Foods

Equivalence / Traceability (organic, grapes)

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He gave a way forward for India to harmonize standards with Codex, introduce guidance

texts for small business / farmers (e.g., GAP, GMP, GHP, conformity assessment), Strengthen

laboratory network, Invest in Scientific Risk Assessment, Play an active role in Codex

(NCCP, WGs, CCSp. be visible), Engage in equivalence negotiations and thereby, Make the

country strong in Codex Activities.

2. Ms Vinod Kotwal, Director (Codex), FSSAI - Codex Procedural Manual

Ms Kotwal made the presentation on Codex Procedural Manual, which is the

foundation for Codex Functioning and Codex Documentation. She explained the structure

and the network of Codex, which was also discussed by Shri Dave. She explained in detail

about the various documents that are circulated by the Codex Secretariat, which are:

Codex Procedural Manual

ALINORMs

Committee working papers (CXs)

Circular Letters (CLs)

Conference Room Documents (CRDs)

Limited distribution documents (LIM)

Information documents (INF)

Adopted texts.

She explained that the Codex Procedural Manual outlines the agreed set of rules to

ensure that the Commission and its subsidiary bodies work in a uniform manner and it is

intended to help member countries to participate effectively in the work of the Joint

FAO/WHO Food Standards Programme. The Manual contains the Statutes of the

Commission and rules of procedure, guidelines for the operation of Committees and Task

Forces and the information on how the Commission carries out its work, including the

reference system for Codex documents. Codex Committee on General Principles is

responsible for updating the Manual, and such amendments are considered regularly by the

Commission. She then elaborated on the various Codex Documents that are circulated by the

Codex Secretariat. All Codex documents contain a reference number which is unique to that

document. She explained to the participants on how to read the reference of a document and

the meaning of each code. She further emphasized on the 8 step procedure that is followed in

Codex and strict adherence to these steps is essential. Since the amount of papers that are

circulated by the Codex Secretariat are huge, it is also equally important to organize them

appropriately. The organization of Codex Documents depends on the Codex Committee that

you wish to participate and send your comments on. As all the Codex Documents are

available electronically, it is now quite easy to organize them in various folders.

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3. Ms Sakshi Gambhir, Technical Officer, Codex Cell, FSSAI - Conducting Shadow

Committee Meetings: Procedure followed by NCCP India & Follow Up Action by the

Delegation

Ms Sakshi Gambhir talked about the procedure that is followed by NCCP, India in

conducting the Shadow Committee Meetings. Her talk focussed on what a shadow committee

is, its role and the composition. For each Codex Committee, a parallel Shadow Committee

has been constituted in India that works for that particular Codex Committee. “Shadow

Committee” means the Committees of the National Codex Committee constituted by the

Food Authority for reviewing the agenda of the Codex Alimentarius Commission and its

subsidiary Committees and finalizing India’s comments on various agenda items. The various

shadow committees are:

1. Shadow Committee on Core Issues – FSSAI, MoHFW

2. Shadow Committee on Processed Fruits Products, Food Additives & Contaminants in

foods –FSSAI, MoHFW

3. Shadow Committee on Food Hygiene (CCFH) – FSSAI, MoHFW

4. Shadow Committee on Fats & Oils, Sugar and Cereals, Pulses & Legumes –FSSAI,

MoHFW

5. Shadow Committee on Food Import and Export Inspection and Certification Systems

(CCFICS) – Ministry of Commerce (MoC)

6. Shadow Committee on Methods of Analysis and Sampling (CCMAS) – FSSAI, MoHFW

7. Shadow Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) –

Ministry of Women and Child Development (MWCD)

8. Shadow Committee on residues of Pesticides & Veterinary Drugs in Foods - Ministry of

Agriculture

9. Shadow Committee on Fish and Fishery Products (CCFFP) - Ministry of Agriculture

(Department of Animal Husbandry, Dairying and Fisheries)

10. Shadow Committee on Fresh Fruits and Vegetables (CCFFV) – Ministry of Agriculture

Most of the Shadow Committees are with FSSAI and some are with other line

Ministries/Departments since the expertise required to manage these committees are with

these Ministries, and therefore, it was very important to follow a uniform streamlined

procedure of conducting meetings and formulating India’s viewpoints. She mentioned that

the important function of a shadow committee is to provide a forum for discussion and

thereafter, to finalise India’s viewpoints. The shadow committee stakeholders include

representatives from various ministries, educational institutions, industry associations and

experts and scientist from concerned areas. She explained the entire process of finalising the

India’s viewpoints that is followed at FSSAI.

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She shared two case studies on Codex Committee on Food Additives (CCFA) and

Codex Committee on Food Labelling (CCFL), how the meetings were conducted with

different strategies based on the concerned agendas. For CCFA, 4 shadow committee

meetings were conducted whereas for CCFL, 2 shadow committee meetings were conducted

and thereafter the meetings of only the delegation were conducted to formulate the India’s

strategy.

The second part of the presentation focussed on the important component of the entire

process involved with Codex Meetings, i.e., debriefing meeting, wherein, the delegation

identify the concerns and necessary action that has to be taken after the meeting is over. The

leader of the delegation should submit a report of participation to the NCCP. The report

should be submitted within a period of 30 working days after the session/meeting is over. The report should essentially contain additional agenda items/notes tabled in the meeting and

the conference room documents/discussion papers circulated by other Member Countries.

The delegation report should also contain the reports of the in–session Working Groups. The

delegation report should include possible strategies for the next session. She shared an

example of the Codex Committee on Food Additive, wherein a number of Electronic

Working Groups (Ewgs) were established by the Committee. However, the delegation

identified the important Ewgs after the session was over and India participated only in the

identified Ewgs.

4. Shri Sunil Bakshi, Deputy General Manager (QA), National Dairy Development

Board - Guidance on how to prepare National Response or National Viewpoint on

Codex Matters

Shri Bakshi gave a presentation on how to prepare National viewpoints on various

Codex issues. The entire process consists of following steps:

Obtaining documents

Identifying concerns

Developing comments

Debating and refining

Presentation of comments

Analysis of some past comments

The documents are available at Codex website www.codexalimentarius.org and are

also distributed by the NCCP, India. It is first important to identify the documents of

relevance based on the competence we have to comment on the subject matter. To identify

the concerns, it is required to read the document carefully and to correlate with past versions

and to locate new concerns arising due to changes. He explained in – depth about the

development of comments and also providing justification for the comments.

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The comments should first be discussed among the colleagues, then within the

organization, thereafter among the organizations and finally should be discussed in the

shadow committee. To refine the comments, check with science, data, previous decisions,

consistency with/contradiction to existing texts and the procedure. It needs to be consciously

decided at every stage of refinement if it is necessary to send written comments and in what

form. It is also important to provide notes for the delegation wherever required. He also gave

some examples of how to present the comments. The comments should be divided into two

parts: General and Specific. The important points to be kept in mind are:

Specific comment: Clear and accurate reference to the text being commented upon

Proposed amendments

Insertions- Bold and underline; deletions- strikethrough (may also be bold)

Not to use ‘track change’

Not to use colours

Not to reproduce excessive text

Rationale for every comment

Note to delegation

5. Shri P. Kartikeyan, Assistant Director, FSSAI - Food Safety and Standards Act,

2006 and Regulations

Shri P Karthikeyan explained that the Food Safety and Standards Authority of India

(FSSAI) has been established under Food Safety and Standards Act, 2006, which consolidates

various Acts & Orders that had hitherto handled food related issues in various Ministries and

Departments.

Various central Acts like Prevention of Food Adulteration Act, 1954, Fruit Products

Order, 1955, Meat Food Products Order, 1973, Vegetable Oil Products (Control) Order, 1947,

Edible Oils Packaging (Regulation) Order 1988, Solvent Extracted Oil, De- Oiled Meal and

Edible Flour (Control) Order, 1967, Milk and Milk Products Order, 1992 etc have been

repealed after notification of FSS Act, 2006. Final Rules have been notified in the gazette of

India on 5th

May, 2011. Six Regulations have been notified in the gazette of India on 1st

August, 2011. FSSAI has been created for laying down science based standards for articles of

food and to regulate their manufacture, storage, distribution, sale and import to ensure

availability of safe and wholesome food for human consumption.

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With the setting up of FSSAI, there have been critical shifts such as now the focus is on

safety rather than adulteration, there is a single authority, and emphasis is given to monitoring

and surveillance rather than inspection. The FSS Act consists of 12 chapters, out of which the

important sections are section 3 (chapter 1), section 4, 5, 10, 11, 12, 13, 14, 16, 17 (chapter

II), section 18 (chapter III), section 19 to 24 (chapter IV), section 25 (chapter V), section 26

to 28 (chapter VI), section 29 to 32, 36 to 39 and 42 (chapter VII). He also explained in detail

the method of sampling and analysis. He also described the prosecution process followed

when a sample fails. The punishment may be with/without fine and with/without

imprisonment. He mentioned that the salient features of FSS Rules and Regulation 2011 are

as follows:

Integrates the erstwhile acts/rules/orders, no new standards being introduced.

Unified Licensing Procedures and application forms

Clear line of distinction between licensing and registration

Standards have been systematically arranged taking into consideration Codex

classification

The 6 notified FSS Regulations are:

1) Food Safety and standards (Licensing and registration)Regulations, 2011

2) Food Safety and standards (packaging and labeling)Regulations, 2011

3) Food Safety and standards (Food products standards and Food Additives) Regulations,

2011.

4) Food Safety and standards (Prohibition and restriction for sale) Regulations, 2011

5) Food Safety and standards (contaminants, toxins and Residues) Regulations, 2011.

6) Food Safety and standards (Referral laboratories and sampling) Regulations, 2011

Food Safety and Standards (Licensing and registration) Regulations, 2011 enlists the

entire procedure to be followed by a Food Business Operator to get a FSSAI license and the

procedure followed by Central Licensing Authority, State Authority and Registering

Authority. Food Safety and Standards (Referral laboratories and sampling) Regulations, 2011

defines the functions of the notified laboratories and the notified laboratories. It prescribes the

notified laboratories for import and Referral Laboratories and their area of jurisdiction,

prescribes the quantity of the sample of various food products and their method of

preservation. It also prescribes the format for the certificate of analysis by the Referral food

laboratories and food analysis report by the Food analyst. There are 13 product categories in

the chapter and standards for about 377 products have been provided in Food Safety and

standards (Food products standards and Food Additives) Regulations, 2011. The second part

of the Regulation deals with use of food additives in various foods and specifies their limits

as well as specifies some specific label declarations with respect to certain food additives.

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Food Safety and standards (contaminants, toxins and Residues) Regulations, 2011 contains 3 clauses that specify the limits in various foods:

METAL CONTAMINANTS: This regulation prescribes the limits for Heavy metals

and Metal contaminants for various foods and commodities.

CROP CONTAMINANTS AND NATURALLY OCCURING TOXINS: This

regulation defines Crop Contaminants and specifies their limits for foods. It also prescribes

limits for 4 naturally occurring toxins.

PESTICIDE RESIDUES: This clause lists down limits for 149 Pesticide Residues and

5 Antibiotics in foods.

Food Safety and standards (Prohibition and Restriction for sale) Regulations, 2011

deals with the restrictions and Prohibitions on sale of certain food products. It contains 3

clauses:

• Sale of certain admixtures prohibited

• Restrictions on use of certain ingredients

• Prohibition and restriction on sale of certain products

Food Safety and standards (Packaging and Labeling) Regulations, 2011 enlists the

packaging and labeling requirements for pre-packaged products.

The Technical Session I was concluded by Question and Answer round giving an

opportunity to the participants to ask questions from the panel members.

TECHNICAL SESSION II

02:00 – 04:00 P.M.

1. Dr. Himanshu Gupta, FICCI –CIFTI Codex Cell - Scientific Basis of Codex

Dr. Himanshu Gupta focussed his talk primarily on what forms the basis of Codex:

The Science. Codex Committees, while developing standards, apply risk analysis and rely on

the independent scientific advice provided by expert bodies organized by FAO/WHO. He

explained about the three FAO/WHO expert committees:

Joint FAO/WHO Expert Committee on Food Additives (JECFA)

Joint FAO/WHO Meetings on Pesticide Residues (JMPR)

Joint FAO/WHO Expert Meetings on Microbiological Risk Assessment (JEMRA)

The Main Principles for developing scientific advice are Excellence, Independence,

Transparency and Universality. He also mentioned that risk analysis within Codex is a

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structured, systematic process that examines the potential adverse health effect consequential

to a hazard or condition of a food, and develops options for mitigating that risk. The whole

risk analysis process includes risk assessment, risk management and risk communication. The

International risk assessors are JECFA, JMPR, JRMRA & Adhoc expert consultations and the

International risk manager is the Codex Alimentarius Commission.

2. Ms Sukhmani Singh, Technical Officer, Codex Cell, FSSAI - Participation in the

EWGs

Electronic Working Groups, i.e., Ewgs are one of the most important stages to make

an intervention since all the discussions and deliberations happen electronically through these

ewgs. Ms Sukhmani Singh provided guidance on how to participate in these ewgs and the

important points for every ewg participant. EWGs have been developed in Codex to enhance

the participation from all member countries and to reach consensus. An eWG is established

at the plenary session by the Committee. Codex Committee decides that the eWG will

be managed by the Host Government Secretariat or by another member of the

Commission which has volunteered to undertake this responsibility. EWG’s membership

is notified to the Chairperson of the Codex Committee and to the Host country

Secretariat of the Committee. She also talked about how an ewg works starting from

circulation of an invitation upto the finalising of the report for consideration by that Codex

Committee, as follows:

The Host is responsible for the management of the eWG for which it has been

appointed.

A notice or kick-off message is prepared indicating the timeline where the start and

end of the program is displayed about particular work and is distributed to all members

and Observers who have been nominated.

The Draft of that particular work for an eWG is prepared and is circulated to the

participants and call of comments are requested from them.

The Comments by the participants are submitted by electronic means.

A compilation of these comments and other contributions received are sent to the

number of countries/ participants who participated in the eWG.

An update of the progress of the work is presented by the Host at each session of the

Codex Committee which has established it.

Once the work is finished of an eWG, the Host Secretariat sends the copy of the final

conclusions in the form of discussion paper or a working document along with the list

of participants to the Codex Secretariat and to the Host Country Secretariat of the

Committee.

The Codex Secretariat then forwards these to the Codex Contact Points and

Observers.

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The Codex Secretariat ensures that these conclusions are included in the distribution

papers for the next session of the Codex Committee, which has established the eWG.

She also shared various examples of various ewgs where India has been a participant

and ewg where India is the host. NCCP India faces a lot of challenges while nominating the

right expert for a particular ewg and then submitting the comments on time. Therefore, it

becomes very important for the stakeholders to come forward with their active participation

and give their nominations for the ewgs. Also, sometimes the comments which are

provided by our stakeholders for an Ewg sometimes are mere statement. So, it is

important that the comments should be backed by data.

3. Shri Karthikeyan, Assistant Director, FSSAI - Harmonization of FSS Standards

with Codex Standards: Where do we stand?

Shri Karthikeyan made a presentation on harmonizing the Indian Standards in line

with the Codex Standards. He also touched upon the other important agreements under World

Trade Organization (WTO) and Sanitary and Phytosanitary Measures (SPS). The need for

harmonization was felt to consider the latest development in food science across the globe,

food consumption pattern, new specifications, presence of new contaminants and toxins as

well as use of new food additives and ingredients required by the producers and

manufacturers in food business. Under the TBT and the SPS Agreement of the WTO, it is

mentioned that countries to use relevant international standards when they exist. CODEX and

WTO members should upgrade National Food Standards and Regulations based on

harmonization with Codex; get involved with Codex work; Strengthen National Food Control

Systems; and Ensure efficient importing and exporting inspection and certification systems.

He described in detail the process undertaken by FSSAI to harmonize the standards

and how the various stakeholders have been engaged in working groups. The Authority has

established 76 working groups to complete the work. The work is expected to be completed

by December 2014. The revision of vertical standards require first to review the Food Safety

Regulations and then initiate the revision process, to identify products where we have no

FSSR but there are Codex/other international standards and then creation of standards for

other (ethnic) products. The revision of horizontal standards involve review standards for

additives, contaminants, etc. for harmonisation with GSFA/GSCTFF, then to harmonise

ingredients/ nutrients and thereafter to develop Codes of Practice for uniform application

across vertical standards.

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4. Ms Vinod Kotwal - Submitting a new work proposal in Codex

Ms Kotwal gave a presentation on how to prepare a new work proposal and submit it

in Codex. She mentioned that the foremost thing is to identify whether new work falls under

the mandate of Codex. She focussed on the various parameters that should be covered in a

project document and provide justification to the new work, which are as follows:

Purpose and Scope

Criteria for establishment of work priorities

Information on relation between proposal and other existing Codex Documents

Identification of requirement of expert advice

Identification of need for technical inputs to the standard from external bodies

Proposed timelines for completion of work

She also mentioned about the criteria to be looked into for a commodity standard and

for a general standard. The criteria for developing a commodity standard are:

Volume of production, consumption and pattern of trade

Diversification of National legislation

International or regional market potential

Amenability of Commodity to standardization

Existing or proposed general standard

Number of commodities covered

Work already taken by other international organizations

The criteria for developing a general standard are:

Diversification of National Legislation

Scope of the work

Work already undertaken by other International organization

Amenability of subject

Global magnitude of the problem

She also elaborated the procedure for getting a new work approved. The project

document is first submitted in the Committee. The Committee after deliberations approves

and then forwards it to the Executive Committee for critical review. If the CCEXEC finds the

project document suitable, it forwards it to the Commission for approval. There is an

exception for proposing a new work on Maximum Residue Limits for pesticides and

veterinary drugs. There is a Concern Form for these two Committees; CCPR and CCRVDF

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which is reviewed by the Joint FAO/WHO Expert Committee. It is then reviewed by the

Committee and thereafter approved by the Commission.

The presentation also included a list of new work proposals that have been approved

by the Codex Alimentarius Commission and some of which are under process, such as:

Inclusion for a New Part B for underweight Children in the Standard for Processed

Cereal-Based foods for Infants and Young Children (CCNFSDU)

Proposed Standard for Okra (CCFFV)

Proposed Code of Hygienic Practice for Street Vended Foods (CCASIA)

Proposed Standard for Ware Potato (CCFFV)

Developing general standard for labelling of wholesale packages of food (CCFL)

Establishment of Maximum level for total aflatoxin in Ready-to-eat peanuts (CCCF)

She also mentioned some of the new works that can be suggested by India such as:

Proposal for Standard for Sapota (CCFFV/CCASIA)

Proposal for Standard for Gourds (Annexes for bitter gourd/bottle gourd etc.) (CCFFV)

Proposal for establishment of MRLs for Chlormequat Chloride in Grapes (CCPR)

Proposal for establishment MRLs for Isoprothiolane in Rice (CCPR)

Proposal for establishment MLs for Aflatoxin in Spices (CCCF)

Proposals for development of commodities standards under Codex Committee on Spices

and Culinary Herbs

Proposal for Code of Practice for hygienic and wholesome food for School Children

(CCFH/CCNFSDU)

The Technical Session II was concluded by Question and Answer round giving an

opportunity to the participants to ask questions from the panel members.

The workshop concluded with the following points:

The experts involved in the area of Spices research were keen to participate in all

Codex related activities.

A shadow committee will be established for Codex Committee for Spices and

Culinary Herbs by NCCP.

A similar workshop will be conducted in the Eastern and Western regions of the

Country to disseminate information across the country.

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