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TRACEABILITY
Traceability
has been defined by the International Organization
for Standardization (ISO 8402) as the"
ability to trace the history, application or
location of any entity by means of recorded
identification".
Traceability
is closely linked with product identification.
It may relate to:
- the
origin of materials and parts (food products
and ingredients);
- the
product processing history;
- the
distribution and location of the product
after delivery.
The
matter of traceability has been raised in various
Codex Committees and Task Forces, including
Codex Committee on Food Import and Export Certification
Systems, Food Hygiene, Food Labelling, Food
Additives and Contaminants, Committee on Fish
and Fishery Products, Task Forces on Animal
Feeding and Foods Derived from Biotechnology.
The
concept of "traceability" has already
been included in many Codex texts and is linked
to product identification and recall procedures.
Codex texts do not currently apply traceability
to the origin of foods and ingredients
with the exception of the Country of Origin
provisions of the General Standard for the
Labelling of Pre-packaged Foods and the Guidelines
for the Production, Processing, Labelling and
Marketing of Organically Produced Foods.
RECENT
DISCUSSIONS
Traceability
was first introduced formally for discussion
at the 9th Session of CCFICS held during 11-15
December 2000 in Perth, Australia.
Thereafter
at the request of CCFICS a background paper
was presented at the 24th Session of the Codex
Commission held during 2-7 July 2001 to consider
means of dealing with it within the framework
of Codex in a uniform manner.
The
issue which was further taken up at the 49th
Session of the Executive Committee in September
2001, where it was highlighted that any measures
requiring traceability should be justified
as:
-
Having a food safety objective (i.e., as
an SPS measure)
- Having
a legitimate objective (i.e., as a TBT measure)
The Executive Committee further:
- recommended
the Codex Committee on General Principles
consider these two aspects of traceability,
although it was of the opinion that first
consideration should be given to the use
of traceability as a risk management option
in the draft Working Principles for Risk
Analysis
- requested
CCFICS to consider the modalities for the
application of traceability, in particular
in reference to the use of official inspection
and certification systems to ensure the
integrity of traceability.
- agreed
that the Committees concerned (including
the Committees on General Principles, Food
Import and Export Inspection and Certification
Systems, Food Hygiene and Food Labelling)
to undertake work as they deemed appropriate,
within their respective mandates.
- welcomed
the suggestion that the Chairpersons of
the Committees concerned and the Codex Secretariat
should coordinate work so as to avoid a
divergence of approach to ensure a consistent
Codex outcome on the issue.
- agreed
that Regional Coordinating Committees may
wish to contribute to the debate on this
issue.
- noted
the usefulness of a proposal for workshops
to be held at the regional level using case
studies of traceability as these would contribute
to a clarification of the economic impact
and technical application, and contribute
to improved understanding.
The
Codex Committee on General Principles, at
its 17th Session held on 15-19 April 2002, has
been asked to provide a draft definition for
Codex use.
The
Codex Committee on Food Import Export Inspection
and Certification Systems, at its 10th Session
held during 25 February-1 March 2002 has formed
a working Group led by Switzerland with India
as one of its members.
The
Codex Committee on Food Hygiene (CCFH),
at its 34th Session during October 2001 was
of the opinion that specific work on traceability
as related to food hygiene was premature.
The
CCFH reiterated its request to the drafting
group that the concept of traceability should
be taken into account in the further elaboration
of the proposed draft Principles and Guidelines
for the Conduct of Microbiological Risk Management.
The
ad hoc Codex Intergovernmental Task Force
on Animal Feeding has included specific
reference to traceability in the proposed
Draft Code of Practice on Good Animal Feeding,
but will discuss the matter at its next session
(2003) in the light of the discussion in the
Executive Committee.
The
ad hoc Codex Intergovernmental Task Force
on Foods Derived from Biotechnology has
discussed traceability in the context of the
Proposed Draft Principles for the Risk Analysis
of Foods Derived from Modern Biotechnology,
but has not come to a consensus on the inclusion
of a reference to traceability as an element
of risk management. In this regard, the Task
Force agreed to circulate for comment a discussion
paper prepared by France and a note prepared
by the USA.
VIEWS
OF MEMBERS
There
is a divergence of views between Members about
the usefulness and application of traceability.
Some
Members have drawn attention to the implications
for developing countries, in particular cost,
the ability to meet traceability requirements
and the potential negative impact on trade.
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