German  English Bundesverband der Lebensmittelchemiker/-innen im öffentlichen Dienst e.V. (BLC) (Federal German Association of Food Chemists in Public Institutions)

Comment on the White Paper on Food Safety of the Commission of the European Communities

Bundesverband der Lebensmittelchemiker/-innen im öffentlichen Dienst e.V. -BLC- welcomes the White Paper on Food Safety as an important step into a modern system of food safety that comprehends the whole chain "farm to table".

In contrast to the Green Paper, the new significance of safeguard against deceit is remarkable in particular, because it is an essential element of health and consumer protection. Many contacts of problems are in the areas of safeguard against fraudulent practices and the areas of health protection.

By this comment on the White Paper and its proposed measures, BLC is following the Commission's invitation.

Principles of Food Safety (Chapter 2)

The laboratories are obliged to prove their systems of quality assurance. In the areas of the national authorities of food inspection also should be introduced some quality controlling elements.

The principle of precaution should always decide the issue of risk management.

The initiation of transparency is welcome, but it may not induce an over-bureaucrated "report system disorder".

Establishing a European Food Authority (Chapter 3 and 4)

Since this authority cannot have the capacity for dealing by itself all the current problems, it will be dependent on scientific experts in the Member States. There are national authorities like Bundesinstitut für gesundheitlichen Verbraucherschutz und Veterinärmedizin - BgVV- (Federal German Institute for Consumer Health Protection and Veterinary Medicine) and Bundesforschungsanstalten (Federal German Research Institutes), but also other experts of all concerning circles. The scientific networks proposed in the White Paper, must be carefully observed for their competence, transparency and independence.

The "declaration of independence" (Chapter 3/22) we do not regard as sufficient. The experts should be selected and appointed by the Food Authority.

We consider to implement a system of reference laboratories which are already existing for food of animal origin, in other areas. First of all should be checked up whether this system has proved itself as appropriate and which amendments could be realised.

We definitely agree to the Commission's consideration that the Authority must be established in an easily accessible location.

Regulatory Aspects (Chapter 5)

In the Council Directive 93/99/EEC on the Subject of Additional Measures Concerning the Official Control of Foodstuffs in article 2, the areas of special knowledge needed for a comprehensive food inspection, are listed. An additional list of single areas in other guidelines is not appropriate. In practice, this would lead into a unilateral inspection, in the end full of gaps that should be avoided in the future.

Wherever possible and appropriate, in the future should be enforced the harmonised European food law, because the transforming of directives with equal matter into national law has proved itself as protracted and ponderous.

An approach to the urgently needed tightening of food law is done by a draft proposal of an Regulation on Food Hygiene, but yet the general guidelines on foods and the vertical guidelines on foods of animal origin are following absolutely different principles - out of the idea of coherence!

Whilst on the one hand the responsibility of economy is preferred and provided by a great scope, the vertical area is restricted yet by a multitude of needless detailed rules which appropriately should be placed at the directives, following the "philosophy" of the Directive 93/43. In the White Paper is found the same approach, the guiding principle for revised hygienic guidelines: Food operators bear the full responsibility for the safety of the food they produce.

The submitted draft proposal of a EU Regulation on Food Hygiene often is stressing the operators in a needless manner without any amendment of food safety. There mostly is no need to differ foods of animal and non-animal origin. The regulatory system will be blown out, unclear and difficult to handle. A range of definitions in the draft proposal is not understandable and in contrast on general food law.

There is an urgent need in the EU of generally valid definitions of "food" and "food-additive" (for others than technological purposes). The lack of these definitions makes an intrinsic confuse by contradictory assessments in different Member States, particularly on the rapidly increasing market of "Food Supplements", "Functional Food" and "Sports Foods".

An easier handling of the admission guidelines on Novel Food (figure 76) is not appropriate to the idea of protection in the Novel Food Directive.

Controls (Chapter 6)

The authorities of the Member States will get a high responsibility on food safety. The qualification of the controlling personnel will be the decisive factor on realising the targets of the White Paper. Therefore must be ensured that in the control authorities intrinsically will be available the special competence according to article 2 of the Directive 93/99/EEC, but also a sufficient number of personnel and - last not least - the suitable financial means for enforcing the rapid alert controls.

There are obvious lacks, for example in food analyses. So it not possible to explore all contaminants or agents in pesticides! It is enjoying that the White Paper shows measures to eliminate lacks in these areas.

The promotion of administrative co-operation, inter alia by education and training, is a very important instrument. The costs should be due to the possibilities of the control authority's employees.

BLC is suggesting the continue of Carolus programme. This programme gave excellent opportunities on information exchanges and promoted the understanding of control authority's employees of different Member States.

Obviously is known that there is a big lack in the current system of food inspection, caused by incomplete controls at imports of third countries. At this place, more efficient controlling measures would enhance food safety in an important extend. Surely the examination of certificates will not be sufficient.

Consumer Information (Chapter 7)

The adjustment of "functional" claims probably will reduce to the prohibition of disease connecting advertising. Health or disease claims not only must be caused by scientific reasons, they also may not lead the consumers into a wrong nutrition manner, or even mislead into therapy of diseases by use of foods.

Labels with such claims therefore should be submitted to the food authority, purposing an examination and permission like FDA in the USA "health claims" is handling.

International Dimension (Chapter 8)

A. Neuhaus, Detmold (Germany)
G. Thomas, Dresden (Germany)
H. Streit, Wackernheim (Germany)

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