IFPS Members

Principles and bases for Food Safety policies

The following principles are put forward as the basis on which SHAFFE and IFPS members can jointly and separately engage retailers and interested parties, (e.g. consumer groups) particularly those in the EU, to discourage them from implementing commercial “food safety standards” that go beyond legal requirements. Besides some general principles, others are grouped into Food Safety/Consumer Assurance Principles, Trade Principles, and Good Agricultural Practice (GAP) Principles.

Food poisoning outbreaks associated with the consumption of fresh produce are extremely rare. Good agricultural practices, hygiene preparations and packaging minimise the potential for contamination. The fresh produce industry has stringent standards in place to ensure that consumers can enjoy healthy, good quality fresh produce. Fresh produce is an essential part of a healthy diet, and retailers and others can all play their part in maintaining consumer confidence.

Management (IPM) approaches

 Integrated Pest Management (IPM) is the careful consideration of all available pest control techniques and subsequent integration of appropriate measures that discourage the development of pest populations and keep pesticides and other interventions to levels that are economically justified and reduce or minimize risks to human health and the environment. IPM emphasizes the growth of a healthy crop with the least possible disruption to agro-ecosystems and encourages natural pest control mechanisms.

 By imposing requirements aimed simply at reducing residues (quantity and concentration) farm managers are not able to pursue IPM in its true form. This also undermines environmental sustainability.
Given the long process of PPP registration, of equal concern is that producers may have to adopt older, less desirable and more hazardous PPPs, possibly making it more difficult to comply with new IPM practices. With the introduction in the European Union of the comparative assessment and substitution of PPPs, the horticulture industry faces further challenges to control pests, weeds and diseases with potentially fewer alternative products being available. All PPPs undergo a rigorous and independent authorisation process. Any active substances put forward as a potential candidate for substitution remains approved for use and must not be regarded as ‘unsafe’.

 Managing resistance is an important component of reducing overall dependence on PPPs. Reducing concentrations of active ingredients in order to meet reduced MRLs, as requested by numerous commercial organisations, selects for resistant pests that soon dominate the population. This leads to the loss of effectiveness of the active ingredient. Resistance management very much depends on the availability of alternate active ingredients used at effective rates, especially those with different modes of action.

Good Agricultural Practice (GAP) Principles

 There are many microbiological control points on farm environment, water, soil, animals, personal hygiene, equipment, storage areas and transportation, all to prevent a microbiological hazard.

 MRLs are set at levels low enough to ensure that safety limits are not reached but such that the Plant Protection Products (PPPs) are effective against the target pest in the country of production.

 Only PPPs with approved uses in the country of production can be used.

 Provided PPP use results in residues that do not exceed the importing countries MRLs, there should be no restriction on their use.

 Restricting PPPs conflicts with other generally accepted GAP principles and Integrated Pest Management.

General priciples

 Food safety is neither a competitive nor a marketing tool by which retailers differentiate themselves; food safety is pre-competitive and the responsibility of all members of the value chain.

 We rely on the independence of governments and the best science available to set legitimate standards, critical limits and tolerances that best ensure the health, safety and welfare of producers, consumers and the environment. Food Safety critical limits and tolerances are established on the basis of detailed technical dossiers and are therefore assured by scientific evidence.

 Consumers entering any fresh produce outlet should be assured that fruit and vegetables offered is safe if it complies with the local and destination-country Food Safety legislation.

 International harmonisation should be encouraged at every opportunity to facilitate trade, protect consumers and to ensure sustainability at all levels.

 Wherever possible international standards (such as CODEX Alimentarius) should be adopted. Again, science-based justification must be provided to deviate from these standards.

 Food supplier and buyer organizations are encouraged to adopt a Food Safety culture, where all parties take more responsibility to ensure safer food.

 Stricter Food Safety requirements themselves do not necessarily result in safer food, as Food Safety limits and tolerances are already securing the safety of the product.

Trade Principles

 The Sanitary and Phytosanitary (SPS) Agreement is the basis for continued access to markets.

 Failure to adhere to the SPS agreement, specifically the failure to control phytosanitary pests and diseases, compels the importing country to take stricter trade measures.

 In the absence of suitable alternative technologies, compliance to phytosanitary requirements is largely achieved through chemical control. Restrictions placed on plant protection product use compromises the biosecurity of the importing country and may lead to stricter trade measures.

 Setting MRLs at a lower percentage of the official MRL could jeopardize the efficacy and resistance management of a particular active, putting the plant health security and quality of the product at risk. For some markets, it may be illegal to use an active ingredient below the label rate and hence below a particular MRL for control of a pest of biosecurity significance.

Food Safety/Consumer Assurance Principles

 Adherence to Maximum Residue Limits (MRLs) is an assurance that the food is safe to consume; detection of a residue below the MRL should not be viewed as a violation.

 MRLs are established considering the amount of residue required to achieve the necessary control of the target organism AND consumer safety indicators such as the Acute Reference Doses (ARfD) and the Acceptable Daily Intakes (ADI). It is redundant to have additional residue restrictions using the ARfD or ADI.

 Import Tolerances (in the EU case MRLs where the active substance is not listed in Annex I of 91/414/EC but has a positive MRL) are the applicable residue limits for commodities imported into a market. This means growers outside the market may use different active substances to control key pests and diseases that occur in those countries compared to local producers.

 Unless an importing country’s legislation limits the number of substances that can be present in a commodity, and provided that individual MRLs are observed, there should not be restrictions on the number of substances used.

 In accordance with According Commission Regulation (EC) No. 2073/2005 on microbiological criteria, the safety of foodstuffs is mainly ensured by a preventive approach, such as implementation of good hygiene practice and application of procedures based on hazard analysis and critical control point (HACCP) principles.
HACCP-based food safety programs, such as GlobalG.A.P., CanadaGAP, China GAP and New Zealand GAP have many controls for microbiological, chemical and physical hazards.