Food standards and the control of chemicals in foods — their impact on international trade

COMMENT

Food standards and chemicals in foods international trade*

the control of - their impact on

C. W. McMillan reports to the FAO/WHO conference on Food Standards, Chemicals in Food and Food Trade, Rome, Italy, 18-27 March 1991

The establishment of international standards for chemicals in foodstuffs is essential if trade disputes are to be avoided. The banning of a particular chemical by an individual country will complicate and confuse international trade, and variations in food quality standards between exporting and importing countries leads to rejection of imports and the possibility of sales to third countries with less stringent controls. The Codex Alimentarius Commission has played a vital role in the control of contaminants such as pesticides, heavy metals, food additives, microbiological contamination and antibiotic residues, and mycotoxins in grains, and this role needs to be extended in the future to embrace genetically engineered products. The Commission’s aims are to harmonize and co-ordinate acceptance of international food standards, to protect consumers and to ensure fair food trade practices internationally. Its work has allowed the minimization of technical barriers to trade through the control of chemicals in foods.

In preparing this paper for the FAOWHO Conference on Food Standards, Chemicals in Food and Food Trade, I have tried to meet the challenge of addressing the complex subject of international food standards and the control of the invisible hazards of chemicals in foods - be they additives, residues, or contaminants - and their impact on international trade.

Soon after World War II, I was a

This article was originally prepared under contract for the Food Policy and Nutrition Division of the Food and Agriculture Organ- ization of the United Nations (FAO) in con- nection with the FAO/WHO Conference on Food Standards, Chemicals in Food and Food Trade (Rome, 18-27 March 1991). This revised version is published by permis- sion of that Organization. Bill McMillan is currently president of McMillan & Farrell Associates, Inc. From 1981-1985 he was Assistant Secretary of Agriculture for Marketing and Inspection Services of the United States Department of Agriculture, where he was responsible for the agriculture marketing service, the food safety and inspection service, the animal, plant health inspection service, the federal grain inspection service, packers and stockyards, administration, office of transportation and agriculture cooperative service. Prior to 1981, the author held various executive posts with the National Cattle- men’s Association. Present address: McMillan & Farrell Associates Inc., 2021 K Street NW, Suite 306, Washington, DC 20006, USA

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County Agricultural Agent in the State of Colorado when chlorinated hydrocarbons were beginning to be widely applied to food crops. Then the emphasis was towards increased efficiencies in food production and these new chemicals, such as DDT, worked like magic. Insects and in- sect damage were major problems in production agriculture, as well as in processing, transporting and in storage. These new products were effective, cheap and thought to be safe. With what we know about these pesticides now, including the evidence that certain chemical contaminants can cause human health problems after a latent period of months or years, how very sur- prised I am to be alive today!

Now, some 50 years later, most developed countries and some developing countries (China and Thailand) have banned the use of DDT in agriculture. However, as DDT has provided a major benefit in public health programmes to help control vector borne diseases such as malaria, yellow fever and sleep- ing sickness, it remains one of the major pesticides used for public health purposes in several countries, to protect against endemic and epidemic malaria.

Any country using chlorinated

hydrocarbons today, for any purpose, will encounter intense scrutiny by an importing country. This increased scrutiny creates major problems for developing countries using those pesticides in the exportation of food products.

The middle of the twentieth century represented a time when no- body thought much about chemical residues and/or their effects on human or animal health, much less the environment. Not only had the ‘environmental movement’ not been activated, but consumer advocates had not organized. The world was recovering from war, new country boundaries were being drawn, and the emphasis was on the scarcity of foodstuffs, rather than the luxury of seeking the absolutes of safety and purity in foods.

What was considered to be ‘zero’ risk only a short time ago is a far cry from what we know today. In those days, I thought parts per million meant ‘less than zero’!

In retrospect, we are indeed for- tunate that the seeds of a Codex Alimentarius Commission (CAC) had already been planted within Europe for the purpose of developing international food standards to facilitate international trade. As a very important part of the Codex mission includes the protection of consumer health, I agree that it is essential for all national governments, international organizations, importers and exporters, and buyers and sellers of food for human consumption to play an aggressive role in assuring the world’s consumers that imported foodstuffs meet a particular country’s specifications for good quality and wholesomeness. But, more importantly in today’s climate of food safety conscious consumers, these foodstuffs must be free of non- permitted levels of food additives, pesticides, chemicals, or any other types of contaminants.

Today we are also encountering a time when various legislative bodies throughout the world are choosing to view international trade in food as being international ‘trade in poisons’. Or, to be more blunt, the international ‘exportation of poisons’. This trend is indeed

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odious for those of us involved in food and agriculture. The FAO/ WHO CAC has an impressive record of achievements which will be addressed by honoured speakers throughout the remainder of the session. Suffice it to say that the establishment of standards which facilitate trade, the monitoring of foodstuffs, the investigations of agricultural practices, the assistance to developing countries in establishing food control systems, the encouragement to utilize new technologies to analyse additives and residues, and the identification of these invisible chemical hazards through a network of Committees has been an impressive undertak- ing.

The one thing we have not been so successful in achieving is effective communication to the consum- ing public. We need to let the public know that all of us involved in agriculture and food are not only concerned about the safety of the food supply, but that we are taking action to ascertain that there is not a circle of international ‘trade in poisons’, but a circle of opportunity.

Often overlooked is the need for certain food additives. Apart from colours and flavours, many additives have a direct bearing on the preservation of food products to prevent the growth of organisms such as those which cause botulism. For example, food-borne illnesses could be curbed with the wider use of low dose irradiation. A lack of adequate refrigeration and transportation facilities in many developing countries underscores this often misunderstood need for food additives. Risk assessment with Codex standards can and should be the basis of worldwide food additive uses.

One answer to this dilemma might be to encourage a more active role in all countries by consumer and environmental activists in the development of Codex food standards.

Overview of value in food trade

Approximately 460 million tonnes of human foodstuffs are traded internationally each year, with a value in excess of US$ 200 billion. Nearly three-quarters of this volu- me is imported and exported by

developed countries. It is generally recognized that developed countries are net importers. Developing countries export more than 50% of the global trade in fruits and vegetables, sugar, coffee, tea, cocoa, vegetable oils and fishery products.

Food control systems

With some notable exceptions, financial resources in many developed countries have been applied to strengthen systems for import control, while many developing countries have put more resources towards export control systems. These export control systems vary widely. For example, private quality control companies are responsible for the quality of fresh fruit exports in Chile, but the Chilean Ministry of Agriculture remains responsible for quarantine aspects, such as plant diseases and preship- ment fumigation. In Uruguay, all export food items are compulsorily inspected and specifically certified, either by the Ministry of Agricul- ture or the Ministry of Industry. In Spain, food for export has to be certified as to standards laid down by the Ministry of Economy. The Asian countries, particularly Thai- land, have worked out export control systems, including regulations, inspections and analytical services. India requires certification for food exports, which is carried out by several Ministries under the aus- pices of the Export Inspection Council of the Ministry of Com- merce. In Mexico, where approximately 85% of their fresh fruit and vegetable exports are sent to the United States, a bilateral agreement between the two countries requires periodic phytosanitary inspections. Each country’s inspectors are present during examina- tions and containers bear the seals of the Mexican and American Sec- retaries of Agriculture.

It has been noted that there is also a lack of uniformity in the ways imports are controlled. In Japan, the responsibility for import control is placed with the Ministry of Health and Welfare under the Bureau of Environmental Health. The Food Sanitation Division is concerned with all foods, the Veter- inary Sanitation Division is concerned with meats and the Food

Chemistry Division is concerned with food additives and pesticides. In some countries, the Ministry of Agriculture is responsible for foods of animal origin and the Ministry of Health for all other foods.

These illustrations demonstrate the confusing and overlapping agency jurisdictions within and between governments. While the CAC cannot force realignments within a particular country’s governmental responsibilities, it can, and does, stress the objective of establishing a multi-lateral framework of rules and disciplines to guide the development and application of sanitary measures - particularly to encourage the long-term objective of harmonization of sanitary measures on the basis of international standards. guidelines and recommendations

I truly believe that today’s economic conditions of worldwide deficits will compel food inspection to develop and utilize technologies not now in use. In earlier times it was possible to have ‘zero’ risk, because we did not have the technological ability to look for minute levels of contaminants. It shocks this non-scientific mind to try to comprehend ‘parts per trillion’.

New technological and scientific breakthroughs have proven there are ‘negligible risks’ which are achievable and practical through good production and manufacturing practices. Good agricultural policy must be based on good technological analyses and good science.

It is time for these trends to prompt the agriculture and food industries to exercise improved production and processing practices in the control of chemicals from the farm gate to the dinner table; for governments to pledge more research resources at the technical and scientific levels and to exchange the technologies worldwide; and for the scientific community to find among its numbers those who can speak out more at the public and political levels.

If we do not change our ways of doing business, we will have inspectors inspecting inspectors in a clum- sy enforcements programme that will continue to raise public con- cerns over the safety of the food supply. We will lose the incentive to develop new and improved products because of emotionally driven demands upon governmental

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bureaucracies to respond to un- grounded fears that ‘chemical’ is a bad word. Is it not amazing that the word ‘chemistry’ inspires a certain respect, while the products thereof have become negatives in the public mind?

Major contaminants

Although not all countries keep good records, studies have revealed that the major contaminants encountered by importing countries include: pesticide residues in fresh fruits and vegetables, as well as in processed food; excessive amounts of heavy metals; unauthorized or excessive amounts of food additives; microbiological contamination and antibiotic residues in meat; and mycotoxins in grains or other products such as dried fruits. Economic violations have also been encountered, including short weight and mislabelling.

Sanitary and phytosanitary measures

Agricultural trade is treated differently in the GATT negotiations, because it is treated differently by most member countries. The parti- cipants in the Uruguay GATT negotiations have endorsed improved international trading rules concerning health related regulations. Objectives have been articu- lated to establish a multilateral framework of rules and disciplines to guide the development and application of sanitary and phytosanitary measures. More importantly, there has arisen a general agreement that harmonization of sanitary and phytosanitary measures should be the basis for international standards, guidelines and recommendations. Significantly, it has been empha- sized that all countries should be obliged to base health related regulations, which affect and influence trade, on sound science.

During the discussions of the Uruguay Round Negotiating Group on Agriculture - Working Group on Sanitary and Phytosanitary Reg- ulations and Barriers, which met on 3 November 1988, Codex’s Chief of the Food Quality and Standards Service, J.R. Lupien noted that ‘as part of its future plan, the CAC will decrease its emphasis on the standardization of specific food com-

modities (i.e. vertical committees) and increase emphasis on the work of general subject committees (i.e. horizontal committees) in areas common to all foods such as labelling, food additives, pesticide and veterinary residues, food hygiene, contaminants (chemical and microbiological), harmonization and coordination of regional activities, and technological assistance to developing countries’. This reflects the change in approach to protection of consumer health while, at the same time, facilitating international trade.

The sanitary barriers to world food trade include four principal categories: (1) chemical barriers, including food additives and pesticide residues which exceed established tolerances or for which no tolerance has been established, naturally occurring metals, such as mercury and lead, and naturally occurring toxicants, such as aflatox- ins, veterinary drug residues and industrial chemicals; (2) microbiological barriers, including patho- genic microorganisms, ‘indicator’ and spoilage organisms, toxins, and animal diseases; (3) filth barriers from insects, rodents and birds, which could be controlled through good agricultural and manufacturing practices; and (4) food labelling barriers such as health and/or nutritional claims.

To ensure the legitimacy of these sanitary and phytosanitary measures, an effective multilateral mechanism should be adopted cov- ering all regulations related to plant, animal and human health which have an impact on international trade. One of the main reasons there is increased emphasis in the GATT on international standards is that, under the current regulations, the lack of scientific criteria makes it nearly impossible to determine which measures are legitimate and which are disguised trade barriers. A requirement to have all sanitary (and phytosanitary) measures restricting trade to be based on verifiable scientific evidence would allow illegitimate measures to be effectively chal- lenged in a multilateral framework. An additional benefit to this requirement would be that it would place the onus upon the importing country to defend the scientific foundation for any different, or more restrictive, standard.

In my judgement, there are a couple of obstacles which could interfere with worldwide acceptance of the GATT/Codex sanitary and quarantine measures promulga- ted by the OIE and IPPC. Whereas it is understood that the principle of equivalency recognizes that differ- ing technical and/or regulatory methods can be used to achieve the same levels of health protection, the experience of the United States Department Agriculture (USDA) Food SOafety and Inspec- tion Service (FSIS) has been that it is sometimes more difficult to convince US consumers that one inspection scheme can be equal to another on a sound scientific basis, than it is to convince US trading partners.

Secondly, and in the extreme, if the ‘green revolution’ continues to gain support, there is great danger that health and safety standards could be imposed which have very little, if any, scientific base. Should the availability of some food additives, pesticides, insecticides, fungi- cides, germicides and animal drugs be curtailed by even one country, the result would have dire effects on agricultural production and processing, on the availability of animal feed, on the food supply itself, on domestic and international trade and on that country’s economy. These two obstacles can and should be overcome with the scientifically based dispute settlement mechanism in GATT and the uniform standards as established in Codex.

Detentions

The enormous impact on international trade from non-permitted or excessive use of permitted chemicals may be best illustrated by citing figures from the US Food and Drug Administration (USFDA). The number of detentions in the USA of imported food products increased from 14000 in 1984 to over 19500 in 1989. This increase represented severe problems for exporting countries - particularly when taking into consideration the dollar value of US food imports in 1989.

The reasons for these food detentions are many - improper or illegal use of food and colour additives, gross filth contamination, misuse of pesticides, chemical con-

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tamination, improper labelling and non-compliance with regulations governing acidified and low acid foods.

In 1988 there were 3066 detentions from Central America for predominantly fresh fruits and vegetables, with pesticide residues being the primary cause. During that same year, processed products from South America had 2361 detentions, mainly for filth. Of the 1450 detentions from one particular country in the region, 843 were detained for the presence of a pesticide not registered for use in the US on fruits and vegetables. Under US law, the residue tolerance is zero for any pesticide that is not registered for application on a particular fruit or vegetable in the US.

Also using 1988 data, Singapore found that 14.7% of the foods inspected contained excessive pesticide residue. Finland found 4.5% of imported vegetables, nuts, grains and fish had excessive pesticide residues. Sweden rejected 371 tonnes of product; 2.6% of imported fresh fruit and vegetables had un- acceptable pesticide residues. In Hungary, 22% of imported foods of plant origin over a two year period were rejected.

The USFDA’s record keeping for detentions could provide a model for other importing countries. The FDA’s detention list includes the name of the food, the amount in a particular consignment, the country of origin, the reason for detention and the exporter. It is significant and necessary that these detentions are reported to the exporting country so that appropriate corrective actions can be taken.

This detained product results in economic losses for exporting countries and the possible loss of buyers for a particular commodity. Good manufacturing practices, greater emphasis on hygiene and a recog- nition of the restrictions and regulations imposed by the importing countries could help curtail these grave problems.

Rejections

It is difficult to determine just what happens to all of this detained food, as essentially no statistics are kept on their disposition by any nation. For instance, we do know that some

fresh fruits and vegetables with pesticide residues were destroyed; there is no specific information as to how many rejected lots of food were returned to the original for- eign supplier or were re-exported to other countries. We also know that USDA FSIS routinely stamps boxes and bills of landing declaring their non-acceptance in the USA, which automatically alerts any potential secondary purchaser.

This lack of record keeping no doubt leads to the ‘dumping’ of rejected products in third countries - particularly those without adequate import inspection systems - and I join others in urging FAO/ WHO and other international bodies, such as the CAC, to work with all nations in establishing adequate import and export control systems. It is also difficult to determine whether or not the country rejecting a shipment notifies the exporting country. Such coordination and communication would be a major step in monitoring the presence of chemical contaminants in foods, which may arise from industrial pollution, agricultural practices and from food processing.

Barriers to international harmonization

To avoid trade disputes and protect both producers and consumers, the use of something, or the banning of the use of something, should be based on good scientific criteria. The controversy surrounding the use of and possible selective banning of bovine somatotropin (BST) and the controversy over other substances are illustrations of what can occur when decisions are solely or largely politically motivated, rather than scientifically justified.

The August 1990 issue of Science contained a report entitled ‘Bovine growth hormone: human food safety evaluation’ by two toxicologists (Juskevich and Guyer, 1990). This report summarized more than 120 studies which document the safety of milk and meat from dairy cows treated with BST. What is significant about the acceptance of this report by Science is that it under- went extensive and lengthy peer review by a panel of expert scientists prior to publication - a review process which rejects submissions about 60% of the time.

The summary data demonstrated that BST is harmless, because it is broken down into inactive fractions in the gastrointestinal tract while being digested and that, even if it were injected into humans, it would remain inactive because BST is species specific. They found that BST, produced in quantity by re- combinant DNA technology, is identical in biological activity to the growth hormone produced naturally by the cow’s pituitary gland.

In the August 1990 issue of the Journal of the American Medical Association, Dr Charles J. Gross- man, in an editorial entitled ‘Gen- etic engineering and the use of bovine somatotropin’ (Grossman, 1990) made several statements, from which I quote the pertinent part:

‘During the last decade there has been an unfortunate reappear- ance in our society of an anti- technology and antiscience atti- tude. This is exemplified by those advocates who would ban all ani- mals in research and block fetal tissue studies and by those who support creationism. An especial- ly vocal group consists of those people who are against any form of genetic engineering regardless of the benefits or potential benefits that might be realized.’

He notes that opponents of the use of BST do so on three grounds. First, that the milk may not be safe for the consumer; second, that BST treatment may not be safe for the cow; and third that increased milk production may create a market glut, further reducing the price of milk and thereby driving the smal- ler dairy farmer out of business. While finding consumer milk to be safe and BST treatment for the cow to be safe, Dr Grossman does agree with the economic impact. How- ever, he pointed out that more than 10 000 dairy farms failed in Wiscon- sin in 1980, when BST was not in use and could not have been the cause. He concluded:

‘Because milk produced from cows treated with bovine somatotropin is no different from the milk of untreated cows, it is both inappropriate and wrong for special-interest groups to play on the health and safety fears of the public to further their own ends.

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If the issue is economic, let it be clearly stated as such and leave genetic engineering out of the controversy.’

In the same issue of the Journal of the American Medical Associa- tion, William H. Daughaday and David M. Barbano published ‘Bovine somatotropin supplementation of dairy cows - is the milk safe?’ (Daughaday and Barbano, 1990). Beyond concluding that the milk and meat from BST supple- mented cows was safe and wholesome, I found it interesting that the authors described BST as simply another milk production manage- ment tool. They also pointed out that, based on scientific evidence, comments from health profes- sionals could play an important role in reassuring the public about the safety of milk and refuting misstate- ments or misconceptions about BST.

become overly reliant on chemicals, the promise of the next generation is in biotechnology. If we, as parti- cipants in the FAOAVHO Codex Alimentarius Commission do not act appropriately, our discussions in the next decade will focus on genetically engineered ‘hazards’ in international trade. During my tenure as Assistant Secretary of Agricul- ture, the regulatory agencies within the US Government, that is, the USDA, FDA and the EPA, agreed that we would regulate the product, not the process. It is my challenge to all to address biotechnology and its promise in an equivalent way.

control those problems before shipment by exercising proper use of chemicals, plus local laboratory analysis.

Standardization of testing and analytical methodologies, based, of course, on sound scientific princi- ples, remains, in my opinion, a critical challenge to the CAC. In an effort to meet this challenge, Codex must:

1

Although not as far along in the registration process, porcine somatotropin (PST) will probably receive the same scientific backing. An added dividend is that PST treated swine will provide nutri- tionally superior pork resulting from the ability to partition the fat to create a leaner product.

Chemicals seem to have a gener- ational life. That is, when I spoke of DDT in the 1940s it was being banned by the 1970s. Chemicals such as EDB being used as fumi- gants in the 1970s were being banned in the 1980s. Even the US Academy of Sciences notes that these products were withdrawn without sufficient human tests. It is incumbent on us to see that GATT and Codex continue to protect the public on the basis of scientific and technological analysis, rather than by purely bureaucratic considera- tions.

It may seem that I have spent an inordinate amount of time on the issue of somatotropins. I have done so on purpose. These products were created by genetic engineering, or biotechnology, which has very vocal detractors in the public arena. Had this technology been applied to the water buffalo cow in India first, just think of the benefits to people lacking in milk products due to short supplies. Think of the praise the developers of such a genetically engineered product would have received worldwide for assisting the hungry. Think of the plaudits the scientists would have received for discovering a path to self-reliance in a country lacking in some resources. Think also of the additional environmental benefits of changing production methods which might result in less waste disposal. Finally, think of the ability to use pest control methods that would leave no residues in the environment or on the food.

It is incumbent for the governments to do for people what they cannot do for themselves. One of those things that governments can do is require the requisite peer review for any scientific claim for a chemical or biotechnologically engineered enhancement to production, processing, transporting or safety of the food supply. By doing so international trade in foodstuffs can be facilitated and enhanced and consumers worldwide will be the beneficiaries.

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The challenge to Codex

Genetic engineering holds the promise of replacing many of the chemicals we are discussing today. If, indeed, world agriculture has

A negative economic impact on international food trade occurs whenever non-permitted levels of pesticides, food additives, chemicals and other types of contaminants are detected by an importing country. When it is determined that foodstuffs have an identifiable health risk to human, animal or plant health, the importing country usually detains the shipment and ultimately rejects it, thereby requir- ing the product to be destroyed or returned to the original supplier. Ideally, it should be possible to

Continue to promote the principle that a scientific basis be established to determine the safety of chemicals and animal health products developed for use in agriculture production and in the processing, transportation and storage of food. A thorough scientific examination of these substances by the scientific community, on which regulatory agencies can base decisions, would help assure today’s food safety conscious consumers that imported foodstuffs are free of non-permitted levels of food additives, pesticides, animal drugs or any other types of contaminants. All member nations should be encouraged to make resources available in an effort to further this principle. Encourage the development of technology to determine and effectively analyse chemical assays. In an era when DNA probes allow us to determine analytical results within two days instead of the customary week, when it is possible to detect ‘parts per trillion’, and when one bac- terium can be distinguished from another, Codex should urge technology transfer within its goal of transparency. It is essential for member nations to share these critical technological advances in protecting consumer health and facilitating worldwide trade of safe and wholesome foodstuffs. Urge the adoption of consis- tent scientific and technical methodologies. Codex should also urge developed and developing countries to adopt standard- ized methodologies as established through Codex to help avoid un- necessary trade disputes under GATT. Strive to include participation by consumer and environmental activists in the Codex food standards dialogue. If Codex and its

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member nations are to successful- ly communicate that its adopted food standards are scientifically based and its analyses technologi- cally sound, participation must be broadened to a wider spectrum - including nay-sayers.

As the clock ticks its way through the last decade towards the next lOO-year cycle, a revolution in technological advances can be envis- aged. During the 1890s the wind down of the 19th century, the world experienced a scientific revolution, for it was during that decade that modern physics was born by the discovery of the X-ray. Four new chemical elements (helium, xenon, krypton and neon) and the electron were discovered. The approach of the year 2000 represents yet another time of scientific and technological discovery. In keeping with the Codex mission to provide for safe and wholesome foodstuffs to the world’s citizens through international trade, all of us involved in food and agriculture must be ready to accept the challenge of the exciting technological advances occurring due to the expansion of biotechnology and computer based diagnostic tools.

I commend the CAC for its com-

mitment to continue the work begun a little over a quarter of a century ago. The Commission’s gal- lant efforts to harmonize and co- ordinate acceptance of international food standards, to protect consumers and to ensure fair food trade practices internationally, created the climate for developed and developing countries to come together and minimize technical barriers to trade through the control of chemicals in food. The Com- mission must remain vigilant and diligent in its efforts to realize this mission. The future holds great opportunity to assure the safety and wholesomeness of the world’s food supply through scientific and technological breakthroughs and I know that the CAC stand ready to accept tomorrow’s challenges.

References

Daughaday, M.D. and Barbano, D.M. (1990) Bovine somatotrophin supplementation of dairy cows - is the milk safe? 1. Am. Med. Assoc. 264, 1003-1005

Grnasman, C.J. (1990) Genetic engineering and the use of bovine somatotrophin. 1. Am. Med. Assoc. 264

Justevkh, J.J. and Guycr, C.G. (1990) Bovine growth hormone: human food safety evaluation. Science

Control of novel, including genetically engineered, foods in the United Kingdom Professor Moseley outlines procedures for control in the UK

Novel and genetically engineered foods are becoming increasingly common as new methodr of food processing and biotechnology develop. It was agreed in 1980 that manufacturers should notify the Ministry of Agriculture, Fisheries and Food before marketing a novel food, and as a result of this agreement several committees have been formed to assess the safety and advise on the labelling of novel foods.

As the result of an understanding reached with the Ministry of Agri- culture, Fisheries and Food (MAFF) in 1980, the Food and Drink Industries Council recom- mended that members of its asso- ciations should notify MAFF before marketing a novel food, so that the

Professor B.E.B. Moseley is Head of Labor- atory at the AFRC Institute of Food Research, Reading Laboratory, Shinfield, Reading RG2 9AT, UK

nutritional and safety aspects of the food could be evaluated, in strict confidence, by independent ex- perts. Subsequently the Advisory Committee on Irradiated and Novel Foods (ACINF) was set up in 1982 with a remit to advise Ministers both on the irradiation of food and on foods produced from novel processes. Most of its work is related to the evaluation of food irradiation and a report was issued on this topic in 1986 (ACINF, 1986).

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The main conclusion of this report was that ionizing radiation up to an average dose of lOkGy, cor- rectly applied, provides an effica- cious food preservation treatment which will not lead to a significant change in the natural radioactivity of the food or prejudice its safety and wholesomeness. ACINF, in addition to giving advice on certain food projects submitted by the food industry, also issued a memoran- dum which included guidelines for the testing of novel foods (ACINF, 1984).

Following completion of the review of food irradiation by ACINF, and bearing in mind the recent significant advances in food biotechnology and, in particular, techniques for genetic modification, Ministers reconstituted the Com- mittee as the Advisory Committee on Novel Foods and Processes (ACNFP) in 1988. The Commit- tee’s new name better reflects its work, which includes the assessment of the safety of foods which are themselves genetically modified organisms, or which are produced in processes involving such organisms, although the Committee continues to advise as necessary on food irradiation and the safety of novel foods which are not the result of genetic modification. The mem- bership of the Committee was increased to strengthen its expertise in biotechnology and genetic modification, while retaining its expertise in the more traditional areas of nutrition, microbiological safety, chemical toxicology and biophysics and radiobiology.

In addition to giving advice to Ministers on submissions on individual novel foods and processes, the work of the ACNFP includes giving guidance to the food industry on the sort of information it would wish to see in any such submission. To fulfil this aspect of its work, the ACNFP has updated and revised the guidelines issued by ACINF in 1984 to take account of the wider range of novel food products now being submitted for assessment and the newer techniques of genetic modification (Department of Health, 1991).

The working definition of novelty with respect to foods and processes is as follows:

‘Novel foods are foods or food ingredients which have not

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Food standards and the control of chemicals in foods — their impact on international trade