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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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