Konsument-Forum/Sveriges Konsumenter i Samverkan

To: Consumers International
From: Konsument-Forum/Swedish Consumer Coalition
2000-10-09

FOR THE CODEX COMMITTEE ON FOOD HYGIENE
33rd Session
Washington, USA, 23 - 27 October 2000

CI should remind CCFH that the goal of risk assessment of microbiological hazards in food is to eliminate the causes of disease from foods - it is not good enough to just assess the problems. Disease brings huge costs and sufferings to the individual and to society. Also, the importance of transparency of the scientific information as well as openess in risk communication should once more be stressed, if you get a chance. We commend this as important work for the Committee.

HACCP (Hazard analysis and critical control point)

Any dilution of the HACCP System would also be counter to the desire "to improve the human health, animal health and situation in all Members" as expressed in the introduction to the SPS Agreement.

CI can suggest that CCFH should encourage countries to make a surveillance of the occurence of antibiotic resistant bacteria at all steps of the food chain, especially for antibiotics used in the treatment of diseases in farm animals, as well as encourage countries to scientifically examine the consequences of growth enhancing antibiotics in feed were this is not yet banned.

ALOPs (Acceptable levels of protection)

We certainly do not support ALOPs and FSOs at this stage and do not understand how this can be a matter for Codex - we think this is a matter that must be debated in the countries in a democratic fashion, depending on a large number of factors, including historical and cultural preferences.

One area Konsument-Forum has campaigned about in Sweden relates to the use of sewage sludge on farm fields. Sewage sludge, treated and untreated, contains many heavy metals, including cadmium, that can cause kidney failures in consumers, as well as hormone disrupting substances and so on. Last year we achieved our goal to get a temporary moratorium on the spreading of sewage sludge, but not all farmers comply yet.

Sincerely

Martin Frid
Konsument-Forum
Swedish Consumer Coalition
Box 88
577 22 Hultsfred
Sweden