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SUGGESTED PLAN FOR NATIONAL FOOD SAFETY POLICY OF IRAQ

By Talal K.Hasan, M.Sc.1 Issam Abdulahad Betrous B.Sc 1 Sabah Faleih Al-Saadi ,B.Sc 3 Nihad Saadoon Gheni ,M.Sc1 Adnan Abed Rajab Al-Temeemi M.Sc 2 Zainab Abdul Adheem Al-Zuraiji ,B.Sc4.

2011

1: Ministry of Planning 2. Ministry of Health 3. Ministry of Trade .. 4. Ministry of Agriculture

TABLE OF CONTENTS

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INTRODUCTION ................................................................................................... 3 INTERNATIONAL BEST PRACTICES...................................................... 4 CURRENT FOOD SAFETY SYSTEMS IN IRAQ ................................. 5 FOOD SAFETY POLICY AND DEVELOPMENT WORK ............... 7 FOOD SAFETY POLICY OBJECTIVES .................................................... 7 POLICY ISSUES AND RECOMMENDATIONS ................................... 7 STATEMENT OF SCOPE .................................................................................. 9 DEFINITION OF FOOD AND STATEMENT OF PRINCIPLES .. 10 POLICY STATEMENT ON FOOD SAFETY ..................................... 14 IMPLEMENTATION STRATEGIES .................................................... 15 MONITORING AND EVALUATION .................................................... 21

APPENDIX 1: CURRENT FOOD SAFETY LEGISLATION IN IRAQ .................................... 22

INTRODUCTION
The protection of human, animal and plant health in todays global food market is an important challenge that must be addressed through internationally recognised health and food safety systems. Such systems must ensure that consumers are supplied with food that is safe to consume, and that the countrys food sources are protected from pests and disease. This will be accomplished by the establishment and maintenance of a rational, integrated farm-to-table agricultural health and food safety system in Iraq that harmonises inter-agency efforts, minimises inter-agency conflict and overlap, and ensures the protection of public safety in a manner consistent with the Sanitary and Phytosanitary Agreement of the World Trade Organization (WTO/SPS) and other international requirements. Iraq need to establish Food Safety Agency (FSA) that will be responsible for the implementation of a food safety programme for Iraq, and guide its ongoing administration. With a population of 30 million persons, and in excess of a million visitors each year, it is of paramount importance that the quality of Iraqis food supply meets the highest standards to satisfy domestic demand, and the requirements of our international trading partners. The Iraq, therefore, must put wide plan to successful implementation of the food safety policy. The food safety policy that will support the programme will complement several national policies in providing a framework for safe, sustainable and ethical food production in Iraq. A food safety programme is necessary in order to address food-related risks and to contribute to the overall health and wellbeing of the population. Furthermore, the health-related emphasis of the food safety policy cannot be understated when the potential fall-out in the tourism industry from an outbreak of Travellers Diarrhoea is contemplated. In addition, good food management practices will not only improve Iraqs international competitiveness, but also heighten awareness within the Iraqis population, particularly when the link is made to lifestyle-related illnesses, and the community can share responsibility for addressing such threats as

Microbial and chemical food safety hazards, such as Salmonella, Listeria and certain heavy metals; Pathogens emerging from the design of the food and agricultural systems, such as intensive livestock operations and the globalisation of distribution and processing; Hazards associated with technologies and their by-products, such as the use of pesticides, heavy metals, growth promotions, antibiotics, fertilisers and genetically engineered crops and foods; Hazards associated with technologies introduced to solve other food safety and quality problems, including additives and irradiation; and Hazards associated with new approaches to food as health delivery agents, functional foods and edible vaccines.

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INTERNATIONAL BEST PRACTICES

In the development of the Food Safety Policy the Jamaican model was used as a base for current Project due to similarities between the two countries at several aspects, also an evaluation of the best practices of the European Union, Canada and United States were incorporated.1 European Union The European Union has established a European Food Safety Authority which speaks to risk analysis, protection of consumers interests and imported, exported food. The tasks and composition of the Authority are clearly stated. The mission of the Authority is to provide scientific advice and scientific and technical support for the Communitys legislation and policies in all fields which have a direct or indirect impact on food and feed safety. The Authority is comprised of a Management Board, an Executive Director and his staff, Advisory Forum, Scientific Committee and Scientific Panels. The tasks of the Authority include promoting and coordinating the development of uniform risk assessment methodologies, providing scientific and technical support to the Commission and ensuring that public and interested parties receive rapid, reliable, objective and comprehensible information in the fields within its mission.

Canada The Canadian Food Inspection Agency was established in 1997 by the Canadian Food Inspection Agency (CFIA) Act. It is a departmental corporation with separate employer status. Its primary responsibility is to enforce technical relations described in legislation pertaining to food safety and to animal and plant health. It does this by providing inspection services such as registration of processing plants, inspection of domestic and imported foods, certification of exports, and quarantine. Prior to the creation of the CFIA, inspection and related services for food safety and animal health were provided by Agriculture and Agri-food Canada, Health Canada and the Department of Fisheries and Oceans. These three departments transferred about $330 million and 4,500 full-time staff equivalents. The human resources implementation team developed criteria to identify those who move to the Agency. Individuals who devoted 60% or more of their time to inspection services were designated a dedicated resource and were transferred. In some cases, non-dedicated staff(those devoting less than 60%of their time to inspection programs) were given the option to volunteer for transfer to any vacant positions. In other cases, transfers of staff were not feasible from the perspective of the parent department, and so dollars were transferred instead. This approach was not used to identify staff when they belonged to largely self-contained inspection units. A deliberate decision was made to leave the details of the financial transfers and the human resource framework until after the launch of the new agency. This led to a phased-in approach. Issues and details that could not be resolved before the legislation was passed and that were not crucial to the legislation were deferred. The accountability regime is a mix of new and traditional approaches to governance. The Agencys regime retains the principles of parliamentary accountability and ministerial responsibility. Two ministers are responsible for implementing the federal food safety program.
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Regulation (EC) No 178/2002 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 28 JANUARY 2002

The Minister of Agriculture is responsible for inspection activities; The Minister of Health sets food safety policies and standards in the area of human health, and assess the effectiveness of the Agencys related activities. 2

United States of America The three branches of government; executive, legislative and judicial all impact on the USAs Food Safety System. Federal, state, and local authorities have complementary and interdependent food safety roles in regulating food and food processing facilities. US food agencies are accountable to the President, the chief executive, who has constitutional responsibility to assure that laws are faithfully executed; who appoints senior officials, and whose Office of Management and budget clears significant regulations. Food agencies are accountable to the Congress, the legislative branch of the US government, which provides the food agencies their authority and budget. They are accountable to the courts, the judicial branch of the US government, which review food agency regulations and enforcement actions. The agencies are accountable to members of the public, who regularly exercise their right to participate in the development of laws and regulations, such as commenting on proposed regulations whose guidance is sought in frequent public meetings; and who provide strong support for food safety regulation, the nutrition label, and other regulatory initiatives.3

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CURRENT FOOD SAFETY SYSTEMS IN IRAQ

Iraqi food safety programme is currently managed by a number of entities and agencies distributed across the ministries of Agriculture (MoA), Health (MoH) ,Planning (MoP) - Central organization for standardization and quality control COSQC Baghdad federal(f) / KSQCA Erbil regional (r),environment ( MoE) for radiation ,MoT ministry of trade for ration card items and finally custom directorate at border. However, there is a lack of coordination of these activities, as no one ministry or agency has overall responsibility for ensuring safe food production and compliance with international agreements. As a result of this uncoordinated approach, there are a number of areas in which there is unnecessary duplication of effort and facilities. Some examples of duplication are in the areas of sampling, inspection, laboratory testing facilities and training. These and other activities are set out in Table 1 below.

Table 1 Summary of Existing Food Safety Activities Showing Samples of Duplication Food Safety Activities
Inspection & Certification Certification & Testing of Meat Products for local consumption , export & import

Ministries & Public Sector Agencies Involved


Veterinary Services Division (VSD) MoA MoH Public Health Department COSQC_KSQCA /MoP MoT MoE MoA MoH COSQC KSQCA /MoP MoT MoE MoA

Inspection & certification of foods and feeds at ports of entry, warehouses and retailers

Registration and inspection of all food

1998 Report of the Auditor General of Canada

processing factories; sampling & testing of raw materials and finished products Training Training of Meat/Food Inspectors in HACCP, general food safety and food hygiene Training & certification of farmers and pest control operators in proper and safe use of pesticides Public Education Public education & awareness on food safety issues Laboratory Testing Facilities Chemistry Microbiology Entomology

MoH COSQC-KSQCA MoH MoP

Under establishments

MoH COSQC -KSQCA MoH MoA COSQC-KSQCA MoT MoE

As can be seen from this table, the responsibility for implementing the current food safety programme is splintered across several agencies in the five (5) ministries named. It is encouraging to note that there is some level of cooperation and collaboration between some directorate and laboratory. The current Food Safety Legislation also shows overlap and duplication, at present a total six Acts cover food safety activities in Iraq that we can found (see Appendix). These Acts and their attendant regulations are administered by the Ministries of Agriculture, Health, Commerce, planning and Technology. An examination of these acts will reveal that there is: Evidence of overlap in the functions of the different Acts; Most have quite strong powers to ensure compliance, although the penalties to be imposed (weak) need to be upgraded in terms of current reality; and Some of the Acts were promulgated many decades ago and so need to be modernised. There is no clear separation between quality and sanitary requirements. There is no sign to risk analysis, evaluation and managements. And how to benefit from the scientific information on building the resolution to protect the consumer.

There is an urgent need for the modernisation of legislation related to food safety, and the development of an Umbrella Legislation that would address the issues mentioned above. Any plan for implementing an effective food safety programme, including the creation of a Food Safety Agency, must take into consideration these gaps, limitations and unnecessary duplications. Such a plan requires the formulation of an appropriate policy, the design of cost effective institutional structures, programmes and activities and the creation of a comprehensive and relevant legislative framework.

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FOOD SAFETY POLICY AND DEVELOPMENT WORK

Iraqi Cabinet must approve the National Quality Policy which we are going to prepare, and after a complete discus it with all Ministries and NGOs through the corresponding and the workshop meeting that well be held later ,The Policy will be reviewed by SWEDAC Consultants . The policy calls for the regulation of foods, food products and food safety which shall be integrated through the establishment of a national food safety agency. However, a comprehensive Food Safety Policy and Programme needed to be developed. After discussions, the final policy submits to Iraqi Parliament to approve as a law.
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FOOD SAFETY POLICY OBJECTIVES

1. To have a system in place that will enable traceability of food from producer to consumer. 2.To institute a system that will enhance Iraqis risk management capability. 3. To upgrade system for administering international agreements with respect to food safety. 4. To streamline institutional arrangements for efficiency and effectiveness. 5. To promulgate a modern food safety umbrella legislation. 6. To institute an appropriate institutional arrangement for accreditation. 7. To establish systems that will ensure food produced by farmers is safe for consumption. 8. To establish systems that will ensure imported food is safe for consumption 9. To establish systems that ensure that food sold to the public by vendors, restaurants and processors is safe. 10. To establish a coordinating mechanism for food safety activities

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POLICY ISSUES AND RECOMMENDATIONS

Issue #1. Traceability Currently there is a lack of proper system to facilitate traceability in animal and plant products from farm to fork. Recommendation The Government of Iraq shall establish systems that facilitate traceability from farm to fork. Adequate procedures to facilitate the traceability of feed and food and their ingredients shall be introduced. These include the obligation for feed and food businesses to ensure that adequate procedures are in place to withdraw feed and food from the market where a risk to the health of the consumer is posed. Operators shall keep adequate records of suppliers of raw materials so that the source of a problem can be identified.

Issue #2. Risk Management System There is a lack of proper infrastructures to facilitate risk management of food. Risk assessment and risk management capabilities are required under the WTO/SPS Agreement to which Iraq is try to be member in near future. The Agreement requires that SPS measures that are implemented must be supported by appropriate competencies and skills in this area. Recommendation The Government of Iraq shall institute a formal risk analysis mechanism which shall include risk assessment, risk management and risk components. In addition, there shall also be a Risk Assessment Policy. Issue #3. Attendance at International Meetings and the Implementation of Agreements There is a need for Iraq to participate more in meetings in which international food safety requirements are being discussed e.g. CODEX Alimentarius, WTO/ SPS Agreement. Also there is a need for closer monitoring and follow-up of food safety matters covered under international agreements. Currently there are several government as well as Private Sector Organizations that monitor international agreements, however, a timely response and subsequent implementation is lacking. Recommendation The Government of Iraq shall enhance participation in international meetings and the implementation of agreements. Issue #4. Overlapping of certain food safety functions Currently there are overlaps in food safety activities such as inspection, certification, training, public education and laboratory testing facilities as shown in Table 1. Recommendation The government shall identify the rules and to streamline the relevant institutions. Issue #5. Legislative gaps and overlaps The implementation of the current Food legislation in Iraq is splintered across various Ministries which leads to overlaps and in some cases gaps our team found that, one of the main problems with the current legislation is the lack of enforcement. This is due partly to the low level of fines, the lack of trained persons to prosecute offences and the inadequate financial commitment given to enforcement. Recommendation The government shall promulgate a modern food safety legislation that will rationalize the current ones. Issue # 6. Lack of local accredited laboratories for food safety analysis Some trading agreements require that testing facilities used for food analysis must be accredited by a recognized body. At present there are no local laboratories that are accredited. This situation impacts on Iraqis ability to enter third country markets requiring this type of verification. Recommendation The government urgently needs to establish an accreditation body that will accredit labs, inspection and certification bodies Issue # 7 Food produced by farmers is not adequately monitored for safety

Farmers are producing and distributing food, which may have a high level of pesticide residue. The current system does not allow for speedy assessment and implementation of corrective measures. Recommendation Farmers shall be responsible for producing and selling safe food to the public. The government shall institute a food safety monitoring system to ensure that only safe food is available to the public. Issue # 8. Ensuring that imported food is safe for consumption Iraqais consume a large amount of imported food and currently the system of testing and inspection on arrival in Iraq is inadequate. Recommendation Importers of food shall be responsible for the safety of food brought into the country for sale to the public. The government shall strengthen the current system for monitoring the safety of imported food and for enforcing the regulations covering this food. Issue # 9. Need to ensure that food sold directly to the public is safe Food is sold directly to the public by a variety of sources e.g. food vendors, restaurants, and supermarkets and at times there is no guarantee that the food being bought is wholesome. Recommendation Retailers shall be responsible for ensuring that food sold directly to public is safe. The government shall upgrade the current monitoring and enforcement system to ensure public safety. Issue # 10. Difficulties exist in coordinating the food safety function. At present there are many directorate and departments of government that are responsible for the safety function along the food chain. This fragmented nature of the function has posed difficulty for coordinating and streamlining activities and has resulted in overlaps and gaps in the countrys food safety system. Recommendation The government shall establish a coordinating mechanism such as an agency which shall be responsible for coordinating food safety activities.

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STATEMENT OF SCOPE

In determining the scope of the food safety policy, it must be accepted that it has to be wideranging and adopted by a number of sectors in the economy, each with their own issues to resolve. This policy shall, therefore, guide the operations of various scientific, technical, operational and management agencies in the public and private sectors. These entities are concerned with:

Nutrition; Food hygiene; Public health; Plant health; Animal health; and International trade (imports and exports).

An underlying expectation of such entities is to provide public education in their respective discipline areas, and to deliver training within their area of competence.

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DEFINITION OF FOOD AND STATEMENT OF PRINCIPLES

Definition of Food

For the purposes of this policy Food or Foodstuff means any substance or product whether processed, partially processed, or unprocessed, intended to be, or reasonably expected to be ingested by humans. Food also includes drink, chewing gum, and any substance, including water, intentionally incorporated into the food during its manufacture, preparation or treatment. Furthermore, Food, as defined for this policy, shall include food ingredients and derivatives, i.e.
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Genetically modified organisms (GMOs); Functional foods (foods which claim to have special properties valuable to health, but which do not have a medicinal product license); Food additives; and Fortified foods (foods to which nutrients have been deliberately added).

Food shall not include: (a) feed (b) live animals unless they are prepared for placing on the market for human consumption; (c) plants prior to harvesting, (d) medicinal products (e) cosmetics (f) tobacco and tobacco products (g) narcotic or psychotropic substances within the meaning of the United Nations Single Convention on Narcotic Drugs 1961, and the Nations Convention on Psychotropic Substances, 1971; (h) residues and contaminants Food Chain In accordance with international practice the food safety management must take place throughout the entire food chain. The Food Safety Policy shall therefore cover the entire food chain from farm to fork. The Food Chain is referred to at various points in the policy statement and the diagram below illustrates the stages of the Food Production Process (Figure 1).

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Figure 1 The Food Chain Supply of Agricultural Inputs e.g. fertilizers, pesticides, veterinary drugs

Primary Production e.g. farmers, fishermen, fish farmers

Primary Food Processing e.g. on-farm, dairies, abattoirs, grain mills

Secondary Food Processing e.g. canning, freezing, drying, brewing

Food Distribution e.g. national/international, import/export

Food Retailing e.g. supermarkets, shops

Food Catering e.g. restaurants, hospitals, schools

DOMESTIC FOOD PREPARATION


All aspects of food safety and the principles guiding its management are covered by internationally-accepted definitions. These are documented in the various references highlighted in this policy paper with important definitions elaborated upon in Appendix 2. The principles guiding the food safety policy are as follows:

Risk Analysis: A formal risk analysis mechanism shall be instituted. This is a process consisting of three components:
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Risk Assessment, which is scientifically based process consisting of the following steps: (i) hazard identification, (ii) hazard characterisation, (iii) exposure assessment, (iv) risk characterisation; Risk Management, which is the process of weighing policy to accept, minimise or reduce assessed risk and to select and implement appropriate options; and

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Risk Communication, which is an interactive process of exchange of information and opinion on risk among risk assessors, risk managers and other interested parties.

In addition, there shall be a Risk Assessment Policy: Documented guidelines for scientific judgement and policy choices to be applied at appropriate decision points during risk assessments. Traceability:

Adequate procedures to facilitate the trace-ability of feed and food and their ingredients shall be introduced. These include the obligation for feed and food businesses to ensure that adequate procedures are in place to withdraw feed and food from the market where a risk to the health of the consumer is posed. Operators shall keep adequate records of suppliers of raw materials so that the source of a problem can be identified.

Shared Responsibility: The guiding principle throughout this policy is that food safety management must be based on a comprehensive, integrated approach. This concept is illustrated in Figure 2 by a diagram from the World Health Organization who also makes the following statement: A safe food supply that will not endanger consumer health through chemical, biological or other forms of contamination is essential for proper nutrition. Consumer protection and the prevention of food borne diseases are two essential elements of a food safety programme, and are the shared responsibility of national governments, the food industry and consumers.

Figure 2:

SAFE FOOD FOR ALL

SHARED RESPONSIBILITY Food Legislation and


Enforcement Advice for Industry/Trade Consumer Education Information Gathering and Research Provision of Health-Related Services

Educated and Knowledgeable Public Discriminating and Selective Consumers Safe Food Practices in the Home Community Participation Active Consumer Groups

Good Practices by Primary Producers and Distributors Quality Assurance and Control of Processed Food Appropriate Processes and Technology Trained Managers and Food Handlers Informative Labelling and Consumer Education

CONSUMER

INDUSTRY/TRADE

GOVERNMENT
NATIONAL COMMITMENT TO FOOD SAFETY

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Precautionary Principle: Decisions on requirements and handling of food, feed, animal and plants shall be taken based on caution having regard for best scientific knowledge, and requires the taking of anticipatory action in the absence of complete proof of a threat. Doubt shall be considered to the favour of consumers and environment.

Preventative Principle: Potential risks for food throughout the food chain shall be addressed at source, preferably through system analyses and control of critical points (HACCP, good agricultural practices, good manufacturing practices, etc.).

Use of resources: Resources shall be directed to problems that pose the most severe threats to health, and where the potential risk reduction is greatest in relation to the resources required.

Transparency: In keeping with the goals of the Government of Iraqs,the Public Sector Reform Programme, the food safety programme shall require transparency in dealings with consumers and producers. There shall be open communication in terms of making results of control activities and other studies public, e.g. via the Internet. Strategies shall be pursued to ensure that systems to trace food and feed back and forth in the chain are in place (see Traceability).

Food Hygiene Principles: The Recommended International Code of Practice General Principles of Food Hygiene issued by Codex Alimentarius4 contains the following opening statement: People have the right to expect the food they eat to be safe and suitable for consumption. Food borne illness and food borne injury are at best unpleasant; at worst they can be fatal. But there are also other consequences. Outbreaks of food borne illness can damage trade and tourism, and lead to loss of earnings, unemployment and litigation. Food spoilage is wasteful, costly and can adversely affect trade and consumer confidence. Consequently, the General Principles of Food Hygiene shall be adopted which entails the following actions on the part of the FSA:
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Identify the essential principles of food hygiene applicable throughout the food chain (including primary production through to the final consumer), to achieve the goal of ensuring that food is safe and suitable for human consumption;

Reference: Recommended International Code of Practice General Principles of Food Hygiene (CAC/RCP 1-1969, Rev. 3-1997, Amd. (1999)) ftp://ftp.fao.org/codex/standard/en/CXP_001e.pdf

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Recommend a HACCP-based approach as a means to enhance food safety; Indicate how to implement those principles; and

Provide guidance for specific codes which may be needed for (i) the sectors of the food chain; (ii) processes; or (iii) commodities to amplify the hygiene requirements specific to those areas.

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POLICY STATEMENT ON FOOD SAFETY

Our first priority is to ensure the health and well-being of our citizens and visitors, and those persons around the world who consume food and foodstuffs originating in Iraq. We shall suggest implement programmes that promote high standards of food hygiene, and maintain systems of surveillance and control to ensure compliance with those standards. Recognising that some members of the society may not have access to information on best food hygiene practices, or the resources to implement them to their fullest extent, we shall design and implement public education programmes. We shall also suggest develop tools and techniques to achieve an acceptable baseline of food hygiene standards that will protect the most vulnerable segments of our society. With our tropical and desert climate and fertile agricultural resources, Iraq is well-placed to produce much of the food we consume. We are, however, prone to a range of plant and animal diseases that affect both agricultural productivity and the wholesomeness of the food we produce. Since the safety of a countrys food supply ranks highly in the priorities of the Iraqis government and Iraqs citizens in maintaining the overall security and quality of life in the nation, then measures shall be taken to minimise these risks. We shall, therefore, use the technical and scientific resources at our disposal to ensure that proactive disease prevention measures are in place and are maintained at all times. We shall also adhere to best practices in the areas of pesticide and fertiliser usage, animal feed production, animal welfare, veterinary support and other factors that may impact on the quality of our food supply. Similarly, appropriate controls will be maintained in the processing of food products. We recognise, however, that there is diversity in the food production resources in Iraq, ranging from subsistence farmers to high-tech production facilities, and programmes must be designed to inform and support baseline producers. The more sophisticated producer must be encouraged to extend their investment into properly maintained controls and self-regulation, where applicable. Iraq has agricultural produce and processed foods that are sought in the international markets While we often meet challenges in remaining competitive, standards must be upheld at all costs. Indeed, access to international markets is often dependant on adhering to the standards of the destination country, and, in particular, the requirements of the WTO/SPS agreements, such as the establishment of risk assessment and management capabilities, and the use of accredited laboratory testing facilities. This dictates that Iraq must speedily move to ensure that its conformity assessment systems are in line with international practice as compliance with international food safety requirements will be mandatory. We recognise also that the worlds trading patterns are changing, with new markets opening up, and traditional assured markets coming to an end, and food safety requirements becoming more stringent and universal. Iraqs food safety programme must, therefore, be responsive to these challenges, and by strengthening our efforts in managing our domestic market, we shall, by

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extension, ensure that food produced in Iraq is of the required requirements wherever it is consumed. As an importer of food, Iraq must ensure that inbound food products meet our national requirements and is safe for its people to consume. Consequently importers are responsible for ensuring that the food which they import into Iraq adhere to these requirements that we have set for ourselves, as we will not accept food that does not meet the requirements set by Iraqs food safety programme. It is expected that Iraqs food safety programme will be implemented by 2017, and we shall be in compliance with a set of food safety standards that have been formally adopted by the Government of Iraq. Thereafter, we shall ensure that this baseline is sustained, and enhanced as local and international developments warrant action on the part of those responsible for the countrys food safety programme. The Government of Iraq, therefore: Declares the intention to focus its food safety activities on the food chain as a whole from Farm to Fork and, in so doing, seek cooperation from all stakeholders. Not only is this done for the benefit of the citizens health and wellbeing, but also to protect the countrys economic development in such areas as tourism and foreign trade. Intends the policy to be adopted by the applicable Ministries and Agencies responsible for the areas shown in the Statement of Scope defined in Clause 7 of this statement, and that the policy will be administered by a designated Portfolio Ministry. Expects that users of this policy will adhere to a set of generally accepted principles 5 in the management of food safety as set out in the Statement of Principles set out in Clause 9 of this document. Cognisant of the need to mandate the creation and management of the technical skills-base required to identify and deal with food safety hazards, the Statement of Strategies in Clause 11 will be implemented in order to protect the integrity of the food supply mechanisms and prevent outbreaks of food-borne disease.

10.0 IMPLEMENTATION STRATEGIES


This food safety policy shall provide the foundation for Iraqs food safety programme and the institutional arrangements. In implementing this policy a collaborative approach, where all
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References: A Review of Canadian Food Safety Policy and Its Effectiveness in Addressing Health Risks for Canadians by R. MacRae and J. Alden, November 2002. http://www.pollutionprobe.org/Reports/foodsafety.pdf WHO: Assistance to National Authorities in Developing and Strengthening a National Food Safety Programme http://www.euro.who.int/document/FOS/gsnfsp6.pdf Commission of the European Communities: White Paper on Food Safety, January 2000 http://europa.eu.int/comm/dgs/health_consumer/library/pub/pub06_en.pdf

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stakeholders play a role in the food safety programme shall be used. Government shall provide the framework for its establishment and operationally but all participants in the Food Chain have specific responsibilities, these are outlined in the strategies which follow:

Information Gathering and Analysis: There are many methods and indicators to identify food safety programmes. They include data derived from controls carried out along the feed and food chain, disease surveillance, epidemiological investigations and laboratory analysis. It is expected, therefore, that those persons and groups responsible for information gathering and analysis will make such data available to all stakeholders in furtherance of the transparency and risk assessment principles. Where they do not currently exist, mechanisms shall be put in place to facilitate:
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Monitoring and surveillance; Rapid alert systems; Research; Scientific co-operation; and Analytical support.

Risk Assessment Risk assessment shall be carried out by an independent advisory committee, the membership of which shall be drawn from specialists in the various food safety risk areas and technical disciplines. This is a requirement under the WTO to which Iraq is still in the accession process, and SPS measures implemented must be supported by appropriate risk assessment capabilities, and Iraq will adopt the recommendations of the three sisters regarding risk assessment, also benefit from other Arab countries experience in this field and starting cooperation with them.

Risk Management: This strategy anticipates the preparation, application and adoption of technical regulations relating to sanitary and phytosanitary measures by parliament and relevant ministries . Such regulations will form part of a modern, integrated and comprehensive legislative framework governing food safety in Iraq. Preparation of such legislation requires the consideration of the following factors:
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The enforcement of food safety laws. The role of the FSA with respect to preparation, adoption of laws and regulations, providing advice to ministries, and participation at the international level (Codex, IPPC, OIE); The role of central government, and will the FSA be the sole body responsible for food safety issues; The role of local government; The role of NGOs in legislative work in terms of consultations, participation in boards, comments on laws and regulation, participation in crisis management committees etc. The relationship with the epidemiological enforcement system and the formation of a standing committee as a forum for discussion when food scares appear; The relationship with the environmental protection institutions on such matters as the use of resources and waste disposal throughout the food chain; 16

The relationship with other ministries and agencies on such matters as responsibility for drinking water.

Enforcement mechanisms are other aspects of the Risk Management Strategy, and this policy accommodates the option of using the FSA or accredited inspection bodies as the technical monitoring facility. Arising from this strategy, decisions are called for in relation to:
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The effects on the existing institutions carrying out inspection and enforcement functions; and The role of research facilities and laboratories in relation to risk assessment and general monitoring. In this respect, private entities will be required under the legislation to report diseases, etc. to the designated authority.

Furthermore, the enforcement mechanisms shall be governed by Inspection Manuals that will interpret the relevant laws and clearly set out the requirements for a food safety system. Risk shall also be managed through prevention and recognition of food safety as a priority issue. To this end, the Government shall promote food safety locally and encourage the development of experts in the field by establishing a National Food Safety Council at the highest level, initiating training and education, promoting awareness through:
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Patronage and sponsorship of food safety related activities by the State; Promoting the concept of food safety in ministries and governmental institutions; Establishing and funding of training activities; and Linking food safety to other national policies.

Risk Communication: Information on food safety risks shall be communicated to consumers through training, webbased media, television and radio, and printed publications. Such communications shall include information on nutrition, the wholesomeness of food, and diet, e.g. food in schools, and will focus on different groups in the society, including children, youth, the aged, etc.

Creation of a National Food Safety Movement: A Food Safety Movement will be established to promote awareness and diffusion of the concept of food safety in all sectors. This movement will be geared to encourage industry and trade to increase food safety and to recognise the minimum requirements set by governments as a precondition for marketing products. Strategies to be employed will include:
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Designation of a National Food Safety Week; and Supporting the growth of the Consumer Movement.

Institutional Infrastructure/Arrangements: There shall be national institutions for the enforcement of sanitary and phytosanitary measures legislated for in the form of technical regulations. In designing the institutional arrangements to support this strategy, the following responsibilities shall be addressed:
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Organisation of the enforcement mechanisms; Formal co-operation agreements and notification procedures; Notification of food safety measures to WTO (TBT/SPS); 17

National system for the notifications/enquiry point (TBT/SPS); Promoting the application and use of international standards (Codex, IPPC, OIE); Participation in international standards work; Development of national measures based on international standards; Identification of activities that are necessary to promote the use of international standards in implementing sanitary and phytosanitary measures; The institutional infrastructure shall accommodate the facilities and services required by industry and trade. In determining this strategy, a policy decision will be made as to whether facilities used by the Government for enforcement purposes shall also be available for service delivery to the private sector, e.g. laboratory services. Further, it shall be determined whether such services will be charged for at full economic cost or at a subsidised rate as user fees.

Certification of Products, Systems and Personnel The regulatory authorities shall use third party inspection and certification as part of the enforcement mechanisms, if necessary. In addition, while some operatives in the food sector currently require certification, i.e. food handlers, the certification mechanism shall be extended to other categories of personnel In the food industry.

National Accreditation Body: The Government of iraq is actively pursuing the implementation of a National Accreditation Body, and its jurisdiction shall extend to the food safety area. Laboratories involved in food safety-related services shall be accredited, and only accredited inspection bodies shall be used.

Inspection Services: The option shall exist for the regulatory authorities to use third/second/first party inspections as part of the enforcement mechanisms. Under this policy, inspection for regulatory purposes need not only be done by governmental inspectors.

Testing and Calibration Services: These services shall be provided by both private and governmental accredited laboratories. Technology Services: These services shall be provided by both private and governmental entities. Private Sector Involvement and Initiatives: Producers shall be responsible for food safety. This will entail:
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Recognition of food safety as an important issue; Implementation of good agricultural/hygiene/manufacturing practices; Verified compliance with legal requirements; and Systems of traceability of feed, food-producing animals and food.

The FSA will recognise the special needs of small and medium-sized enterprises, and will provide support in the form of:

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Provision of guidelines, training, and information; Guidance on good hygiene in catering establishments through training, manuals, etc.; Encouraging the involvement of farming and industry associations; and Facilitation of consultancy services for producers.

Other non-governmental involvement will be encouraged in the following stakeholder groups: -

NGOs involved in food safety activities; Consumers; Consumer organisations; Professionals; Professional associations; and Schools and universities etc.

Education and Training (Industry/Service Sector): Programmes of education and training for food industry personnel shall be established. Similarly, in-house training within the sector shall be supported. The main areas to be included in the programmes are:
-

General awareness of food safety concepts; and Training in food safety techniques at all levels.

Education and Training (General): The concept of food safety shall be introduced into the curricula of the countrys educational system, with material appropriate to the following levels:
-

Early childhood; Primary; Secondary; and Tertiary.

Education and Training (Consumers): Programmes of public education shall be conducted to inform consumers of their rights in relation to food safety. In so doing, support will be given to consumer organisations to facilitate this process.

Food Safety Agency: After the Cabinets teak decision to establish the Food Safety Agency (FSA) and in order to put this policy into the context of the FSA, the broad functions of this entity shall include the following areas: o Coordinate the administration of regulations applicable to the food sector, which may include carrying out supervision required by the food laws, and coordinating food control activities; Keep the Government informed about developments in the food sector(feedback); 19

o o o o

Assist the Government with, and participate in international work in the food sector; Carry out or instigate investigations and scientific studies on food and dietary habits, and develop methods for food control; Mobilise resources for the improvement and sustainability of service delivery in the food safety sector; Inform consumers and other interested parties in the food chain about current legislation and other important matters related to food; and participate in the execution of national development policy Coordinate strategies for emergencies and emerging issues

A phased approach shall be adopted in the establishment of the Food Safety Agency (FSA). A phased approach entails the setting up of a governing body/working group that will be assigned the responsibility of setting up a FSA Secretariat, and initiating legal and other reviews. The FSA Secretariat shall be established for a three year period. During that three year the FSA Secretariat will initiate the development of updated food safety standards and regulatory processes, establish key administrative/support services, appoint Risk Assessment Committee, prepare detailed Food Safety Programme, finalize and approve umbrella legislation, contract with accredited agencies for service delivery, issue import and export permits, establish and conduct risk assessment procedures and prepare reports, provide policy advice and assess compliance with national economic policies. At the end of year three, an assessment will be done to ascertain whether or not to maintain the FSA Secretariat or integrate regulatory functions. If a decision is taken to integrate regulatory functions then these activities will be done during the fourth year of the FSA Secretariat: o o o o

Updating and modernizing the facilities of the entities providing services Rationalizing resources needed to provide food safety services Identifying resources which need to be absorbed into the FSA Arranging for smooth transition of resources, for example, personnel and equipment

Special Programmes: Specific policies and strategies will be developed to address the issues and needs relating to such groups as:
-

The tourism industry; and The informal economy, i.e. higglers, market vendors, sellers of street food, etc.

In addition, the FSA shall be available at a consultative level for the development and monitoring of food-related programmes operated by the Government and other organisations. Such programmes will include:
-

The School Feeding Programme ; The Programme of Advancement Through Health and Education; Food Aid Programmes.

Umbrella legislation

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As a consequence of adopting this policy, the Government of Iraq will embark on a programme of legislative reform as it applies to food safety matters. The aim of this exercise will be to arrive at a legislative framework that synchronises regulatory activities and modern, internationally compliant laws that protect the interest of Iraqis at home and in external markets. The new legislative framework will also provide the mandate for the governing body of the FSA to have powers of direction and coordination in the food safety sector, so that they can effectively manage Iraqs food safety programme. Complementing the legislative changes, a programme of institutional development and strengthening will be embarked upon. The objective of this programme will be to address the overlaps and gaps in service delivery and to ensure that adequate coordinating mechanisms are in place with which to optimise the strengthened statutory powers.

11.0 MONITORING AND EVALUATION


Monitoring and evaluation of the effectiveness of this policy will be the responsibility of the Portfolio Minister on the advice of the Chairman of the governing body of the FSA. It is anticipated that this policy will require a full review in six (6) years of its adoption to ensure compliance with local and international developments.

FOOD SAFETY POLICY

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APPENDIX: CURRENT FOOD SAFETY LEGISLATION IN Iraq


1. COSQC law No. 54/1979 2. General Health Law No.89/1981. 3. Food Law No.29 /1982(it is not really a real food law). Or we can say it is Food System This system is widely used by MOH to issue standards. 4. Consumer Protection Law No.1/2010 5. Plant Development and Protection Law No. 71/1978 6. Agriculture quarantine Law No.17/1966 7. Slaughtering Arrangement Law No.22/1972 8. General Trade Laboratory Law No. 9. National Quality Control System/ 1988

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