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Food Safety in New Zealand: Application of a Risk Management Framework

Why the need for an agreed risk management process?

A time of change

Food safety is an accepted consumer requirement but one that courts controversy. The last decade has seen vastly increased knowledge on risks to consumers associated with biological, chemical and physical hazards in the food chain, along with demonstrated success in the application of new regulatory systems and food safety programmes. Nevertheless, foodborne illness continues to be a significant problem in all countries and governments are responding in a number of ways to assure the safety of food provided to domestic consumers and to those in offshore markets.

Global drivers of change

Global drivers of change are particularly important in the New Zealand situation, given that high volumes of exported food are a major part of our economy. New Zealand is also importing a greatly increased range of food from different countries and this now constitutes 20% by value of food consumed.

Along with the increasing volumes of imported and exported food, the geographical origin, nature, range, preservation requirements and intended end uses of foods are now vastly expanded. This places ever-increasing demands on NZFSA resources, especially in terms of identifying emerging hazards associated with changing agricultural practices and new processing technologies, and applying appropriate control measures.

Domestic drivers of change

The seamless nature of the international and domestic food environment means that new and emerging hazards anywhere in the world inevitably impact on domestic stakeholders. Specific concerns of domestic consumers add to the range of potential hazards that must be addressed by NZFSA, which aims to target the steps in the food chain where prevention or control is practical and cost-effective. Areas of increased consumer awareness include nutritional deficiencies and allergens.

In a modern food safety system, there is an ever-increasing onus on the food producer and processor to produce safe food. While the Food Safety Authority is responsible for developing regulatory standards and carrying out other regulatory activities such as consumer education, industry players themselves must implement and verify relevant food control measures to the satisfaction of government. Both the standards themselves and the level of official supervision needed are under constant review by NZFSA in terms of effectiveness and efficiency.

NZFSA’s Statement of Intent includes an emerging focus on nutrition and facilitating consumer choices that support better health. This is a complex regulatory area and may involve risk management decisions that have to deal with competing elements, for example the potential of developmental risks in children from low levels of mercury in fish compared with the general nutritional benefits of fish consumption. Regulatory decisions such as this have ever-increasing demands for high-quality scientific input and specialist risk communication skills.

Figure 1: Global drivers of change in food safety

NZFSA Statement of Intent 2008–2011 • Improved safety and suitability of food • Improved business opportunities through safe and suitable food • Consumer food practices and choices that support better health

NZFSA also has a mandate to improve business opportunities wherever practicable. This is driving closer cooperation between NZFSA and industry in identifying priority areas for applied research and regulatory change so as to accommodate innovative and cost-effective technologies. Government promotion of economic, environmental and social sustainability (non-harmonised under international food trade agreements) also influences NZFSA domestic regulatory policies.

Emergence of food safety risk analysis

Risk analysis has recently emerged as a core food safety discipline. It is employed to answer a basic set of questions:

• What can go wrong?

• How likely is it to go wrong?

• How serious would it be if it went wrong?

• What can be done to reduce the likelihood and/or seriousness of it going wrong?

The components

Risk analysis is supported by a set of internationally agreed principles and guidelines that are now applied by many countries. Three components – risk assessment, risk management and risk communication – are described.

Prevention, reduction or elimination of risks can take many forms and may involve balancing of scientific findings against other questions such as the health expectations of society and the likely costs of potential control measures. Risk communication involves a continuous and interactive exchange of information between all parties throughout the risk analysis process.

Since the early 2000s, Food Safety Authorities around the world have undergone structural change so as to better support risk analysis.

Figure 2: Components of risk analysis

Categorisation of control measures

With the widespread commitment to risk analysis at the international and national level, it is important to establish the difference in the types of measures now available for food control, as follows:

GHP-based control measures

GHP-based control measures are generally qualitative in nature and are based on empirical scientific knowledge and experience. They are usually prescriptive and may differ considerably between countries.

Hazard-based control measures

These are developed from scientific knowledge of the likely level of control of a hazard at a step (or series of steps) in a food chain, have a quantitative base and can be validated as to their efficacy in hazard control at the step. There is an obvious expectation of consumer protection but the actual degree of protection will be unknown.

Risk-based control measures

Risk-based control measures are developed from risk assessments or other information on risk, eg surveillance data, on the basis of specific knowledge of the likely levels of consumer protection that will result. They have a quantitative base and can be validated against a required level of consumer protection.

A modern food safety programme will be made up of food control measures in all these categories. However, inclusion of an increasing proportion of risk-based measures that have been developed and implemented according to an agreed risk management process will have marked benefits for all stakeholders. In the ideal situation, a proposed food safety programme should be broad enough to encompass all parts of the food chain and standards should be implemented wherever they will be the most effective in reducing risks.

Consumer health goals

Food Safety Authorities around the world are adopting specific consumer health goals as part of government policy. Monitoring of foodborne disease statistics not only demonstrates achievement of food safety outcomes; it also provides information on the effectiveness of underlying regulatory systems and the necessary allocation of food safety resources proportional to risk.

Attribution is a key consideration when setting consumer health goals and represents the extent to which a change (or no change) in an outcome, can, with a reasonable degree of certainty, be attributed to the actions of the Food Safety Authority.

NZFSA has recently established three consumer health goals for New Zealanders:

• 50% reduction in reported annual incidence of foodborne campylobacteriosis after 5 years

• 30% reduction in reported annual incidence of foodborne salmonellosis after 5 years

• no increase in reported annual incidence of foodborne listeriosis over 5 years.

Achievement of these outcomes over time is highly dependent on systematic application of risk analysis principles and guidelines according to an agreed risk management process.

In support of NZFSA’s goals for reduction in rates of foodborne illness attributable to specific pathogens, ‘intermediate’ outcomes are expressed in terms of hazard reduction at specific steps in a food chain, as follows:

• one log average reduction in Campylobacter on chilled broiler meat against the 2007 baseline, following implementation of a new regulatory standard in early 2008 (interim target)

• 50% reduction in prevalence of Salmonella positive broilers after five years

• 50% reduction in prevalence of E. coli O157:H7-positive bobby calves after five years.

Consumer health goals NZFSA goals can be compared with those recently established in other countries. In the United States, the consumer health goals of ‘Healthy People 2010’ include a 50% reduction in both general cases of campylobacteriosis and cases of post-diarrhoeal haemolytic uraemic syndrome (HUS) in young children by 2010. In the United Kingdom, food safety goals include a 50% reduction in the incidence of broiler chickens which test positive to Campylobacter and a 50% reduction in the incidence of pigs that test positive to Salmonella at the end of slaughter by December 2010.

Risk management and government

During the years 2002–2007, significant policy and structural changes that supported a risk-based approach to food safety issues were put in place by NZFSA. Regulatory reform also promoted increased stakeholder participation in standard development and increased the focus on public health outcomes rather than prescription of regulatory process.

Since 2007, NZFSA has been a stand-alone Department of State and has continued to fine-tune the risk-based approach to food safety. New work programmes reinforce the ‘production-to-consumption’ approach to food control and draw on an increasing range of expertise as inputs to risk-based decisions, eg in areas of economics, human medicine, genomics, information technologies and social sciences. This multidisciplinary approach is important if consumers are to have full confidence in the regulatory activities of NZFSA.

As a signatory to the World Trade Organization Agreement on the Application of Sanitary and Phytosanitary Measures (WTO SPS Agreement), New Zealand is acutely aware of its responsibilities in pursuing a risk-based and equitable international trading environment. Consequently, NZFSA has developed a comprehensive strategy for incorporating the risk analysis guidelines developed by the Codex Alimentarius Commission (CAC) in its regulatory systems wherever appropriate.

Finally, NZFSA recognises that a regulator has a special responsibility to put health risks in perspective in all aspects of its activities. In times of limited technical resources, NZFSA must prioritise its risk management activities to those areas constituting the greatest foodborne risks to consumers. Further, many foods that may have some potential to generate adverse health effects are also essential components of a healthy diet and these situations can comprise complex risk management challenges. The consequences of accepted food practices, eg, adding nitrates to preserve ready-to-eat meats and generation of acrylamides when cooking starch-based prepared foods such as potato chips, also need further research to determine if there are any quantifiable risks associated with levels of exposure in the normal diets of New Zealanders.