1

SUGGESTED PLAN FOR

NATIONAL FOOD SAFETY POLICY OF IRAQ

By

Talal K.Hasan, M.Sc.1 Nihad Saadoon Gheni ,M.Sc

1

Issam Abdulahad Betrous B.Sc 1 Adnan Abed Rajab Al-Temeemi M.Sc

2

Sabah Faleih Al-Saadi ,B.Sc 3 Zainab Abdul Adheem Al-Zuraiji ,B.Sc

4.

2011

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

2

TABLE OF CONTENTS

1.0 INTRODUCTION ................................................................................................... 3

2.0 INTERNATIONAL BEST PRACTICES ...................................................... 4

3.0 CURRENT FOOD SAFETY SYSTEMS IN IRAQ ................................. 5

4.0 FOOD SAFETY POLICY AND DEVELOPMENT WORK ............... 7

5.0 FOOD SAFETY POLICY OBJECTIVES .................................................... 7

6.0 POLICY ISSUES AND RECOMMENDATIONS ................................... 7

7.0 STATEMENT OF SCOPE .................................................................................. 9

8.0 DEFINITION OF FOOD AND STATEMENT OF PRINCIPLES .. 10

9.0 POLICY STATEMENT ON FOOD SAFETY ..................................... 14

10.0 IMPLEMENTATION STRATEGIES .................................................... 15

11.0 MONITORING AND EVALUATION .................................................... 21 APPENDIX 1: CURRENT FOOD SAFETY LEGISLATION IN IRAQ .................................... 22

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INTRODUCTION

The protection of human, animal and plant health in today’s 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 country’s 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 Iraqi’s 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 Iraq’s

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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2.0 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 Community’s 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

Agency’s regime retains the principles of parliamentary accountability and ministerial

responsibility. Two ministers are responsible for implementing the federal food safety program.

1 Regulation (EC) No 178/2002 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 28

JANUARY 2002

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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

Agency’s related activities. 2

United States of America

The three branches of government; executive, legislative and judicial all impact on the USA’s

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

3.0 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 Ministries & Public Sector Agencies Involved

Inspection & Certification

Certification & Testing of Meat Products

for local consumption , export & import

Veterinary Services Division (VSD) –MoA

MoH – Public Health Department

COSQC_KSQCA /MoP

MoT

MoE

Inspection & certification of foods and

feeds at ports of entry, warehouses and

retailers

MoA

MoH

COSQC – KSQCA /MoP

MoT

MoE

Registration and inspection of all food MoA

2 1998 Report of the Auditor General of Canada

6

processing factories; sampling & testing of

raw materials and finished products

MoH

COSQC-KSQCA

Training

Training of Meat/Food Inspectors in

HACCP, general food safety and food

hygiene

MoH

MoP

Training & certification of farmers and

pest control operators in proper and safe

use of pesticides

Under establishments

Public Education

Public education & awareness on food

safety issues

MoH

COSQC -KSQCA

Laboratory Testing Facilities

Chemistry

Microbiology

Entomology

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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4.0 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 NGO’s 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. .

5.0 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 Iraqi’s 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

6.0 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.

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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 Iraqi’s 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

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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 country’s

food safety system.

Recommendation

The government shall establish a coordinating mechanism such as an agency which shall be

responsible for coordinating food safety activities.

7.0 STATEMENT OF SCOPE

In determining the scope of the food safety policy, it must be accepted that it has to be wide-

ranging 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).

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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.

8.0 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.

o Genetically modified organisms (GMOs);

o Functional foods (foods which claim to have special properties valuable to health, but

which do not have a medicinal product license);

o 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

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:

­ 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

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

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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:

NATIONAL COMMITMENT TO FOOD SAFETY

GOVERNMENT

INDUSTRY/TRADE CONSUMER

Food Legislation and

Enforcement

Information Gathering and Research

Consumer Education

Advice for Industry/Trade

Provision of Health-Related

Services Active Consumer Groups

Community Participation

Safe Food Practices in the

Home

Discriminating and

Selective Consumers

Educated and

Knowledgeable Public

Informative Labelling and

Consumer Education

Trained Managers and Food

Handlers

Appropriate Processes and

Technology

Quality Assurance and

Control of Processed Food

Good Practices by Primary

Producers and Distributors

SHARED RESPONSIBILITY

SAFE FOOD FOR ALL

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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 Iraq’s,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:

­ 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;

4 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.

9.0 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 country’s food supply ranks highly in the priorities of the Iraqis government

and Iraq’s 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 world’s 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. Iraq’s 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 Iraq’s food

safety programme.

It is expected that Iraq’s 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 country’s 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 citizen’s health and wellbeing, but also to protect the country’s 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 principles5 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 Iraq’s food safety programme and the

institutional arrangements. In implementing this policy a collaborative approach, where all

5 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

16

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:

­ 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:

­ 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;

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­ 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:

­ 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:

­ 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, web-

based 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:

­ 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:

­ Organisation of the enforcement mechanisms;

­ Formal co-operation agreements and notification procedures;

­ Notification of food safety measures to WTO (TBT/SPS);

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­ 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:

­ 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 country’s 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 Cabinet’s 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;

o Keep the Government informed about developments in the food sector(feedback);

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o Assist the Government with, and participate in international work in the food sector;

o Carry out or instigate investigations and scientific studies on food and dietary habits,

and develop methods for food control;

o Mobilise resources for the improvement and sustainability of service delivery in the

food safety sector;

o 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

o 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 Updating and modernizing the facilities of the entities providing services

o Rationalizing resources needed to provide food safety services

o Identifying resources which need to be absorbed into the FSA

o 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 Iraq’s 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