Designing Effective Food Safety Interventions in Developing Countries

Laurian Unnevehr, University of Illinois Nancy Hirschhorn, USDA/FAS Contents: The Key Issues The Key Principles The Basic Food Safety Road Map Notes Abstract: Food safety is an important part of both public health and food market development. This guide examines the types of public interventions that can improve food safety as part of the process of economic development and poses useful questions to help understand the food safety system. An initial motivation for such interventions may arise in marketing food exports to countries with higher standards. Because food safety is a significant public health threat in developing countries, larger benefits from food safety interventions can be obtained when these also address the domestic market. An excellent resource section at the end guides the reader to more in depth information on this topic. 1. The Key Issues Inadequate food safety is a significant contributor to the burden of disease in developing countries. In the less developed countries, 70 percent of deaths among children under 5 are linked to biologically contaminated food; mycotoxins are more prevalent; and foodborne parasites (e.g. cysticercosis) are more common. Food safety is clearly linked to public health but it also plays a critical role for developing new export markets that can significantly alleviate rural poverty. Thus, improving food safety can contribute to both public health and export earnings in developing countries, but setting priorities for investments in food safety requires careful evaluation. Food safety is an issue of growing importance due to several worldwide trends that contribute to increasing safety risks in food systems: the growing movement of people, live animals, and food products across borders,       rapid urbanization, changes in food handling, the emergence of new pathogens or antibiotic resistance in pathogens. Public interventions are needed to improve food safety, because it is often a public good. That is, consumers cannot detect the safety of individual products, and therefore cannot demand greater safety through their purchasing decisions. Therefore, governments frequently intervene to regulate food safety, but the kinds of interventions that make sense change with a country's level of development. Regulating food safety requires significant public capacity that may be impractical for small, low income countries. This paper gives an overview of the kinds of investments that can be undertaken to improve food safety. Specific examples are given of the kinds of interventions that have been successful in either facilitating exports or improving domestic public health. Methods of evaluating whether food safety interventions make sense are also discussed. 2. The Key Principles Many industrial countries have reformed their food safety regulatory systems and developing countries can learn from their experiences. A progressive food safety regulatory system includes: Consolidated authority with ability to address the food system from farm to table and to move resources towards the most important sources of risk. Use of comparative risk assessment as one criterion for prioritizing public action. Cooperation with industry and consumers to provide information and education. Use of HACCP (Hazard Analysis of Critical Control Points) 1  principles to promote prevention and industry responsibility in place of prescription and inspection. An open decision making process that allows stakeholder participation. Evaluation of public health outcomes from regulation. These elements provide guidelines for developing food safety regulation in developing countries. But developing countries must decide at what point in the development of the food system intervention makes sense and what specific kinds of interventions make sense. Table 1 shows the types of public activities that can improve food safety, how these activities evolve during the process of development, and examples of related project components for investment. Food safety interventions build from basic investments and simple interventions to more complex regulatory systems as economies develop. Priorities for public action change at different levels of development. At low levels of income, investments in water and sanitation and targeted interventions to reduce child malnutrition are the highest priority for food safety interventions targeted to public health. As food systems and the capacity for food safety policy develop, then targeted interventions for single source hazards or important control points in the food marketing chain become practical. At higher levels of income, more extensive regulation and enforcement are feasible. These would include setting specific standards for food products (e.g. pesticide residues) and monitoring the food supply to ensure compliance with these standards. At any level of development, specific interventions targeted towards exporting food to high income markets may be undertaken by both the private and public sector, and these are discussed below in section IIIC. These interventions are complementary to the evolution of food safety policy for the domestic market. Interventions to improve export quality can facilitate improved food safety for the domestic market and are easier to undertake as domestic food safety policy evolves. 3. The Basic Food Safety Road Map Building public capacity Stakeholder involvement in policy making, disease or hazard surveillance, and participation in international standard setting organizations is fundamental to public capacity. These activities inform the process of risk management, which includes decisions about which risks are important and which can be effectively addressed through intervention. A related issue is setting standards for food safety. Countries can adapt internationally recognized standards from the Codex Alimentarius when domestic capacity for risk assessment is limited. As countries develop, they will gain greater public capacity for setting standards and designing interventions according to local risk conditions and preferences. It is useful for countries to develop a process for setting priorities among risks, based on their importance. Risk assessment can provide the basis for understanding the sources of risk and their consequences. This can better inform efforts to meet export market standards or the development of domestic food safety regulations. Risk management, which is the policy process of making decisions about where to reduce risks, must rely on risk assessment for guidance. Risk management is a political process, and will reflect public perceptions about risk sources. A process of risk communication that includes stakeholders can help to create policies that will be more easily enforced. For example, some risks might provoke public outrage or be identified by firms as export barriers. A country might choose to focus policy making on these risks. To manage them effectively, the public agency responsible could carry out a risk assessment to understand the sources of the hazard and potential control methods. This would inform the design of measures for risk management, which could then be discussed with stakeholders to gain support for enforcement. | Link to Table 1. Public Activities to Improve Food Safety | Any investment must provide a return greater than cost but most food safety investments are hard to evaluate because the outcomes are not market goods. Only in export markets will project evaluation be straightforward. The value of additional exports gained through access to new markets can be compared to the costs of private and public investments to improve food safety. But even in export markets, there may be benefits for domestic consumers that help to justify investments in food safety. Cost-benefit analysis for domestic food safety investments must use some technique to value improvements in health. Cost-of- illness estimates have been used in several countries and in some World Bank studies. These estimates place a value on lost productivity from illness, including disability and death, and provide one way of comparing the benefits from reducing foodborne illness to the costs of investments to prevent or control hazards. In practice, such estimates may be difficult to generate with the limited data available on the incidence of diseases. Building public capacity to evaluate investments can be part of developing an effective food safety system. Links to public health In low income countries, food safety is closely linked with sanitation, water supply, and nutrition. Because the burden of illness, particularly for children, is a function of all of these variables, it is difficult to address food safety risks separately. Thus removing one source of hazard may or may not reduce the consumer's risk. In very poor countries or households, the provision of basic water and sanitation services may be a prerequisite for efforts to reduce the most important food safety risks. Such investments can also facilitate export market development, when they occur for regions or households engaged in export production. Thus projects to improve health through sanitation and water could also address food safety. Decisions about public interventions to prevent or control food hazards must recognize the limited public capacity for enforcement and the need for prerequisite investments in food marketing infrastructure. As food systems develop, urban markets, street food vendors, and slaughterhouses are highly visible points of concentration in the food chain and are therefore often the focus of initial interventions to impose standards of hygiene or to provide the means to improve hygiene (e.g. cold storage). Effective and Enforceable Interventions By imposing food safety standards, governments risk raising food costs or driving the informal food sector underground. One of the difficulties that developing country governments face is how to identify enforceable interventions as the formal food sector grows, without driving out informal activities that still serve an important economic and social function. Some guidelines are possible for the evolution of domestic market controls. First, the control of single source hazards is the type of intervention that is more easily implemented when public capacity is limited. Some examples are hazards that enter only through imports (i.e. a non-native pest or disease) or hazards that have only one source, such as a parasite or disease carried only by one animal species. Interventions to reduce these kinds of hazards can be enforced more easily than interventions to reduce hazards that enter food at many points (e.g. microbial pathogens). Rather than try to enforce strict standards with limited public capacity, the feasible approach to food safety improvement can build on these policies: targeting sanitation investments to improve food handling and processing; addressing the most important and easily controlled risks first; training for industry and food handlers in basic hygiene; provision of information to consumers about how to avoid risks. These kinds of activities help improve food safety throughout the entire food system without penalizing the informal sector. Investments in laboratories are often the only 'food safety' component of larger projects in agricultural sector development, such as in some World Bank projects in Eastern Europe. But such investments do not bring about a comprehensive and effective system. Use of laboratories for increased monitoring of the food supply should be linked to enforcement and to outcomes in food safety improvement. But more importantly, such investments need to be part of a larger effort that includes the legal framework for regulation, capacity building for comparative risk assessment and for HACCP approaches, and institution building for greater stakeholder involvement. Ideally, a comprehensive approach would also identify key infrastructure investments to support food safety through better sanitation at key points in the food chain. 3.B. Questions For Understanding a Domestic Food Safety System Legal and Regulatory Framework What is the current legal framework authorizing for food safety regulation? Which kinds of hazards are covered? Which government agencies are involved? Is there legal liability for the food industry under some circumstances? How are food safety regulations and laws enforced? Answers to these questions will identify gaps in the legal and regulatory framework for food safety. Establishing such a framework is a prerequisite for public action. Public Capacity Which government agencies are involved in regulating food safety? What are their budgets and staff? Do they report to ministries of health, agriculture, trade, other? What is their training and background? If hazards are monitored, what use is made of the information? Answer to these questions will show the current public capacity for food safety policy and enforcement, and whether investments to build capacity are needed. Stakeholders Who are the important stakeholders representing the food industry and food consumers? What issues do these groups think are most important? Answers to these questions will help to identify the food safety interventions that would have broad public support and therefore would likely be easier to implement. Initial Risk Prioritization What are the most important food safety hazards and what are their sources? What are the most important foods in the diet and what kind of risks do they carry? What are the most important diseases and which ones can potentially arise from contaminated food? Which hazards can be controlled by the consumer or food preparer? Which ones can only be controlled during the production process? What proportion of the food supply is marketed to urban areas? Which food products are likely to pose the greatest hazards to urban consumers? Answers to these questions will help to identify targets for initial interventions, by identifying the most important risks that need to be addressed during food production and processing. Design of Education Programs for Food Processors and Handlers What kinds of quality and safety control do large scale food companies follow in their processing? What kinds of quality and safety control are followed in the tourist industry? Do these control programs suggest areas for public investment to remove constraints? Do they suggest model HACCP plans that could be adapted for training processing firms in the informal sector? What existing programs could provide vehicles for training food preparers, such as food and nutrition intervention programs or licensing of street food vendors? Answers to these questions will show what the food sector is already doing and where existing private sector models could be adapted to training and interventions for the informal food processing and service sector. 3 C. Meeting Sanitary and Phytosanitary Standards in Export Markets Food export markets present a somewhat different set of challenges from domestic food safety regulation. Exports of fresh food products such as meat, fish, fruit, and vegetables represent a desirable growth opportunity because these products have a high demand and fewer trade barriers than staple commodity agricultural exports. Fresh food products are also more likely to encounter sanitary and phytosanitary (SPS) barriers to trade. Delivering safe food to distant markets requires process controls throughout the production process and mechanisms to certify to buyers and government regulators that such controls are effective. Developing--country exporters need to know how to meet standards in different markets and how to meet the increasing demand for product trace-back and certification of production methods. Food safety investments for export markets will be influenced by the growing recognition that a farm to table approach is necessary to address food safety. Table 2 shows the many different kinds of activities needed throughout the food production chain to ensure food safety. Because many hazards can enter the food chain at different points and it is costly to test for their presence, a preventative approach that controls processes is the preferred method for improving safety. The HACCP system is increasingly used as the basis for food safety regulation and for private certification of food safety. The 1994 SPS agreement of the WTO provides a framework for resolving disputes about SPS measures. Developing countries need to participate in this and and other standards setting organizations such as the Codex Alimentarius, the Office International des Epizooties (OIE), and the International Plant Protection Convention (IPPC) in setting internationally recognized standards. Many developing countries do not have the capacity to participate in these international organizations and it is not clear that their interests are always taken into account. Learning how to participate effectively involves capacity building within the public sector in developing countries and may also involve forming coalitions around issues of mutual regional interest. Export promotion projects provide lessons regarding the importance of partnerships between the public sector and the private sector, the importance of training and market information, the close connection between safety and quality management in practice, and need for sometimes small, but crucial, infrastructure investments or policy reforms. For example, a World Bank project for Export Promotion in the Ivory Coast supported a producer organization that developed a private system for quality and safety assurance in fruit exports to the EU. Another World Bank project for Agricultural Sector Investments in Tunisia made investments in cold storage for fishery products at a port, and charged user fees for cost recovery. USAID activities in Guatemala support snow pea exports through developing Integrated Pest Management to reduce pesticide residues leading to rejections in the U.S. The FAO provided technical assistance to support Bangladesh shrimp exports to the EU and the U.S., through providing HACCP training and sanitation investments. These projects and other studies of successful non-traditional food exports suggest that the best practice is to rely on private certification and private investments as much as possible, but that key public monitoring and intervention can be needed. The strong market incentives to export motivate both public and private responses. (More information about these examples can be found in the internal World Bank publication,Food Safety: Issues and Opportunities for the World Bank). Insert table here: Table 2. Food Safety Activities in Food Production Farm Production Transport of Animals & Agicultural Products Slaughter House, Packing House, First Distributor Transport of Products Industrial Process Retailers, Food Services -Hygiene of facilities -Hygiene of personnel -Use of water -Sewage contamination -Control of use of agricultural pesticides -Control of use of veterinary pesticides, antibiotics, hormones -Cleaning -Disinfection -Hygiene of establishments -Hygiene of personnel -Ante and post-mortem inspection and hygiene handling –Hygienic handling of products -Monitoring of agrichemical residues -Monitoring of residues of antibiotics, hormones, etc. -Microbiological monitoring -Labeling -Cleaning vehicles -Cooling -Hygiene of personnel -Hygiene of establishments -Hygiene of personnel -Hygienic handling of products -Microbiological monitoring -Labeling -Hygiene of establishments -Hygiene of personnel -Hygienic handling of products -Labeling Source: Kevin D. Walker, IICA. Prepared for the World Bank Rural Week Conference: Political Dimensions of Food Safety, Trade, and Rural Growth, March 26, 1999. An important issue is how efforts to improve export quality may provide benefits for domestic consumers. The foreign exchange generated from export markets can provide incentives for food safety improvements, e.g. through investments in processing facilities, that have positive spillovers for domestic markets. On the other hand, export standards may not be appropriate for domestic production, if domestic risks differ due to local handling and preparation. Understanding the priorities for domestic public health can inform policies that capture benefits for domestic consumers and capitalize on the incentives for better safety in export markets. 3 D. Questions for understanding food safety in export market development Current Barriers to Exports What are the major food exports and what kinds of sanitary regulations do they encounter? Do the major importers conduct in-country inspections or pre-certification? If so, what problems did they identify? Have export shipments been rejected or embargoed for any products? If so, for what reasons? Answers to these questions will identify which food safety hazards need to be addressed to develop export markets and to ensure continued market access. Private Sector Information about Export Standards How do export producers obtain information about foreign import regulations, food safety standards and cultural preferences? Are foreign firms involved in communicating information to local producers about foreign import standards? Answers to these questions will show if the private sector has adequate information about food safety standards in export markets, and whether they would benefit from public efforts to communicate such information. Private Sector Capacity for Responding to Export Standards What kinds of sanitation measures, good manufacturing practices, or HACCP systems are currently in place in export production? Who verifies that sanitation, prevention, and control procedures take place in export market production-- local firms? Government agencies? Importing firms or governments? Is there a need for targeted infrastructure investment or public monitoring to help local producers meet foreign standards? Are the exported products consumed domestically, and if so, then do domestic standards differ from export standards? Answers to these questions will show where gaps in hazard control, monitoring, or infrastructure prevent the private sector from meeting exports standards. 4. Notes Prepared by Laurian Unnevehr (laurian@uiuc.edu), University of Illinois; and Nancy Hirschhorn (hirschhorn@fas.usda.gov), USDA/FAS. For more information see Resources section IV. Peer review: Michel Simeon, principal economist, The World Bank. - Naim khalid