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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop Day 2 Afternoon Session     Food Traceability: A Response to Consumers         The Role of Risk Analysis in a Science-Based Approach to Food Safety         The Hazard Analysis and Critical Control Point System         Implementing and Auditing Hazard Analysis and Critical Control Point Systems and Difficulties in Iran         The History of Food Safety in Iran         Discussion    

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop Food Traceability: A Response to Consumers Dr. Alfredo M. Montes Niño International Consultant, Food and Agriculture Organization—World Health Organization I will start with some definitions of traceability as it refers to food. This term and the concept behind it also apply to other industrial products. In the food area, traceability is important for commercial and safety reasons. Definitions allow us to distinguish the scope covered by this concept and establish legal requirements. Possible consequences of the legal requirements are violations of established rules that end up as disputes or cases. The importance of Codex Alimentarius definitions, as you may know, is that these standards have been adopted by the World Trade Organization (WTO) in its Sanitary and Phytosanitary Agreement as practically the highest standards that a country can set for its import requirements. Codex Alimentarius: “Traceability is the ability to follow the food movement through its specified stages at production, processing, and distribution” (WHO/FAO, 2004). The European Union (EU) has established its own definition. This has to be considered in cases of exports to that region despite the right of countries to initiate actions within the scope of WTO procedures. Rule EC 178/2002, Article 3: “The ability to trace and follow a food, feed, food-producing animal or substance intended to be, or expected to be incorporated into a food or feed through all stages production, processing and distribution” (EU, 2002).

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop As mentioned, definitions are needed for different purposes, but for practical purposes a more descriptive explanation is necessary. Traceability is a group of actions, measures, and procedures that reveal a product’s history, from its birth until the end of the commerce chain, passing through all intermediary production processes. Traceability in the food chain was initially raised as a proposal of the EU. Originally it was created to control taxes along the wide and varied commercial channels through which cattle moved within that ever more communal territory. The trigger was the mad cow disease crisis in 1996 that generated mandatory and voluntary requirements for the traceability of cattle and beef in the EU. Consumers’ frustration and general discredit of the traditional control systems prompted the implementation of a new system that would generate greater credibility among consumers. This crisis also led to changes in the organization of food control within the European Commission and to the creation of the European Food Safety Agency. In the wake of the latter, corresponding institutions were created in the EU’s member countries. Implementation of a total traceability system for cattle and beef requires the following two elements: identification and registration of bovine animals and labeling of beef and beef products. Needed to achieve such a system are the following: documentation concerning the origin and all transportation or relocation of bovine animals; regaining the consumer’s confidence in beef by labeling it with information concerning origin and slaughtering; and obtaining at least minimum information on the beef imported from third-party countries. Currently, the identification of each animal is under discussion. A decision on mandating animal identification has been postponed. For the moment the accepted means of identification include the following: ears tags; a passport; a record of all transport from birth (or importation) to slaughter of each animal, with this record in a central database within each member state; and individual registries on each farm. Although a voluntary system has been in place since January 1, 2005, a traceability system ought to be established for all food. The labeling of beef has already been implemented and the system’s main characteristics are:

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop an indication of the member state(s) or other countries where the animal was born, fattened, and slaughtered; the abattoir’s and deboning hall’s approval numbers; and a reference number that links the meat and the animal. As mentioned above, traceability of products through the food supply chain is in response to the European consumer’s desire for full traceability in order to guarantee safety, quality, authenticity, and rapid response. The final response to these needs is still in process and a final definition of traceability has yet to emerge from the diverse numbering systems, barcodes, electronic tags, biological markers, and communication systems. The effectiveness of responding rapidly to these increasing consumer demands was proven during the recent bovine spongiform encephalopathy and avian influenza crises. Certain supermarkets in the United Kingdom had already gained a reputation for selling products that were traceable. Consequently, the sale of the sensitive products at these shops did not decrease during the crisis; they increased considerably. The above scenario provides an example for countries that want to maintain, increase, and even diversify their food exports. The safety of their food products must be linked clearly to practical, efficient, and transparent identification systems capable of offering importers a useful tool for satisfying both the new legal requirements in their countries and consumers’ demand for reliable information. REFERENCES EU (European Union). 2002. Regulation (EC) No 178/2002 of the European Parliament and of the Council, Official Journal of the European Communities. Available at http://europa.eu.int/eurlex/pri/en/oj/dat/2002/l_031/l_03120020201en00010024.pdf. Accessed November 18, 2005. WHO/FAO Codex Alimentarius Commission, Report of the Twenty-Seventh Session, Geneva, 28 June-3 July 2004. WHO/FAO, Rome, 2004. Available at http://www.fao.org/documents/show_cdr.asp?url_file=/docrep/007/y5549e/y5549e00.htm. Accessed November 18, 2005.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop The Role of Risk Analysis in a Science-Based Approach to Food Safety Charles Yoe Professor of Economics, College of Notre Dame of Maryland Traditional food safety management systems with their focus on end-product testing no longer suffice to deal with the complex, persistent, pervasive, and rapidly changing food safety problems of a global economy. Science-based approaches to food safety systems are increasingly in use. Many science-based approaches to food safety have already been implemented successfully. Risk analysis, a process comprising risk management, risk assessment, and risk communication, is an essential element of any science-based food safety system. Risk analysis is a problem-focused paradigm designed to work with ambiguous data, using many people to find the best solution now while looking toward the best solution in the future. Disease surveillance both provides risk assessment with data and is guided by the research needs identified by risk assessment. TRADITIONAL FOOD SAFETY SYSTEMS NO LONGER SUFFICE Food safety is an essential public health issue for all countries. Foodborne diseases present a real and formidable problem in both developed and developing countries, causing great human suffering and significant economic losses. Up to one-third of the population of developed countries is affected by foodborne diseases each year, and the problem is likely to be even more widespread in developing countries. The true dimensions of the problem are unknown because most cases of foodborne disease are not reported. This absence of reliable data hinders the effectiveness of public health professionals and food safety regulators. Effective food safety systems are vital to public health, in order to maintain consumer confidence in the food system and provide a sound regulatory founda-

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop tion for domestic and international trade in food, which in turn supports economic development. The emphasis of food safety regulatory agencies must continue to be on prevention, reduction, or elimination of foodborne hazards throughout the food chain. New international trade agreements developed under the auspices of the World Trade Organization (WTO) have shown how necessary it is that regulations governing international trade in foods be based on scientific principles. The Sanitary and Phytosanitary Agreement (SPS), for example, permits countries to take legitimate measures to protect the life and health of consumers, animals, and plants with the provisos that such measures can be justified scientifically and do not unnecessarily impede trade. Food safety is the responsibility of everyone in and along the food chain, from regulators to producers to consumers; however, governments are responsible for providing an enabling institutional and regulatory environment for food control. Traditional food safety systems are no longer sufficient to meet the food safety needs of either the developed or the developing world. The focus of traditional food safety systems has often been on hygiene, inspection, and end-product control. These systems may include food laws and regulations, food control management, inspection and laboratory services, and mechanisms for information, education, and communication. Decision making in traditional systems has often been ad hoc, relying on one or more of the following: precedent; trial and error; expert opinion; compromise; safety assessment; the precautionary principle; professional judgment; inspection; zero tolerance; or ignorance. Much progress has been made with these traditional approaches to food safety problems, but these systems are now inadequate. Among other failings, traditional approaches: do not adequately detect and resolve many current problems; do not effectively deal with the complexity and rapid pace of change; do not effectively integrate science and social values in decision making; and do not address the entire food chain.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop FIGURE 1 Shortcomings of traditional food safety systems. Although traditional food safety systems have been somewhat effective in reducing food hazards in the past, they are unable to detect and resolve many current problems and deal effectively with the full range of complex, persistent, and pervasive challenges confronting different parts of the food chain (see Figure 1). Too many complex, persistent, and pervasive food problems are escaping the traditional systems. Re-emerging and newly emerging pathogens are but examples of these problems. The toll on human health around the globe is unacceptable, all the more so because many of these problems can be addressed.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop PERSISTENT PROBLEMS Traditional systems no longer suffice to solve the world’s food safety problems. The food hazard concerns of virtually all nations include one or more of the following: misuse of food additives, colors, and flavors; veterinary drug residues and use of growth promoters; animal feed additives; fertilizer and growing aids; irradiation; microbiological contamination that is ubiquitous, re-emerging, or newly emerging; mycotoxins and other naturally occurring food toxicants; pesticide residues; pollutants; defective packaging and labeling; adulteration and tampering; or extraneous matter. When these hazards exist within the context of global changes in food production and consumption, the result is a growing number of food safety problems. Production of food on a large scale means that a single mistake can have more extensive and far-reaching consequences than the small-scale production of the past could. Many more people can be affected by a single incident. The desire for more year-round foods means nations must import from new producers who may lack the knowledge about good agricultural practices, good manufacturing practices, and good hygiene practices that exists among nations more experienced with these foods. In the United States more food is being consumed outside the home where consumers have less control over the conditions under which the food is being prepared. Much of this food is being prepared by relatively untrained food workers. A great deal of this food is being prepared in large quantities and served in such institutions as schools, nursing homes, and prisons. Consumers are increasingly interested in more exotic foods and imports. In the United States raw vegetables and fruits, sushi, sashimi, raw shellfish, and other underprocessed foods expose consumers to a greater variety of hazards that can be relatively unknown in the countries where they are eaten. As life expectancies increase and health care improves, there are more immunocompromised consumers than ever. These populations are often more vulnerable to many of the modern food safety hazards. The increasing importance of international trade makes it likely that many of these trends will continue to spread around the world.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop SCIENCE-BASED FOOD SAFETY SYSTEM A number of developing countries are already taking steps to improve and strengthen their systems for food safety management. Several are moving away from the traditional approach focused on end-product control toward a science-based process. Food safety regulators in many countries are already implementing different types of science-based actions and decision making in their day-today work (see Box 1). Science and good data are essential to decision making in a modern food safety system. A science-based approach strengthens the capacity of traditional food safety systems to meet current challenges and improve the availability of safe food for consumers. Scientific evidence can be used to minimize the occurrence of foodborne hazards, to reduce and manage risk, and to improve the outcomes of decision making. A science-based approach enhances the ability of food safety regulators to identify hazards, characterize the nature and extent of those hazards, assess exposure to the identified hazards, and estimate the likelihood of the resulting risks and potential impacts on human health. Risk analysis is an important part of a science-based approach to food safety (see Figure 2). Risk analysis provides a means to strengthen the ability of traditional food safety systems to meet current challenges. It provides a framework to effectively manage, assess, and communicate risks through the cooperation of the diverse stakeholders involved. Most importantly, it aids decision makers and supports decision making with evidence. As a concept a science-based approach to food safety is not completely new. It is related to such processes as good agricultural practices, good hygiene practices, good manufacturing practices, and the Hazard Analysis and Critical Control Point (HACCP) system, which are already used in many countries. What is new is the use of risk analysis as a framework to view and respond to food safety BOX 1 Examples of Science-Based Activities Implementing Hazard Analysis and Critical Control Point (HACCP) systems Establishing acceptable daily intakes for chemical additives in food Estimating maximum allowable exposure levels to pesticides Using labels to warn consumers about potential food allergens Using risk assessment to support food safety regulations and other decision making Establishing product safety standards, performance standards, and specifications for use in international trade Resolving trade disputes based on the WTO Sanitary and Phytosanitary Agreement

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop FIGURE 2 An effective modern food safety system. problems in a systematic, structured, and scientific way in order to enhance the quality of decisionmaking throughout the food chain. A science-based risk analysis framework builds on the traditional systems and creates a need for modern food safety and public health institutions and infrastructures as well as an overall environment that values and supports the risk analysis paradigm. Risk analysis is just one part of an effective food safety system. It will also be necessary to develop and improve other essential components of food safety systems, such as national food safety policies and infrastructure, food legislation and inspection services, laboratories, epidemiological surveillance of foodborne diseases, monitoring systems for chemical and biological contamination, and the update and harmonization of standards. RISK ANALYSIS IS A PARADIGM Risk analysis is more than an activity. It is a way of thinking about things and organizing resources to solve problems. It is a science-based approach to problem solving, but it is more than science. It is the interface between science and the values of an organization or society. It is a paradigm designed to make decisions in the face of uncertainty.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop The Hazard Analysis and Critical Control Point System Dr. A. Djazayery Professor of Nutrition, School of Public Health and Institute of Public Health Research Tehran University of Medical Sciences With traditional methods of food control in food processing plants it has been usual to take a sample of the final product leaving the factory and perform laboratory analyses on this sample. When a bacterial contamination was detected, there was no way to know its source or pinpoint exactly where in the processing line it had occurred. Observation, experience, and controlled research showed that contamination could occur at any stage; from the point at which raw materials entered to the final point of the product leaving the processing plant, including outside exposures to contaminants. The source(s) of contamination in the plant could potentially be raw materials, machinery, equipment, or personnel. Thus, food processors and control experts adopted the Hazard Analysis and Critical Control Point (HACCP) system, which has had wide application and success in other industries. In this system it is possible to detect contamination at its origin (biological, chemical, or physical) and take appropriate remedial action. The HACCP system is different from traditional control methods and can play an effective role in promoting food safety and consequently in food security (i.e., access to sufficient, safe food by the community).1 1   According to the U.S. Department of Agriculture (USDA), “Hazard Analysis and Critical Control Points (HACCP) is a production control system for the food industry. It is a process used to determine the potential danger points in food production and define a strict management system to monitor and manage the system ensuring safe food products for consumers. HACCP is designed to prevent the potential hazards, including: microbiological, chemical, and physical. Juice, meat and poultry, and seafood are regulated at the federal level. Meat and Poultry HACCP systems are regulated by the USDA, and juice and seafood systems are regulated by the FDA.” More information about the HACCP is available at http://www.nal.usda.gov/fsrio/topics/tphaccp.htm and http://vm.cfsan.fda.gov/~lrd/haccp.html.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop The HACCP system is based on the following well-known principles: Analyzing hazards. Identification of potential hazards associated with a food and of measures to control those hazards. Identifying critical control points. These are points in a food’s production (from its raw state through processing and shipping to consumption by the consumer) at which the potential hazard can be controlled or eliminated. Establishing preventive measures with critical limits for each control point. For a cooked food, for example, this could include setting the minimum cooking temperature and the time required to ensure the elimination of any harmful microorganisms. Establishing procedures to monitor the critical control points. Such procedures could include determining how and by whom cooking time and temperature should be monitored. Establishing corrective actions to be taken when monitoring shows that a critical limit has not been met. Examples include reprocessing or disposing of food if the minimum cooking temperature is not met. Establishing procedures to verify that the system is working properly. Examples include testing time-and-temperature-recording devices to verify that a cooking unit is working properly. Establishing effective record keeping for documentation of the HACCP system. This could include records of hazards and their control methods, of the monitoring of safety requirements and the action taken to correct potential problems. Today the HACCP system is being used in many food processing plants worldwide. Over the last decade or so, action has been taken in Iran to introduce the system to food processors (requiring or at least encouraging them to adopt it) as well as to the relevant authorities and personnel in the health, agriculture, and industry sectors, to food standard authorities, and to food legislators. In the development of an HACCP plan, five preliminary tasks need to be accomplished before an HACCP plan can be developed which include assembling the HACCP team, describing the food and its distribution, describing the intended use, developing a flow diagram that describes the process, and verifying the flow diagram. The development of an HACCP plan involves 12 phases as follows: Assembling the HACCP team. HACCP teams consist of individuals who have specific knowledge and expertise appropriate to the product and process. It is the team’s responsibility to develop the HACCP plan. Describing the food and its distribution. This consists of a general description of the food, ingredients, and processing methods. The method of distri-

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop bution should be described along with information on whether the food is to be distributed frozen, refrigerated, or at ambient temperature. Describing the intended use and consumers of the food. Describe the normally expected use of the food. The intended consumers may be the general public or a particular group of the population (e.g., infants, immunocompromized individuals, the elderly). Developing a flow diagram that describes the process. The purpose of a flow diagram is to provide a clear, simple outline of the steps involved in the process. Verifying the flow diagram. The HACCP team should perform an on-site review of the operation to verify the accuracy and completeness of the flow diagram. After these five preliminary tasks have been completed, the seven principles of HACCP are applied. The next seven phases are application of the seven principles described above. The last phase (Phase 12, Principle 7), as described above, is to establish a record-keeping and documentation system. Generally, the records maintained for an HACCP system should include the following: A summary of hazard analysis; HACCP Plan that lists the HACCP team and assigned responsibilities, description of the food, its distribution, intended use and consumer, verified flow diagram, and the HACCP plan summary table. The table should include information on steps in the process that are critical control points, the hazard(s) of concern, critical limits, monitoring, corrective actions, verification procedures and schedule, and record-keeping procedure; Support documentation, such as validation records; and Records that are generated during the operation of the plan. Four basic steps in establishing an HACCP system in food industry in a country are as follows: Preparation of relevant national standards by the food standard agency (general guidelines for HACCP-system establishment in the food industry, plus standards for specific food or food group); Introduction of the HACCP system to food processors and the relevant government authorities and personnel through short training courses, seminars, and workshops; Development of an HACCP plan in a food processing unit as a pilot; this involves the 12 phases (see above); and Implementation, expansion of the system throughout the province or country.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop Implementing and Auditing Hazard Analysis and Critical Control Point Systems and Difficulties in Iran Sassan Rezaie Assistant Professor of Microbiology Tehran University of Medical Sciences As is well known to this audience, the Hazard Analysis and Critical Control Point (HACCP) system is used for food safety and for controlling food processing. I will review the basic aspects of the system that have been widely documented in the scientific literature. I will not attempt to cite the many references that I am sure are well known to our American guests.1 HACCP is usually referred to as a preventive, documented, and verifiable system. It is preventive because it focuses basically on the entire process and not merely on the final product. It is documented because there are procedure manuals as well as work instructions for implementing HACCP and there is also a record-keeping system for control. Finally, HACCP is verifiable because its effectiveness can be checked and verified by such methods as internal audits and final product examination. This preventive, documented, and verifiable system will control food hazards by identifying and characterizing all food hazards from farm to fork, followed by determining critical control points at which a monitoring system for detecting the hazards triggers corrective action. To implement 1   According to the U.S. Department of Agriculture (USDA), “Hazard Analysis and Critical Control Points (HACCP) is a production control system for the food industry. It is a process used to determine the potential danger points in food production and define a strict management system to monitor and manage the system ensuring safe food products for consumers. HACCP is designed to prevent the potential hazards, including: microbiological, chemical, and physical. Juice, meat and poultry, and seafood are regulated at the federal level. Meat and Poultry HACCP systems are regulated by the USDA, and juice and seafood systems are regulated by the FDA.” More information about the HACCP is available at http://www.nal.usda.gov/fsrio/topics/tphaccp.htm and http://vm.cfsan.fda.gov/~lrd/haccp.html.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop and also audit HACCP systems in food processing industries we have three basic requirements as follows: It begins with management requirements that are usually referred to as management responsibilities. The first management requirement is setting a hygiene policy. This is done by top management. This policy will give the organization a hygienic direction. The second management responsibility is the determination of the HACCP system’s scope; this locates the implemented HACCP system in the big picture of “from farm to fork.” The third management responsibility is designating the HACCP team, which is usually selected from the company’s middle managers following the implementation of the HACCP system. The second group of responsibilities concerns the operational prerequisites. These prerequisites are referred to as good manufacturing practice principles as well as hygiene training. The basic aspects involved include the following: Operating conditions for the equipment used in food processing. Rooms in operating facilities should be indicated as clean and unclean areas in food processing and include any cold rooms. Old infrastructures in many companies usually do not meet the requirements for this aspect of the operation and money should be spent on infrastructure renovation in order to separate the clean from the unclean areas. Cleaning and disinfection procedures in processing areas for the general environment as well as for the machinery. Sanitary services and facilities. Drainage. Lighting. Ventilation. Pest control, particularly in geographic areas with warm climates like Iran. This is an important operational prerequisite in HACCP. There are three strategies in pest control: preventing the entrance of pests into the operations area, preventing the nesting and growth of any entered pests in the operations area, and finally killing the insects and pests. Waste disposal. Water supply: in HACCP we always need detailed and precise water analysis data to control the waterborne pathogens and contamination in food processing. Personal hygiene: all workers and operators should have been tested and certified by the Ministry of Health in Iran. In addition, their protective clothes in clean areas should be prescribed by HACCP documents. Hygiene training is a basic requirement in implementing HACCP. To be effective, hygiene training must change or improve hygienic attitude and behavior.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop Other operational steps and requirements for implementing HACCP are as follows: Operational requirements originate from product specifications. The ingredients of food as well as its formulation and all additives with their amount should be determined here. The second step is the process description, drawing a flow diagram and finally confirming it at the operation site. The third step is the first principle of a HACCP system. All potential hazards—biological, chemical, and/or physical—should be classified in three groups: hazards due to raw materials, hazards caused by cross-contamination, and hazards that are resistant to the elimination process during the operation. The fourth step is the second principle of an HACCP system. A critical control point (CCP) is a stage in the process that can be controlled, and controlling it can decrease or eliminate a determined hazard. The fifth step is the third principle of an HACCP system. For each CCP we should have at least one critical limit. The sixth step is installation of monitoring systems for the critical limits at CCPs that will monitor hazards. The seventh step is corrective actions that must be performed when monitoring indicates a deviation from the critical limit of a CCP. The eighth step is verification: this means internal audits plus microbiological, chemical, and/or physical tests of the final product, as well as investigations of customer complaints regarding the product. The ninth step is documentation; documentation should cover all procedures and work instructions in use as well as the recording system. The final step is revision and updating of the HACCP system; this should happen at least once a year and focus on all possible problems that could affect the system.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop The History of Food Safety in Iran M. Ebrahimi Fakhar Food and Drug Deputy, Ministry of Health Based on the 1967 Food Safety Law, each food factory must be approved by the Food Safety Department as to good manufacturing practices (GMPs), good laboratory practices, and generalized system of preferences. Each food factory must employ a food technologist (at the B.S.-degree level or higher) approved by the Food Safety Department. This individual is responsible for quality control in the factory at three levels: quality control of raw materials, quality control of processing, and quality control of the finished product. The food technologist must send monthly reports to the Food Safety Department. In addition, the Food Safety staffs in the provinces periodically inspect food factories and check them by testing random samples. At the distribution level there is a post-marketing surveillance system in order to control finished products in the market. Recently, the Food Safety Department has encouraged food factories to establish Hazard Analysis and Critical Control Point (HACCP) systems and this will become obligatory in the near future. The supervisory administration for food, drink, cosmetics, and sanitary stuffs started teaching HACCP in 1994, in keeping with World Health Organization (WHO) aims. It has promoted and encouraged the development and use of HACCP systems. In recent years many workshops and seminars on GMPs and HACCP systems have been organized by the above-mentioned administration or by medical science universities. WHO tutors and consultants have served as tutors and lecturers. The first food safety meeting and related workshops were held in August 1996. The participants were managers and experts of the Supervisory Administration of Food and Sanitary Stuffs from Iran’s medical science universities. The second meeting was held in November 1996; it was sponsored by Tabriz Univer-

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop sity of Medical Sciences in East Azerbaijan province and lasted for three days. Subsequently, many HACCP workshops were held in 1997 in Bushehr, Fars, Isfahan, Khorasan, Tehran, and Azerbaijan. The supervisory administrations have translated and published papers on hazards and critical control points and, in this respect, the Institute of Standard and Industrial Research of Iran can be said to have published standards of practice (SOPs). To coordinate all food safety programs in different organizations, the Food and Drug Administration of the Ministry of Health established a committee in March 1999 to help plan and harmonize HACCP systems. This committee consists of experts from different responsible organizations and ministries. It meets under the auspices of the Supervisory Administration of Food, Cosmetics, and Sanitary Products. Other organizations from the veterinary and fishery sectors have performed similar work adapting HACCP systems to veterinary and fishery products. This committee started work on food safety through the use of HACCP and tried to replace old control methods with HACCP systems. Exclusive use of HACCP is now mandatory for potentially hazardous products such as dairy and meat. Since 2000 the committee has performed the following main actions: Established committees in provincial universities of medical science for improving HACCP systems; Published various educational pamphlets and sent them to where-ever needed (including provincial committees). These pamphlets include the following: A general guide on HACCP in food industries; National Standard No. 4557. SOPs for hazard analysis and critical control points; National Standard No. 1836. SOPs for the main sanitary principles in food production units; A guide to HACCP system validation; Elementary programs and a revised work sheet for HACCP systems; A hazard analysis and critical control points book; and A checklist of differentiation patterns for HACCP systems based on conventional international methods. Provided a list of the expert consultants and user information at various levels; Trained the nuclear group of the committee; Held workshops for related experts in collaboration with corporate teaching centers, university scientists, and committee teachers; Held a three-day workshop in 2002 on GMP principles taught by WHO consultants; Established a Web site hosted by the Food and Drug Office’s Web site;

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop Developed an HACCP system data bank for users worldwide; Identified HACCP rules, proposals for each foodstuff, and how to determine and validate hazards in food industry systems; Established SOPs for using an HACCP system on pistachios; participated in national Codex Alimentarius committees; developed a proposal for control and screening of pistachio contamination; Established an HACCP SOP system for raisins; Collaborated with the Iran Accreditation System; Prepared a data bank for producer units that could obtain HACCP certificates; Validated HACCP systems in production units and issued the permit for using HACCP certificates on labels or in advertisements; Prepared a checklist for validation of dairy production for GMPs and HACCP; and Established HACCP system certification requirements for the import of processed materials, such as dried milk. Activities of the National Committee for Coordinating and Planning HACCP Implementation, 2000-2004: Number of approvals and administrative actions 94 Number of committee sessions 81 Number of pamphlets 6 Number of established training workshops 49 Number of educated individuals 4,779 Hours of training 784 Number of pamphlets in Persian and English 30 Number of establishments successfully setting up HACCP systems 88 The government of Iran continues to be committed to establishing and implementing appropriate food safety measures, including HACCP systems for various food products. It is hoped that these measures will improve food safety throughout Iran.

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Food Safety and Foodborne Disease Surveillance Systems: Proceedings of An Iranian-American Workshop Discussion Dr. Mohammadreza Razailashkajani Research Center for Gastroenterology and Liver Disease Shaheed Beheshti University of Medical Sciences Panel: Dr. Yoe, Professor Djazayeri, Mr. Ebrahimi Fakhar, Dr. Sassan Rezai, and Dr. Jamdar Mr. Schweitzer asked about the reaction of the Iranian population to government messages on food risks and hazards. Iranian participants noted that this was a poorly developed area of concern. Labeling of fast food in the United States was then the focus of attention. Dr. Jackson said that ingredient content and nutritional information are on the menus of some individual restaurants and fast food chains, but not yet uniformly so. This may become obligatory in the future. A discussion ensued on food labeling and food allergies. Food advertisement regulation in the United States was another issue. Dr. Jackson stated that health claims in food advertisements are regulated. Dr. Djazayeri mentioned that some standards for food advertisements exist in Iran. Dr. Keene was eager to know about the experience of Iranian counterparts with foodborne disease outbreaks, and several Iranian experts responded. Other discussion topics included risk communication, influence of food import executives on food safety legislation in Iran, and high counts of Campylobacter that Research Center for Gastroenterology and Liver Disease researchers had found in some foods compared with the counts found in feces. The last item was believed to be a technical mistake by most experts at this session.

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