Commission decides to initiate new work Proposed draft standard prepared Written comments Session: discussion/amendments Adoption as a draft standard Written comments Session: discussion/amendments Adoption by the Commission 1 2 3 4 5 6 7 8 Possible Omission
Benefits and weaknesses of the procedures General: possibility to comment at all stages of the process prior to –the committees (Step 3 and 6) and the Commission (Steps 5 and 8): inclusiveness and transparency –Issue: possible length of the process – management of large quantity of comments submitted shortly before the Committee Decision to initiate new work –Criteria –project document -coordination of the overall programme of work in the Executive Committee –possible issue: rigidity of the process, need for approval even for limited amendments –however, this is for decision by the Commission
Benefits and weaknesses of the procedures Food safety: structured risk analysis process based risk analysis principles and policies to ensure the scientific basis of standards: –Working Principles for Risk Analysis (general) and specific principles: pesticides, additives/ contaminants, veterinary drugs, food hygiene Issues: ensuring the continuity of the scientific advice, addressing emerging issues – how scientific advice is used by risk managers
Concerns: delays in the process The procedure allows standards to be developed very rapidly: example: the large majority of MRLs for pesticide residues are developed in one year. Main issues are not related to the procedure but rather to other aspects: –Lack of consensus –Use of risk assessment (from expert committees) by risk managers (committees): lack of clarity, delays due to further request for advice –Endorsement by general committees (additives, labelling): standards referred back to the originating committee
Questions under consideration How to proceed when Standards and related texts are held at Step 8 (currently 2 MRLs for veterinary drugs are held at Step 8) Consideration of statements of economic impact (currently the Elaboration Procedures includes a general reference in this respect) Next session of the Committee on General Principles : April 2012 Risk Analysis Principles applied by the Committee on Pesticide Residues (revision)
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