Food Import Control Program Ministry of Health

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Food Import Control ProgramMinistry of Health
Dr.Aaisah Senin Food Safety and Quality Division
Ministry of Health MIFT Seminar 26th August 2005
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Content

• Objectives
• Background
• Legal Framework and Obligation
• Infrastructures
• Principles of import control
• Risk Based Approach /Risk Based Inspection

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Ministry of Health Food Import Control Program

• Objectives
• Food Safety and Quality of Imported Food
• Prevent Consumer Deception and Fraudulent
  Practices in sales of food

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Background-What and Why Food Safety

• Availability of safe food improves the health of
  people and is a basic human right
• Safe food contribute to health and productivity
  and platform for development and poverty
  alleviation
• Food and waterborne diseases kill 2.2 million
  people in the developing world every year.
• Diarrhea is the most common symptom of food borne
  illness and other serious consequences are kidney
  and liver failure, brain and neural disorder and
  death
• Long term complications of food borne illness
  include reactive arthritis and paralysis

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Background-CAUSES OF FOOD POISONING

• BACTERIA / TOXIN
• STAPH. AUREUS
• SALMONELLA
• VIBRIO CHOLERA
• CLOSTRIDIUM
• SHIGELLA DLL
• VIRUS
• HEPATITIS A

• CHEMICAL
• PESTICIDES
• HERBICIDES
• HEAVY METAL
• MERCURY
• PLUMBUM
• POISONOUS PLANTS
• MUSHROOM
• ALGAE

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Background-Chemical hazard in food

• Significant source of food borne illness but
  difficult to link
• Can affect health after a single exposure or more
  often after long exposure
• Natural toxin- mycotoxins (aflatoxin) in nuts and
  nuts products)
• Marine toxin Ciguatoxin in fishes
• Environmental contaminants mercury ,lead
  (poisoning), dioxins (carcinogen)
• Food Additive to increase shelf life, cancer
  causing agent and hypersensitivity
• Veterinary drug Nitrofuran in prawns and poultry
  added to increase productivity

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Background-Other Hazards

• Physical low quality of food, choking
• Larvae in chocolate raisins, Conjac jelly,
• New Technology
• Biotechnology enhance the toxicity, allergies,
• Irradiation- alter the genetic makeup

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Legal framework and Obligation

• Food Act 1983 and Regulations 1985
• Section 29 of the Food Act
• Customs prohibition of Import Order Schedule 4-
  All imported food shall require approval from
  FQCD (MOH at entry points)
• WTO Obligation, SPS Agreement- Article 2
• Codex guidelines Codex Committee of Food Import
  and Export Certifications

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World Trade Organisation SPS Measure

• WTO Agreements demand the importance of standards
• Improved assurance of safety in traded goods,
  e.g. food products (health certificates)
• SPS measures are measures needed to ensure that
  food is safe and that pests or diseases of
  animals and plants are not introduced into the
  country.

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The SPS Measure

• Reaffirms countries right to protect health
• Uses Codex Alimentarius Commission standards as a
  basis for decisions to be made in regard to food
  safety

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Legal framework and Obligation

• Proposed Food Import Regulation
• registration of importers and agents, ()
• prior notification of import consignment, (/-)
• electronic notification, (/-)
• inspection, ()
• detention for further action, ()
• rejection , ()
• cost incur on importers, (- )
• sanitary/health certificate, ()
• Bilateral and Mutual Recognition Arrangement
  (MRA) ()
• Equivalence (-)

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LIST OF ENTRY POINTS
Kuala Perlis
Sandakan
Tg. Lembung, Langkawi
Pdg. Besar
Kota Kinabalu
Bkt. Kayu Hitam
Labuan
Pengkalan Hulu
Miri
Pengkalan Kubur
Bintulu
Rantau Panjang
Sibu
Bukit Bunga
Tawau
Kuching
Butterworth
Bayan Lepas, Pel. P. Pinang
Pelabuhan Klang
Sarikei
Kuantan
Tebedu
KLIA
Melaka Tengah
Pasir Gudang
Tanjung Pelepas
Laluan Kedua
Tanjung Puteri
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Physical Infrastructure

• Physical Infrastructures of Entry Points (POE)
• Category of POE workload, shifts duty, scopes
  (full PH functions)
• Inspection Bays- facilitate sampling, based on
  science.
• Detention Facilities with refrigeration
  modalities.
• Bukit Kayu Hitam
• New Approved Sites Rantau Panjang, Pasir
  Gudang, Padang Besar
• Undertaking Procedures for sites with no or
  inadequate inspection bay

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Inspection bay Bukit Kayu Hitam
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Physical Infrastructure

• Accessible laboratories (minilab /use of rapid
  test kit for screening)
• IT infrastructures (enhanced use of FoSIM)
• Inspection Tools (risk based program sampling
  equipment )
• New Infrastructure Development (Pengkalan Hulu,
  Southern gateway- Tg Puteri Bridge, Northern
  gateway- Kota Perdana),

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Infrastructure-Inspection Bay and Warehouse
(Public/Private Owned)

• Suitable for inspection activities at the border
  checkpoint
• Suitable for sampling activity
• Hygiene

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MAIN PAGE
http//fsis.moh.gov.my/fqc/
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Principles of Import Control Program
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Principles of Import Control

• Characteristics of food import control systems
• Prioritize protection of health of consumer and
  fair practices in food trade
• Requirement of imported food consistent with
  domestic foods
• Clearly defined authority for the competent
  authority or authorities
• Clearly defined and transparent legislation and
  operating procedures
• Importing country recognize the food control
  system applied by the exporting countries
  equivalence
• Uniform nationwide implementation

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Principles of Import Control -Documents
Inspection

• Document Inspection
• Provided by the exporting country competent
  authority or Exporter or importer
• Verification of product identity against
  documentary attestation
• Health Certificate from competent authority,
  minimize risk of fraud serial number- stamp
  mark- contain required health status/ product
  conformity with particular standard/status of
  production or licensing details.
• Certificate of analysis accredited laboratory
• Warranty of quality of product from the
  manufacturer

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Electronic document check
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Principles of Import Control Details of the
consignment

• Nature of the product
• Name of Product
• Quantity in appropriate unit
• Lot or date coding
• Manufacturer
• Name and address of importer/ consignee
• Name and address of exporter/ consignor
• Country of dispatch
• Country of destination

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Principles of Import Control Physical Inspection

• Consider the nature of food
• Designated Food- Perishable or Non perishable Raw
  /Fresh/Processed/ Minimally processed
• Type of food packages whole/ in small packages
  - drums, tin, plastics, gunny sacks, glass bottle
  or plastics
• Hygiene condition whole food or packages
  -tear-broken seal-wet /dry-clumping-chipping of
  glass, dented tin, suitable drum, suitable
  packages, lining of packages, colour
• Organoleptic inspection

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Principles of Import Control Physical Inspection

• Label
• ?language
• ?designated names
• ?claim medicinal? Function?
• Information on the importers/exporter
• Expiry dates for food that require expiry date
• ?Nutritional labeling
• Ingredients list ?requirements

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Principles of Import Control Physical Inspection

• Temperature control- Fresh products Vegetables,
  Fruits, Fish and Fish Products
• Chill temperature 2-6 degrees celcius
• Frozen temperature lt18 degrees celcius
• Vehicles hygiene and temperature control

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Look for evidence of melting
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Port Klang Malaysia
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KLIA airport Malaysia
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Principles of Import Control Food Sampling

• Sampling Plan Laboratory capability
• Sampling Techniques Random Sampling
• Microbiological sampling
• Chemical sampling
• Transportation of Samples
• Test Kits

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Principles of Import Control Sampling Techniques

• Regulatory requirements
• Random sampling
• Practicality versus statistical sampling
• Facilities required inspection bay /warehouse
• Sampling equipments checklist
• Test Kits Limitation, Screening methods,
  Specificity and Sensitivity

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Sampling methods
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• Contain Benzoic acid more than 1000 mg/kg

• Labeling offences

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• Containing Sulphur Dioxide non permissible
  preservatives

Biscuit
Chewing gum
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• Imported Longan containing more than 30 mg/kg

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• Imported dried fish containing Lead more than 2
  ppm

• Imported Dried Seaweed containing Lead more than
  2 ppm

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Principles of Import Control -Blacklisting

• Products has history of non conformity to
  requirements pertaining to food safety and
  standard.
• Importer/manufacturer/country blacklisted
• Increase intensity of inspection detain and
  test ,reject, reexport ,reprocess, recondition,
  for animal use only
• Establish database of blacklist item
• Sharing of information with the other border
  check points and the exporting countries

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Principles of Import Control -Food Alert

• Identification of non conformance to requirement
  of regulation pertaining to food safety
• System to take immediate action to protect the
  consumers against health related hazard
• Need to share this information with other
  checkpoints, states and HQ in order to protect
  public health
• May need to share information with other
  stakeholders involve in the food chain and maybe
  consumers depending on the situation.
• May need to share information with the exporting
  country to rectify problem

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Examples of Data collected at border check points

• Consignment details type of food ,food code,
  Food Group, Food Brand, Quantity, Weight/Ton),
  Value,
• Name and address of importer (consignee)
• Name and address of exporter (consignor)
• Name and address of agents /forwarding agents or
  shipper
• Country of dispatch
• Country of Origin
• Place of Sampling
• Analysis requested micro, chemical, physical
• Analytical result and date received
• Offence committed (what section of the
  regulation)
• Any legal action taken and types of actions

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Risk Based Inspection New Approach in
enforcement
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Important Considerations

• Risk of imported food products
• nature of food
• Raw or processed
• Perishables or non perishables
• presence of a hazard,
• Inherent risk
• Risk resulting from processes
• or intended to prolong shelf life
• concentration of a hazard
• Exposure assessment food consumption
• Exceeding regulatory requirement or Appropriate
  Level of Protection
• the handling condition the food is subjected

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Benefits

• Inspection of imported food , based on the risk
  to human health presented by the products
• Focus resources on those products presenting the
  greatest potential risk of public health to
  consumers
• Categorize the food into different risk
  categories with intensity of inspection
  proportionate to the risk
• Use various forms of assurance of compliance e.g.
  certification, system audits, equivalence
  determinations to allow further assurance to the
  level of risk and hence the intensity of the
  inspection

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To start using risk based inspection

• Need Data and information ,risk analysis approach
  /risk based approach/ evidence based
• Local data blacklists item, violation data
  either imported food or local food, food borne
  disease surveillance, contaminant and residue
  information
• Regional Data Similarity in food consumption
  data, cultures, epidemiological data
• International Data- Codex, advanced countries

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How to establish risk category

• based on the assessed risk to human health the
  food presents or is likely to present based on
  available scientific information in relation to
  the consumption of the food
• Evidence based approach
• Scientifically demonstrated ability of the food
  product to present public health risks
• Use internationally accepted scientific risk
  assessments for biological, chemical and physical
  hazards associated with the type of products
• food borne illness outbreak and epidemiological
  findings/history,
• contaminant and residue information

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How to establish risk category - continued

• Adequacy of processing controls in the exporting
  countries
• countrys laws, regulations,
• its infrastructures,
• ability to effectively enforce food safety
  requirements- laboratory sampling program and
  results and audits
• Compliance history of the food product
• Compliance history of food with respect to source
  of the food incl.
• exporting countries
• Producer or manufacturer
• Exporter
• Shipper
• Agents/Importers
• Should be periodically reviewed

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How often?

• Intensity of inspection of specific food
• should be correlated with its risk category
• should consider the compliance history of
  exporting countries, manufacturer, agents and
  importers, food control system in the exporting
  countries.
• May be increase if no prior knowledge a product
  (new products)

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How often do you check?

• reduced if conform demonstrated by audit checks
  or border checks
• Place in higher risk categories/ intensity of
  inspection if
• food borne illness outbreak,
• epidemiological findings,
• non compliance at entry points
• detection of pathogens, contaminants, residues
  until corrective measures introduced and
  implemented by the exporting countries

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What else do you need to consider

• Sampling plans based on risk categories
• Follow appropriate inspection procedures,
• Follow appropriate sampling techniques,
• Competent laboratories using validated analytical
  methods
• consistent not result in trade barrier and
  unnecessary delays
• Requirements used at border should be harmonize
  with similar products in the domestic market
• Transparency ,up to date information about all
  procedures

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Implications of RBI

• Strengthening National Food Import Surveillance
  Program
• Risk Based Inspections and Sampling
• Risks Categories of Food Commodities and Types- 6
  Levels of Examinations ,Process criteria
  development , Development of Assigned risks to
  food commodity (risk ranking) based on risk
  analysis.
• Risk Based Inspection- focus resources to high
  risks food
• Sampling based on science vs. Statistically
  Validated Scientific Sampling
• Surveillance of Trading partners Countries Export
  Programme
• Strengthening Food Alert Surveillance
  Domestic/Global

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Malaysias Risk category

• Level 1 Automatic Clearance for specific food
  items subjected to equivalent determination with
  an exporting country under MRA or bilateral
  agreement.
• Level 2 Document Inspection 100 of the
  documents submitted should be inspected
• Level 3- Monitoring Subject to type of Border
  (land 70,sea- 35, air-40) and 10 taken for
  sample out of the physical inspection done. Will
  be subjected to changes in future according to
  risk the food present to public health

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Dynamic Risk (Managed risk) Categories vs. Static
Food Item category

• Level 4 Surveillance High risk food usually
  had history of violation in the past but has
  passed the detention testing but still pose a
  risk
• Level 5- Hold Test and Release Deemed to be
  high risk from history of violation or rejection
  data and food alert from another port or another
  country. 3 consecutive detention of different
  consignment should be negative before level drop
  to level 4.
• Level 6 Automatic Rejection Banned Item e.g.
  Avian Flu, BSE, Frequent violations

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Registration of Importers/Agents
Pre-Import Notification
Arrival of Consignment
Custom Notification K1
Inspection Level
LEVEL 1 AUTO CLEARANCE
LEVEL 2 DOCUMENT EXAMINATION
LEVEL 3 MONITORING EXAMINATION
LEVEL 4 SURVEILLANCE EXAMINATION
LEVEL 5 HOLD TEST RELEASE
LEVEL 6 AUTO REJECTION
Inspection Action
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Level 3 Monitoring
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Level 3 - Monitoring
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• Food Alert and Rapid Alert System of Imported
  Food
• System allows MOH to determine types of
  management options for entry points/districts
• Level of Examination
• Alert state and districts on food safety concern
  for further action
• Facilitate Recall Procedures
• Format
• Exchange of Information between countries.

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FOOD ALERT ISSUED BY FOOD SAFETY AND QUALITY
DIVISION
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• Electronic system of food import control FoSIM
  (Food Information System of Malaysia)
• Incorporate Principles of integrity,
  traceability, risk based, transparency and audit
  trail.
• Strengthen the risk based content development
• Managed risks and inherent risk
• Risk based inspection
• Strengthen coding management
• Parameter analysis coding management (gt30,000
  codes)
• Food Codes Management
• FoSIM infrastructure
• Improve connectivity and sustainability of
  infrastructure converting to IPVPN for 14 sites
  and Streamyx for the low utilisation sites.
• Hardwares replace old JICA PC
• Maintenace tender process
• Application enhancement
• Extension to FoSIM Domestic ( 2.5 million
  excluding network under RM9)

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Data on Consignments inspection
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Violation Data for Imported Food 1999- 2004
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Thank You