Risk Ranking Moving towards a Risk-Based Inspection and Surveillance System

THE NEED FOR A RISK-BASED FOOD INSPECTION AND SURVEILLANCE SYSTEM

A report by the Food and Agriculture Organization of the United Nations (FAO) and the World Trade Organization (WTO) stated that the annual value of trade in agricultural products has grown almost threefold over the past decade, largely in emerging economies and developing countries, reaching US$1.7 trillion (FAO/WTO, 2017). Countries worldwide have also experienced an exponential increase of small-scale farming operations and micro and small food processing and distribution enterprises (formal and informal) in urban areas in response to the fast population growth and consumer demands for locally produced food (Cabannes and Marocchino, 2018). A special case is the growth of artisanal and family-owned cheese-making businesses that have emerged as a result of demands for artisanal dairy products and local economic incentives (see for example the case of Mexico and Brazil in Gonzalez-Cordova et al., 2016 and Campagnollo et al., 2018, respectively).

It is common to find food safety regulatory agencies struggling to fulfill their routine inspection duties as budgets and work force reduce and small- size establishments and street vendors increase. In addition, inspection activities are often reactive (i.e., respond to specific food safety incidents), based on out-of-date regulations and on a fragmented and weak public health reporting system, making it difficult to identify which foods and hazards pose the highest risk to consumers (Jaffee et al., 2019). As a result, the use of resources is inefficient and often does not address the most critical food safety risks, failing to protect public health (Jaffee et al., 2019).

The current challenges faced by regulatory agencies require a modern and risk-based food inspection and surveillance system that is able to identify the products and establishments that pose the greatest public health risk so that they can be targeted and inspected more frequently (FAO, 2008). Such a risk-based system must be rooted in the risk analysis principles defined by the Codex (CAC, 1997) and can be achieved by using risk ranking approaches to better guide food safety control activities in the country.

IDENTIFYING FOOD SAFETY RISKS: RISK RANKING

Risk analysis (assessment, management and communication) has emerged as the foundation for developing food safety systems and policies around the world (Hoffman, 2010). The implementation of risk analysis at the country level requires that governments conduct the following steps (adapted from CAC, 2007): 1) identify public health objectives and establish a risk management plan with measurable metrics; 2) identify and prioritize the main food safety risks; 3) allocate resources to collect data relevant to the identified risks or to conduct a risk assessment; 4) analyze and select intervention strategies for implementation; 5) design and implement an intervention plan; and 6) monitor and review the plan to evaluate whether the interventions met the public health objectives.

A common situation encountered by countries when embarking on the implementation of risk analysis is the lack of knowledge of their main food safety risks. Identifying such risks remains the logical place to start thinking about the most effective measures to reduce public health risk (Hoffman, 2010). Food safety risks can lead towards the implementation of risk analysis (i.e., conducting a risk assessment, developing a risk- based inspection and generating a risk communication plan). Conversely, advances in risk analysis have mostly centered around quantitative risk assessment methodology for single food product-pathogen pairs, missing an important aspect of identifying the food safety risks (Newsome et al., 2009). This has resulted in a lack of adequate methodology for risk ranking or at least, national food safety authorities not giving it adequate attention until recently (Hoffman, 2010; Speybroeck et al., 2015).

Food safety risk ranking involves systemically identifying what hazards (mainly biological and chemical) and/or food products pose the greatest risk to public health. Risk ranking is the first step towards prioritization of future risk management decisions, where the ranking based on public health risks is taken into consideration along with other relevant factors (e.g., economic impact, feasibility, and consumer perception) for decision making (FAO, 2017). In decision-making prioritization, all these factors as well as public health are integrated to identify food safety priorities for the country to take action in a way that is structured, transparent and provides national food safety authorities with the basis for making objective and evidence-based decisions on how to better allocate their resources (FAO, 2017). Risk ranking can be used to (EFSA, 2012a; Stella et al., 2013; van der Fels-Klerx et al., 2018):

  • • Identify food safety issues that have the highest public health impact
  • • Develop a risk-based disease and hazard surveillance program
  • • Develop a risk-based food inspection program
  • • Identify research and data needs
  • • Develop a risk communication plan targeted to the most significant food safety risks

Risk ranking and prioritization terms have been used interchangeably, but it is important to differentiate them. According to FAO (2017), "risk ranking is the systematic analysis and ordering of foodborne hazards and/or foods in terms of the likelihood and severity of adverse impacts on human health in a target population". Risk ranking is a primary consideration (public health) in the prioritization of risk management decisions, but other types of impact are also considered in prioritization, such as social, economic, and political consequences. Examples can include pressing public or political demands, trade restrictions, reduced revenue from exports and significant impacts on the vulnerable.

Recent review publications have highlighted the need for a harmonized framework for food safety risk ranking (EFSA, 2012a; Mangen et al., 2010; van der Fels-Klerx et al., 2018). A recent survey also stressed the need for more formal training in risk ranking and case-studies among decision makers and stakeholders (Speybroeck et al., 2015). A range of risk ranking (based only on public health) methods have been applied to address a variety of food safety scenarios (Table 2.1). Some of the studies also included prioritization of interventions.

The next section in this chapter will cover the general framework for conducting a risk ranking exercise.

RISK RANKING FRAMEWORK

There is no internationally recognized framework to rank foodborne risks; however, the European Food Safety Authority (EFSA) (2012a) and an FAO expert panel of risk assessors (FAO, unpublished) have proposed a series of steps to objectively and systematically rank microbial and chemical risks in food, which are described in the following. Figure 2.1 illustrates the seven steps, which will be discussed in detail.

Defining the Scope

Risk ranking can be overwhelming when the number of foods and/or hazards is too large for it to be feasible (EFSA, 2012a). The scope should be defined by the risk managers and decision makers and should include the goals for risk ranking. Defining the scope is a critical step that will

Table 2.1 Risk Ranking Methods Used in Food Safety

Type of Hazards

Topic

Approach

Reference

Biological

Foodborne

pathogens

Ranking

Cardoen et al., 2009; Batz et al., 2012; Devleesschauwer et al., 2017; Felicio et al., 2015; Stella et al., 2013

Bioterrorism

threats

Ranking and prioritization

Ranking

FAO/WHO, 2014; Robertson et al., 2015

Tomuzia et al., 2013

Chemical

All chemicals

Ranking

Langerholc et al., 2018; Stroheker et al., 2017; van Asselt et al., 2018a,b; Vromman et al., 2014

Veterinary drug residues

Pesticides

Ranking and prioritization

Ranking

Ranking

Felter et al., 2009; Papadopoulos et al., 2015

FDA, 2015; van Asselt et al., 2013

Chou et al., 2019; Labite and Cummins, 2012; Melnyk et al., 2016; Nougadere et al., 2011; Tsaboula et al., 2016

Heavy metals

Ranking

Groth, 2010

guide all risk ranking activities, from identifying the applicable foods and hazards to choosing the risk ranking approach. Risk ranking is rooted in the basic definition of risk by the Codex Alimentarius as the probability of an adverse health effect, and the severity of that effect, consequential to a hazard(s) in food (CAC, 1999). Risk managers are usually interested in the highest-risk outcomes (hazard-food pair combinations that are both severe and likely to occur), and that is generally the scope of risk ranking. Risk ranking focuses on one of three levels: ranking foods (single hazard in multiple foods), ranking hazards (multiple hazards in a single food), or a combined ranking of foods and hazards (multiple hazards in multiple foods). The broader the scope, the more resources and data are needed to complete the risk ranking exercise.

The use of a food classification system whereby food products (products that share similar composition and production characteristics) are grouped into a single food category (e.g., fresh chicken parts) has been

Risk ranking framework

Figure 2.1 Risk ranking framework. (Adapted from EFSA (2012a, Scientific opinion on the development of a risk ranking framework on biological hazards) and FAO, Preliminary Guide to Ranking Food Safety Risks at the National Level, Rome, forthcoming.)

proposed as a reasonable approach to simplify and reduce the burden of the ranking (EFSA, 2012a). In other instances, the food categorization scheme used to collect data on food consumption or to categorize food production establishments could be used. Examples of food categories can be found in EFSA (2011), FDA (2012) and Richardson et al. (2017). The choice of how to categorize the foods will need to be compatible with the initial goal of the risk ranking as defined by the risk managers and should follow a common set of principles as described by Morgan et al. (2000) and summarized in Table 2.2.

Identifying the hazards of concern is also a critical task when defining the scope. Using the national food safety regulations (e.g., microbiological criteria) to identify potential hazards as the only data source may not be comprehensive when regulations are not up to date with the current

Table 2.2 Desirable Attributes for an Ideal Risk Ranking Categorization System

Attribute

Description

Logically Consistent

  • • Exhaustive so that no relevant risks are overlooked.
  • • Mutually exclusive so that risks are not double-counted.
  • • Flomogeneous so that all risk categories can be evaluated on the same set of attributes.

Administratively

Compatible

  • • Compatible with existing organizational structures and legislative mandates so that lines of authority are clear and management actions at cross purposes are avoided.
  • • Relevant to management so that risk priorities can be mapped into risk management actions.
  • • Large enough in number so that regulatory attention can be finely targeted, with a minimum of interpretation by agency staff.
  • • Compatible with existing databases, to make best use of available information in any analysis leading to ranking.

Equitable

• Fairly drawn so that the interests of various stakeholders, including the general public, are balanced.

Compatible with Cognitive Constraints and Biases

  • • Chosen with an awareness of inevitable framing biases.
  • • Simple and compatible with people's existing mental models so that risk categories are easy to communicate.
  • • Few enough in number so that the ranking task is tractable.
  • • Free of the "lamp-post" effect, in which better- understood risks are categorized more finely than less well-understood risks.

From FAO Guidance forthcoming and adapted from Morgan, M.G. et al., Risk Anal. 20,49-58,2000.

scientific knowledge. Risk managers should seek additional sources of data, which may include published literature, national outbreak data, the WHO's global burden of foodborne diseases (WHO, 2015), international food standards such as the Codex Alimentarius, food recall databases such as the European Commission's Rapid Alert System for Food and Feed (RASFF) and the FDA's Reportable Food Registry for Industry, and expert committee sources such as the International Commission for Microbiological Specifications in Food (ICMSF), the National Advisory Committee on Microbiological Criteria for Foods (NACMCF) and EFSA expert panel scientific opinions.

 
Source
< Prev   CONTENTS   Source   Next >