CONSCIOUSLY INSUFFICIENT
PROTECTION OF CONSUMER AGAINST FOODBORNE DISEASE PATHOGENS: international
policy admitting them in food of animal origin !
(to be elaborated)
V. Kouba
Formerly: Animal Health Officer
(Research and Education), Animal Health Officer (Veterinary Intelligence), Senior
Officer (Veterinary Services) and Chief, Animal Health Service, Food and
Agriculture Organization of the United Nations; Editor-in-Chief, FAO/WHO/OIE
Animal Health Yearbook; Informatics Expert, OIE; Czechoslovak and Czech Chief
Epizootiologist; Professor of Epizootiology,
Table of Contents
Introduction
1. “Foodborne disease pathogens-free food” = unknown term in relevant international documents (WTO/SPS, FAO/WHO CODEX Alimentarius, OIE Code, etc.) to “facilitate trade”; importing country cannot refuse to import food having not full sanitary guarantee without presenting to exporting country convincing scientifically justified “risk assessment”
2. The international documents do not respect the health of consumers and their opinions = bureaucratic dictate favouring exporting countries
3. The international documents deliberately do not require any guarantee that traded food is free of pathogens transmissible to man = mass spreading/globalization of foodborne diseases (deterrent example: EU provisions for food free circulation without any sanitary documents on pathogens-free quality !)
4. The international documents do not require any active etiological sanitary investigations in herds/flocks where the food chain starts = missing knowledge of real sanitary quality = support of foodborne disease export and spread
5. The international documents do not require obligatory foodborne disease microbiological investigations of food (incl. raw material for food) for export = missing full sanitary guarantee (ad hoc investigations, if any, are far from being representative, i.e. not presenting at all sanitary reality)
6. The international documents do not require medical tests of personnel processing food to eliminate pathogen-carriers from contaminating the foodstuff
7. The international documents do not require full guarantee that private professionals and laboratories, investigating food and issuing sanitary documents, are properly trained and tested as well as fully objective, i.e. independent on producers, processors and exporters
8. The international documents do not require at all official guarantee documents on foodborne disease pathogen-free status (exceptionally replacing them by legally not-biding “certificates” or simply without any sanitary documents) = food without full sanitary quality = support of foodborne disease export and spread
9. Zero or minimal (mostly formal = papers without seeing the commodity) government inspection of food of animal origin and zero or ineffective field control of foodborne diseases by private service = support of foodborne disease export and spread
10. Zero or minimal government food sanitary control facilitating maximal profit of traders at the expense of consumers’ health; the “sanitary” control is let to non- qualified and non-competent producers and exporters; government animal health services are usually excluded from controlling the food chain not to complicate the trade.
11. Deliberate over-appraisal of HACCP (avoiding only secondary contaminations but not filtering foodborne disease pathogens coming from original herds/flocks) to suppress artificially the requirement for effective health/diseases controls of food producing animal populations at the field level
12. The international documents deliberately do not require labelling food of animal origin to inform consumers on true sanitary quality (full or not) = conscious concealment of sanitary reality cheating the consumers who need to know the truth about foodborne disease pathogen status
13. The international information systems deliberately do not collect data on real foodborne diseases’ situation in food exporting countries = concealment of sanitary reality facilitating foodborne disease pathogens export and spread
14. OIE Code – consciously missing import sanitary conditions for food of animal origin (meat, milk, eggs, etc.) = support of foodborne disease export and spread (“fit for human consumption” is not any sanitary guaranty)
15. WTO and OIE artificial absurd obstacles for refusing import of food without the guarantee of pathogen-free status = support of foodborne disease export and spread
16. Perverse international anti-sanitary concept “import risk analysis is preferable to a zero risk approach” (OIE Code) = risky food export regardless of consumers’ health in importing countries
17. Unacceptable opinion “it is impossible to obtain salmonella-free foods of animal origin” = support of salmonellosis spreading and its globalization through trade
18. The international documents admitting the export of non-pathogen-free food of animal origin = lost of motivation for foodborne disease control and eradication in exporting countries being anyway paid by importing countries as for innocuous (healthy = pathogen-free) commodities = internationally organized trick and mass robbery
19. The international documents deliberately admitting the supply of consumers by sanitary harmful food of animal origin – official nonsense quantitative norms of foodborne disease pathogens in food applying the abused “risk assessment”, i.e. trade in non-pathogen-free food = support of foodborne disease spreading
20. The international policy deliberately avoiding consumer opinion objective survey if they accept consciously and voluntarily non-pathogen-free food
21. The international policy deliberately avoiding effective and practical international (global) reporting system on foodborne disease occurrence and their export/import to conceal the truth about catastrophic impact on human health from the governments and consumers
22. The international policy consciously not requiring necessary reinforcement of government mechanism and staff for effective foodborne diseases’ control and consistent systematic objective inspection of food of animal origin (no punishable and almost non-controllable private services and exporters are very often unreliable and susceptible to corruption)
23. The international documents deliberately do not require any information of the consumers on the sanitary status of foodstuffs – to “facilitate trade” (!?)
24. The international documents deliberately do not require effective sanitary control of food of animal origin imported from “third countries” – re-export
25. Exaggerated liberalization of food of animal origin export oriented at highest possible profit at the expense of consumers’ health in importing countries = liberalization of foodborne disease pathogens export and spread
26. Bureaucracy, formalism, demagogy and theory/philosophy isolated from practice combined with “mountains” of papers (instructions) produced by relevant above mentioned organizations not requiring at all the full protection of consumers’ health against foodborne disease pathogens
27. Countries with minimal number of government veterinarians, not only in poor developing countries, after drastic privatization are practically defenceless against the import of foodborne disease pathogens
28. The international documents supporting openly anti-human priority of traders in food of animal origin = maximal possible profit at the detriment of importing country consumers’ health
29. Main natural motivation of private sector is the profit (the ethics is only theoretical) and not the protection of consumers’ health
30. OIE, WTO/SPS, FAO/WHO
31. OIE document even threatens importing countries: “zero risk importation policy would require the total exclusion of all imports”(!?!) = to exclude from international trade the importing countries requiring pathogen-free food of animal origin
32. The international organizations do not require effective sanitary control of the whole food chain “from stable to table” = “facilitating trade” through the export of animal commodities regardless of foodborne disease pathogens
33. Globalization of foodborne diseases through international trade is consciously organized by international organizations (OIE, WTO, etc.) not respecting even the basic principles of international trade applied currently in any other commodities
34. Infinite number of international meetings, documents, declarations, programmes, trainings, “mountains” of papers, etc. (enormous number of persons-bureaucrats involved) on consumer health protection however without any critical analysis of foodborne disease pathogen spreading through trade and without any effective actions to avoid it (theoretical words on risk only instead of practical measures) and mainly based on subjective non-measurable “pathogen introduction risk assessment” based on speculations and estimates
35. Instead to declare as the basic concept the food of animal origin to be free of foodborne disease pathogens and any deviation as the exception (its risk assessment to be convincingly justified), above mentioned international organizations declare exactly the opposite principle = declaring as the basic concept the food of animal origin to be not free of foodborne disease pathogens and any requirement for full sanitary quality to be based on scientifically convincingly justified risk assessment (??). (The “duty” of scientific justification of the import of sanitary innocuous food is an absurd requirement unknown in the history of international trade).
36. Conscious and organized international spreading of foodborne disease
pathogens = crime against humanity
37. Conclusions
38. References
39. Annexes
a) Warning letter sent to UN Secretary
General on