Wednesday, June 3, 2020

Evaluating National Food Control System of Nepal: Part 1

Please read the first post before reading this post.

In this post we will try to use the FAO tool to evaluate the National Food Control System of Nepal. The evaluation will be done in four dimensions:

Dimension A: Are system resources and inputs adequate?
Dimension B: How do the controls function?
Dimension C: How does the system interact with stakeholders?
Dimension D: Is the system evidence based ? Does it support continuous improvements?

In this first part, we will only evaluate the first dimension A: Are system resources and inputs adequate?”


food control system evaluation dimension A
 (Source: FAO/WHO, 2019)
The dimension A of the evaluation focuses on mapping the fundamental elements required for the system. Basically, it focuses on legal and policy instruments, institutional frameworks, financial aspects, equipments, infrastructure and human resources etc.

We are going to use following qualitative scoring scale during evaluation:
1 = Absent
2 = Insufficient
3 = Basic requirements exist
4 = All requirements exist
5 = Exceeds the requirement

(Please note that CA has been used frequently as a short form for “Competent Authority”)
S.N.
Criteria
Score
A
INPUTS AND RESOURCES

A.1
POLICY AND LEGAL FRAMEWORKS




A.1.1
Policy and legal drafting process: The policy framework and legal drafting processes allow the legislation of the country to be of high quality, fit for purpose and transparent

A1.1.1
Clear policy guidance is available for food safety and quality
3
A1.1.2
Food control strategic plans are prepared by Competent Authorities (CAs) and translate into action the overarching objectives set out in the food safety and quality policy
2
A1.1.3
Food safety and quality policy and legislation are developed on the basis of written principles and procedures that enable comprehensive and participatory processes and ensure “fit for purpose” results
2
A1.1.4
Legislation recognizes the stakeholders’ right to have access to information on food control measures (including sanitary and quality requirements) and includes provisions on publicizing them
2
A1.1.5
Legislation is unambiguous, and allows for evolution over time
2
A1.1.6
CAs make decisions in a consistent and impartial manner and are free of improper or undue influence or conflicts of interest
2



A.1.2
Institutional framework: The distribution of powers and responsibilities as well as the coordination mechanism among competent authorities enable an effective and efficient institutional framework for food control

A1.2.1
Mandates of CAs involved in food control, at central and decentralized levels, are clearly defined in legislation and ensure an efficient distribution of roles and responsibilities among CAs, over the entire food chain
1
A1.2.2
A formal communication mechanism is in place between CAs and other stakeholders involved in food control, to exchange relevant information over the entire food chain, from primary production to human health
2
A1.2.3
Legislation includes coordination mechanisms that enable CAs to develop a common vision of food control, to facilitate multi-sectoral planning and implementation of food control measures, and to promote communication
2
A1.2.4
Legislation provides the CAs with all the necessary powers and responsibilities to implement the law, within their mandate
3
A1.2.5
If appropriate, legislation allows the CAs to delegate some functions to other public or private entities
1
A.1.2.6
Legislation provides designated officials with the necessary authority to carry out their mandates, and sets sufficient safeguards to prevent abuse of power
3
A.1.2.7
Legislation provides an array of effective enforcement provisions as well as the right to appeal decisions made by the CAs
2



A.1.3
Elements for food control legislation: Legislation provides all the technical provisions necessary to implement food control activities and achieve the overarching objectives set in the food safety and quality policy

A.1.3.1
National legislation recognizes the primary responsibility of food business operators (FBOs) for food safety and quality and lays out their specific obligations, including placing only safe food on the market and recalling products that do not meet the prescribed standards
1
A.1.3.2
Food control legislation applies to all steps of the food chain in a coherent and coordinated manner
1
A.1.3.3
The definitions used in food control legislation are clear, unambiguous and consistent with internationally recognized standards (e.g. Codex Alimentarius)
2
A.1.3.4
Legislation introduces the principle of risk analysis and this is used as a basis for establishing food safety measures
1
A.1.3.5
Legislation includes provision for inspection, monitoring and control of the food supply for hazards
3
A.1.3.6
Legislation includes provisions for setting import requirements
3
A.1.3.7
Legislation includes a mechanism that enables CAs to identify all FBOs throughout the food chain
2
A.1.3.8
National food standards, regulations and guidelines provide an appropriate foundation for food control, and these are based on Codex or other international reference standards
2
A.1.3.9
Legislation includes an obligation to ensure food traceability from farm to fork
1
A.1.3.10
Legislation includes a provision for a rapid alert system, emergency preparedness and response
1
A.1.3.11
Legislation contains requirements for food packaging, labelling and advertising
2
A.1.3.12
Legislation includes provisions for surveillance of priority FBDs, guided by the food safety and quality policy
2



A.2
INFRASTRUCTURE AND FINANCE

A.2.1
Financial resources: Sufficient budget is secured to implement the strategic food control plan at all levels of government and to respond to food safety emergencies and events

A.2.1.1
Preparation of budget allocations for CAs is carried out in a participatory and transparent manner that reflects a strategic plan for food control at national and sub national levels.
1
A.2.1.2
CAs can easily access the allocated funds, including any recovery of fees, commensurate with the controls to be carried out as per the strategic plan
2
A.2.1.3
An analysis of the cost of the relevant scientific services has been reflected in budget allocations
3
A.2.1.4
The financial resources required to hire, pay and retain sufficient and skilled staff are secured and accounted for in financial planning and budgeting
3
A.2.1.5
Training and ongoing development of food control staff is financially secured in CAs’ budgets
2
A.2.1.6
The financial resources required to purchase, renew and maintain essential infrastructure and equipment (office, logistic, transportation, IT, etc.) are financially secured in CAs’ budgets
3
A.2.1.7
Funding for the sampling activities related to monitoring of priority food safety risks, as well as human health surveillance relevant to FBDs, is financially secured in the CAs’ budgets
2
A.2.1.8
In the event of a national food-related emergency, there is sufficient and realistic financial allocation secured in the budgets to support the mobilization of the national emergency plan
2


A.2.1.9
Staff preparation for, and attendance at, selected international scientific and policy-makers’ meetings and conferences relevant for food safety and quality is financially secured in the CAs’ budgets
1
A.2.1.10
Post-expenditure audit of the budget and review of management performance in relation to the budgetary expenditure are performed
3



A.2.2
Infrastructure and equipment: Suitable and sufficient infrastructure and equipment are available for CAs to perform their work effectively and according to the strategic food control plan

A.2.2.1
Food control services are provided with suitable accommodation and with special facilities at all locations where official food control work is carried out
2
A.2.2.2
There are suitable and sufficient vehicular assets adequately maintained for the implementation of the food control programme by CAs
2
A.2.2.3
There is an IT system in place for recording, analysing and sharing the data collected during food controls and surveillance of FBDs
1
A.2.2.4
Staff operating inspection, monitoring and surveillance activities have access to reliable modern technologies for rapid communications in central and local offices
2
A.2.2.5
Suitable sampling equipment, space and facilities (such as temperature-controlled storage and infrastructure for transportation of samples to laboratories), are provided for monitoring or surveillance activities
2



A.2.3
Analytical resources: Suitable and sufficient analytical services are available and accessible by CAs to carry out the analyses required by the food control system.

A.2.3.1
CAs and laboratories work jointly to plan the analytical workload for servicing routine inspections, sampling programmes for monitoring of priority food safety risks, FBD surveillance and other scientific related activities
2
A.2.3.2
The laboratory capacities meet the country’s strategic analytical needs with appropriate geographical coverage across the country, including for import and export
2
A.2.3.3
The national system of laboratories has sufficient technical capabilities to address priority hazards and quality parameters for food analysis, and the analysis of clinical samples for detection of FBDs
3
A.2.3.4
In case of a food safety emergency, food control laboratories have the capabilities and versatility to adapt to the resulting changes/surges in demand of tests to be performed
2
A.2.3.5
Codex and other official recommended methods of analysis and sampling are implemented
3
A.2.3.6
Laboratories are following Good Laboratory Practices and have quality management systems in place
3
A.2.3.7
Designated food control laboratories are accredited ISO 17025 (testing laboratories) and ISO 15189 (clinical laboratories) by internationally recognized bodies
3



A.3
HUMAN RESOURCES

A.3.1
Qualification of personnel: CAs implement a systematic approach to ensure they have access to suitably qualified personnel in sufficient numbers

A.3.1.1
A duty is placed upon the State to ensure that CAs have access to sufficient and suitably skilled personnel with adequate qualifications and ability
3
A.3.1.2
CAs have clear internal policy guidelines addressing the prerequisite qualifications for the various employees supporting food control activities
3
A.3.1.3
CAs base recruitment on clear job descriptions and transparent processes
2
A.3.1.4
The prescribed requirement for properly qualified staff also extends to the professional employees of agencies engaged by CAs
3



A.3.2
Capacity development of personnel: CAs have clear and comprehensive capacity development programmes in place to ensure staff can carry out the necessary range of food controls

A.3.2.1
Newly recruited staff are provided with formal orientation courses, allowing them to enter on duty in an effective manner
2
A.3.2.2
CAs encourage active exchange of knowledge and skills among staff
2
A.3.2.3
CAs supply or facilitate periodic update training events for staff with responsibilities in food control
2
A.3.2.4
CAs actively facilitate continuing professional development of food control staff, at both central and remote locations
2
A.3.2.5
CAs have an internal policy to conduct internal review of the capacity development needs of the staff at all levels within the workplace, at both central and remote locations
2



A.3.3
Staff management & staff motivation: CAs have systems in place to ensure staff are properly compensated, motivated and protected

A.3.3.1
Staff salary is sufficient, commensurate with duties and supplied on time and regularly
2
A.3.3.2
Staff competence and performance are assessed routinely by means of formal appraisal
1
A.3.3.3
CAs encourage good work performance, which is linked to opportunities for career development
1
A.3.3.4
CAs enable confidential reporting of wrongdoing by colleagues and officers without exposure to adverse reactions
2
A.3.3.5
CAs maintain sustainability of programmes and internal stability even in times of political changes
2




Total score
126

Average score
2.06

Total score of this section is 126 out of 62 criteria. Hence the average is around 2.
Based on the above evaluation, we can conclude that:

“The system resources and inputs for National Food Control System of Nepal are insufficient.”

Note: this is authors personal opinion and you are free to agree or disagree on this evaluation. If there are mistakes or suggestions, please feel free to make positive comments and feedback below.


References:
FAO and WHO. 2019. Food control system assessment tool: Introduction and glossary. Food safety and quality series No. 7/1. Rome.
FAO and WHO. 2019. Food control system assessment tool: Dimension A – Inputs and resources. Food safety and quality series No. 7/2. Rome.

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