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Ma. Concepcion C. Lizada, Ph.D.

October 2007

“The views expressed in this report are strictly those of the authors and do not necessarily reflect those of
the United States Agency for International Development (USAID) and the Ateneo de Manila University”.

Rapid urbanization, increased demand for convenience food, new processing and
handling technologies, immune-compromised and susceptible populations and
emerging pathogens, among others, point to the need for an effective national
food safety program in the Philippines. The study discusses issues surrounding
food safety in the country, including recent developments that emphasize the need
to assure food safety, trade issues, the scientific basis of food safety measures and
the Philippine commitment to food safety. It finds that although Philippine
legislation and related issuance provide for various aspects of food safety, the
absence of a clear statement of national policy on food safety and the number of
agencies involved have led to overlaps and gaps in the implementation of this
program. The author proposes constituting an interim Task Force on food safety,
ensuring that the ongoing rationalization of relevant agencies adequately address
food safety, strengthening consumer education programs towards effective
consumer advocacy for food safety, and ensuring the good complementation of
mandatory and voluntary food safety measures.

Ma. Concepcion C. Lizada


Executive Summary

Food safety is the assurance that the food supply does not pose an unacceptable risk to
human health. A number of developments point to the urgent need for an effective food
safety program. Among these are:

1. Rapid urbanization;
2. Increased demand for convenience food;
3. Increased travel;
4. Increased consumption of fruits and vegetables;
5. Interest in ethnic and non-traditional food;
6. Novel foods;
7. New processing and handling technologies;
8. Emerging pathogens; and
9. Immune-compromised and susceptible populations

These developments, along with trade liberalization in agriculture and food products
point to the need for aneffective national food safety program in the Philippines.

Although Philippine legislation and related issuance provide for various aspects of food
safety, the absence of a clear statement of national policy on food safety and the number
of agencies involved have led to overlaps and gaps in the implementation of this
program. Monitoring and surveillance programs covering food borne diseases are
implemented by the Department of Health (DOH). Unfortunately, these programs which
can provide the much-needed data for a robust economic analysis of the consequences of
food borne diseases and the potential benefits that can be derived from an effective
national program on food safety, needs to be expanded to cover major food borne
hazards. The DOH itself has identified the need to integrate these programs.

The World Health Organization (WHO) has provided the framework for the design and
implementation of a national food safety program, involving the forging of partnerships
among government, industry, the academe and civil society. Cognizant of the
Philippines’ commitment to food security and, concomitantly, to food safety, the DOH
and the Department of Agriculture have presented a proposal on a National Food Safety
Program involving the National Food Security Council (NFSC). The NFSC, as created
by Executive Order No. 86 s. 1999 is viewed in the proposal as the appropriate body to
integrate a highly participatory national food safety program. Unfortunately, the Council
has not been convened since 2000. The proposal is consistent with the WHO
framework and identifies the roles of the various stakeholders. In the absence of a well-
defined program on food safety, the agriculture and food sectors, particularly the
smallholders and micro and small enterprises engaged in food production cannot fully
take advantage of the opportunities presented by the increased global concern for food
Summary of recommendations/policy recommendations

1. That an interim Task Force on Food Safety be constituted to continue the joint
efforts of the Department of Health and the Department of Agriculture towards
the formulation of a national policy statement on food safety and the National
Food Safety Program;

2. That the on-going rationalization process being undertaken in the relevant

agencies adequately address and provide for a unified program on food safety,
adequately addressing the need for risk-based measures and good governance;

3. That consumer education programs towards effective consumer advocacy in the

area of food safety be strengthened; and

4. That government and industry take steps to ensure good complementation of

mandatory and voluntary measures.

Introduction and background

The Department of Health (DOH) defines food safety as “the assurance/guarantee that
food will not cause harm to the consumers when it is prepared and/or eaten according to
its intended use” (DOH, 2006). An effective national food safety program, therefore,
instills confidence in the food supply and, in risk terms, may be defined as assurance that
the food supply does not pose an unacceptable risk to human health. This definition is
consistent with that of the Food and Agriculture Organization of the United Nations
(FAO, 1999), i.e.

"Food safety" implies absence or acceptable and safe levels

of contaminants, adulterants, naturally occurring toxins or
any other substance that may make food injurious to health
on an acute or chronic basis.

Previous to this the FAO together with the World Health Organization jointly defined
food safety as “all conditions and measures that are necessary during the production,
processing, storage, distribution, and preparation of food to ensure that it is safe, sound,
wholesome, and fit for human consumption” (FAO/WHO, 1996).

Food is inherently safe, particularly if it has a history of traditional use. However,

exposure to hazardous contaminants, the application of novel processes and technologies,
and poor handling can render food unsafe for consumption. A hazardous contaminant or
hazard in food is any “biological, chemical or physical agent in, or condition of, food
with the potential to cause an adverse health effect” (FAO/WHO, 2006 b).

Biological hazards include pathogens that are highly infectious at low levels, e.g.
Hepatitis A virus, Shigella, E. coli O157:H7. Salmonella (Trauve, 2005). They also
include E. sakazakii associated with infant formula. Chemical hazards include toxins of
fungal or algal origin, dioxins, heavy metals (mercury, lead and cadmium), polyaromatic
hydrocarbons in smoked food, and pesticide and veterinary drug residues. Some food
plants and animals naturally contain toxins such as alkaloids, cyanogenic glucosides,
antinutrients, neurotxins and allergens. Acrylamides and trans fats are examples of
unintended by-products of food processing (Taylor, 2005). Additives that are not
permitted for food use, or added in excess of allowable levels are also health hazards.
Physical hazards include bone fragments, glass, metal and pebbles.


Although the Philippines implements a number of food safety-related activities, a unified

national program is lacking. The World Health Organization (WHO) has provided the
framework for the design of sucha program, and a Philippine Food Safety proposal
guided by this framework has been presented in various forums. Unfortunately, the
initial attempts to actualize this proposal have not been sustained. There is a need to
reiterate the need for and resume discussions on this proposal. This paper is an attempt to
focus attention on what needs to be done, and what has been done so far in formulating a
Philippine Food Safety Program.

Food security and food safety

Food security has been described as

“A situation that exists when all people, at all times, have physical, social
and economic access to sufficient, safe and nutritious food that meets their
dietary needs and food preferences for an active and healthy life.”

FAO food security definition, 2005

The above definition emanated from the 1992 Rome Declaration on World Food
Security, a commitment the Philippines was signatory to (FAO/WHO, 1992). From its
very definition, food security cannot be achieved without food safety. Although food
safety is of paramount concern in trade liberalization, it is first and foremost, a nation’s
commitment to its citizens (FAO/WHO, 2004 b). Food safety is not just a trade issue; it
is a public health issue (Brundtland, 2001).

Recent developments and the need to assure food safety

Rapid urbanization

Rapid urbanization has given rise to longer distribution channels. Serious diarrheal
illness in the United States caused by enterohemorrhagic Shiga-toxin producing E. coli
has been attributed to hazards arising from the pooling of beef from grain-fed cattle
raised in numerous feedlots for distribution in many supermarkets in multiple states
(Maki, 2006). Food-borne diseases (FBDs) associated not only with beef, but with fruits
and vegetables as well, have been associated with a production-marketing system that has
been altered from one where the local farmer supplies local grocers to a system where
food is produced on a vast, industrial scale.

Increased consumption of fruits and vegetables

While it is commonly accepted that fresh fruits and vegetables are health-promoting
components of the diet, microbial and chemical contamination can lead to FBDs.
Even in developed countries FBD outbreaks have been associated with the microbial
contamination of fruits and vegetables (Table1). The 2006 multi-state E. coli O157:H7
outbreak in the United States, for example, was associated with bagged spinach
(CalFERT, 2007).

Increased demand for convenience food

A fast-paced lifestyle and mothers joining the workforce have led to the increased
demand for convenience food. The consumption of convenience foods involves the
assumption that measures to safeguard against the introduction health hazards are in place
during food preparation, consistent with the onus put by regulations in more developed
economies on food business operators to assure safety (EC, 2002; FAO, 1999). Besides
the risks involved in their preparation, convenience foods are consumed without the usual
measures (e.g. extensive heating) that can mitigate risks associated with food borne

Increased travel

The main food- and water-related health problem for travelers is diarrhea, which has been
associated with microbial (bacteria, fungi, viruses, parasites) or chemical contamination.
The risks are particularly high in countries with low standards of sanitation and hygiene,
even in higher-quality hotels and restaurants (WHO, 2007). The problem can be
aggravated by lack of access to medical services in many travel destinations.

Travelers to developing countries might be considered as being at a greater risk of

contracting FBDs; however, travelers to developed countries also need to guard against
chemical and microbial contaminants in food.

Documented FBD outbreaks (see table 1, for example) and the 1999 dioxin crisis in
Belgium (Lok and Powell, 2000; Jakubowski, 2004) illustrate the possibility of food
safety breaches even in developed countries. Although observed increases in FBDs
might be attributable to vast improvements in diagnosis and surveillance systems,
specimens taken from European countries between 1985 and 1997 indicated real
increases in microbial contamination, for example (McNicolas et al., 1995 as cited by
Rocourt et al, 2003). FBD concerns in OECD countries include Vibrio in oysters and
salmonellosis and campylobacteriosis in contaminated meat and meat products, poultry
and eggs. Time/temperature abuse has been identified most frequently as a contributing
factor to sporadic cases of FBDs associated with food eaten outside the home or prepared
by commercial establishments in these countries (Rocourt et al, 2003).
Table 1. Outbreaks associated with microbial contamination of fruits and vegetables in
the United States (Harris, 2005).

Organism Contaminated produce Symptoms (CDC, 2004-07)

C. botulinum cabbage salad, garlic in oil double vision, blurred vision,
drooping eyelids, slurred
speech, difficulty swallow-
ing, dry mouth, muscle
weakness, paralysis of
breathing muscles
Campylobacter jejuni salad, lettuce diarrhea (may be bloody),
nausea, vomiting
E. coli O157:H7 lettuce, sprouts, cantaloupe, bloody diarrhoea, acute renal
unpasteurized apple cider failure, death
Shigella green onions, parsley, bloody diarrhea, fever,
shredded lettuce seizure, chronic joint pains
L. monocytogenes cabbage salad fever, muscle aches, nausea,
diarrhea. headache, stiff neck,
confusion, loss of balance,
convulsions, miscarriage
Salmonella melons, tomatoes, sprouts, diarrhea (some for months),
unpasteurized apple cider fever, abdominal cramps,
unpasteurized orange juice, chronic joint pains, eye
mango, raw almonds irritation, painful urination
Hepatitis A lettuce, frozen strawberries, fever, anorexia, nausea,
raspberries, diced tomatoes, vomiting, diarrhea, myalgia,
watercress, green onions malaise, jaundice
Calicivirus salad, frozen raspberries,
celery, coleslaw, fruit salad,
green salad, melon
Cyclospora raspberry, basil pesto,
lettuce, basil
Cryptosporidium unpasteurized apple cider diarrhea, fever, nausea,
Giardia lettuce and onions diarrhea

Interest in ethnic and non-traditional food

Travel and the availability of a wider range of food products have sparked interest in
ethnic and other non-traditional food products. Moreover, the demand for ethnic foods
grows as immigrant populations increase in such markets as the United States and
Europe. Novelty and the lack of familiarity with processes involved affect consumer
perception of the safety of these products. Moreover, international trade in ethnic foods
can give rise to situations where safety is compromised as a result of inappropriate
handling in markets unfamiliar with these products. While the increased demand for
ethnic foods create opportunities for trade, uncharacterized food safety risks have
emerged and food control systems are faced with new challenges in assuring food safety
(The Houston Chronicle, 2007).

Emerging pathogens

Emerging food borne pathogens include new microorganisms or pathogens whose

transmission through food has only been recently recognized, and known pathogens that
have recently spread to previously unaffected geographic areas (WHO, 2002). The
serotype O157:H7 of Escherichia coli (E. coli) was not recognized as the causal organism
of FBDs leading to bloody diarrhea, acute renal failure and death until 1982. Outbreaks
associated with beef, and, more recently, alfalfa sprouts, unpasteurized fruit juice, lettuce,
game meat and cheese curd, have been reported in Australia, Canada, Japan, United
States, in various European countries, and in southern Africa. The role of food in the
transmission of Listeria monocytogenes has only recently been recognized.
More than 10 percent of the world's population, particularly in Asia, Africa, and Latin
America, have recently been put at risk of becoming infected by trematodes, which are
transmitted through the consumption of raw or inappropriately processed freshwater fish,
shellfish, or aquatic plants (Käferstein, 2003).
In recent years, strains of Salmonella resistant to a range of antimicrobials have emerged,
and this has been attributed to the use of antimicrobials both in humans and food animals
(WHO, 2005).
Immune-compromised and susceptible populations
Persons affected by HIV/AIDS or cancer become highly susceptible to infections,
including FBDs. The aged, infants and children, particularly those with reduced
immunity as a consequence of poor nutritional status in developing countries, are more
likely to succumb to FBDs leading to severe illness with high death rates (WHO, 2002;
IFPRI, 2005).
New processing and handling technologies
Innovative technologies can lead to the modification of environments to favor the
proliferation of food borne pathogens and the elaboration of toxins. Packaging and
storage systems based on controlled or modified atmosphere technologies can lead to
produce rendered inedible by the presence of C. botulinum toxin (Harris, 2005).
The safety assessment of food from genetically manipulated (GM) organisms has
indicated the safety of widely cultivated GM crops (FAO/WHO, 2000). Safety-related
questions that have persisted reflect the need for better risk communication covering not
only GM food, but food products derived through novel technologies.
Novel foods
Functional foods and foods at the food-drug interface or neutraceuticals present yet
another challenge that points to the need for food safety assurance. The structure of
regulatory bodies in most countries require good coordination between separate agencies
responsible for regulating food on the one hand, and drugs, on the other.

The above developments have focused attention on the urgent need for an effective food
safety program. Food insecure populations are at greatest risk from the debilitating and
life threatening effects of FBDs (CGIAR TAC, 2001).

The Philippines has not been exempt from the consequences of the above developments.
The emergence of fast food chains in the Philippines has led to the sourcing of local and
imported raw materials. Beef for burgers and even fish served in the larger fast food
chains is imported.

Food safety is a key concern in the consumption of local salad vegetables grown in the
highlands. Lettuce, which might be grown in Mindanao, is shipped to Manila for cleaning
and cutting by a toll processor for a fast food chain. For produce going through
traditional channels, marketing usually involves several intermediaries, subjecting the
commodity to handling under variable conditions that hardly assure safety.

Risks resulting from the misuse and abuse of pesticides in such vegetables as bitter
gourd, string beans and eggplant make some Filipino consumers shy away from
consuming these popular vegetables. Measures to safeguard the quality of water used for
irrigation and/or washing vegetables in some production areas are not in place.

Local producers of convenience foods are not necessarily equipped to assure food safety
in convenience foods. The manner in which street-vended foods are prepared and served
can easily lead to contamination by microbial, chemical and physical hazards. At greatest
risk are consumers of such food (WHO, 1996 a), who usually belong to the lower income
brackets in developing countries.

In 2002 researchers funded by the National Research Council of the Philippines identified
Listeria monocytogenes, Campylobacter jejuni and Yersinia enterocolitica as among the
emerging virulent food-borne bacterial pathogens (Bungay et al, 2002 as cited by
Carteciano, 2004).

The Philppine experience with comfrey (Symphytum officinale) provides a good

illustration of how popular but unfounded claims can lead to misguided use of herbs or
food supplements with potentially deleterious effects. Comfrey has been found to
contain pyrrolizidine alkaloids that can obstruct blood flow to the liver and cause serious
liver damage in humans (Pinyuh, 1992; USFDA, 1998).

Despite calls for stronger national food safety control systems, the Philippine response
has been predominantly reactive and rarely preemptive. Effective monitoring and
surveillance of FBDs in developed countries have provided data for policy studies,
which, in turn, have led to strengthened national commitment of resources for food safety

Food safety as a trade issue

A national food safety program has for its focus the health of its own consumers.
However, it should lead to an enhanced confidence in the country’s food exports.

With the establishment of the World Trade Organization (WTO), significant

commitments to liberalize trade were viewed as giving rise to benefits in international
trade in agricultural and food products. Although there have been significant reductions
in tariffs covering these products, non-tariff barriers, in contrast, have increased (Henson
et al, 2002). The spread of risks to human health and safety were anticipated as a
consequence of liberalized trade in agricultural products, particularly food. The
Agreement on the Application of Sanitary and Phytosanitary Measures (the SPS
Agreement) was, therefore, included in the GATT -UR, which established WTO in 1994.
The SPS Agreement reaffirms “that no Member should be prevented from adopting or
enforcing measures necessary to protect human, animal or plant life or health…” (GATT-
UR, 1994). Although food safety has always been a principal concern in international
food trade, the advent of the WTO has resulted in food safety becoming a major trade
issue. Trading partners have become more conscious of the need for effective food safety

Trading partners have to be assured that food safety is not used as a non-tariff barrier.
The SPS Agreement requires that “measures are not applied in a manner which would
constitute a means of arbitrary or unjustifiable discrimination between Members where
the same conditions prevail or a disguised restriction on international trade…” (Preamble
of the Agreement on Sanitary and Phytosanitary Measures; Annex I). The SPS
Agreement thus provides that Members “ensure that any sanitary or phytosanitary
measure is applied only to the extent necessary to protect human, animal or plant life or
health, is based on scientific principles and is not maintained without sufficient scientific
evidence…” (Article 2).

Ensuring the scientific basis of food safety measures

The standards and related texts of the Codex Alimentarius have been identified as the
benchmark for food safety-related measures. The Codex Alimentarius is a collection of
internationally adopted food standards and texts presented in a uniform manner with the
twin objectives of “protecting consumers’ health and ensuring fair practices in the food
trade ” (FAO/WHO, 2006b). Through the years Codex texts covering food safety have
been elaborated following the risk analysis paradigm (Figure 1, FAO/WHO, 2004 a and
2006 a).

The Codex Alimentarius Commission (CAC), the international body, which is

responsible for the elaboration of Codex standards, established the Working Principles
for Risk Analysis, providing guidance to WTO Members in establishing SPS measures.
Within this framework, the CAC is a risk management body. Risk assessment, which
provides the scientific basis for CAC decisions, is provided by expert bodies consisting of
the Joint FAO/WHO Expert Committee on Food Additives (JECFA), the Joint Meetings
of the FAO Panel of Experts on Pesticide Residues in Food and the Environment and the
WHO Core Assessment Group on Pesticide Residues (JMPR), and the Joint FAO/WHO
Expert Meeting on Microbiological Risk Assessment (JEMRA). Thus, in cases where a
WTO Member has opted to adopt Codex standards, the output of these expert provides
the scientific justification for a food safety measure. Where a WTO Member adopts a
measure that achieves a level of protection higher than that provided by a Codex
standard, it will have to provide its own risk-based justification.

RISK Informs/ RISK


Scientific involving policy
inputs influences and values

Figure 1. The risk analysis framework covering the elaboration of Codex Alimentarius
standards and related texts (FAO/WHO 2004a and 2006).

Despite the above provision to pre-empt arbitrary trade-restrictive measures, there is

growing concern that SPS measures might actually be disguised insurmountable barriers
to trade in food. A World Bank report on food safety and agricultural health standards
identified the following concerns, among others (World Bank,2005):

1. Discriminatory application of emerging food safety measures;

2. Inadequate capacity in developing countries to comply with new or increasingly
stringent requirements; and
3. The cost of compliance, which can undermine developing countries’ comparative
advantage in high-value food trade and marginalize weaker economic players,
including small farmers and enterprises.

Technical Barriers to Trade or TBT measures (e.g. labeling requirements) add to the
burden of complying with SPS measures.

Most SPS-related concerns in developing countries have focused mainly on food and
agricultural exports, as these contribute to and provide opportunities for increased export
earnings (Pay, 2005). Unfortunately, this focus tends to shift attention away from a
country’s principal responsibility to assure a safe food supply to its own consumers. The
greater focus on exports has resulted in dualistic food safety measures, with control
measures concentrated on export-oriented enterprises and the national market largely
neglected (FAO/WHO, 2004).

The 2007 Bangko Sentral ng Pilipinas statistics on food exports and imports (Table 2)
show that the value of total imports is comparable to that of total exports (including
unspecified non-durable consumer products).

The Philippines’ recent experience in dealing with risks associated with imported
Chinese food products highlight the Filipino consumer’s vulnerability to food borne risks
in imports, and the need to ensure that these are covered by appropriate food safety

The status of the Philippine commitment to food safety

The need for food safety measures emanates from the fundamental responsibility of
protecting the consumer against adverse health effects of unsafe food. Considering the
volume of imported food, the Filipino is exposed to food borne risks largely through
domestically produced food. As early as 1976 the FAO/WHO publication “Guidelines for
Developing an Effective National Food Control System” has provided guidance in the
development of national food control programs. In these guidelines, food control, is
defined as

“a mandatory regulatory activity for enforcement by national or local

authorities to provide consumer protection and ensure that all foods during
production, handling, storage, processing, and distribution are safe, whole-
some and fit for human consumption; conform to safety and quality
requirements; and are honestly and accurately labelled as prescribed by

Food control is the primary responsibility of regulatory agencies of government, although

it is not the sole mechanism for ensuring food safety (WHO, 1976). Nevertheless, on
account of the covert nature of health hazards in food, and the segment of the population
most vulnerable to such hazards, government needs to play the major role in food safety.

National Food Control Programs

In the 1996 WHO guidelines on strengthening national food safety programs, a

statement of the national policy on food safety was identified as the first step in the
preparation of a national food safety program. The Philippines has yet to issue a
unifying food safety policy statement as it did in the case of products of biotechnology.
Table 2. Value of food exports and imports in the Philippines
(BSP, 2007).
Commodities FOB value in million USD
2006 2005
Coconut (food, feed) 748 813
Sugar and products 98 81
Fruits and vegetables 718 660
Fish, fresh or preserved 258 240
Processed food and beverage 583 519
2405 2313
Total exports in Jan-Dec 2006 47037 41255
Contribution of food to exports 5.11 5.61
Wheat 467 318
Corn 49 21
Unmilled cereal, excl rice, corn 2 1
Feeding stuffs 409 426
Animal & veg oils & fats 152 143
Dairy products 443 414
Fish and fish preparation 58 61
Rice 58 61
Fruits and vegetables 161 114
1799 1559
Total imports 53474 48528
Contribution of food to imports 3.36 3.21
Other non-durable consumer goods 850 788
Contribution (including other non-
Durable consumer goods) 4.95 4.84

The need for epidemiological data on FBDs

The lack of a sense of urgency in the formulation of a unified food safety program stems
partly for the failure to generate data in support of such a program. In turn, this can be
attributed to the paucity of epidemiological data from which the socio-economic
consequences of FBD outbreaks or cases can be derived. Qualitative and quantitative
information is needed to formulate cogent arguments for policymakers to pay attention to
the urgent need for food safety programs. Such information can then be processed with
the help of tools available to provide the basis for decision-making in matters of food
safety. The Foodborne Illness Cost Calculator designed by the Economic Research
Service (ERS) of the US Department of Agriculture (USDA), for example, provides food
borne illness cost estimates for use by policymakers and the general public. Information
derived from the use of the Foodborne Illness Cost Calculator cover FBD incidence,
productivity losses and disutility (USDA, 2006).
In the Second Global Forum of Food Safety Regulators, the Philippines, through the
Department of Health (DOH), outlined the monitoring and surveillance programs
covering FBDs (DOH, 2004). The National Epidemic Sentinel Surveillance System
(NESSS) is an active surveillance system which monitors 14 infectious diseases 4 of
which are food and water borne diseases, i.e. cholera, hepatitis A, typhoid fever and
paralytic shellfish poisoning. Unfortunately, the sentinel site laboratories under the
NESSS cannot routinely undertake serotype identification for E.coli O157:H7 and other
pathogenic E.coli, Shigella, or Salmonella.

The Field Health Service Information System (FHSIS), on the other hand, is a passive
surveillance system covering cases clinically diagnosed as “acute water or bloody

A laboratory-based surveillance system called the antimicrobial resistance surveillance

program (ARSP) is implemented by the Research Institute for Tropical Medicine
(RITM), can potentially be used for the surveillance of foodborne infections as this
program monitors a broader range of microorganisms.

The Philippines is a participant in the WHO Global Salmonella Surveillance starting in

2002. The program involves an enhancement of the Salmonella surveillance system,
which includes nontyphoidal Salmonella. Unfortunately, there is no surveillance program
covering viral and parasitic agents of food borne infections in humans or animals.

The surveillance programs implemented by the DOH involve independent surveillance

systems with distinct personnel and infrastructure. However, steps to merge surveillance
data are being taken to provide both clinical and laboratory data which can be used to
better undertake risk assessment initially of Salmonella infections and, subsequently,
other food borne pathogens.

Although the DOH surveillance system cannot provide a complete picture of FBD cases
and outbreaks, it should provide information with which the impact of FBDs can be

Food safety legislation

An effective national food safety program requires the development or upgrading of

food legislation. The legal framework and principles to guide the national program on
food safety are provided by the 1987 Constitution which states that of the Constitution
states that “The state shall establish and maintain an effective food and drug regulatory
system and undertake appropriate health manpower development and research,
responsive to the country’s health needs and problems ” (Art. XIII, Sect. 12). This served
as the basis for E. O. 175, which amended R. A. 3720 (Food, Drug and Devices, and
Cosmetics Act of 1963) to the Food, Drugs and Devices and Cosmetics Act, providing
for the conversion of the Food and Drug Administration to the Bureau of Food and Drug
(BFAD). BFAD’s activities in food control include:
1. the licensing and inspection of food processing plants, monitoring compliance
with GMP requirements;
2. registration of food products for direct sale to consumers, evaluating conform-
ance with quality standards and labeling;
3. monitoring of products in trade outlets and action on consumer complaints; and
4. the regulation of the production and distribution of processed foods by prohibiting
the sale and distribution of adulterated and misbranded food products.

BFAD standards do not cover fresh or dried fruits or vegetables.

Republic Act No. 7394 (1992) or The Consumer Act of 1992 provides for the protection
of consumer interests and general welfare, and establishes standards of conduct for
business and industry. It further mandates the provision of information and education to
enable the consumer to make sound choices and exercise his/her rights, including active
participation in the formulation of relevant social and economic policies. The Consumer
Act of 1991 specifically protects the consumer against hazards to health and safety.

Another major piece of legislation covering food safety is Republic Act No. 8435 or the
Agriculture and Fisheries Modernization Act of 1997, which provided for the
establishment of the Bureau of Agriculture and Fisheries Product Standards (BAFPS),
with the following functions:

1. “Formulate and enforce standards of quality in the processing, preservation,

packaging, labeling, importation, exportation, distribution and advertising of
agricultural and fisheries products;
2. Conduct research on product standardization, alignment of the local standards
with the international standards; and
3. Conduct regular inspection of processing plants, storage facilities, abattoirs, as
well as public and private markets to ensure freshness, safety and quality of
More specific mandates were provided for by Presidential Decree (PD) 1144, which
created the Fertilizer and Pesticide Authority. Together with the Bureau of Plant
Industry, FPA is tasked with the establishment of maximum residue levels for pesticides
in agricultural products.

The Meat Inspection Code of 2005 or Republic Act 9296 mandates the National Meat
Inspection Service (NMIS) to implement food safety control measures in the slaughter of
food animals, and in the preparation, processing, handling, packaging or sale of meat and
meat products. Veterinary quarantine measures are undertaken by the Bureau of Animal
Industry as mandated by Act 3639 of 1929 and the Administrative Code of 1987, while
fisheries quarantine and food safety-related measures are implemented by the Bureau of
Fisheries and Aquatic Resources, as provided by the Republic Act 8550 or the Philippine
Fisheries Code of 1998.

Issuances from the Department of Agriculture covering fod safety concerns include:
1. Administrative Order No. 25 s. 2005 – Guidelines on the Certification of Good
Agricultural Practices (GAP) for Fruit and Vegetable (FV) Farming, and
2. Administrative Order No. 26 s. 2005 – Revised Rules, Regulations and Standards
governing the Importation of Meat and Meat Products into the Philippines

Upgrading legislation to strengthen the food safety program of the Philippines will
involve reviewing all the above instruments and other related issuances to ensure a clear
delineation of responsibilities and scope to eliminate gaps and avoid duplications. The
BFAD, on the one hand, and BAFPS, NMIS, FPA, BPI, on the other.

Given their respective mandates, the agencies involved in food safety programs are
tasked with risk management. To respond to this mandate, BAI has developed
competence in risk analysis, not only in animal health, but in food borne zoonotic
diseases as well. BPI has the capacity to undertake plant pest risk analysis. The FPA
operates in a risk analysis framework, commissioning external experts ito undertake risk
assessment. Unfortunately, the appreciation of the requirement that management
measures have to be risk-based is lacking in a number of implementing agencies.

A unified National Food Safety Program

Except for the statement of a national policy on food safety, there is obviously no lack of
legislation or administrative instruments that provide the basis for an effective food safety
program. With the mandates of the different agencies, the delineation of responsibilities
and elimination of gaps needs to consider the principle of specialization. The statement of
Brundtlandt (2001) points to two delineated areas: public health and food as a

Orchestration from a single national agency can effect coordination and facilitation.
Consistent with the strategy formulated by the 2002 WHO consultation for countries to
integrate food safety policy with those covering food security and related concerns, the
National Food Security Council created by Executive Order No. 86 s. 1999 would be an
appropriate body to integrate a highly participatory national food safety program. The
National Food Security Council membership consists of representatives of government,
with LGUs playing a prominent role. Risk assessment will need the establishment of a
Philippine Food Safety Committee with experts commissioned on an ad hoc basis. Risk
management measures will be coordinated by the Executive Committee, co-chaired by
the DOH and DA (Figure 2). Unfortunately, the National Food Security Council has not
been convened for more than 5 years.

The risk analysis paradigm also requires that the formulation and implementation of risk
management measures be transparent. Effective risk communication is needed to elicit
participation from all concerned sectors.

The Red Tide Task Force covering algal bloom toxins (DOH, 1997) provides a good
example of an integrated national food safety program, despite resource limitations. This
program involves all stakeholders and covers the following activities that constitute
requisite investments towards an effective food safety program (FAO/WHO, 2002):

1. legislation and associated standards and regulatory measures;

2. information communication program with provisions for consumer education and
rapid alert;
3. research, including predictive modeling and analytical methodologies;
4. monitoring and surveillance; and
5. international networking

The Red tide Toxin task Force actively involves the academe, particularly in research.

Along with other programs that have yet to be established, the Red Tide Task Force
program can be further strengthened with the establishment of a coordinating body.

National Food Security Council

National policy on food safety

Philippine Food Safety
Executive Committee on Food Safety
Committee (experts)
DOH-EH, DA-BAFPS as co-chair

Scientific advice
National Programs


Agency/local Programs, Internal monitoring/evaluation

Figure 2. A proposed national organization for an integrated National Food Safety


Complementation between mandatory and voluntary measures

An integrated food safety program involves complementary measures implemented by

industry, consumers and non-government organizations. Thus, food control measures are
complemented by voluntary measures.

Information asymmetry and added costs associated with food safety measures make it
unattractive for food manufacturers/producers to implement food safety measures (James,
2001). Available safety-related information will not necessarily influence a consumer’s
purchasing decision in favor of products perceived as safe, where the market is
segmented on the basis of incomes (Galvez et al, unpublished observations). Food safety
assurance is one area where government intervention is justified on account of market
failure (Smith, 2001) requires public investment in terms of inspection, monitoring and
surveillance and information and education.

Food manufacturers and establishments that have built and maintained a reputation for
safety and overall quality, are likely to be adversely affected by a breach in food safety.
These enterprises would have the incentive to assure the safety of their products for both
domestic and international markets (Buzby and Unnevehr, 2003). These enterprises
invest in risk management measures, e.g. Good Agricultural and Manufacturing Practices
(GAPs and GMPs; UM-FDA, 2002) and the Hazard Analysis and Critical Control Point
(HACCP) system (WHO, 1997) in terms of training, expert services, accreditation and
Cognizant of the need for a partnership to effect a good complementation of mandatory
and voluntary measures, BFAD and the Philippine Chamber of Food Manufacturers Inc.
have formed a Joint BFAD-Industry Committee on Food. This joint undertaking
addresses mutual concerns of BFAD as a regulatory agency and the food industry in the
enforcement of food safety regulations and covers the following specific tasks:
1. Review of existing and/or proposed policies and procedures related to food safety
and quality assurance by the food processing industry;
2. Development of strategies to ensure industry compliance with pertinent rules and
3. Provision of inputs to address relevant issues affecting consumers and processed
foods producers including those covering international trade; and
4. Implementation and enforcement of policies and procedures agreed upon by the
Joint Committee.
Technical working groups (TWGs) have been formed to implement the joint program:
• TWG on Codification of Food Laws and Regulations
• TWG on Systems and Procedures on Licensing and Registration
• TWG on Food Standards
• TWG on Food Labelling

Opportunities for smallholders and enterprises

National food safety programs need to give special attention to small- and micro-
enterprises, which are faced with resource limitations. LGUs play a key role in both the
enforcement of food safety regulations and accessing resources to enhance compliance.
LGUs in the National Capital Region have expressed the need for capacity building for
their health and sanitation officers (Vicente and Lizada, unpublished). Smallholders will
have to be provided appropriate technical assistance in GAP and Good Handling
Practices. Smallholders can take advantage of opportunities only where such assistance
is part of a farm-to-fork program on food safety.

The role of local government

LGUs can help ensure the inclusion of smallholders in supplying markets concerned with
safety. Among the general powers of LGUs as provided by The Local Government Code
of 1991 (http://pcij.org/blog/wp-docs/LGC1991) is the promotion of public health and
safety. The Code assigns the responsibility of providing agricultural extension services
to both the provincial and municipal governments, with the barangay sharing in the
responsibility of providing agricultural support services (Section 17). LGUs can help
ensure GAP-compliant production systems that ensure both food safety and the
protection of production areas from contamination and degradation.

LGUs in consumption centers can contribute to the attainment of a farm-to-fork foo

safety assurance. The municipality of Marikina, for example, has introduced several
innovations to ensure sanitation, product safety and consumer protection. The Marikina
Public Market operates the Marikina Clean Food and Water Laboratory and participates
in two WHO Food Safety Programs. The market is open to simple screening procedures
for pesticide residues in produce. For the innovations introduced by the market, it has
been recognized by DA-Agricultural Marketing Services of the Department of
Agriculture (DA-AMAS) as a model market.

Street vended foods, which are mainly produced and sold by the informal sector, are
covered in the Philippine National Plans of Action for the Promotion and Protection of
Human Rights (http://www.ohchr.org/english/issues/ plan_actions/philippine.htm). The
DOH has been tasked with setting guidelines for hygiene and sanitation for street food
vendors, while the LGUs assume the responsibility of identifying possible locations
where food vending my be allowed.

In food manufacture, national government agencies, notably the Department of Trade and
Industry (DTI), the Department of Science and Technology (DOST) and the Department
of Agriculture, implement programs assisting SMES to meet GMP, HACCP and other


Consumers collectively demanding quality can be a potent force in a food safety

program. The European Economic and Social Committee, which represents civil society
organizations including consumer organizations, provide key inputs in EU programs on
food safety. Consumer organizations in the Philippines need to be strengthened and
guided by science-based information for them to function as effective food safety
advocates. Unfortunately, a concerted move to make consumers aware of the availability
or reliability of information on food safety is lacking.
The role of different stakeholders in ensuring food safety is illustrated in Figure 3.
Unfortunately, academe has not been identified as a distinct pillar in this framework.
Expert service in risk assessment, laboratory tests and inspection, research and education
can be sourced from academe.

Safe Food for All

Food Legislation Educated/Know- Good Practices: Primary
and Enforcement ledgeable Public Producers/Distributors
Advice for Discriminating/Se- QA and Control of
Industry/Trade lective Consumers Processed Food

Consumer Safe Food Practice Appropriate Processes

Education in the Home and Technology

Information Gath-ering/Research
Community Trained Managers & Food Handlers

Provision of Health- Active Consumer Informative Labeling & Consumer Education

Related Services Groups



Figure 3. Schematic representation of the FAO/WHO model for an integrated

national food safety program (FAO/WHO, 1976).

Consistent with the above model is the BFAD view that considers continuing cooperation
and effective partnership between government, the food industry and the consumers as
primordial to an effective national food safety program.

Recommendations/ policy proposals

The unique features of relevant government programs and the needs of both the food
industry and consumers point to the following recommendations:
Formation of National Task Force on Food Safety
A committee working with the National Food Security Council has been proposed earlier.
As the Council has not been convened and the prospects of this taking place are not
bright, it is recommended that an interim Task Force on Food Safety (TFFS) be
constituted. Consistent with the WHO framework, it is proposed that it involve the
participation of all stakeholders, i.e.
1. concerned government agencies at different levels;
2. food industry;
3. consumer organizations and relevant civil society organizations; and
4. the academe
A clear statement of policy on food safety
As a first step, the TFFS needs to formulate a national policy statement that can be
presented to the President for approval and promulgation.
Formulation of the National Food Safety Program
It is recommended that the TFFC formulate the framework to guide the design and
implementation of the National Food Safety Program, consistent with the need for a risk-
based approach and the principles of good governance (delineation, accountability and
transparency, specialization and competence, participation and consultation, and
Partnerships guided by specialization and a clear delineation of roles
The rationalization of the government bureaucracy as provided by EO 366 (http://www.
lcp. org.ph/ref_statutes_EO366.htm) presents an opportunity to streamline the programs
and structure of the concerned government agencies to minimize overlaps, while
instituting measures to address gaps. The following mandates of the different agencies
might be considered to delineate roles:
1. DOH – “ensuring access to basic public health services to all Filipinos through
the provision of quality health care and regulation of providers of health goods
and services” (http://www2.doh.gov.ph/profile.htm);
2. DA – “the promotion of agricultural development and growth” (http://rfu3.
3. DTI - serve “as the primary coordinative, promotive, and facilitative arm for
trade, industry and investment activities”, adopting the strategies of “promoting
and developing business, with focus on SMEs; lowering the cost of doing
business; and ensuring consumers get the best value for money”( http://www.dti.
gov.ph/About_Mandate_History.php); and
4. DOST – “provide central direction, leadership, and coordination of scientific and
technological efforts and ensure that the results therefrom are geared and utilized
in areas of maximum economic and social benefits for the people” (http://www.
The distinct areas might be public health (DOH); agriculture and fisheries production up
to primary processing (DA); food manufacture, fair practices in food trade, and consumer
protection (DTI) and methodologies for inspection, monitoring and surveillance (DOST).
While the role of national agencies might focus on setting policies and providing
guidelines, that of LGUs is the provision of support services.
Consistent with the assurance of food safety supply for its citizens as a primary focus of a
food safety program, public health takes precedence over other concerns related to food
safety. The DOH’s mandate and core competence render it the most appropriate agency
to lead the proposed TFFS. In line with this, the current disease surveillance program
needs to cover FBDs more adequately. To facilitate access and utilization of data
generated, moves towards better integration of the programs need to be taken.
As the inherent quality and safety of raw materials for food is established during
production, the DA plays a key role in food safety assurance. The recent efforts of the
department in responding to the provisions of EO 366 were guided by the principles of
good governance and provided the framework for reforms in both regulatory and
development programs in support of food safety. The proposed rationalization plan
deserves consideration by the proposed TFFS.
There is a need for the inter-agency programs provided for in the Consumer Act of 1992
to put greater emphasis on consumer education with the objective of strengthening
consumer advocacy. The Department of Education has been identified as playing a major
role in this area.
Academe needs to undertake relevant research and develop needed expertise in food
safety through appropriate curricular programs. More specifically academe needs to
utilize FBD surveillance data in socio-economic analyses that will lead to appropriate
policies. Academe is also in the best position to address capacity building and research
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