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Suspension of Eligibility
Published on February 18, 2002
Countries often update and revise public
health sanitary measures. For example, the United States Food
Safety Inspection Service (FSIS) implemented a new sanitary
measure domestically, the Pathogen Reduction/HACCP final rule.
In this case, a notice was given to each exporting country
that the new measures must be adopted by the foreign food
regulatory system in either the same way or in an equivalent
manner.
When an Importing country updates its
importing regulations, it must provide notice of the particular
sanitary measure, which must be achieved by the exporting
country at a level of protection the importing country deems
appropriate. To ensure that the importing countries maintain
equivalency, the Exporting countries first provide a written
assurance that the new Food Safety Objectives (FSO) are being
implemented and second to submit documentary evidence to support
measures implemented are equivalent. During the next on-site
foreign inspection system audit, the implementation of the
measure is verified. The Importing country will
then release one of the following final rulings:
- The Importing country recognizes that
the exporting county's alternative sanitary measure achieves
the same level of protection provided by the importing country's
measures
- The Importing country requests more
information to facilitate further consideration of the submission
or
- The Importing country rejects equivalence
of the alternative sanitary measure and provides appropriate
reasons for that decision.
Occasionally, some circumstances could result in the suspension
of eligibility and an interruption of trade. One example is
if an exporting country does not provide satisfactory documentation
of an equivalent sanitary measure. A second example could
be if a system audit reveals that an exporting country is
not implementing a public health sanitary measure in the manner
that FSIS initially determined to be equivalent. A third example
is if an emergency sanitary measure is implemented by FSIS
to address a hazard that is so severe that no product can
enter the marketplace from a foreign establishment until the
control is in place.
In December 1999, after the United States FSIS announce it
had completed its annual review of equivalent countries, of
the 37 countries evaluated, 32 had implemented an equivalent
of the new pathogen reduction/HACCP requirements. Paraguay
was suspended for both unsanitary establishment conditions
and for failing to implement E.coli requirements. Guatemala,
Honduras, Slovenia and the Dominican Republic voluntarily
delisted all establishments certified for export to the U.S.
while they continued to implement pathogen reduction/HACCP
systems.
An importer applies a rational evaluation process to determine
the initial eligibility of foreign inspection systems and
verifies, annually, that equivalence is maintained. Cumulatively,
the evaluation process summarized in this document complies
with international obligations under the SPS Agreement, comports
fully in the Importers laws, and effectively implements the
Importers inspection regulations by ensuring that domestic
consumers receive the same level of protection in imported
meat and poultry as is achieved domestically.
The degree to which consumers will trust food from an exporting
country is directly related to how effectively food production
is regulated by the foreign system. Thus, trust becomes an
equivalence issue with both food safety and trade implications.
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