86
H. Toyofuku
Discussion and Conclusions
For biotoxins the CCFFP should use scientific methods to make risk management
decisions and document the reasons why the CCFFP did not accept recommendations from the expert consultation group. Risk management decision should be
based on science and other legitimate factors, if relevant. From the Salmonella
example, the need for risk assessment was highlighted. Some hygienic provisions
in the Standards developed by CCFFP need scientific information for decision
making. So CCFFP as a risk manager should ask timely and cogent risk management questions, understand the outcomes of risk assessments together with
associated uncertainties, and make risk management decisions in a transparent
manner.
The Vibrio example might be considered as a good example of utilizing the
risk analysis framework. CCFH asked a precise risk management question to
FAO/WHO, and FAO/WHO replied to the question in a timely manner. As a result,
CCFH made a decision which was not to establish microbiological criteria on
pathogenic Vibrio spp. in seafood.
From these examples, the following policy lessons were drawn:
• Risk management should be based on the results of risk assessments, and
decisions on risk management should be clearly documented.
• Risk assessment needs data, resources, expertise, time, etc. Sometimes large data
gaps prevent risk assessments; however, even in those cases, risk managers need
to make a decision. Therefore, continuous interaction between risk assessment
and risk management is needed from the beginning to the end of the risk
analysis process, in order to better use risk assessments in the decision making
process.
• The risk analysis process should be well planned, coordinated, transparent, and
documented.
• In converting the outcomes of risk assessments into mitigations, clear documentation of the process and the reasons for selecting an option are needed.
• Risk managers should be encouraged to understand risk assessment.
• The biggest concern is that risk managers use a hazard based risk management
option because of the history of successful implementation of such an option.
However, this does not guarantee future successes, because of possible lower
sensitivities in previous surveillance systems and/or underreporting factors.
• As indicated in the Criteria for Salmonella in bivalve molluscs, some hazard
based/microbiological criteria might not be meaningful depending on the prevalence of Salmonella. Establishing and implementing MC is a risk management
tool; however, such MC should be based on sound science and the MC must
protect public health of the consumers.
H. Toyofuku
Discussion and Conclusions
For biotoxins the CCFFP should use scientific methods to make risk management
decisions and document the reasons why the CCFFP did not accept recommendations from the expert consultation group. Risk management decision should be
based on science and other legitimate factors, if relevant. From the Salmonella
example, the need for risk assessment was highlighted. Some hygienic provisions
in the Standards developed by CCFFP need scientific information for decision
making. So CCFFP as a risk manager should ask timely and cogent risk management questions, understand the outcomes of risk assessments together with
associated uncertainties, and make risk management decisions in a transparent
manner.
The Vibrio example might be considered as a good example of utilizing the
risk analysis framework. CCFH asked a precise risk management question to
FAO/WHO, and FAO/WHO replied to the question in a timely manner. As a result,
CCFH made a decision which was not to establish microbiological criteria on
pathogenic Vibrio spp. in seafood.
From these examples, the following policy lessons were drawn:
• Risk management should be based on the results of risk assessments, and
decisions on risk management should be clearly documented.
• Risk assessment needs data, resources, expertise, time, etc. Sometimes large data
gaps prevent risk assessments; however, even in those cases, risk managers need
to make a decision. Therefore, continuous interaction between risk assessment
and risk management is needed from the beginning to the end of the risk
analysis process, in order to better use risk assessments in the decision making
process.
• The risk analysis process should be well planned, coordinated, transparent, and
documented.
• In converting the outcomes of risk assessments into mitigations, clear documentation of the process and the reasons for selecting an option are needed.
• Risk managers should be encouraged to understand risk assessment.
• The biggest concern is that risk managers use a hazard based risk management
option because of the history of successful implementation of such an option.
However, this does not guarantee future successes, because of possible lower
sensitivities in previous surveillance systems and/or underreporting factors.
• As indicated in the Criteria for Salmonella in bivalve molluscs, some hazard
based/microbiological criteria might not be meaningful depending on the prevalence of Salmonella. Establishing and implementing MC is a risk management
tool; however, such MC should be based on sound science and the MC must
protect public health of the consumers.