The need to improve FSMSs and HACCPs

While the global merchandising of food commodities remains strong, safety and quality standards between countries differs greatly. Food exporters and importers should evolve trade rules, unify inspection processes and synchronize food related statutes. By Logan Portmann

The global merchandising of food commodities is as formidable as ever, but lately trade is also intertwined with safety and quality standards of various consumer nations. This tends to put the peril of contamination back into our spotlight…whether accidental or something sinister.

It seems that as consumer countries become ‘greener,’ they are also becoming more aware of the health costs of food safety. Then the subject is addressed with a bevy of acts and procedures to promote healthy foods while detecting and arresting food adulteration. As a result, not only do we see that Food Safety Management Systems (FSMSs) have become more robust over the past decade or so, but they now also vie with politically strong new views on food quality and integrity.

Years ago, the World Trade Organisation (WTO) recognised the United Nations-established Codex Alimentarius (with origins in the Austro-Hungarian Empire) as the basic standard for Hazard Analysis and Critical Control Points (HACCP). However, the prevention and mitigation of food safety risk is largely left to manufacturers, exporters, and controllers, who in turn, must work with country specific implementation and regulation.

In the United States, the overhaul of our Food Safety Modernization Act (FMSA) began in earnest in 2017 and now includes various deadlines and dates extending through 2022.

However, as mentioned, there are similar acts in Canada (Food Safety Enhancement Program), Australia and New Zealand (Imported Food Control Act), the European Union (Regulation 178/2002), and Brazil (regulations enforced by the National Agency of Sanitary Surveillance). Further, China, Russia and India have their own regulations and laws enacted to help prevent contamination and infestation.

Turning to our coffee-trading friends – we note with thanks to the Green Coffee Association (GCA) and National Coffee Association (NCA) of the United States – that green coffee quality regulations recognise the more flexible and transitory nature of a product subject to roasting. Still, wherever possible, traders must steer clear of contaminates such as pesticides, mycotoxins, and the emerging issue of MOSH (mineral oil saturated hydrocarbons) and MOAH (mineral oil aromatic hydrocarbons) from packaging materials.

The problem is how to mesh our markets. For instance, the US, Brazil and the EU all have differing Maximum Residue Levels (MRLs) for many contaminates. For example, phorate has an MRL of 0.05 mg/kg for coffee beans in the EU, while the US sets it to 0.02.

For glyphosate, another pesticide that is used in Brazil, the EU sets a maximum level of 0.1 mg/kg in coffee and 2.0 mg/kg for tea and mate (per Regulation (EC) No 396/2005 of the European Parliament and of the Council of 23 February 2005 on maximum residue levels of pesticides in or on food and feed of plant and animal origin). Incredibly, the US Environmental Protection Agency has a tolerance of 1.0 mg/kg for glyphosate for coffee, according to the Electronic Code for Federal Regulations or eCFR (which is ten times the amount the EU accepts). For tea, the US’s MRL is lower than the EU, at 1.0 mg/kg. Luckily, glyphosate was removed from the list of authorised products in Vietnam by its Ministry of Agriculture and Rural Development this past April.

MRL Country Standards Differ Greatly

The International Coffee Organisation (ICO) published a report on the MRLs of pesticides applicable to coffee in selected countries. The report included a table that lists the MRLs for the 32 pesticides applicable to coffee beans (SB 0716) and roasted coffee (SM 0716) covered by the Codex Alimentarius that compares various countries’ MRLs for a number of pesticides, which quickly demonstrates how varied the standards can be. An excerpt is provided as the table above.

Considering the importance of the large export volume of Brazilian coffee, proper national tests for levels of contaminates at pre-shipment will go far to help consignees mesh with destination food grade requirements – if only the requirements were uniform.

When exporting from Brazil, the levels should be well below the allowable range and indeed compliant with the EU MRLs. Thus, upon arrival and discharge say in the EU, if for some exterior reason these goods out-turn with excess levels of any kind, a rejection issue may arise.

Only with proper pre-shipment testing of goods, packaging materials, and review of containers can it be shown that the increased levels of contaminates occurred during the transit and were an insurable fortuity.

Imagine yourself as the supplier at origin. How would you process consignee’s assertions of non-compliant goods, improper packing, and flawed containers? Or imagine yourself as consignee at destination, would you accept cupping as conclusive proof compared to the (expensive) precision of gas chromatography machines?

The problem for commodity insurers is that the ability to detect contaminates in a laboratory setting is expanding at levels that are effectively magnitudes above the actual workplace levels, ie parts per billion (PPB) vs parts per million (PPM).

This makes it relatively easier to assert fault from the confluenced vantage point of high-tech end processors compared to the disparate shipping points of origin suppliers.

For the moment our job as commodity insurers is to press for international agreement on uniform pre and post export procedures that cut away the source of as many contaminate laden variables as possible.

How would this apply when considering coffee packaging? Stay tuned!

It is in the interest of food exporters/importers to evolve trade rules, unify inspection processes, and harmonise food-related statutes. In turn, we (as insurers) can continue to provide broad protective coverage against the external perils of contamination with the on-going use of those magic words… “howsoever arising.”

  • Logan Portmann is an account executive at Rekerdres & Sons Insurance Agency, Inc, a Dallas, Texas based commodities insurer. He may be reached at [email protected].

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