4th Meeting of the Pan American Food Safety Commission (COPAIA 4), Mexico, F.D., Mexico, April 20, 2005

FOOD CONTROL IN VENEZUELA

Summary
Unlike other Latin American countries, Venezuela lacks a tradition of exporting agricultural products; an exclusive oil economy --with a strong tendency to food imports -- prevails both in the private and in the public sector. This, along with other political, economic, social and cultural reasons make food control in Venezuela unable to follow a systematized model such as that of countries with strong external demands regarding quality, and where, very frequently, these demands extend towards the production aimed at domestic consumption. The Venezuelan food control system has been characterized by the participation of multiple organizations with several legal frameworks, functions and responsibilities acting on a separate way.
Nevertheless, the country’s favorable constitutional framework supplies the basis for the development of updated and harmonized standards in order to support the modernization of food control. Likewise, the infrastructure of national laboratories and food inspection services, attached to the corresponding ministries, may be strengthened through adequate actions, including the training of human resources and sufficient supply material resources and other managerial aspects.


Background

Oil exploitation, as the almost exclusive activity for the production of financial resources in Venezuela, condemned the agricultural and breeding activity to have a low impact on the GDP. This low impact is also related to the systematic and sustained establishment, for over fifty years, of inadequate non-sustainable policies lacking financing and/or support and with a mere subsistence value for the rural area people. Therefore, Venezuela holds a high agro-ecological potential but a low production and productivity of its land; so, agricultural and livestock activity is not enough to cover the demand for fresh products or commodities for the agro-industrial sector and, in conclusion, imports are necessary.

This supply and demand unbalance of strategic agricultural and livestock sectors makes imports necessary, generating an evil dependency relation, which undermines the national security.

In the political-legal field, this situation is being faced with the “Organic Bill for Food Security and Sovereignty” (“Proyecto de Ley Orgánica de Seguridad y Soberanía Alimentaria”); in the field of alliances with other countries, commercial relations are oriented towards complementary actions and in our land, setting special development regions or areas to timely focus the economic-financial resources in order to plug this gap. In short, we are establishing the endogenous development.

Given that food import is a way to outline hegemony-dependency, who would be interested in the development of production-exportation of agricultural-livestock products in Venezuela? Would it be the old developmental model or the new neoliberal one with the Green Revolution framework that for years buried our agro-ecological potential and our ancient capacities regarding food production adapted to our dietary requirements and consumption patterns? Evidently, it would not be those who, for years, amassed a fortune thanks to their indifference towards true national concerns such as freedom-independence, sustainable development, equity-solidarity; but Venezuela is another country, and it has changed for ever.

In this sense, the Venezuelan Ministry of Health and Social Development [Ministerio de Salud y Desarrollo Social, MSDS] has regulatory authority concerning regulation, writing and follow-up of policies, planning and performing National Executive’s activities regarding integral health, including sanitary regulation and control of food and products for human use and consumption such as medicines, cosmetics and similar products. (1)

The legal framework is completed with around 500 standards drawn by the Technical Committee for Food Products with the participation of the Food Hygiene Management, the National Hygiene Institute [Instituto Nacional de Higiene (INH)] and the National Nutrition Institute [Instituto Nacional de Nutrición (INN)].

The integration of INH to the MSDS Food Hygiene Program is materialized through the activities of the Food Control Division, which checks the fulfillment of legal regulations evaluating food products for sanitary record or control. The INH coordinates the National Network of Food Analysis Laboratories (bound to RILAA) in order to investigate the causative agent in foodborne illness outbreaks and allow the competent authorities to take the appropriate corrective and preventive measures.

The INN, as MSDS attached organism, represents a supportive tool for the Food Hygiene Program as well, since it channels the efforts of the Venezuelan society in order to obtain the enjoyment of the right to an ideal nutritional level through the coordination of national nutritional plans, the surveillance of the food and nutritional situation, the development of regulations and follow-up activities, assessment and control, promotion and orientation of education regarding food and nutrition.

The General Direction of Environmental Health and Sanitary Control is the Department of the Ministry of Health and Social Development in charge of conducting the managerial activities of the Food Hygiene Program. It

exercises its legal competence through the Food Hygiene Direction [Dirección de Higiene de los Alimentos (DHA)] and the Regional and Local Services attached to the Regions of Health and Social Development throughout the country. As a central level organ, the DHA performs regulation, assessment, advisory, and coordination activities as well as registration, surveillance and control of food, equipments, packaging and materials in contact with food. At a national level, the program is carried out by the Regional and Local Services of Food Hygiene present in every state of the country.

The program is aimed at minimizing the risks for the population’s health, protecting the consumers’ interests and contributing to the improvement of the quality of life of the Venezuelan people through sanitary control and surveillance at the different stages of the productive chain.

This approach faces a number of restrictions concerning the achievement of the intended goals, since it is not focussed on the identification and control of those activities carrying an increased risk of contamination and it does not allow the use of preventive measures to reduce or minimize the adverse effects caused by the consumption of contaminated food. This should be added to the fact that the registration activity has been exaggerated at the expense of food control and surveillance.

This model of control has been strongly questioned since practice has shown that it is not effective to remarkably reduce FBD incidence, protect the consumers’ interests, prevent or reduce food spoilage, issue warranties for exports, and perform surveillance of special programs such as flour and salt fortification, among other weaknesses. In order to advance towards the implementation of an integrated food control system capable of accounting for the complexity of the issue, the Venezuelan Ministry of Health and Social Development faced the present situation diagnosis of the food control program in the country, conducted with the participation of the DHA, the INH and the INN, in cooperation with the PAHO/WHO Representation in Venezuela.


Current Situation

The present evaluation was carried out using the questionnaire suggested by the Pan American Institute for Food Protection and Zoonoses for the assessment of food control systems in the Region of the Americas, considering the following items:

I.  Food Laws and Regulations

II.  Food Control Management

III.  Inspection Services

IV.  Epidemiological Surveillance and Laboratory Services

V.  Education, Communication, Information and Training

The approach methodology consisted in organizing five working groups, one for each of the abovementioned items, with the representation of each of the aforementioned participants in all of them. Their diagnostic picture for their pertinent areas is the following:

I. Food Laws and Regulations

In Venezuela, food legislation is not based on risk assessment, management and communication, although MSDS technical regulations and current standards are taking some of these aspects into account.

Nevertheless, the Venezuelan legislation gathers almost every aspect considered relevant in this regard, such as the possibility of taking provisional measures when unacceptable risk levels are identified (2, 3); it acknowledges the right of consumers to have accurate information (4, 5, 6, 7); it foresees food follow-up and confiscation of food if problems arise (8, 9) and primary responsibility of processors and producers towards food quality and safety (10, 11, 12), and it defines control (13, 14) and sanction (15) mechanisms.

Similarly, Venezuela is trying to harmonize its legislation with international standards. Therefore, during 2001 the National Codex Committed was created with the participation of all the actors of the food chain, except for the primary producers who have not yet appointed their representative before the Committee. Both the Focal Point and the different Codex Subcommittees work according to the Regulations established for that purpose by the National Committee.

II. Food Control Management

MSDS’ food control is essentially limited to sanitary record, inspection of industrial and commercial facilities and vehicles for food transportation along with sample taking during production, elaboration and commercialization of food for their analysis by officially well-known laboratories and according to a schedule annually established by the DHA and the INH, considering the following aspects: high-risk food, food for vulnerable populations, and attention to special programs developed by the Ministry. Preventive actions coordinated with other official institutions are uncommon, with a prevalence of those of retrospective nature.

The legislative and regulatory framework, in general, does not consider the principle of shared responsibility between the government, the productive sector, the marketing sector and consumers; therefore, surveillance and control strategies based on this principle are not used.

For this and other tasks, the DHA has a multidisciplinary team formed by graduate professionals, some of them with a Masters degree or specialized in food science and technology. The Regional and Local Services of Food Hygiene attached to the Regions of Health and Social Development throughout the country have human resources with basic instruction regarding food surveillance and control, such as Veterinary Doctors, Sanitary Inspection Senior Technicians, and Public Health Inspectors. However, these officials need to be updated regarding application of new control strategies such as risk analysis, GAP, GMP, HACCP, sampling methods and new production technologies.

The financial resources for the Program come from the National Government and both the central level offices and their attached institutes are considered to lack sufficient and timely budgetary assignments to perform the essential role of the institution as regards food control and surveillance and FBD prevention and control.

Twenty out of 23 Regions of Health and Social Development throughout the country are not centralized; they are autonomous regarding budget, administration, financial and managerial aspects, compliant with the relevant Decrees, as foreseen by the Organic Law of Public Administration (16), although the Services of Food Hygiene are regulated by the regulatory guidelines put forward at central level.

The MSDS and all its organisms elaborate the annual activity plan called National Operative Annual Plan [Plan Operativo Anual Nacional (POAN)] following the strategic guidelines established in the 2001-2007 Economic and Social Development Plan for the Nation, which is quarterly followed-up using an application which gives an estimate of the managerial indicators.

III. Inspection Services

Inspection can be performed at any stage of the food chain, including production, elaboration, commercialization, and any other activity in which food handling is involved. Inspection activity may be focused on food, processes, facilities and quality assurance systems used in the food chain. The Regional Services of Food Hygiene perform the sanitary inspection in compliance with the established conventional standards and procedures, although it is clear that in order to ensure food safety and quality a combination of strategies based on the analysis of risks for the population should be set forth and applied.

Despite the fact that a Procedures Manual for execution is lacking, and the documentary evaluation of HACCP plans is not carried out and food establishments do not verify their implementation, it is possible to assert that there are inspection premises and processes to comply with hygiene regulatory standards, which are set in the following legal instruments.

The officials in charge of the Sanitary Inspection are responsible for recognizing, gathering and forwarding evidence and they are acquainted with the legal standards in force. In most cases, the Regional Services themselves take the legal measures and only on very specific instances they wait to receive instructions from the central level.

In general, the national network of laboratories has the adequate conditions to perform physical, chemical, microbiological and toxicological tests, and to submit reliable analytical results.

Inspection, sampling and certification of food for import and export are partially performed, generally when required; nevertheless, the requirements set forth in the regulations in force are demanded according to the following cases:

a) Registered Imported Products. The Food Sanitary Register issued by the Ministry of Health and Social Development should be submitted at ports, airports, and at any other border post authorized for the entry or exit of food products, and for some items the Certificate of Sanitary Guarantee of the country of origin is binding for each product lot.

b) Imported Products not requiring Sanitary Register. It is necessary to submit the Sanitary Importing Permit issued by the Ministry of Health and Social Development and the Certificate of Sanitary Guarantee of the country of origin for each product lot.

It can be asserted that the inspection and certification systems of the country are not effective to track the origin of products which do not comply with the sanitary standards and technical regulations due to the different criteria to perform the inspection of food products entering or exiting the country, overlapping functions among the different competent ministries, lack of updated personnel in charge of inspection at ports, airports and at any other border post authorized for entering or exiting food products and, particularly due to the absence of a Procedures Manual to carry out inspections and certifications of imported or national products although the required bails are legally established in the General Regulations for Food and Supplementary Standards.

Likewise, the country does not count with a procedure manual to deal with emergencies. When this kind of situation took place, the pertinent inspections and sample taking for analysis and confiscation of products were carried out. For imported products, when International Organisms sent a warning, the same abovementioned steps were taken, timely proceeding to confiscate goods.

Besides, it is worth mentioning that although the country does not apply risk analysis, in 1991, when an emergency related to the Cholera epidemics in Peru emerged, the MSDS took control measures and elaborated a Manual for Analytical Procedures and Special Sanitary Measures to prevent cholera from entering the country. Also, a timely response was given in the case of Dioxins in powdered milk coming from Belgium and, although official laboratories did not carry out this analysis as a routine, the relevant analysis were performed to facilitate decision making in order to protect the health of the population.