Dr. S. Farzad Talakesh and Dr. Hamid Khaneghahi

Public Health Department, Iran Veterinary Organization

Food safety is an issue of increasing concern worldwide and prioritization of food safety as an essential public health function has been advocated recently in Iran by the following bodies:

• Iranian parliament ratifies the laws and regulations.

• The administrative branches of the Iranian Government (IVO,¹ MOH,² ISIRI³) prepare and suggest legal drafts and forward them to special committees of parliament for ratification. Because of the separate efforts, there are overlaps that create obstacles to progress on food safety.

Most of Iran’s organizations related to the health of plants, animals, and humans focus on maintaining and developing food safety standards through the ISIRI and the PPO.⁴ There are five aspects as follows:

The laws and regulations on food safety in Iran include the following:

• The food, drug, and cosmetics act—MOH;

• The veterinary act—IVO;

• The standards act—ISIRI;

• The plant protection act—PPO; and

• The environmental protection act—EPO.

We know that Iranian citizens have become more aware not only of food safety issues but also want to know who is responsible for such issues. Iranian food safety programs aspire to be risk-based, science-based, and transparent; however, most of these acts are rudimentary and need strengthening in order to implement new monitoring and surveillance programs and achieve improved food safety. In addition, each administrative branch has specific legislation, and the results of a branch’s activities are disseminated widely. Expert advisory committees and public meetings sometimes help in the preparation and ratification of the pertinent laws and regulations.

At a time when issues such as globalization, self-regulation, hazard analysis and critical control points, and quality control have become so important, Iranian food safety principles incorporated in regulations are considered as urgent national priorities to meet the needs, demands, and concerns of industry and citizens. These principles include the following:

• Foods must be safe and wholesome to be marketed.

• Regulatory decisions regarding food safety must be based on sound science.

• The government has enforcement authority.

• Processors, manufacturers, distributors, importers, and others engaged in food marketing must comply with the law.

• The regulatory process should be transparent and should be made accessible to the public (through MOH, IVO, ISIRI Web sites).

The principal objectives of the food control system are:

• Promoting public health by reducing the risk of foodborne illnesses (IVO and MOH);

• Protecting consumers against unsanitary, unwholesome, mislabeled, or adulterated raw food of animal origin (IVO) and processed food of animal and plant origin (MOH);

• Contributing to economic development by maintaining consumer confidence in the food system and providing a sound regulatory foundation for the domestic and international trade in food (IVO’s Quarantine and International Affairs Office is responsible for this aspect);

• Encompassing all the food produced, processed, and marketed within the country, including imported and exported food; and

• Maintaining a statutory basis that is mandatory in nature.

Administrative branches and their responsibilities include the following:

• The Food, Drug, and Cosmetics General Office of the MOH is responsible for most foods, particularly processed ones.

• The General Health Office for Food Establishments of the MOH is responsible for the control of health measures in food establishments, except those for animal products.

• The General Public Health Office of the IVO—particularly the Animal Health, Food Safety, and Inspection Service—is responsible for meat, fish, egg, poultry, and other products of animal origin as well as for monitoring drug residues.

• The General Quarantine Office of the IVO, especially, is responsible for animal transport and certification of animal products for export and import.

• PPO is responsible for pesticide registration and plant health inspection.

• The AEO is responsible for radioactivity assessment in foodstuffs.

The national food monitoring and inspection system activities include the following:

• Inspecting for compliance with the hygienic and other requirements in standards and regulations;

• Evaluating Hazard Analysis and Critical Control Point (HACCP) plans and their implementation (HACCP is now mandatory in fish and shrimp processing plants, and many food processing plants also follow HACCP plans);

• Sampling food during harvest, processing, storage, transport, or sale to establish compliance, gather information for risk assessments, and to identify offenders;

• Detecting different types of food decomposition by organoleptic assessment to determine which food is unfit for human consumption or which is otherwise sold deceptively to the consumer, and taking the necessary remedial action;

• Detecting, collecting, and transmitting evidence when breaches of law occur, and appearing in court to assist in prosecution;

• Encouraging voluntary compliance, particularly by means of quality assurance procedures;

• Inspecting, sampling, and certifying food for import and export; and

• Risk-based audits in establishments working under such safety assurance programs as HACCP.

The following are the needs and requirements for laboratory services, an essential component of a food control system:

• More capital investment;

• Well-qualified staff;

• Continuous updating of knowledge and skills at the international level;

• Qualifying the national food reference laboratory to deal with each type of animal that is a source of food; and

• Adoption by regional analytic laboratories of instrumentation and methodology that have been standardized and validated by the national reference laboratory.

Food control agencies currently identify the specific training needs of their food inspectors and laboratory analysts as a high priority. These activities provide an important means of building food control expertise and skills in all interested parties, and thereby serve an essential preventive function. They include:

• Delivery of information, education, and advice to stakeholders across the farm-to-table continuum;

• Provision of balanced factual information to consumers;

• Information packages and educational programs for key officials and workers in the food industry; and

• Provision of reference literature to extension workers in the agriculture and health sectors.

The Bureau of Public Health has six offices that are involved in food safety functions:

1. Animal Health and Sanitary Office, whose role is policy making and providing standards for, and hygienic control of, farms and processing plants. It is responsible for application of good animal husbandry practices and good man-

ufacturing practices (GMPs) in farms and processing plants and issuance of health licenses for animal husbandry and for processing plants.

2. Animal Feed Inspection Office, whose role is policy making and providing standards and hygienic control of the animal feed chain. It is responsible for the application of GMPs in animal feed manufacturing and chemical and micro-biological monitoring of animal feed.

3. Edible Animal Products Inspection Office, whose role is policy making and providing standards and hygienic control of edible animal products. It does this through application of HACCP systems and risk assessment and management.

4. Chemical Residues Monitoring Office, whose role is to set maximum residue limits for veterinary drugs. It does this through sampling for residue assessment and monitoring of veterinary drugs and other chemicals, such as heavy metals, in foodstuffs.

5. Meat Inspection and Abattoirs Supervision Office, which is responsible for policy making and providing standards and hygienic control of abattoirs (slaughterhouses). These activities include upgrading and modernizing abattoirs, tracking animal diseases, application of HACCP systems in abattoirs, and risk assessment and management.

6. Nonedible Animal Products Inspection Office, which is responsible for policy making and providing standards and hygienic control of nonedible animal products, such as casings. It does this through risk assessment and management and application of HACCP systems.

What Does the National Food Control System Need?

In summary, the system needs the following elements:

• Policy and operational coordination at the national level;

• Delineation and implementation of clearly defined leadership functions and administrative structures, including accountability;

• An integrated national food control strategy;

• Implementation and operation of a national food control program;

• Establishment of regulatory measures;

• Monitoring of performance systems;

• Facilitation of continuous updating and improvement;

• Overall policy guidance;

• Additional funds and resource allocation;

• Setting of advanced standards and regulations;

• Compliance with international organizations, in particular with Codex Alimentarius; and

• Participation in international activities related to food control.