Coalition for an Enhanced Codex

Codex has produced an admirable number of MRLs for crop protection products considering the number of expert reviewers available and their volunteer status. However, the recent improvements in evaluation and scheduling processes have led to even greater demand for evaluation resources. Efforts must be taken to build on these process and scheduling successes and adopt changes to increase the JMPR efficiencies and review capacity to meet the ever-increasing demand for the review and recommendation of Codex MRLs for:  • New active ingredients, around the same time or shortly after their introduction into the marketplace,  • New uses, particularly for minor/specialty crops, and, • The reevaluation of chemicals that have been on the market for 15 years or more.  

Ideally Codex MRLs are established around the same time or soon after a new active ingredient or new use is approved by a national authority and in use on crops entering international commerce. If this does not occur, then farmers do not have access to new crop protection products and agricultural efficiencies cannot be realized by both farmers and consumers. 

There is a widely recognized need for adequate and sustainable funding to support the scientific advice provided to Codex Committees and the secretariat services. Stable and predictable funding is necessary for this fundamental area of work.  

While the demand for panel reviews has increased over the years, the number of experts on each panel has not increased substantially. The current rosters of JMPR Experts include just 45 toxicologists and 28 residues experts (status November 2018). The output of these experts is limited by the fact that they are working professionals who conduct reviews for JMPR on a volunteer basis, in addition to their normal professional workload (based on a survey in 2018, about half of the experts are allowed no time on the job to devote to JMPR work). JMPR Panels are similarly constrained in the number of evaluations and proposed MRLs that can be reviewed during an annual two-week joint meeting. The Canadian and US government have made funding available to train additional experts to serve in JMPR to respond to increased demands for Codex MRLs and to ensure a sufficient number of experts on the roster. 

During the review of dossiers, expert reviewers may reach out to data submitters for additional data or information. However, sometimes data needs or other issues are raised late in the process, leaving no time for the submitters to resolve them prior to the JMPR meeting. Where reviews are then postponed until the following JMPR, establishment of a Codex MRL is delayed by a full year and JMPR’s backlog is exacerbated.  

The FAO Manual provides a general timeline for Experts to communicate with their peer reviewer and the JMPR Panel, but does not provide the reviewers with any guidance regarding the timing of communication with submitters, which may be needed to complete the review and establishment of a Codex MRL during a single cycle.  

Following each session, the recommendations of the JMPR are reported out with full explanations regarding the scientific rationale for each recommended MRL. However, a full explanation is not necessarily provided for decisions to not recommend an MRL that was sought or decisions to recommend single-commodity MRLs rather than a crop group MRL. These explanations are of significant importance to registrants, farmers and national governments that rely on Codex MRLs. 

The World Trade Organization’s Agreement on the Application of Sanitary and Phytosanitary Measures (WTO SPS Agreement) references Codex as the relevant food safety standard setting body for harmonization and facilitation of international trade. It encourages Members States to harmonize SPS measures to the extent possible and to base these on international standards, guidelines and recommendations. 

National governments, registrants, farmers and traders, and the development community all have a growing awareness of MRLs and growing concerns about trade disruptions that can be caused by missing, non-aligned MRLs or zero tolerance policies. While Codex MRLs must be science based, this does not preclude CCPR from considering the trade impact and implications for farmers, countries, the global market for food, and the global economy. Codex MRLs can help ensure consumer health and safety and address practical trade facilitation needs for importing and exporting countries without sacrificing safety and scientific rigor.