The Evolving Appreciation of Food Safety

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There is a saying in China that people are the foun-
dation of the state while food is their basic neces-
sity. The state therefore has the obligation to ensure
sufficient food supplies to the people. Generally
speaking, there are two requirements as to the food
supply: one is sufficiency in quantity and the other
in quality.

As regards the food quantity, on the one side, the

state has the motivation to keep independence by
guaranteeing food security. On the other hand, it
also concerns its obligation to protect people from
hunger and malnutrition. Against this backdrop, the
appropriate agriculture policy as well as legislation
relating to food security

1

should be enacted in order

to ensure sufficient food from the perspective of
quantity. Meanwhile, the international community
also has undertaken considerable efforts to solve
the food insecurity issue, such as the role of the
World Food Program in food aid. Given the current
global hunger issue, however, further efforts are
called for both at the national and the international
level if the Millennium Development goal to reduce
poverty and hunger by half by the year 2015 is to be
realized on time.

Comparatively, the quality aspect of food is also

an important but more complicated concern since it
can display many attributes, including hygiene,

safety, nutrition, etc. It is therefore not surprising
that food safety and food quality are used together
or interchangeably from time to time. Certainly,
with the endless outbreak of food safety issues, food
safety has become a public concern and attracts
ever increasing attention. Yet, it is important to note
that this is not the time for food safety to become a
food quality characteristic,

2

but to remain separate

from the latter, in order to restore consumers’ confi-
dence in the credibility of government and the food
industry. That is to say the long term considerations
regarding food quality have shifted, at least par-
tially, toward food safety. Evidently, contrary to
other quality attributes, safety is a fundamental
requirement for food in which it is the precondition
to realize other quality attributes and as well as food
quantity. It is this very considerable significance to
health and life that makes food safety worthy of

The Evolving Appreciation of Food Safety

84

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* Sun Juanjuan is a PhD candidate in the Nantes University and

researcher in the Lascaux Program. Contact email: sunjuanjuan_
1984@163.com.

1 As a case in this point, a draft Grain Law is under the public

consultation currently with the purpose to ensure food security in
China.

2 A. Rohr, K. Luddecke, S. Drusch, M.J. Muller and R. v. Alvensleben,

“Food Quality and Safety – Consumer Perception and Public
Health Concern”, in Food Control 16 (2005), at p. 649.

The Evolving Appreciation of Food Safety

Juanjuan Sun*

The growing attention placed on food safety as a public concern relates to a background
of food safety issues that arise one after another. Besides, with the passage of food
safty issues along the worldwide food trade and food production chain, food safety
has inevitably become a global issue. Therefore, a joint effort is required in order to
ensure food safety regulation. In this case, the priority is evidently to formulate a unified
definition of food safety since it is forms the foundation for further harmonization in
the food domain. To this end, it should be noted that on the one hand, the food safety
issues are quite negative as regards consumer confidence in the food industry and food
regulatory agencies; nevertheless, on the other hand, it can still help us to understand
how the appreciation of food safety develops and how the corresponding food safety
legislation is drafted. This paper therefore aims to first explain how the evolution of food
safety issues gives rise to a changing appreciation of food safety and then points out its
valuable significance to the common appreciation, legal requirements and regulatory
approaches towards food safety.

EffL 2-12 16.04.2012 11:23 Uhr Seite 84

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The Evolving Appreciation of Food Safety

particular attention in the food control system. A
finely developed trend has therefore emerged in
national/regional practice, namely to establish fun-
damental legislation on food safety so as to lay the
legal foundation for the entire framework of food
legislation. Additionally, it is also important to sepa-
rate the appreciation of food safety from the gen-
eral idea of food quality in order to distinguish the
regulation of food safety and of food quality which
may have different purposes and demand a differ-
ent regulatory approach. In view of this, the paper
will first provide a general overview of the food
safety issue in order to introduce how the independ-
ent appreciation of food safety came into being.

I. The Appreciation of Food Safety

Based on Individual Issues

Regarded as the inventor of farming and medicine
in ancient china, Shen Nong is remembered as a
famous hero from generation to generation. For his
contribution, he tested numerous plants in order to
find out whether or not they were safe; sadly, he
died of a plant-test due to its inherent toxin. Though
it is only a myth, it is the personal practice and
experience dedicated to the historical appreciation
of food safety. Fortunately, with the development
of science and technology, increasingly effective
methods have been found in order to test the safety
of foods. As early as 1800s, a booked named A trea-
tise on adulterations of food, and culinary poison

3

offered methods for people to distinguish pure food
from adulterated food based on the development of
chemistry. Certainly, food adulteration has been a
food safety issue for a long time and still occupies
consumers in the developing countries. In addition,
other long-term coexistent or newly emerged food
safety issues have also led to the up-to-date appreci-
ation of food safety. The following section will pro-
vide a general introduction to the evolution of food
safety issues and their influences on the apprecia-
tion of food safety.

As regards the evolution of food safety issues, it is
interesting to note that the incidence of food safety
issues has a pattern over the times. In this respect,
the publication of the EU in 2007, 50 years of food
safety in the European Union

,

4

provides the best

illustration in which the food safety issues vary
in each decade due to societal and economic devel-
opments. As a result, the resulting regulation has
given rise to a corresponding appreciation of food
safety. Similarly, with the first food law coming into
effect in 1906 as a response to maintaining the
purity of food, the experiences of the USA also
provide an example of how food safety issues and
their corresponding influences on on the apprecia-
tion of food safety progressed. Based on those
regional/national experiences, the observed pattern
of food safety issues and the resulting regulation
was addressed as follows.

In the first place, food safety issues arose from

sanitary concerns/ food hygiene. In this regard, the
novel The Jungle, in which the preparation of food
in disgusting unsanitary conditions in the food
companies was described, is always mentioned as a
catalyst to advance food regulation in the USA. As a
matter of fact, food hygiene is a basic requirement
for food. And for a very longtime, the prediction
of whether the foods were safe or not mainly
depended on their sanitary conditions, in particular
certain visible sanitary problems on the surface of
food or in the plant which used to be targeted by
sanitary requirements and controlled by organolep-
tic monitoring. It is important to note here that the
term sanitary conditions meant not only free from
foreign agents or the clean appearance of the final
product, but also the food production process such
as the environment in which it was produced or
processed. Besides, the foreign agents which may
cause safety issues on food, may be some physical
substances like hear or stone, and it can also be bio-
logical agents. With the advancement of science and
technology, the environment for food production
was improved. Yet, biological contamination re-
mained a serious concern to food safety. Given its
invisible nature, it can only be handled with the aid
of science and technology, such as the application of
Hazard Analysis and Critical Control Point.

Secondly, the abuse or misuse of chemical sub-

stances such as the agricultural inputs or food addi-
tives led to food safety issues in which food adulter-
ation could be a consideration. As a response, differ-
ent legal approaches were adopted in order to han-

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85

3 Frederick Accum. A Ttreatise on Adulterations of Food, and

Culinary Poisons

, published in 1820, available on the Internet at:

http://www.gutenberg.org/ebooks/19031 (last accessed on
29 February 2012).

4 EU, 50 years of food safety in the European Union, Office for

Official Publication of the European Communities, 2007, available
on the Internet at: http://ec.europa.eu/food/food/docs/50years_
foodsafety_en.pdf (last accessed on 29 February 2012).

EffL 2-12 16.04.2012 11:23 Uhr Seite 85

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dle this issue. For example, for the former, there are
sound reasons to use pesticides or animal drugs,
yet, the excessive residue of those chemical sub-
stances can also put consumers in danger. As a
result, positive list systems were generalized for
residue control. And for the latter, an early legisla-
tive approach, so-called recipe legislation, was
applied both in the EU and the USA so as to ensure
the purity of food by providing compositional stan-
dards for a certain food. Yet, such strict restrictions
on the substance of food composition were not
compatible with the rapid development of the food
industry. As a result, the general principle was
applied that chemical substances can be employed
as long as their safety is proved by long term experi-
ence or scientific assessment. Certainly, as put by
Paracelsus, the dose makes the poison. Hence the
use of safe chemical substances is still subject to
limitations such as the quantity requirement or tar-
geted population. However, it is important to note
that the adulteration in this respect may not only
cause food safety concerns but also food quality
concerns. For example, the addition of hazardous
substances like melamine which is not a food addi-
tive into food can cause harm or even death to con-
sumers. On the contrary, the illegal substitution of
inferior or cheaper ingredients for profit may not
be dangerous for the consumer but sub-standard to
their expectations. Regulation in the form of com-
positional specifications may therefore have two
concerns, including food safety and food quality.

Third, food nutrition has caused safety concerns

since either both undernutrition and overnutrition
can give rise to the safety considerations. For a long
time and even now, food nutrition is still a serious
concern from the perspective of food security,

5

in

order to solve the problem of malnutrition. Nowa-
days, with the rising of living standards, more and
more nutrition targeted foods are being placed on
the market. Though food nutrition has been adver-
tised as an attractive way to improve food quality, a
variety of safety concerns have also caught the
attention of the public. For example, one serious
food safety issue happened in China in 2004, where
a large number of babies suffered from ‘big head
disease’ on the ground that the milk powders lacked
protein. And even where foods linked with con-
sumer expectations are concerned, such as health
food, the exaggerated nutritional declaration may
mislead them. Furthermore, the issue of obesity is
becoming increasingly prevalent. As a reminder, it

important to note that obesity is a problem not only
in western countries but also in developing coun-
tries like China.

6

Additionally, since food is not only produced in a

natural environment but also as the result of sci-
ence and technology, doubts relating to science and
technology have give rise to the argument whether
the tech-food is safe or not for human consumption.
It is certain that benefits from food have been con-
siderably developed by science and technology.
However, as each coin has two sides, the negative
impact in this regard can never be ignored. As far as
science and technology are concerned, risk was
acceptable where it could be compensated for.

7

However, this risk is difficult to predict. Given the
uncertainty around the risk for human safety and
the environment, the application of certain modern
food technologies has faced challenges, as shown by
the arguments relating to biotechnology for geneti-
cally modified food or nanotechnology.

Based on this general review of food safety

issues, three conclusions can be drawn here to con-
tribute to the regulation and appreciation of food
safety.

II. Common Appreciation of Food

Safety

As a vehicle, it is the food related hazards that cause
the adverse health effect.

8

Varying in physical,

chemical, biological, nutritional or technical proper-

The Evolving Appreciation of Food Safety

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5 Food safety and food security are also closely. Generally speaking,

the evolution of the concept of food security has taken food safety
into consideration. for example, on the Rome Declaration on
World Food Security and World Food Summit Plan of Action, the
concept of food security was defined as “when all people, at all
times, have physical and economic access to sufficient, safe and
nutritious food to meet their dietary needs and food preferences
for an active and healthy life”.

6 T. Colin Campbell and Thomas M. Campbell II, The China Study,

the Most Ccomprehensive Study of Nutrition Even Conducted and
the Starling iImplication for Diet, Weight Loss and Long Term
Health

, First BenBella Books Paperback Edition, 2006.

7 Christine Noivile, “The French Regulatory System on GMOs”, in

Michelle Everson and Ellen Vos (Eds)., Uncertain Risks Regulated,
published by Routledge-Cavendish, 2009, at p. 159.

8 The following analysis is based on the definition of hazard which

refers to a biological, chemical or physical agent in, or condition
of, food with the potential to cause an adverse health effect.
And risk which means a function of the probability of an adverse
health effect and the severity of the effect consequential to a haz-
ard(s) in food. See, Codex Alimentarius Commission, Procedural
Manual, Nineteenth edition, p.92.

EffL 2-12 16.04.2012 11:23 Uhr Seite 86

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The Evolving Appreciation of Food Safety

ties throughout the years, it can be said that it is the
changing nature of hazards that has given rise to a
more flexible appreciation of food. Certainly, the
category of hazards is not watertight in which they
may combine together or change in their own char-
acteristics. For example, as far as biological hazards
are concerned, the newly emerged pathogens like
Salmonella Enteritidis in the 1980s or newly dis-
covered E.coli O157:H7 in 1982 have posed new
challenges for food safety.

9

Thanks to the role of

science, the characteristics of risks can be assessed
and described. Based on this, the probability of
occurrence and severity of known or potential
adverse health effects can be further clarified, i.e.,
the characterization of risks. Subsequently the cor-
responding method to prevent, eliminate or reduce
them to an acceptable or tolerable level can be
established.

10

In view of this, food safety can be

regarded as an assurance that the product will not
cause harm to the consumer when it is prepared
and/or eaten according to its intended use.

11

Hence

by targeting hazards, the scientific judgment on
what food safety may be has reached agreement to
some degree since scientific evidence is a neutral
value criterion.

12

As regards the achievements, not

only scientific principles but also science-based
food safety standards have been developed at the
international level in order to guide food safety
regulation.

Even though, a consensus on food safety has yet

to be achieved. First of all, despite the important
contribution of science to the abovementioned con-
vergence, there is still divergence on scientific mat-
ters from time to time or place to place. For exam-
ple, the lack of information may result in uncer-
tainty in the scientific assessment. Or the interpre-
tation of a scientific study may be influenced by the
political press. There are comparatively more diffi-

culties when food safety is regarded as a judgment
by adding different values. It is not difficult to
understand that regarding food safety as a value
judgment since it is a highly political issue.

13

Throughout human history, food not only provides
a means for human survival but also constitutes
an instrument of political, economic or cultural
concern. As a result, when the political, social value
is taken into consideration depending on its own
situation, the interpretation of food safety can be
multiple. Therefore, even though science-based
food safety standards have been established inter-
nationally, the value-based judgment of what food
safety may be still leads to the disagreement.

III. The Legal Requirements Regarding

Food Safety

As mentioned above, food safety has been an inde-
pendent subject in the framework of food legisla-
tion. As far as food legislation is concerned, the sub-
stantive provision addressing the food safety can be
categorized basically in three aspects. These are
rules concerning the substances, process and infor-
mation.

14

Firstly, food safety should be determined from

the perspective of substance, either single or a com-
bination of substances. As demonstrated by the
practice in the USA, the assurance of food safety
was realized by food orientation at the very begin-
ning. In this respect, there were bans on adulterated
food and permission in terms of food compositional
standards. Given the considerations of food diver-
sity, the introduction of general safety requirements
can promote the application of chemical substances
where the substance at issue may not be added into
food before its safety has been proven.

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87

9 Tanya Roberts, “Food Safety Incentives in a Changing World food

System, in Food Control 13 (2002), at p. 73.

10 It should bear in mind that the term “acceptable” and “tolerable”

have different meaning. The former refers to an activity where
any residual threat is so low that additional measures for mitigat-
ing the threat are not seen as necessary. The latter refers to an
activity that is seen as warranted on the grounds of associated
benefits, yet which requires additional measures in order to
reduce the threat below reasonable limits. See, A. Ely, A. Stirling,
M. Dreyer, O. Renn, E. Vos, and F. Wendler, “Overview of the
General Framework”, in Marion Dreyer, Ortwin Renn (Eds.),
Food Safety Governance, Integrating Science, Precaution and
Public Involvement

, Springer-Verlag Berlin Heidelberg 2009, at

p. 39.

11 CAC (2003). Recommended International Code of Practice Gen-

eral Principles of Food Hygiene, CAC/RCP1-1969, Rev.4-2003,
p. 5, available on the Internet at: http://www.fao.org/docrep/005/
Y1579E/y1579e02.htm.

12 Alberto Alemanno, Trade in Food, Regulatory and Judicial

Approaches in the EC and the WTO

, published by Cameron May,

2007, at p.293.

13 Marion Nestle, Safe Food: Safe Food: Bacteria, Biotechnology,

and Bioterrorism

, University of California Press, 2003, at p.1.

14 This idea is addressed based on the previous analysis, see

Bernd van der Meulen and Menno van der Velde, European Food
Law Handbook

, Wageningen Academic Publishers, 2009, at

p. 252.

EffL 2-12 16.04.2012 11:23 Uhr Seite 87

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Secondly, food safety concerns the process. That is
to say, it should take the safety of Processes and
Production Methods (PPMs)

15

into consideration,

which means that appropriate measures are carried
out to prevent risks during the food chain from
farm to folk. In early days, the regulation of sanitary
conditions was the concern in this respect. How-
ever, with development of the food industry, the
sanitary considerations in major food companies
were resolved by food technology. However, with
the food chain getting longer and longer, more and
more biological risks can find their way into food,
and then cause food-borne disease. In view of this,
many good practice codes have been developed to
ensure safety during the food production, such as
Good Agricultural Practice for the primary sector,
Good Manufacturing Practice for food manufacture,
etc. Furthermore, both the USA and the EU have
enacted legislation to impose the HACCP system on
food production.

Thirdly, guarantee food safety still depends on

information. The information in the labelling is
important to provide appropriate information for
an informed decision and avoiding misled choices,
especially to satisfy different food preferences or
consuming objectives. The safety concern in this
respect is manifold. Generally, the food product
should bear certain types of mandatory presenta-
tion – such as the name of the food, list of ingredi-
ents, net contents and drained weight, name and
address of operators, country of origin, instruc-
tions for use, etc.,

16

in order to make sure that

the consumers have adequate information about
the food they eat. Besides, the provision of ingre-
dient information which may give rise to allergies
or health issues is linked to safety concerns. More-
over, with the diversity of the food demand, infor-
mation in the form of nutritional declarations or
eco-labels is essential for consumers to make a wise
choice.

IV. Food Safety and Other Food –

Related Concepts

As discussed in the historical review, the apprecia-
tion of food safety is combined with other food
related concepts, including food hygiene, food qual-
ity and food nutrition. The distinction between
them not only contributes to a better understanding
of food safety, but also to the food regulation.

1. Food Safety and Food Hygiene

Whether food is safe or not, the hygiene condition
is the first criteria to tell since it can be observable.
Therefore, it is not surprising that at the very begin-
ning, the concept of food hygiene and food safety
were one and the same. In 1983, between 30 May
and 6 June, a joint FAO/WHO Expert Committee on
Food Safety met in Geneva to prepare a report on
food safety. In this report named the role of food
safety in health and development,

the concept of

food safety has the same meaning as food hygiene
that is defined as being all conditions and measures
that are necessary during the production, process-
ing, storage, distribution, and preparation of food to
ensure that it is safe, sound, wholesome, and fit for
human consumption.

17

However, with the develop-

ment in this domain, the terms have been distin-
guished from one another. In the document, Guide-
line for strengthening a national food safety pro-
gram

, prepared by WHO in 1996, the definitions

of food hygiene and food safety were renewed
and addressed by their differences as follows: food
hygiene means all conditions and measures neces-
sary to ensure the safety and suitability

18

of the

food chain while food safety refers to the assurance
that food will not cause harm to the consumer
when it is prepared and/or eaten according to its
intended use.

19

The significance of this differentiation between

them is twofold.

As regards food safety, the perennial food safety

issue has suggested that food safety could no longer
only be the problem of food hygiene but may also

The Evolving Appreciation of Food Safety

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15 The term PPMs refers to processes and production methods

and is defined as the way in which products are manufactured
or processed and natural resources extracted or harvested. See
OECD, Processes and production methods (PPMs): conceptual
framework and considerations on use of PPM based trade
measures. This paper was prepared as part of the OECD work
programme on trade and environment, 1997, p. 7.

16 WHO/FAO, Food labeling, Fifth edition, 2007, Rome, at

pp. 3–8.

17 FAO/WHO, The Role of Food Safety in Health and Development,

Expert Committee on Food Safety, 1984, at p7.

18 By definition, food suitability means assurance that food is

acceptable for human consumption according to its intended
use.

19 FAO/WHO, Guideline for strengthening a national food safety

program

, 1996, p.22. Notably, by definition, food suitability

means assurance that food is acceptable for human consumption
according to its intended use.

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The Evolving Appreciation of Food Safety

concern other issues. In this case, the focus on food
hygiene regulation is not adequate to ensure food
safety. Therefore, to establish a food law, focusing
on food safety especially has been become a trend
to lay down the legal basis for the whole food regu-
lation while food hygiene law has become a subor-
dinate legal requirement.

As regards food hygiene, on the one hand, it has

become one of the aspects with regard to the food
safety requirement. On the other hand, it should be
noted that food hygiene as such not only has the
requirement on food safety but also food suitability
which means an assurance that food is acceptable
for human consumption according to its intended
use. Different from the safety requirement, the suit-
ability can vary from person to person. That is to
say, while the basic part of food hygiene is fit for the
requirement on food safety; the so-called suitability
can be flexible according to the consumers.

2. Food Safety and Food Quality

When it comes to food-related concepts, the rela-
tionship between food safety and food quality can
be rather confused. For one thing, they are linked
together to some degree. Secondly, they can be
totally different when it comes to the regulation.

For the former, food safety is only part of the

attributes of food quality which is multidimen-
sional.

20

In addition to safety concerns, food quality

also includes nutritional attributes, value attributes
and package attributes. There is no doubt that food
safety is the primary requirement for realization of
the other parts. In this case, different from other
possibly optional attributes, which are added par-
tially or wholly to a food, the safety requirement is
obligatory in order to be permitted to put a food
onto the market.

For the latter, since food quality can be more gen-

eral than food safety, the separation of safety parts
from other parts in the food quality can be signifi-
cant to regulation. As to food, only food safety is
ensured according to legal requirements, can they
obtain the qualification for access to the market.
Therefore, the food safety standards should be

enforced by the official control. As to food quality,
the attribute orientation can be self determined to
serve as a weapon for competition. For example,
establishment of a degree of quality standards to
realize higher or highest quality, or addition of
nutritional substance or obtainment certification
from the perspective of environment protection,
animal protection to realize quality distinctions.

3. Food Safety and Food Nutrition

The basic function of food is to provide the nutri-
ents in order to meet our bodies’ basic needs.
Undoubtedly, the intake of nutrients should be
based on individual conditions to keep the physio-
logical balance, the basic nutritional needs of
human beings are the same and they are protein,
fats, carbohydrates, minerals, vitamins and water.
As regards food nutrition, it was first the focus of
food security. It can be also used as a means to
improve food quality. Now, with the awareness that
an inadequate or excessive or unbalanced intake of
nutrients can cause dietary disease, the nutritional
problem has been the focus of food safety as well
since it concerns not only human survival but also
health and even life.

Nowadays, the improvement in living standard

has led to the people paying growing attention to
nutrition either for food quality purposes or food
nutrition demand. As a response, the food industry
has also produced the nutrient-fortified foods.
However, the lack of certain nutrients or abuse of
them can give rise to health issues. In addition to
substance safety, the difficulties in food nutrition
regulation are more related to information since
government intervention in food nutrition is quite
limited. Therefore, it is the consumers themselves
who should have adequate information to make
wise choices on nutritional food. In this case, regu-
lations relating to labeling help to guide consumers
towards proper food choices, including nutritional
information, health claims on the one hand. And
specific regulations are necessary on the other
hand, such as the information on trans-fats with
regard to the concerns of obesity.

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89

20 For their relationship, one opinion is that the food safety is one

of attributes of quality since product quality itself is multidimen-
sional. According to this opinion, See, Neal H. Hooker and Julie

A. Caswell, “Trends in Food Quality Regulation: Implications for
Processed Food Trade and Foreign Direct Investment, in Journal
of Agribusiness

(1996)), Vol.12, No.5. at p.412.

EffL 2-12 16.04.2012 11:23 Uhr Seite 89

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V. Conclusion

As a global issue, harmonization of the food control
system in term of food legislation or a regulatory
approach has attracted increasing attention. Among
this work, the common appreciation of food safety
is no doubt a primary step. The abovementioned
analysis is supposed to smooth this progress in
three aspects.

Firstly, it is the promising work to improve the

common appreciation of food safety based on the
role of science. However, since food safety is not
only a scientific judgment but also a value judg-
ment, the common appreciation of food safety is
still undergoing challenging developments given
the socioeconomic diversity in each country. In this
case, the other legitimate factors that should be
taken into account during the decision-making
process require further clarification.

21

Secondly, the framework of food legislation may

vary from place to place given the different political
and legal systems. In light of this, the three aspects
of the structure of rules on food safety, i.e. sub-
stance, process and information, are supposed to

facilitate the understanding of the legal arrange-
ment with regard to food safety.

Thirdly, the practices have indicated the neces-

sity for a fundamental law on food safety which sets
out the legal basis for the whole food regulation.
Yet, the purpose of food regulation is multiple in
which food hygiene, food quality and food nutrition
also are important concerns. As analyzed here,
their differences may call for different regulatory
approaches, especially between food safety and
food quality. Therefore, the clarification of these
definitions may be the initial step to figure out
an appropriate regulatory framework in the food
domain, such as the domain for public intervention
and private regulation, which can provide more
involvement of different stakeholders to make their
contributions to ensure food safety.

The Evolving Appreciation of Food Safety

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21 For example, other legitimate factors are relevant to the health

of consumers and the promotion of fair trade practices. See,
Codex Alimentarius Commission, Procedural Manual, Nineteenth
edition, p.180.

EffL 2-12 16.04.2012 11:23 Uhr Seite 90

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