@2016 The World Bank and ILRI, FAO, Canada, ADB, CIRAD, Australia ( Development Partners) 1818 H Street NW Washington DC 20433 Telephone: 202-473-1000 Internet: www.worldbank.org This work is a product of the staff of The World Bank and the above referenced Development Partners (DPs), with external contributions. The findings, interpretations and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent, or those DPs. The World Bank and the DPs do not guarantee the accuracy of the data inclued in this work. The boundaries, colors, denominations and other information shown on any map in this work do not imply any judgement on the part of The World Bank or of the DPs concerning the legal status of any territory or the endorsement or acceptance of such boundaries. Vietnam Food Safety Risks Management Nothing herein shall constitute or be considered to be a limitation upon or waiver of the privileges and immunities of The World Bank, all of which are specifically reserved. All queries on rights and licenses shoud be addressed to the: Challenges and Opportunities Publishing and Knowledge Division, The World Bank 1818 H Street NW, Washington DC 20433, USA Fax: 202-522-2652 E-mail: pubrights@worldbank.org Cover design: 5S Consulting and Media Introduction The World Bank Group together with donors and development partners, peer reviewers and experts, the development partners in Vietnam received a request from policy note would be endorsed by the World Bank Group the Government of Vietnam to provide advice for food management as the basis for submitting to the Government safety capacity building1 . This policy note is the outcome of Vietnam. An important framework within which this of a continuous collaborative effort by partners, including analysis has been conducted is the toolkit that the WBG’s intensive discussions with government agencies at central and Trade & Competitiveness Practice has published on Food local levels, visits to farms, agri-food enterprises and markets, Safety Reform in 20143. Through its eight Fundamental and a two-day workshop on food safety organized in Hanoi in Pillars, the toolkit serves as a comprehensive checklist of January 2016. This note builds on the available background where to get started and how to prioritize when undertaking material as well as on the material and background papers Food Safety reform process. prepared by partners2 . The policy note is complemented by a more in-depth The objective of the policy note is to develop options and analytical paper, which presents the evidence and analytical policy recommendations for the Government of Vietnam framework for the recommendations. As such, the policy note on strengthening food safety capacity. The note lays focuses on selected areas for food safety capacity building, out the available information, analyzes the institutional which according to experts, team members and workshop and policy framework for food safety, discusses possible participants, are of high priority and demand critical policy recommendations and provides an outline for actions for actions. the next steps. It is expected that after being reviewed by 1 Development partners: FAO, ILRI, CIRAD, ADB, Canada and France 3 http://globalpractices.worldbank.org/trade/Knowledge%20Base/IC/ 2 References are available Business_Environment/Food%20Safety%20Toolkit-%20Guiding%20 Principles%20of%20Food%20Safety%20Reform.pdf Vietnam Food Safety Risks Management - Challenges and Opportunities Page 5 The background and context The recent Vietnam Development Report4 oof the World issues have proliferated, causing public outcry and pressuring eggs has been the highest compared with other countries in practices and even improved profits, though also resulting in Bank predicts that in the next two decades the agri-food sector the government to react. In response to these concerns the the region. According to the Vietnam Development Report5, consolidation of the agri-processing industry. will continue to play the key role in Vietnam’s economy and government reviewed its food control system. It reduced the significant growth has also occurred in the consumption Such an effect has not happened in Vietnam yet, or rather in people’s livelihoods. The sector’s development will largely number of ministries responsible for food safety from six of fish and of certain processed foods. In the meantime, is happening but at a very slow pace. This report does be driven by urbanization and a growing middle class, with to three and is redirecting its capacity for controlling food food shopping habits still remain mostly traditional. There emerging affluent consumer segments and changes in dietary safety for exports to developing systems for greater coverage not promote “supermarketization” but it notes that the is a preference for fresh meat and produce, and there is patterns. This would transform the agri-food industry from of the domestic food supply chain. However, these recent development process in Vietnam is different, and therefore more trust in traditional or wet markets than in modern being previously commodity export oriented to becoming changes brought little improvement in food safety and were food safety policies may not follow the same path as those in supermarkets (although some studies are showing growing an industry that increasingly focuses on value addition. not enough to comprehensively address the issue. In order other countries that have more established formal retail, and trust in supermarkets). The penetration of supermarkets is the Improved safety in the food supply chain, in this context, to build on achievements to date, there are some areas where more strength in the agri-processing industry. lowest in Vietnam as compared with other countries in the will not only open up new premium markets and increase Vietnam can learn from the available international practice, region6. The strength of the agri-processing industry is also Vietnamese people tend to prefer fresh and unprocessed food, the competitiveness of Vietnam’s food products, but will also with the caveat that some of the underlying factors in below of that of other comparators. “Supermarketization” in although there is growing demand for more convenience protect the domestic consumer and will bring significant Vietnam are different from those observed in other countries. many countries drove out the micro and small traditional ready-to-eat and processed foods. As the urban middle class benefits to public health. The food consumption patterns in Vietnam have changed grows, the demand for processed and convenience food is businesses but resulted in the introduction of more Food safety has been a source of major concern in recent years. significantly during the recent decade, and changes will modern food safety practices and standards. Especially the likely to grow as well. Interestingly, the share of primary Both the public and the government have been concerned continue. The most significant is the increased diversification international leading brands of supermarkets brought their agriculture in Vietnam’s economy increased with economic about the integrity of the food supply chain and its ability to of diets across all income groups of population. The corporate food safety practices, which resulted in trickle- growth, in contrast to other countries where the transition to deliver safe food to people. Media reports about food safety consumption growth of meat (especially pork), milk and down effects on agribusiness through improved food safety a middle income country has seen agriculture’s share decrease. 4 World Bank. 2016. Transforming Vietnamese Agriculture: Gaining More from Less. Vietnam Development Report. Washington, D.C. 5 Ibid World Bank. 6 Ibid 6 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 7 The processing industry is not as robust and developed as in other countries. Most processing is based in micro or small outlined below are based on the experience of countries that successfully dealt with similar food safety issues, but most Summary of available evidence on food safety enterprises and is local. This means that processing is spread across hundreds of thousands of firms, making it difficult if importantly reflect some of the experiences of Vietnam. hazards and risks not impossible to monitor for food safety using conventional methods. This also makes it difficult to promote certification There is evidence that food contamination in Vietnam is schemes or private standards that are widely used in other Main messages for public policy widespread, as found in numerous scientific studies. Food countries and that have been successful in building industry contamination hazards appear at all stages of the value chain. compliance with food safety rules in some countries with • The risk of foodborne illness is real, even if it is Specifically, ILRI’s studies show high level of contamination high levels of governance. Conventional certifications and not at crisis level. Microbial contamination is with Salmonella, Escherichia coli and other contaminants. standards are too expensive for micro and small producers, responsible for the greatest health risk, followed The findings in Vietnam are consistent with most surveys of and although other approaches exist that are less onerous by risks associated with excessive chemicals and food in Asia and Africa, which find that a large proportion of (e.g. group certification), they have not been widely used. toxins. domestically produced food, often the majority, fails to meet • Nevertheless, Vietnam is not in food safety crisis These unique food system features of Vietnam are coupled basic food safety standards. in terms of public health, despite the overall public with similarities in food production to other countries perception and media representation. Over the recent years, there have been many research of South East Asia. That is a production base consisting initiatives in Vietnam that analyzed food safety risks and of millions of small farmers, often overusing chemicals, • The public are rightly concerned that the implementation of preventative controls falls well hazards. These initiatives have been supported by various antibiotics and growth promoters to get higher yields and short of what should be achievable. Public policy domestic and donor programs, and build a strong research desired product characteristics, because most farmers rely on needs to be proactively responsive to the public’s community that is able to identify and estimate food safety agriculture income as the main source of their livelihood. concerns. hazards and their likely impact on public health based on This report is about how Vietnam can prepare for new food • In the absence of more comprehensive data, modern science. Most of these initiatives are supported safety challenges and what policy measures can be adopted research findings and international experiences through various grants and programs, and hence serve as to ensure the safety of the food supply chain in the context should help guide the public policy response but independent scientific information on the likely presence of its imminent transformation within next two decades. improved information needs to be developed. and impact of food safety hazards. Examples such as ILRI’s Many policy-relevant options and recommendations PigRisk Project, recent risk assessment studies carried out 8 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 9 jointly by FAO and MARD, provide credible evidence and in these figures. Good production, storage and handling tip of the iceberg. There are from-time-to-time media reports in Vietnam – significant media attention on food safety conclusions regarding the need to further control food safety practices can reduce the risks to human health. about outbreaks of one or another food poisoning event that and high-level government concern – demonstrates that hazards. More detailed information about the findings of affected significant number of people9. the public are seriously concerned about the food. Public Consumer confidence has been seriously affected by these studies is provided in the accompanying Food Safety concern, if not addressed timely and effectively, may media reports about contaminated food. A nationally According to Authority figures10, during four years of Technical Working Paper in Section 4. undermine Vietnamese people’s trust in the government and representative survey funded by USAID8, ffound that reporting (2012 to 2015), the highest proportion of public policy. However, the public policy must distinguish Independent research surveys, such as those by ILRI7, based food safety was one of the two most pressing issues for foodborne disease outbreaks was traced back to micro- between the food safety crisis and a communication crisis. on literature reviews, as well as covering tens of thousands people in Vietnam, higher than education, health care or organisms (42%), followed by natural toxins (28%) and There is no food safety crisis in Vietnam in terms of public of food samples, found that around 10-40% of food is governance. A large survey in 2010 found that respondents chemicals (4%) while for 26% the causal agent remained health, but public policy must be proactive in reassuring contaminated with microbes or parasites, which cause were pessimistic about the food safety situation in Vietnam: unknown. Where a single food source was implicated, this the public that food is safe and the government is doing all foodborne diseases. Unacceptable levels of pesticides, heavy 43% of interviewees felt that food safety had worsened in was most commonly seafood, followed by mushrooms. possible to ensure food safety. metals and antibiotic residues are also commonly present. the previous 10 years, while only 22% felt otherwise. City Studies from countries (including USA and Europe) with For example: salmonella was found in 30% of food (67 dwellers, high-income earners and young people were much much more sophisticated public health reporting systems Observations show that consumers tend to be more studies); pig tapeworm in 7% of pork (9 studies); antibiotic more frequently concerned about food safety than rural suggest only a small proportion of foodborne diseases is concerned with chemical and toxin contamination of residues in around 30% of pork (3 studies). In the absence dwellers and low income earners. ever recorded as outbreaks. Accordingly, it is difficult to food rather than with microbial contamination. Also, high profile events create more concern than low profile of comprehensive regulatory results from government extrapolate from the limited data available in Viet Nam Despite seemingly alarming results from the research events although the latter undoubtedly cause most of the sources, surveys reported in the literature are probably the other than to say they are likely to greatly underestimate findings, there is little or no scientific evidence to estimate burden. There is a perception that household practices and most reliable way of assessing the safety of food in domestic the true incidence of foodborne disease. They are however the likely burden of foodborne illnesses. Public data of cooking methods may reduce the impact of any possible markets. informative in understanding some of the risk factors for foodborne illnesses is very limited. Food poisoning events microbial contamination. In Vietnam, households typically However, these results do not mean that food with these involving concentrated groups of people often receive the food safety outbreaks11. wash the produce and meat very carefully before consuming characteristics will necessarily lead to illness. Proper washing most media and subsequently government attention because Public policy must distinguish between food safety it. However, the most recent research data and available and cooking can remove many of the dangers represented of their visibility but in reality are likely to represent just the and consumer confidence crises. The current situation information indicate that microbial contamination (through 9 During the mission, there was a media report about an outbreak in a 10 VVFA (Vietnam Food Authority). 2016. BÁO CÁO Kết quả công 7 Grace, D., Mutua, F., Ochungo, P., Kruska, R., Jones, K. E., Brierley, 8 USAID. (2015). Report, National Opinion Survey 2015. Hanoi, factory canteen that made 650 people ill. http://www.foodnavigator- tác phòng chống ngộ độc thực phẩm giai đoạn 2011–2015. L., ... & Thao, N. B. (2012). Mapping of poverty and likely zoonoses Vietnam. asia.com/Policy/Food-poisoning-cases-soar-as-650-Vietnamese- 11 Nestle, M. (2010). Safe food: The politics of food safety. Univ of hotspots. workers-are-hospitalised California Press. 10 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 11 bad hygiene, pollution, cross-contamination, bad practices) to represent the higher end of the agri-food production Table 1. Reasons for rejections of agri-food product imports from Vietnam into the European Union, United States and is likely to cause the most immediate food safety concerns and processing industry. A recent analysis of reasons for Japan from 2002 to 2010 and health impacts. The publicity of recent outbreaks as rejections of agri-food product imports from Vietnam into reported by official sources and discussions with experts the European Union, United States and Japan from 2002 to suggests that the majority of outbreaks happen in factory 2010 found that bacterial contamination was the prominent Reason EU US Japan canteens or student cafeterias. The major cause of these reason for all rejections, suggesting widespread weaknesses outbreaks is microbial contamination. Research findings in hygiene controls, notably for fish and fishery products, Adulteration/missing documentation 18 490 0 around the world confirm that overall microbial risks but also other major agri-food product exports13. While Bacterial contamination 170 1088 145 in developing countries are hugely understated; various these data are only for exports, they show how pervasive the Food and/or feed additives 78 402 14 estimates suggest that microbial pathogens alone in food can bacterial contamination issues are in the food industry. cause 20-40% of intestinal diseases in developing or middle Heavy metal 61 0 0 As such, the greatest short-term burden of foodborne income countries12. However, the public in Vietnam (as well Hygienic condition/controls 28 1174 23 illnesses both for public health and for the economy is likely as in other countries of East Asia) are primarily and only Labelling 2 997 0 to be caused by diarrheal disease agents, particularly bacteria, concerned with chemical contaminants. which are also responsible for the majority of deaths due to Mycotoxins 23 32 7 As a way to reinforce the assertion that the bacterial foodborne illnesses. This is consistent with the findings in Other contaminants 101 214 16 contamination is one of the most important hazards, one the rest of the world, as documented by the recent WHO can look at the findings of other enforcement agencies vis study14. Other 27 25 6 a vis food from Vietnam, noting that such exports tend Packaging 4 0 2 Pesticide residues 15 19 50 Veterinary drugs residues 198 174 300 12 Grace, Delia. “Food Safety in Low and Middle Income Countries.” 13 STDF and MARD. (2013). Using Multi Criteria Decision Analysis International journal of environmental research and public health 12.9 to Identify and Prioritize Export Related Sanitary and Phytosanitary Source: STDF and MARD. (2013). Using Multi Criteria Decision Analysis to Identify and Prioritize Export Related Sanitary and (2015): 10490-10507. Capacity-Building Options in Viet Nam. Tran Viet Cuong et al. Phytosanitary Capacity-Building Options in Viet Nam. Tran Viet Cuong et al. Page 7. 14 Havelaar, A. H., Kirk, M. D., Torgerson, P. R., Gibb, H. J., Hald, T., Lake, R. J., ... & Speybroeck, N. (2015). World Health Organization Global Estimates and Regional Comparisons of the Burden of Foodborne Disease in 2010. PLoS Med, 12(12), e1001923. 12 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 13 Features of Food Safety Control in Value Chains research projects and government programs. Consumers are also not fully confident of the safety of products even with facilities. But what is needed more, to promote safer food, is the implementation of better practices. Around the world, certification marks. food safety is mostly achieved not through better equipment and facilities – though they are also essential – but through The value-chains for food production in Vietnam are good production and manufacturing practices, clean and typically short, which is important in reducing risk. The Vietnam’s agriculture and food production is fragmented hygienic food production environments and trained staff. food is typically sold through wet markets, normally fresh What are the main messages for public with very many small farmers and producers involved and often with only limited processing. Supermarkets, stores Another important aspect for focusing on improved food policy? in food production. Average farm size is very small. Small and small shops have started to increase their share in food production practices is that regulatory product-testing farms are typically unable to provide enough income to farm retail, especially in urban centers such as Hanoi and Ho is not sufficient to deliver food safety. Proposals such as • Improving food production and handling households unless farmers employ extensive production Chi Minh City. Most meat is slaughtered in small (rather those to supply rapid testing kits to markets is unlikely to practices is more important than promoting large practices. As a result most agricultural production in micro) slaughtering facilities. Most basic food processing provide much benefit and may give a false sense of security. infrastructure investments, such as consolidation Vietnam is highly dependent on extensive use of chemical is done as well in small-scale family-owned enterprises. Testing food does nothing to make it safe and there are so of slaughterhouses or wet markets. inputs, such as fertilizers, pesticides, veterinary drugs etc. There is a unique street food culture. Typically, such small many parameters to test for that no rapid testing method • Testing, especially end-product testing cannot The official controls of chemical inputs are inadequately and micro enterprises or wet markets have hygiene and is able to capture them all. In a well-functioning regulatory deliver food safety and efforts should be refocused enforced resulting in a wide availability of prohibited and sanitation conditions rarely adequate for good practices in system, there may be scope to do regular product testing to towards good practices. low-effect chemicals in the market. In addition, given the food production. ensure that the regulatory oversight is effective and working. legacy of industrial development, many industrial complexes Relying only on end-product testing cannot guarantee that • Adoption of improved Food safety interventions There still remains a need for some infrastructure (often polluting plants) are concentrated near agricultural deficient products will not enter the market through other by producers, processors and retailers should have improvements but the main need is for change in practices. lands. Such a situation creates an overall and justified concern channels. minimal or no impact to the traditional food For example, wet markets would benefit from better water culture of Vietnam. among the population and policy makers about the safety of supplies, drainage and waste management. Investments are the food supply. There is considerable evidence that residue also needed to upgrade street food stalls to help improve levels of heavy metals, pesticides and antibiotics are high in hygiene and sanitation around street food. Food producers selected agricultural products that have been tested through would benefit from improved processing equipment and 14 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 15 Challenges for Government Regulation delivery of the intended regulatory outcomes. Since 2010, Vietnam has modernized its regulatory framework and management within the three Ministries in charge of food safety, in order to improve outcomes-focus delivery by these and Controls its administrative structures in relation to food safety but there is still significant scope for improvement particularly Ministries. Such process may take some time to be in place and efficient, but could be launched immediately as an with respect to implementation. The government is aware incentive for Ministries to better cooperate and deliver joint Public anxiety over food safety issues is an important issue of where some improvements are needed. The provincial results on-the-ground. Moving from outputs to outcomes What are the main messages for public in itself. It is not simply a question of whether the public has Peoples Committee is also considering pilots in Ho Chi is always challenging but is what is needed for government policy? misunderstood the situation since that level of understanding Minh City to test the model of a single Food Safety Agency. interventions to be effective. will shape their decisions as consumers. Consumer flight In addition to these legal and institutional reforms, just as The following table presents some of the experiences from • Public concerns associated with high- profile food from a product or a sector can be economically devastating with the food producers, what is needed is the application other regulatory systems in addressing the similar challenges poisoning incidents distract attention away from for that product or sector and the effect can be immediate of good practices. as in Vietnam. the need to address a wider production, processing and unforeseeable. A domestic “food scare” could be used The operational modalities of the Ministries and agencies are and handling food safety issues which are likely by competitor countries to impose trade barriers which may not geared to delivering the intended regulatory outcomes. having a much greater economic and public health take some time to dismantle. There is an argument that the Performance management has been used in other countries impact economic effects of “food scares” can be a bigger problem for as a way of improving the delivery of results by government • The regulatory framework in Vietnam needs to the economy than days lost from work due to food-borne bodies. It can lead to individual accountability or to focus more on the implementation of preventative illness. Managing a “food scare” better is also a matter of budgetary accountability, with the latter being a stronger controls and practices domestically if it is to better building a more productive relationship with consumers. way of ensuring that the whole organization has a stake in deliver the intended regulatory and consumer This will allow not only a better chance of reducing future better delivery. Inherent to better performance management expected outcomes. “scares” but can harness consumers as drivers of food safety, is the use of independent system audit mechanisms to assess demanding better standards and better practices. performance against agreed outputs and outcomes sought. The regulatory framework in Vietnam has improved but Further strengthening in the institutional structure there remain serious concerns over implementation and would focus on the development and use of performance 16 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 17 Table 2. International Trends in Reform of Regulatory Delivery   Type of Reform Examples   Type of Reform Examples Creating a lead agency for Food Safety is the most common model and it comes in Risk-based targeting allows reduction in resources since only a small number of Streamlining administrative 1 different variations. But many countries fail to integrate at levels below National, businesses need to be inspected. Also political pressure in many countries to reduce structures 5 Resource reduction e.g. UK. burdens on business drives reduction in inspections. Poland has shown dramatic results in reduction without losing effectiveness. Coordination can be an alternative to creating a lead agency, e.g. Germany. But it Coordination across is also used to direct collaboration between all major inspection bodies, e.g. Dutch Regulatory organization has clear strategic and annual objectives, with specific 2 inspection bodies Inspection Council and “Domain” system. The UK has a looser system under a performance indicators linked to risk criteria. These are reflected in performance special government department, the Regulatory Delivery Directorate. indicators for staff that drive staff behavior in line with the organization’s objectives, 6 Performance management i.e. raising compliance levels rather than imposing penalties. The UK is particularly Detailed risk criteria developed for both food products and types of business and strong on this approach but Estonia has shown how well it can be applied in recently then combined with compliance record to form a risk assessment matrix to allow developed economies. 3 Risk profiling of businesses fairly precise calibration of risk levels presented by any company. Best examples in Netherlands and UK. Regulator provides advice to business on which business can rely in order to ensure Providing assured advice on 7 compliance. Can be at inspector level or at corporate level or telephone help line. request Inspections are targeted at High Risk businesses and even High Risk is then prioritized Best examples in UK and Lithuania. individually. Low Risk businesses are largely ignored. Unplanned inspections Risk-based planning of 4 reduced through applying same risk criteria when responding to complaints. One of Export-led drive to raise Benefits of compliance seen as allowing access to new markets, especially foreign inspections the best studies of problems of unplanned inspections is from Mongolia. 8 standards and encourage markets. Domestic inspection then becomes supportive, to help meet foreign compliance standards. The best example is AQSIQ in China. Source: Authors Source: Authors 18 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 19 The regulatory system is not fully risk-based in its operation. This can be seen in the planning of sampling, The concept of risk-based food controls and ability to ensure a safe food supply is highly dependent on a strong Recommendations Based on Global Experience where the results are difficult to use as a basis for action. evidence basis. This requires good data through residue and It can also be seen in the approach to risk classification of contaminant monitoring and surveillance programs on a businesses which depends on compliance records rather than nationwide basis. Currently such programs are operational on a mixture of that and also the nature of the business, for the export sector based on needs of importing countries. During the past five years, Vietnam’s Government has The recommendations are provided keeping in mind two the nature of the products and processes used and the Many countries especially developed economies have such made significant improvements in its food safety control important features: potential extent of damage that could be caused. In certain programs not only for export based products but also policies. Food Safety legislation and institutions have been • Safe food should be delivered by the private sector, cases, sampling is done from areas that are known to be those supplied to domestic markets. This also requires a streamlined to some extent to help implement more of a risk- whether micro- or large-scale, and by all actors in non-compliant rather than being used to confirm whether good laboratory network in the country with accredited based food safety control system. However, the capacities for value-chains from inputs suppliers and producers any improvements to the food control system have been laboratories. Most importantly the data generated needs to effective implementation of food safety control have not yet to processors and food distributors, through use of effective or not. Further, the methods or approach of each be analyzed from the point of view as to what it is showing been brought up to the level of institutional streamlining. good practices and adapted technologies. The public organization varies and is not uniform. needs to be addressed from a national food control system The Government of Vietnam is considering a formal review authority’s mandates are to (i) provide an enabling point of view. of its food safety policies and legislation with a view to Ensuring that requirements are clearly stated, practical environment so that safe food can be delivered, entailing: and non-ambiguous is important if the various sectors potentially amending the laws and regulations and further proper legislative and policy framework; institutions/ (producers, processors, exporters, importers, and streamlining the food safety control system. incentives to empower the private sector to deliver safe retailers) are to embrace them and effectively implement Given the widespread failure to develop effective, sustainable, food; promoting good practices and offering compliance them. Each Ministry has some system of documentation and and scalable models of improving food safety in domestic support; and (ii) establish and implement a well-designed the SPS Enquiry Point maintains a consolidated system of markets, these Recommendations are strategic directions and balanced control and enforcement system to ensure requirements of different Ministries – however this requires (“direction of travel”) rather than firm recommendations that food is safe and build confidence among customers updating. Many countries in the region are struggling with for actions that will deliver solutions. It will be important to while avoiding undue interference with market functions; this aspect of transparency and risk communication which institute an experimental and learning approach to changes this includes: a network of well-trained food inspectors; additionally would improve communication at various levels in the food system, with frequent assessments of progress and proper, coordinated and science- and risk- based Food on food safety. consequent adjustments. Safety Surveillance Plans; recognized laboratory networks 20 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 21 (public and private) providing timely and quality-assured 2. Improve data management to fill the need for better 5. Develop a “farm to fork” approach for food safety that tests; risk communication capacity and strategies etc. Below are the recommendations evidence on risks, impacts, and costs of foodborne covers inputs, production, processing and retail. This disease and the efficacy and cost benefit of can start with higher value “safer and trusted” products • The current food production system in Vietnam, The overall recommendation is to develop a risk-based interventions. Evidence from the ministries is still building on current initiatives (e.g. LIFSAP, VietGAP, mainly relying on a multiplicity of micro- and small limited and it is advisable to use independent available PGS, Fresh Studio “TracePigs”, etc.), with an emphasis scale producers, operators or businesses, make it system using the principles of risk assessment, risk data, notably from research and academics as well as on providing incentives for adoption of better practices. challenging to assure the delivery of safe food in the management and risk communication as set out by very short term. Consolidation of production systems to WHO/FAO. from the private sector, in order to help understand 6. Start with farm inputs: Pesticide anti-microbials misuse is reduce reliance of the supply chain on micro-producers and manage risks. a key concern in Vietnam, and the legislative framework will facilitate the process but will take time, and is not the Risk assessment is the scientific evaluation of known or on this remains very permissive. It is recommended only option for a safety assured food system. However, that potential adverse health effects resulting from human 3. Create a culture of evidence-based decision making in to start immediately developing a results-oriented, should not prevent the Government and private sector which decision makers seek and use evidence. This will exposure to foodborne hazards. Current, credible participatory and progressive plan aiming at (i) decreasing to start taking measures immediately. Therefore, these require strong leadership and capacity building. There the overall use of chemical inputs in production (notably information on food safety is a prerequisite for risk recommendations are structured around interventions is also a need to establish a database system, collection antibiotics in animal production), with targets, and (ii) management and communication. Actions to improve that can start immediately, and those that must be of data from province/district, for the purpose of removing antibiotic as growth promoters in animal feed. envisaged with a medium to long term perspective. risk assessment could include: more effective and targeted surveillance planning – Innovations, such as the recently introduced replacement 1. Strengthen national food safety monitoring and including investing in technologies and equipment. of antibiotics (e.g. by probiotic bacteria) could be surveillance system in general and specifically address promising approaches currently promoted by the private Risk management is the process of selecting appropriate sector, if science-based and well documented. discrepancies between surveillance and control prevention and control options for improving food for export versus domestic market. As efforts in safety. It is based on risk assessment. 7. Improve traceability along the chain: Traceability is an surveillance by different agencies are fragmented essential part of “farm to fork” approaches. Again it and insufficiently coordinated and integrated, a 4. Establish a performance management system to set, can start with high-value and high-risk products, e.g. comprehensive and joint |National Surveillance Plan implement and monitor delivery of Food Safety vegetable, indigenous pork products. The methods, should be developed, keeping in mind that foodborne outcomes by the three Ministries. This would require application, and awareness of all value chain actors on diseases are preventable and prevention starts at the jointly agreeing outcomes, plans and targets and traceability should be adapted to context and expanded farm. regularly reporting on progress. gradually. First attempts, already made by some large 22 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 23 or medium scale business in Ho Chi Minh City and shorted time and awareness raising on end-consumers safe food. Efforts should be refocused towards (i) the benefits of this do not exceed the costs, Hanoi, should be monitored in terms of challenges, and producer groups. promoting good practices and creating incentives to including jeopardizing employment and food and lessons learned. sustain them, (ii) testing at different points of the security benefits of the small-scale private sector. 10. Training efforts: Training of actors, e.g. farmers, on product chain based on risk-based approaches; and 8. Align Infrastructure upgrading with practice change: good practices and food safety is recommended but (iii) end-products testing only used cautiously and b. Trade and export: Vietnam has been very Research and lessons learnt from experience bring noting that evidence has shown this to be most useful ultimately to check if the food safety system is reliable successful in exporting food products. Expanding caution in assuming that provision of upgraded when there are clear incentives for changing practices. and integrated into the proper food safety National its export portfolio to include more high quality, and modern infrastructure will necessarily reduce Surveillance Plan mentioned above. At the same time, branded products alongside the mainly lower value foodborne disease and deliver safer food. Current 11. In the long term, the progressive consolidation of hazard testing of food is an important part of building and undifferentiated products which currently national policy on slaughterhouses network production systems to reduce reliance of the supply chain and maintaining consumer trust and providing dominate exports could increase foreign earnings consolidation and use of Gates Wholesale Markets on micro-producers could facilitate all interventions incentives to the private sector. and decrease the risk inherent in a narrow portfolio. must prioritize good practices and behavior change listed above. At the same time, consolidation can This needs to be aligned with not only effective of related actors towards hygienic practices including also multiply the hazards and spread illness more 13. Develop risk -targeted recommendations: Performance food safety systems but with visibly safe systems incentives rather than focusing on infrastructure only. effectively, and hence requires more careful and improvement plans should be developed for that start to build more international confidence In addition, ‘appropriate’, intermediate technologies effective monitoring than the traditional sector. The major agri-food sectors taking into account their in Vietnamese food products. (e.g. at slaughterhouse) should be also considered, as current efforts undertaken by the Government of characteristics and risks. most expensive best practices will be more difficult to Vietnam to promote cooperatives, and build their c. Address the informal sector context: Seek to maintain. capacity goes in the right direction. However, there are a. The large scale private sector has significant upgrade rather than replace the informal food many roads to food safety and innovative approaches experience in meeting food safety criteria through sector. Consider other models e.g. the farmer’s 9. Strong consumer preference for fresh animal source food: based on upgrading value chains, empowering small ‘farm to fork’ approaches. Efforts should be made market approach rather than the supermarket Given that preference and that most of consumers do holders and small scale retailers, and farmers markets to leverage the potential of large scale national and approach and pilot these. Some approaches not store purchased food for long periods, focus should should also be considered. foreign companies to contribute to attaining food may be better suited to large scale farms but be placed on identifying technological solutions and safety. This may entail reconsidering the current given the predominance of small producers and management procedures to enable quick and efficient 12. Supplement end-product testing with a focus on process legal framework (through Circulars) limiting the importance to livelihoods and nutrition in tests of fresh products, promoting business models quality: End-product testing is important to ensure foreign companies to link directly with producers. Vietnam, it is also important to develop “light” with lean value chains to deliver fresh products within consumer confidence but alone will not deliver However, careful monitoring is required to ensure approaches suited to small farmers and processors. 24 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 25 In particular approaches that are based on have to be consistent based on genuine collaboration are mostly country-specific. For instance, in c. It should increase the Government and other working with the existing situation and gradually and coordination. To support this the government Vietnam, the role of social media and web-based stakeholders’ preparedness with pre-designed improving it, have shown success. Continue to needs to develop a communication strategy to build communication is fast growing and therefore may protocols and procedures that will increase develop interventions but place more emphasis on consumer trust in government advice on food issues. be a good medium to use (i.e. the MoH website responsiveness, and ensure that they are country- understanding what works and what doesn’t such While this requires a long term change, in the short has specific pages on Food Safety, FAQ sections, specific and adaptable to the Vietnamese context. as develop lighter approaches to GAP which may term, government messaging in a food crisis should use of Facebook and other social media, etc.). have greater uptake. avoid strengthening negative perceptions. As already 16. Use successful examples to motivate change: Vietnam mentioned above there is a need for good evidence on b. It should cover, and set the framework for, the three food exports are rapidly growing as the result of Risk communication is the interactive exchange of which to base future communications in order to be following aspects: (i) day-to-day communication uptake of general modern processing. These follow information and opinions among risk assessors, trustworthy. The communications strategy should link aimed at rebuilding enough trust with consumers GMP, HACCP, ISO and other standard processes. risk managers, consumers, industry, the academic with an economic strategy for the role of consumers in to be able to guide their buying decisions in Despite existing challenges for some commodities community and other interested parties, including the strengthening markets (instead of weakening them). positive ways (see Chapter 5.6 for more details in meeting international standards there are also explanation of risk assessment findings and the basis Consumer education and awareness also needs to be successful examples (e.g. 95% compliance for prawns and examples); (ii) guide reactions and responses of risk management decisions. Actions to improve risk imparted so that they are aware of food safety practices exported to Australia). Over time, compliance has for regular food safety criticisms/issues that are communication include. at the consumer end but also better understand improved. Efforts should be made to replicate these sometimes biased and not necessarily documented common risk. also domestically. The recent decision to give authority 14. Improve risk communication: To address public and/or backed with evidence, to re-establish to NAFIQAD to scale up its residue monitoring concerns over food safety and the problem that risk the truth; and (iii) crisis communication when 15. The communication strategy’s development will require system to pork and poultry value chains is a good first perception is often not well aligned with reality there is a mix of international expertise and local knowledge legitimate food safety issues arise that does not step. an imminent need to educate the public and decision about the Vietnamese context. It should have the hide facts, nor defend those responsible for the makers not only on risks but on the psychology of risk following key features: incident, but highlight the actions being taken by Optimising risk assessment, risk management and risk perception which means they are often worrying about the Government and other stakeholders, including communication can be facilitated by building capacity the wrong thing. This should include that messages a. It should use means, instruments and channels all the efforts undertaken to mitigate the event’s and improving co-ordination between actors. This may from the “government” related to food safety risks adapted to the targeted beneficiaries and that impacts (including allaying the public concerns). be facilitated by the following actions: 26 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 27 17. Build capacity in risk-based approaches including risk government has the major responsibility for food safety safety outcomes. In light of the decision by HCMC 19. Improve networking, consensus building and consistency to a system where the private sector is empowered to take assessment, risk profiling and risk categorization to municipality to move forward with piloting a “Board” among institutions, relevant authorities and labs, greater responsibility. ensure that limited resources are used most effectively constituted by some fulltime staff from DOH, in particular when attached to different Ministries, for monitoring and control of foodborne disease. The DARD, DOIT, among others, and that reports to as well as strengthening the sampling capacity of capacity in risk assessment is spread across universities, the Chairman of the People’s Committee and works lab personnel. Build capacity in diagnostics, and research institutes, ministries (MOH, MARD, as “coordinator” for food safety in the city, it would laboratory quality assurance, harmonization of MONRE), CODEX. Training has been carried out be important to establish a strong monitoring and standards and approaches among food testing labs and with international assistance. However, more focus evaluation system of this pilot. It will be crucial to surveillance system (national and regional). must be put on systematic application of a risk-based learn from this experience to assess the pros, cons, approach to food safety in which the private sector 20. Develop inter-connected food safety strategy and SPS and unexpected bottlenecks and analyse its suitability should take a leading role – while the Government action plans: Begin a phased process by which to and replicability in the Vietnamese context. Indeed, keeps its core function of regulating and enforcing facilitate and ensure that the Food Safety Strategy and as demonstrated in the Module 4 of the WBG Food the legal framework given the insufficient capacity, the SPS National Action Plan are closely coordinated Safety Toolkit15 there is no “perfect” institutional resources and enabling environment for successful and aligned. Given that the coordinating ministries structure and the decision to go for single versus application. are different, these two strategic documents must be multiple agencies (both having several “sub-models”) written / updated synergistically to ensure that the 18. Institutional re-arrangement: Although undertaking a will notably depend on (i) capacities of agencies proposed objectives, results and interventions are well major reform of the legal and regulatory framework (level of expertise, number of staff, equipment), (ii) aligned and complementary. is not considered to be an urgent priority, it is constitutional organization of the country, (iii) level recommended to continue to identify mechanisms of decentralization, (iv) number of premises to be 21. Strengthen the implementation of food safety regulations by which to enhance implementation arrangements inspected, and (v) the level of development of the food and give more responsibility to food producers and and overall coordination to ensure greater food safety system overall. retailers. It is important to move from a system where 15 https://openknowledge.worldbank.org/bitstream/ handle/10986/25204/911840WP0Box380od0Safety0Toolkit0IC. pdf?sequence=1&isAllowed=y 28 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 29