The food control system in Saudi Arabia – Centralizing food control activities

Food Control 28 (2012) 33e46

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The food control system in Saudi Arabia e Centralizing food control activities Dina Al-Kandari*, David J. Jukes Department of Food and Nutritional Sciences, The University of Reading, Whiteknights, Reading RG6 6AP, United Kingdom

a r t i c l e i n f o

a b s t r a c t

Article history: Received 30 July 2011 Received in revised form 24 March 2012 Accepted 30 March 2012

Today, many governments have chosen to centralize their food control systems as a means to improve effectiveness and efficiency. There has been a growing tendency to improve the national administrative framework for food control by establishing a primary authority to oversee the whole food chain from farm to fork. International Organizations have worked to assist food control authorities in reviewing and adjusting their national regulatory frameworks for food, supporting at many times, the centralization of food-related activities and suggesting that a self-contained structure would best serve the goals of integration and a food chain approach to food safety while eliminating inconsistencies and gaps. Based on international guidance, this study analyses and evaluates the centralization of the food control system in Saudi Arabia. The Saudi Government moved towards the centralization of its food control activities, restructuring institutions to establish the Saudi Food and Drug Authority as an independent administration to coordinate and implement all activities related to food control. An examination of the advantages and challenges of reforming and streamlining food control activities are included. The internal Strengths and Weaknesses, as well as the external Opportunities and Threats that the Government is facing towards centralization have been identified. The study demonstrates how significant progress has been made and highlights areas where continuous efforts are still needed. Ó 2012 Elsevier Ltd. All rights reserved.

Keywords: Food control Centralization Saudi Arabia Saudi Food and Drug Authority

1. Introduction An awareness of the importance of food safety has been increasing nationally and internationally as a result of the occurrence of various foodborne pathogens and hazards from imported and domestically produced foods. Threats such as bovine spongiform encephalopathy (BSE), avian flu, salmonella, mycotoxins, acrylamide, dioxins, and residues from antibiotics, as well as radiation have affected many countries and resulted in a decline in public trust in food safety regulation and management systems. The rapid development of international food trade and the expansion of food distribution systems have greatly increased the potential for the spread of foodborne diseases and contaminants. This has prompted major concern among consumers, industries and governments about the ability of existing food control systems to guarantee the safety and quality of foods. As a result, many countries have launched comprehensive reforms of their food safety control systems in order to find more effective ways to protect consumers. Since 1976, the Food and Agriculture Organization of the United Nations (FAO) and World Health Organization (WHO) have taken a strong interest in promoting effective national food control * Corresponding author. Tel.: þ44 775 492 5858. E-mail address: [email protected] (D. Al-Kandari). 0956-7135/$ e see front matter Ó 2012 Elsevier Ltd. All rights reserved. doi:10.1016/j.foodcont.2012.03.030

systems and prepared guidelines to provide developing countries with advice on strategies to protect public health, prevent fraud and deception, avoid food adulteration and facilitate trade. For more than twenty five years, the publication “Guidelines for Developing an Effective National Food Control System (FAO/WHO, 1976)” containing a Model Food Law within it, has been a reference for national authorities in planning, organizing, and implementing their national food control programmes. With the advances that have been occurring globally including the increasing foodborne diseases and emerging foodborne hazards; the rapidly changing lifestyles and food technologies; the globalization of the food supply chain and the increasing importance of harmonizing food safety and quality standards with Codex, the FAO and WHO developed an updated publication in 2003: “Assuring Food Safety and Quality: Guidelines for Strengthening National Food Control Systems” to replace the 1976 publication. According to the FAO Food and Nutrition Paper No. 76, “the 1976 FAO/WHO Model Food Law has not always been appropriate, because its precepts have not been consistent with all legal systems”. The publication stated that “many concepts and issues in food law have evolved over time and these were not reflected in the Model Food Law. In addition, strict adherence to the terms of the Model Food Law meant that many countries left out provisions, concepts and standards that their individual circumstances, administrative structures and legal frameworks required” (FAO/WHO, 2003).

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The FAO/WHO (2003) guidelines focus on the development of an integrated regulatory system for food control founded on a transparent, risk-based approach and the involvement of all the concerned stakeholders from farm to table (FAO, 2006). The guidelines are based on scientific principles and address all sectors of the food chain, presenting a preventive approach to food control. This is particularly important for countries where effective food control is undermined by the existence of fragmented legislation, multiple jurisdictions, and weaknesses in surveillance, monitoring and enforcement. These guidelines seek to enable authorities to choose the most suitable options for their food control systems in terms of legislation, infrastructure and enforcement mechanisms (FAO/WHO, 2003). With the series of food safety threats and crises that have affected many countries, many governments have come to realize that their systems are incapable of providing the necessary controls to protect the health of consumers against the widespread and increasing food safety risks. The distribution of responsibilities for food control among various ministries and agencies creates administrative burdens and an inefficient resource use. Acknowledging the need to update and modernize their food regulatory frameworks, many countries have moved to review their food legislation to identify and overcome the gaps and fragmentation among the various responsible ministries. Today, many governments have chosen to centralize their food control systems to improve their effectiveness and efficiency; and to regain public confidence in food safety. There has been a growing tendency to improve the national legal and administrative framework by adopting a basic food law which establishes a primary authority to oversee the whole food chain from “farm to fork”. Experiences gained in some countries indicate that reforming and streamlining food safety systems with a central authority to lead food safety enforcement, has led to more efficient use of resources, reduced overlaps and gaps in oversight, increased coordination of food safety activities, improved transparency and commitment, increased consistency in enforcement, and more efficient communications (US GAO, 2005). The Food and Agriculture Organization of the United Nations (FAO) and World Health Organization (WHO) have worked to assist food control authorities in reviewing and adjusting their national regulatory frameworks for food to meet national and international needs. Based on the experience gained in providing assistance to member countries, their Legislative Study, “Perspectives and guidelines on food legislation, with a new model food law” (FAO,

2005), describes existing legal and regulatory frameworks and identifies best legislative practices. It discusses the possibilities for, as well as the advantages and disadvantages of, centralizing most food control activities into one framework food law; and, in several of its chapters, the study has consistently supported the centralization of food-related activities.

1.1. International guidance on revising and updating national legal frameworks for food The FAO/WHO guidelines of 2003 discusses the importance of strengthening organizational structures for national food control systems and provided comprehensive advice on the many considerations affecting the design of national food control systems. The guidelines offer examples of three possible infrastructures and approaches for national systems, enabling authorities to choose the most suitable options for their country. Also, the Legislative Study builds on the guidelines and presents a New Model Food Law in three versions, reflecting the three main approaches to designing national food control systems. A description of the three main types of organizational arrangements for food control systems is given below (Table 1). The choice of assigning a system for food control in a country may be affected by existing government policies and priorities. Systems for food control management differ significantly across countries, reflecting different historical situations, as well as socioeconomic and political circumstances (FAO, 2006). Although the three systems offer distinct advantages and disadvantages, every country will have to decide according to its own goals and needs. The Legislative Study however consistently supports the centralization of food-related activities and suggests that a self-contained structure e the single agency or the integrated approach e is more likely to avoid problems of conflicts and duplication of activities. A centralizing approach would best serve the goals of integration and will best achieve a food chain approach to food safety while eliminating inconsistencies and gaps (FAO, 2005). The principal functions of the Authority in a Single Agency System according to the New Model Food Law (FAO, 2005) shall be to: “(a) employ risk management with the goal of ensuring that all: (i) food produced in the country, whether for domestic consumption or export; and

Table 1 Organizational structures for national food control systems. Organizational structure

Description

The single agency system

The single agency system is based on a single, unified agency for food control where a central authority independently administers and carries out all responsibilities related to food. The single food control agency system has been found to offer the most effective approach to uniformly coordinate food control activities, minimizing the duplication of tasks between the different bodies involved in food control, eliminating inconsistencies, overlaps and gaps. This system has also been found to allow for a more efficient use of resources, enhancing the ability to act rapidly in case of foodborne disease outbreaks. The Legislative Study notes however that the creation of such a system could weigh heavily on governments which will face significant disruption in food control activities, at least at first. Some of the countries which have chosen this approach include Bahrain, Belize, Canada, Ireland and Saudi Arabia. The multiple agency system is based on having several agencies responsible for food control. Different government ministries and agencies within one country carry out their sectoral activities but with a supra-ministerial advisory board to assist with coordination. A number of countries which have adopted this approach include Ethiopia, Kuwait, Oman, Qatar and South Africa. This system frequently results in increased bureaucracy, fragmentation and duplication among all the bodies involved. However, because food control systems also have the objective of creating and maintaining trade, the need to develop a particular sector may result in the establishment of separate food control activities resulting in responsibilities being distributed among the multiple agencies. In an integrated system, responsibilities for food control can be divided into four levels of operation. These are: (1) risk assessment and management, the formulation of policy and the development of laws, regulations and standards; (2) coordination of food control, monitoring and auditing; (3) inspection and enforcement; (4) education and training. A central agency should be responsible for activities at levels 1 and 2, while the responsibility for level 3 and 4 activities should remain with the existing multiple agencies. The advantages of such a system include effective collaboration and coordination between agencies across the food chain. Indonesia, Jordan, Thailand, and the UAE have chosen the integrated approach.

The multiple agency system

The integrated system

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(ii) food distributed or marketed in the country, whatever its origin; meets the highest standards of food safety. (b) take the lead in coordinating and harmonizing food control activities in at all stages of production, manufacture and distribution; (c) prevent and protect against fraud in connection with the sale of food; (d) formulate strategies and policies on food, nutrition and food security, including procedures for emergency response, and monitor their implementation; (e) encourage and promote research on food matters within the country; (f) prepare and amend regulations, orders, standards, codes of practice and notices under this Act; (g) consult widely with all sectors of the food chain in carrying out its activities under paragraphs (a)e(f); (h) provide advice, information or assistance to any public authority in relation to food control, food safety and food trade; (i) obtain, compile and keep under review information concerning food control, food safety, food trade and nutrition; (j) promote consumer education regarding food safety and nutrition; (k) carry out any other matters in connection with or reasonably incidental to the foregoing” (FAO, 2005). Based on our previous studies of food control systems in countries of the Gulf Cooperation Council regional group (Al-Kandari & Jukes, 2009), this paper will expand on the experience of Saudi Arabia in centralizing its food control activities into a single institutional framework. The paper will present an overview of the country and the food control system, describing the approaches taken in moving from a multiple agency system towards a single agency approach, the challenges faced, and the results/benefits obtained. For the purposes of this paper, centralization has been defined as the transfer of responsibility and resources for performing food control activities from multiple agencies to a single authority. The study will also include an examination of the internal Strengths and Weaknesses and the external Opportunities and Threats (a SWOT analysis), that the Saudi government is facing. The principal functions of the Authority in a Single Agency System according to the New Model Food Law (FAO, 2005) will provide a general structure for analyzing the reorganized food safety activities. The Guidelines and Legislative Study will also be used as a guide to evaluate the reformed food safety system in Saudi Arabia. We believe that the experience of Saudi Arabia in establishing a single regulatory body for food control can offer useful information to government officials and policymakers in other developing countries of the world where similar developments may be occurring. The information presented was obtained through key person interviews (with senior government officials, food safety officers, and food standard employees), questionnaires (sent to key persons in the Saudi Arabia Food and Drug Authority (SFDA) and the Saudi Arabian Standards and Specification Organization (SASO) as well as a literature review of published and unpublished national documents including studies and investigations available from international organizations and international mission reports.

2. Saudi Arabia e an overview of the country 2.1. Background The Kingdom of Saudi Arabia is the largest country in the Middle East in terms of land area, constituting an area of 2,250,000 km2 (SAMIRAD, 2010). Geographically, the country is divided into five

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regions; Central, Western, Northern, Southern and Eastern and there are thirteen provinces each with their own capital city. The Central region is where the Provinces Riyadh, Qasim and Hail lie. This region is mostly arid with a number of oases in the northern area. It is considered the heart of the Kingdom where the capital Riyadh is situated. With intensive irrigation projects, fertilizers and modern technologies, the area lying south of Riyadh, has become a major source of wheat. Qasim Province lying to the north of Riyadh has also become a larger farming area, significantly contributing to the Kingdom’s self-sufficiency in wheat and poultry (SAMIRAD, 2010). The Western region which lies along the Red Sea coast is where the Provinces Al-Baha, Makkah, Madinah and Tabouk lie. The holy cities of Islam, Makkah and Madinah are visited by more than 3 million pilgrims annually. The Northern region is where Al-Jouf and the Northern Border provinces lie. Al-Jouf is an excellent agricultural region mainly for the cultivation of palm trees. Al-Jouf also produces wheat, fruits and vegetables including grapes, figs, potatoes, tomatoes and olives. The Northern Border capital Ar’ar is also known for the production of dates, fruits and vegetables, as well as sheep, goat and camel herding. The Southern region where the provinces Najran, Asir and Jizan lie, is the relatively fertile area of coastal mountains where rainfall supports natural vegetation and cultivation (SAMIRAD, 2010). The Eastern region is where the Eastern Province, the largest province of Saudi Arabia is located. This region is characterized by sandy and stormy weather, and contains most of the Kingdom’s petroleum resources. The mostly populated provinces are Makkah (6.1 million), Riyadh (5.8 million), and the Eastern Province (3.5 million) (Fig. 1). 2.2. Economy Saudi Arabia possesses 25 percent of the world’s proven petroleum reserves and is the world’s largest exporter of petroleum (OPEC, 2008). Although the economy is based to a great extent on the production and exportation of oil, efforts have been made to reduce the dependence on oil and to encourage the development and diversification of the economy. In this respect, the government became committed to develop and transform the agricultural sector, in an attempt to reduce food import costs, achieve self-sufficiency, and provide employment. Although Saudi Arabia is widely thought of as a desert, there are regions where the climate has favoured agriculture, and with the major irrigation projects that have been implemented, agriculture has been able to substantially contribute to the Kingdom’s economy (SAMIRAD, 2010). In 2007, the agriculture sector accounted for 4.8 percent of the gross domestic product (GDP), and employed about 500,000 workers (USDA Foreign Agricultural Service, 2009a). The Kingdom has achieved self-sufficiency in the production of wheat, eggs, milk, and dates, and among the important foods produced are fish, poultry, fruit and vegetables including tomatoes, potatoes, cucumbers, pumpkins, squash and watermelons. Saudi Arabia exports these commodities to its neighbouring countries as well as other markets around the world. The food sector is therefore considered to be one of the most important sectors in the Kingdom’s economy through importing, exporting, manufacturing and distributing food products (SFDA, 2006b) (Table 2). Despite the efforts that have been made to increase food production and to bring a decline in food imports, Saudi Arabia still continues to import most of its food products (around 60% from over 150 countries). Many of the food industries cannot function without the imported raw materials. Large quantities of food must therefore be imported, transported and distributed over vast

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Fig. 1. Map of the Kingdom of Saudi Arabia. Source: http://www.riyadh.gov.sa/Eng/images/KSA_Eng_Map1.jpg (Riyadh Principality - MOI - KSA, 2012).

distances of the Kingdom. Wheat, which has been the principal agricultural accomplishment in recent years, is gradually being eliminated from production. Such crops require/consume a relatively high amount of water and the government has decided to terminate local wheat production by the spring of 2016 in order to conserve its water (USDA Foreign Agricultural Service, 2009a). The scarcity of water and fertile soil are major constraints on cultivation in Saudi Arabian land. Unable to sustain its irrigation, the Kingdom will increase imports to meet local wheat demands. With a rise in export restrictions by trading partners, a decline in domestic food production and a rapidly growing population, Saudi Arabia including the other five GCC countries (Bahrain, Kuwait, Qatar, Oman, and UAE) have in the recent years shifted away from their policy of achieving food self-sufficiency and moved towards a food security approach which has placed greater reliance on imports. The countries have invested in farm projects in countries that have sufficient resources to ensure secure farmland that would enable them to import more food for a rapidly growing GCC nation (Choi, 2010). Saudi Arabia has also been committed to developing tourism as part of its overall economic diversification strategy (SAMIRAD, 2010) and to create employment for a large number of young Saudis. A number of tourism expansion projects are currently underway and it has been predicted that there would be 45.3 million tourists in the year 2020, and a tourist expenditure of 80 billion riyals ($21.3 billion) (SAMIRAD, 2010). One of the main drivers for the tourism industry in Saudi Arabia is religious pilgrimage where the Islamic holy cities, Makkah and Madinah attract millions of Muslims every year. Makkah annually receives Table 2 Agricultural production in the Kingdom of Saudi Arabia. Commodity

Quantity

Eggs Fish and shrimp Meat and poultry Palm dates Vegetables Grains

3161 million eggs 75,000 tonnes 516,000 tonnes 970,000 tonnes 2,617,000 tonnes 3,043,000 tonnes

According to Ministry of Agriculture (2005) census.

over three million pilgrims during the month of Hajj and around two million during the month of Ramadan. During the rest of the year, the holy cities receive around four million tourists. With the development of the tourism sector, it has become important that food safety and quality are ensured to safeguard the health of the visitors and to maintain a healthy and hospitable tourist trade. According to the SFDA, a number of studies have been carried out to assess the hygienic status of food catering establishments in Makkah and Madinah, as well as on Riyadh and Jeddah highways during the pilgrimage season. Results revealed that a high percentage of the food catering establishments had violation notes in their health inspection log books and a number of them were working without a heath inspection log book. High levels of risk were observed due to food handler malpractices including inappropriate cleaning and disinfecting of food containers and utensils; as well as incorrect food preparation, thawing of frozen foods, service, display, storage and transportation. The surrounding environments were found to be unsuitable for the activities of the majority of the food catering establishments, indicating low levels of sanitation. They were described as being considered a good haven for pests, a source of offensive smell or containing stalled water and wastes. Insect traps were not functional or insufficient. Buildings were also described with unclean roofs, doors and windows; cracked and broken walls and floors. It was concluded that stricter control measures were required and meeting sanitary requirements in catering establishments needed more attention in order to limit or prevent food poisoning among pilgrims (SFDA, 2011e). These studies provide clear evidence of the SFDA’s effort to increase their activities in gathering data and in setting the requirements that should exist, thus, contributing to strengthening consumer confidence in the safety and quality of food. 3. The national food control system 3.1. Saudi Arabia Food and Drug Authority (SFDA) e reasons for centralizing food safety responsibilities In Saudi Arabia, the responsibility for all matters related to food had been spread across a number of government ministries and

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agencies. Food control officials reported that this multiple agency food control system resulted in a number of weaknesses/limitations which include: the overlapping and duplication of activities; the lack of transparency and free flow of information among all the agencies involved; differences in experience between the various resources; a discrepancy in the implementation of regulations and standards by each agency; and conflict in setting priorities to meet responsibilities for protecting public health against/versus obligations for trade facilitation. The idea behind centralizing responsibilities for food control within a single body emerged in 1989 (1409H), when his Royal Highness Prince Sultan bin Abdul Aziz, Crown Prince, Deputy Prime Minister, Minister of Defence and Aviation and Inspector General, Head of the Ministerial Committee for Administrative Organization, proposed to re-structure part of the governmental sectors to create a public authority for food and drugs. The idea took many years of comprehensive study by groups of committees and teams including specialists and consultants from within the secretariat general of administrative development and other relevant bodies, to reveal the need of establishing an independent authority to deal with all food and drug issues. The Saudi Food and Drug Authority (SFDA) was established in March 2003. The Council of Ministers enacted legislation to establish this authority, which went into effect in March 2003. Pulling together food control and drug control under the same central authority, where this authority acts as a scientific source of information and advice, would enable setting high standards to ensure consumer safety. When science is used effectively to make food and drug safe, this will contribute to the protection and advancement of health in a country. Within the SFDA, the food sector operates separately from the drug sector, with each sector having its own departments and staff. In the food sector, the SFDA has unified food safety activities, covering all matters related to food including food laws and regulations, food control management, foodborne disease surveillance and investigation systems, inspection services, recall and tracking systems, food monitoring laboratories and information and education activities for the consumers (Elmi, 2004) (Fig. 2). According to food control officials, the reasons for centralizing food safety activities within the SFDA have mainly been for the purpose of improving the effectiveness of Saudi Arabia’s food safety system by reducing overlap and duplication of efforts and enhancing coordination among the multiple governmental bodies responsible for food safety in the Kingdom. Centralizing the responsibility for food control would facilitate the harmonization of food laws and regulations; the standardization of implementation, unifying decision making processes and setting and distributing resources where most needed and in cases of emergency. Among the main objectives of establishing the SFDA, has been to ensure the safety of food across the food chain (local and imported) , by developing and enforcing an appropriate regulatory system for food control that contributes to the protection and advancement of health in Saudi Arabia (SFDA, 2011b). The SFDA plans to adopt a system based on risk analysis, involving and sharing the responsibility for food safety with producers, factories, importers, and consumers, and to work and communicate with them in a professional and transparent manner (SFDA, 2006a). The SFDA has carried out several consultative workshops encouraging the participation and involvement of private food sector companies as well as consumers so that their needs are taken into consideration (SFDA, 2005). Authorities have stated that the SFDA is planning to measure/evaluate their effectiveness in developing/improving the food safety and control system within the Kingdom through Key Performance Indicators (KPIs) which have been selected/decided

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upon in SFDA’s strategic plan. Details of the (KPIs) have not been provided. 3.2. Responsibilities and structure before and after centralization Prior to the establishment of the SFDA, responsibility for food control was divided among various government agencies which include the Ministry of Agriculture, Ministry of Commerce and Industry, Ministry of Municipality and Rural Affairs, the Saudi Arabian Standards and Specification Organization (SASO), Ministry of Health, and the Ministry of Finance e Customs Authority (Table 3). The SFDA has been working with all these ministries in order to develop the general policies and procedures required to ensure and meet safety and quality requirements for food and to ensure readiness before the transfer of any of the functions to the Authority. In a central food authority, a food board acts as one of the principal organs of the authority, with concomitant regulatory and oversight roles (FAO, 2005). The Food Board advises the minister or the head of the food authority on food control and safety matters and includes representatives of all the ministries and agencies involved in food control activities in the country (FAO, 2005). Within Saudi Arabia, the General Authority for Food and Drug is chaired by HRH the Deputy Premier and Minister of Defence, and consists of a Board of Directors composed of the following members: HRH Minster of Municipality and Rural Affairs as vicechairman, HRH Minister of Interior, Minister of Health, Minister of Commerce and Industry, Minister of Agriculture, Minister of Water and Electricity, Minister of Finance, Minister of Economy and Planning, Director General of the Saudi Arabian Standards and Specification Organization (SASO), the Chairperson of the Council of Chambers of Commerce and Industry in the Kingdom, the Authority’s Executive President, and Saudi food and drug experts (SFDA, 2011a). In 2003, the SFDA commenced its assigned tasks in two fiveyear phases (SFDA, 2011c). During the first phase which was also considered preparative and inceptive for phase two, the Authority devoted its efforts to establishing its organizational structure and resources (USDA Foreign Agricultural Service, 2009b). The Authority revised, developed and updated regulatory laws to cope with quality requirements and health safety. In the second phase, the Authority is to assume the criterion, procedural and regulatory tasks mentioned in the first phase, as well as carry out executive tasks such as: inspect all agricultural and animal products and goods for customs clearance; chemical and microbial analysis of food and water samples; control and inspect imported food items as well as locally processed food items before and during production process in markets, commercial centres, restaurants, and food plants to ensure their abidance by and adherence to Saudi specifications (SFDA, 2011a). Authorities have stated however, that the SFDA has abandoned the time phases for completing the assigned tasks, and has postponed setting the deadline for when the Authority has reached readiness. 3.3. Food legislation In Saudi Arabia there has been no comprehensive/unified legislation to include all issues related to food control. There have been a number of laws enacted by the council of Ministers concerned with the protection of health and safety of consumers, and enforcement has been supervised by a number of ministries. The most important law is the Commercial Anti-fraud Act (Royal decree No. 45 dated 14/8/1381H w 21/1/1962). It is the basic food and drug law of Saudi Arabia and is supplemented by special acts

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Fig. 2. SFDA food sector organizational structure (SFDA, 2010).

for commodities such as meat, milk and poultry. The law is intended to assure the consumer that foods are pure and wholesome, safe to eat and have been produced under proper conditions, and that all labelling and packaging is truthful, informative and not deceptive. This act also defines the major types of commercial frauds, including violations and penalties. It also specifies the controlling and investigating departments and offices that have the authority to impose proper penalties according to the current laws, rules and regulations against commercial fraud. The Saudi Standards, Metrology and Quality Organization (SASO) have been the main regulating body concerned with the formulation and setting of food regulations and standards. They have been responsible for issuing mandatory and nonmandatory standards and specifications for foods, food

additives, food packaging materials, pesticides and their requirements of use and pesticide residues in food, as well as the development of public health requirements, i.e., food sanitation laws and guidelines to be met by food establishments and their employees. Since its establishment in 1972, SASO has issued more than 700 production and testing standards for food products, most of which are mainly based on Codex Alimentarius standards and to a lesser extent on European and U.S. standards (USDA Foreign Agricultural Service, 2009b). The standards are carefully selected and adopted after the necessary modifications are made to reflect local conditions. The SASO have also been responsible for granting certificates of conformity and quality mark and regulating their issuance and use through their testing laboratories.

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Table 3 Responsibilities and structure before centralization. Food control management authorities

Main responsibilities

The Ministry of Agriculture

Veterinary and animal healthcare, regulation of all agricultural (fresh fruits and vegetables) and live animal imports, regulating the import, registration, clearing and handling of pesticides, establishing clear policies for their use, and detecting residues in food. The Ministry carries out inspection and testing for all agricultural and animal products. Examining and analyzing imported food products, carrying out testing of the imported foodstuffs at ports of entry, as well as inspecting and sampling at the point of retail sale and in food establishments, the licensing of food premises, and implementing regulations against food commercial fraud. Establishing health and technical requirements for all food establishments, carrying out inspections to verify compliance, and imposing fines in cases of violation. The Ministry also monitors and inspects animal slaughtering facilities and meat sale outlets, collects food samples from the market and sends them off for analysis at the food control laboratory, issues permits for licensing of food establishments and health certificates qualifying food workers. The Ministry also controls products in markets, restaurants, hotels, and local plants in collaboration with the Ministry of Commerce and Industry (FAO/WHO, 2005). More than 200 municipalities distributed over the regions of the Kingdom are responsible for carrying out these tasks. In Riyadh alone, there are 40 municipalities, 20 in Asir, 18 in Qasim, 17 in Makkah, and 17 in the Eastern Province, 11 in Madinah, 15 in Jizan and 13 in Hail. Setting and issuing all standards and specifications related to the safety and quality of food.

The Ministry of Commerce and Industry

The Ministry of Municipality and Rural Affairs

The Saudi Standards, Metrology and Quality Organization (SASO) The Ministry of Health

The Ministry of Finance e Customs Authority

Carries out tests on herbal preparations, health and supplementary foods at the ministry’s central laboratory before registration with the General Directorate of Medical and Pharmaceutical Licenses of the Ministry of Health in order to be marketed in the Kingdom (USDA Foreign Agricultural Service, 2009b). The Ministry of Health has also been responsible for food surveillance in food poisoning cases and related health education. Regulate customs clearance procedures for imported foods.

All activities relating to food standards have shifted from the SASO to the SFDA in July 2011. Thirty five SASO food employees have moved to the SFDA, including 10 food standard employees, 5 quality control employees, and 20 laboratory employees. The SFDA have been setting up the necessary mechanisms that would pave the way for the Authority in taking over the task. An Executive Department for Technical Regulations and Standards has been established within the SFDA. This department holds within it a Food Products of Animal Origin section, a Food Products of Plant Origin section, and a General Food Products section. The following departments have also been established: A Technical Committees Department with separate Food, Feed and Pesticide sections; A Regional and International Standards Department with a Codex National Committee section and an International contact point section; as well as a Compliance Department. For the organizational structure of these departments, refer to Fig. 2. The SFDA has been working and collaborating with the SASO as well as the other concerned ministries in drafting the new Saudi food law. During the first five-year phase of the SFDA’s assigned tasks, the Authority has worked with the concerned ministries and agencies to revise, develop and update regulatory laws to meet human/animal health safety and product quality requirements i.e. regulations & standards related to food safety and quality as well as feed & pesticide safety. A Saudi Feed law has already been drafted and various new standards have been drafted including those related to food nutritional and health claims. In coordination with SASO, the Authority has also worked to prepare specifications, procedures and methods of analyzing food products, i.e., the setting of specifications for code identification and sampling methods of food products. In collaboration with the Ministry of Commerce and Industry, the Authority has worked to establish hygiene specifications and requirements for food industry facilities and workers. In collaboration with the Ministry of Municipality and Rural Affairs, the Authority has worked to establish hygiene requirements for all outlets linked with public health. The Authority also coordinates with this Ministry to develop rules, procedures and requirements for the control and inspection of Saudi Arabia’s animal slaughtering facilities and related sales outlets. The new Saudi food law has been put together by reviewing and renewing current inspection policies and applying international

standards in order to accompany the World Trade Organization (WTO) membership requirements for the Kingdom (SFDA, 2006b). Saudi Arabia became a full member of the WTO in December 2005. During the drafting of the Saudi Food Law, the following resources were considered:  Existing national control laws and regulations  Generic Food Law prepared by FAO  Benchmarking with international and regional food laws such as that of EU, USFDA, Australia, and Japan  In addition to technical assistance from international experts and organizations such as the World Bank, UNDP, WHO, FAO, etc.  The draft law was harmonized with related regional and international laws and regulations and to meet commitments towards the WTO.  The draft law adopts a risk-based and food chain concept to ensure traceability.  The draft law was presented to all concerned parties. Regulations have been reviewed by the Shoura Council which is the consultative assembly and the legislature of the country. The new Saudi food law is currently at its final stage where it is being discussed by a panel of experts, awaiting approval by the council of ministers. General Features of the Saudi Food Law include the following:  Defines the authority’s mandate and powers as well as its organizational structure.  Sets and defines the responsibilities and functions of the SFDA for regulating, overseeing, and controlling food which include: B setting mandatory standards for both imported and locally manufactured products; B HACCP or any similar food safety and quality assurance system has become mandatory for food imports as well as local food premises; B issuing mandatory technical regulations, standards and specifications for food, fodder and pesticides; B inspection of imported foods; B inspection of food factories and large food warehouses; B licensing of food establishments

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B issuing the quality mark and granting certificates of conformity; B granting accreditation and licensing to private food laboratories  Provides the SFDA with the legal tools necessary to match its new responsibilities  Lays down methods of inspecting, monitoring and verifying the safety and quality of food products.  Lays down effective enforcement mechanisms (e.g. the imposition of sanctions where fines have dramatically increased; provisions falling into offences and penalties.  Declaring a state of emergency for particular situations.

national human resources for the control of imported food. The program involves developing advanced, risk-based and unified food inspection and sampling techniques at all ports of entry. The SFDA are expecting to complete the Food Imports Control Program by June 2012. The SFDA is to gradually take over the inspection of local food and food premises, starting with large food establishments. This responsibility however, still remains with the various municipalities under the Ministry of Municipality and Rural Affairs. An Executive Department for Local Markets Control has been established within the SFDA (see Fig. 2). A Food Factories & Warehouse Databases Project has also been launched to include databases of food factories and warehouses and their branches within the Kingdom (SFDA, 2011d).

3.4. Food inspection 3.5. Food control laboratories Saudi Arabia’s Ministry of Agriculture has been responsible for the inspection of imported livestock, plants, seeds, pesticides and animal feed as well as fresh fruits and vegetables. The Ministry has animal and agricultural quarantine facilities located in the customs access points (FAO/WHO, 2005). The Ministry of Commerce and Industry e Quality Control and Inspections Department have been responsible for inspecting imported processed and packaged food items at the various ports of entry. The Ministry of Municipality and Rural Affairs has been responsible for monitoring of products already in the market. Inspectors at the municipality levels inspect retailers, wholesalers, restaurants, hotels, local plants, bakeries, fast food chains, vegetable and meat markets for expiration dates, sanitary and storage conditions as well as product handling. Outlets found selling unhygienic or expired products are exposed to stiff financial fines, temporary closure or both (USDA Foreign Agricultural Service, 2009b). After an assessment of the current approach that has been followed in Saudi Arabia for food inspection, an evaluation of international experiences, and a study of the modern trends, food control officials have adopted a system termed the “Oversee and Verify” approach to be implemented by the SFDA. The regulators/ inspectors are to verify compliance with food safety and quality requirements at all stages of the food chain, from production to consumption, together with the implementation of national food contaminant monitoring programs, to ensure the prevention of potential risks according to the risk assessment. Since May 25, 2009, the responsibility for inspection of imported food has moved from the Ministry of Commerce and Industry to the SFDA. The Authority has become responsible for inspecting imported high value food products at 23 ports (land, air, and sea) of the Kingdom’s 29 ports of entry. There are 300 staff members assigned to this task. An Executive Department for Imported Food Control has been established within the SFDA (see Fig. 2). The majority of Saudi food imports enter the country via Jeddah port on the Red Sea or Dammam port on the Arabian Gulf. About 70 percent of all foodstuffs enter Jeddah port. Imports from Jordan, Syria, and nearby countries enter the Kingdom by truck. King Khalid International Airport in Riyadh and King Abdulaziz International Airport in Jeddah also receive significant quantities of food items, particularly fresh fruits, vegetables and chilled meat (USDA Foreign Agricultural Service, 2009b). The responsibility for inspecting imported fresh fruit and vegetables as well as feed and pesticides still remains with the Ministry of Agriculture. It is expected to gradually shift to the SFDA, however, a specific timing or period for when this is expected to occur has not been provided. . The authority has hired “GTZ”, a German Government body, to help implement its three-year (starting 2009) 750 million Saudi Riyal ($200 million dollar) capacity building program, “Food Imports Control Program”, aiming to train and qualify professional

The Ministry of Commerce and Industry have been responsible for examining and analyzing imported food products introduced into the Kingdom by land, air, and sea (FAO/WHO, 2005). There are ten food control and analysis laboratories with eleven branches located at different ports (cities) within the Kingdom. Locally produced foods in the market are also analyzed by the Ministry of Commerce and Industry, where the inspectors make periodical visits to the factories and markets, and refer food samples of doubtful integrity/fraud for laboratory analysis in order to verify suitability for human consumption and conformity with standards and specifications. The Ministry also analyses food samples referred by the municipalities and other government ministries. The Ministry of Commerce and Industry food control laboratories included the following departments:  Sample receiving department  Chemical analysis department: analyze pesticides, heavy metals, toxins and mycotoxins, growth hormones, antibiotics, food additives, alcohols, emulsifiers, oils and fats, dairy products, carbohydrates, proteins, salts and minerals.  Microbiological analysis department: carry out general analyses for meat, poultry, fish and baby foods.  Food irradiation testing department  Standardization and metrology department  Quality assurance department  Research department The responsibility for food analytical laboratories shifted from the Ministry of Commerce and Industry to the SFDA in May 2009. The SFDA has been cooperating with the MOCAI in order to develop a sophisticated plan that seeks taking over several activities of the food control laboratories gradually. Several trips have been made by the Authority to the ports to evaluate the laboratories from different aspects including the buildings infrastructure and the level of human abilities and their training needs. The authority also discussed working mechanisms at the ports including the process of receiving and analyzing food samples, the process of customs clearance, and the Authority’s electronic system for tracking analysis results and the clearing process of foodstuff shipments. The Authority reports that it has been working to comprehensively develop the food control laboratories by establishing new ones, developing the existing ones (restructuring the food laboratories at the ports); updating equipment and machinery; reviewing and restructuring the mechanism of sampling and analysis, as well as the laboratory work plan to facilitate the customs clearing process and flow of goods through the ports. GTZ is providing

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expertise to help SFDA in the qualification and accreditation of its laboratories. The capacity building programme involves upgrading food analytical laboratories at custom ports; developing a laboratory information management system; and linking all laboratories at the custom ports with the SFDA through a local internet network. The SFDA is also working with GTZ on preparing national qualified food laboratory staff by conducting training courses and workshops in order to improve their abilities in dealing with imported food (SFDA, 2007). The Authority now has 9 laboratories involved in the analysis of food (two at the SFDA headquarters in Riyadh and seven laboratories at ports of entry). These laboratories carry out physical, chemical and microbiological analysis of the food samples according to their risk. There still remains a lack of staff and laboratories to cover the 29 ports distributed throughout the Kingdom. The authority is working to establish food inspection, sampling and analytical laboratory facilities for imported foods at all ports of entry within the Kingdom. A laboratory project has been launched to assess the safety of food containers and packing materials. The Laboratory is to test for any migration in food that may cause its contamination or damage (SFDA, 2011d). This again is clear evidence of the SFDA’s effort in extending their activities to ensure the safety of food for consumers.

3.6. Food safety and quality information education and communication (IEC) In the past, consumer education and participation in Saudi Arabia was facilitated by the industrial chambers of commerce, through consumer protection committees. According to the report of the third session of the FAO/WHO coordinating committee for the Near East region, the industrial chambers of commerce participated along with the technical and general committees and the SASO board of directors in the food standards setting process, therefore enabling consumer participation. Also, most government entities have directorates responsible for consumer protection which participate in the food standards setting process through the SASO (FAO/WHO, 2005). The SFDA has established a Department for Awareness and Communication. Its organizational structure consists of a Consumer Awareness Department with a section for handling enquiries and complaints; and a Business Sector Department with a section for providing technical assistance. Within the department, a Centre for Information and Communication has also been established, with a World Trade Organization Enquiry section, a Food, Feed and Pesticides Database section as well as an Electronic Library section. The department is responsible for preparing food safety educational and awareness materials (legible, audio and visual) as well as carrying out national campaigns, workshops and seminars to raise awareness, guide and spread the food safety culture among consumers, food handlers and food control officers. An ongoing Food Safety Awareness Program aims to raise awareness on safe food handling practices, providing indirect support to food factories and stores. The department also carries out the needed studies to cover the latest local and global food safety topics and to remain updated with all new safety issues in the field of food, feed and pesticides. The SFDA is implementing an integrated electronic database on food, animal feed and pesticide safety awareness, linked to their official website on the internet. Consumer opinion polls are carried out periodically and a database and information system is being built for producers and stakeholders, in order to facilitate communication with them.

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4. Building a modern food control system Since its establishment, the SFDA has worked to create a strategy for developing the food control system by shifting to follow a more modern and globally accepted scheme/trend based on risk analysis and an integrated farm-to-table approach. The Authority has been acting on the development of a number of departments and centres such as: a department for risk assessment, a centre for the monitoring of food contaminants, a centre for the control of foodborne illness, as well as an early warning centre for food “Centre for Food Rapid Alert” and crisis management (see Fig. 2). 4.1. Risk assessment department The risk assessment department is responsible for carrying out science-based risk assessments for food, feed and pesticides. Within the risk assessment department, a department of exposure assessment and a department of scientific databases also exists. Together, these three departments carry out the following main tasks:  Identify risks (physical, chemical and biological) associated with local and imported food and classify them according to the degree of danger they present.  Provide a system for classifying risks associated with all food, feed and pesticides which involves categorizing them if they have the potential to pose a high, medium or low risk to public health. Food, feed and pesticides would then be inspected and tested according to a pre-determined list of potential hazards both at all ports of entry and in local markets.  Develop a mechanism that allows for constant updating of the risk classification and coding system in response to new safety threats for food, feed and pesticides as they arise.  Provide the scientific support necessary in developing the methods and mechanisms for crisis management as well as assist in the development of policies and regulations for food, feed and pesticides.  Conduct research to meet deficiencies in the data currently available, which prevents the risk assessment of food, feed and pesticides as required; through participation in research projects (locally and internationally).  Establish the Department of Scientific Databases to include integrated, comprehensive scientific information and data on the safety of food, feed and pesticides.  Develop training programs to raise the eligibility and efficiency of employees.

4.2. Centre for monitoring and control of foodborne illness The centre carries out investigations of foodborne disease incidents and monitors these cases through food poisoning reports which are received. Reports and notifications are received from hospitals and medical laboratories. The centre investigates and follows up the collection of this information on an ongoing basis, analyzing, concluding and planning for appropriate implementation measures to reduce food contamination. Results and recommendations on ways to avoid such incidents are then disseminated at all levels (consumers, food industries, food control officers) and used as a basis for policy making (to develop food safety regulations and directives). The centre consists of four sections: a centre for epidemiological surveillance; a section for monitoring of diseases transmitted by food; a section for foodborne disease prevention programs and

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Table 4 SWOT analysis of centralizing food control in Saudi Arabia. Strengths A. Employ/apply a risk-based system to ensure the safety of food across the food chain ➢ GTZ food imports control program ➢ Unified and risk-based inspection and sampling techniques at all ports of entry ➢ Mandatory HACCP/equivalent quality assurance system for imported ➢ and locally produced food and food establishments ➢ Risk assessment department for food, feed and pesticides B. Take the lead in coordinating and harmonizing food control activities across the whole food chain ➢ Clear national policy ➢ Leadership and commitment from governmental officials to transform and harmonize food control activities ➢ More efficient use of resources ➢ Increased coordination and transparency ➢ Standardization of implementation & unifying decision making processes ➢ Harmonization of food laws and regulations ➢ Adequately training resources ➢ Upgrading food analytical laboratories with information management systems C. Prevent and protect against fraud in connection with the sale of food ➢ ➢

The new Saudi Food Law lays down provisions falling into offences & penalties The new Saudi Food Law lays down effective enforcement mechanisms (e.g. the imposition of sanctions where fines have dramatically increased ➢ Inspection and laboratory analysis to assess conformity D. Formulate strategies and policies on food, nutrition and food security, including procedures for emergency response, and monitor their implementation ➢ National food contaminant monitoring programs to ensure prevention of potential risks ➢ Centre for foodborne illness control develop food poisoning prevention programs based on risk ➢ Centre for food rapid alert and crisis management ➢ New standards drafted on food nutritional and health claims ➢ Food security approach to invest in overseas farm projects E. Encourage and promote research on food matters within the country

Weaknesses ➢ ➢

➢ ➢ ➢ ➢ ➢ ➢ ➢ ➢ ➢ ➢

The application of risk analysis is not yet strong Mandatory HACCP creates a challenge where strategies to facilitate and encourage implementation and required for the food industry and food control officials (inspectors/auditors) Centralization involves financial costs and disruption of food control activities Limited resources Lack of staff and laboratories to cover the 29 ports distributed throughout the Kingdom Food control activities in a transitional period Inspection and analysis of local food has not yet shifted completely to the SFDA Gradual decline in domestic food production Financial costs involved with greater reliance on imports As a result of the major reform, activities have been progressing rather slowly Language barrier created by a largely foreign workforce in the food industry Promoting the development of a common organizational culture is challenging

➢ ➢ ➢ ➢

Studies carried out to assess the hygienic status of food catering establishments Project launched to assess the safety of food containers and packing materials Ongoing research studies to remain updated with all new food safety issues Epidemiological studies to determine incidence of foodborne illnesses in the community F. Prepare and amend food laws, regulations and standards ➢ Legislative overhaul to clarify changes in food control and safety measures ➢ Harmonization with related regional and international laws and regulations ➢ Meeting the Kingdom’s commitments towards the WTO ➢ Adopting safety of the whole food chain concept to ensure traceability ➢ Adopting a risk-based and preventive control concept ➢ The new law was presented to all concerned parties G. Consult widely with all sectors of the food chain ➢ Several consultative workshops carried out with private food sector and consumers ➢ Saudi Food Law draft has been presented to all concerned parties H. Provide advice, information or assistance to any public authority in relation to food control, food safety and food trade ➢ Centre for Information and Communication established ➢ World Trade Organization Enquiry section ➢ Codex National Committee section and international contact point section I. Obtain, compile and keep under review information concerning food control, food safety, food trade and nutrition ➢ Databases of food factories, warehouses and their branches within the Kingdom ➢ Electronic linking systems with local internet network ➢ Food, Feed and Pesticides Database section ➢ Electronic Library section J. Promote education regarding food safety and nutrition ➢ ➢ ➢

SFDA department for awareness and communication established Ongoing food safety awareness programmes and communication with producers, factories, importers, and consumers. Training programmes to raise efficiency of SFDA employees

Opportunities ➢ ➢ ➢ ➢

Increased awareness on food safety and foodborne illnesses Membership of the World Trade Organization (WTO) Membership of the Codex Alimentarius Commission Harmonizing national standards with Codex

Threats ➢ ➢ ➢

Mandatory HACCP for food imports & difficulty in finding and/or ensuring HACCP certified suppliers Export restrictions by trading partners Rapidly growing population & increasing food demand

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Table 4 (continued ) ➢ ➢

Availability of funds and government commitment Plans to establish a database to be used for educational purposes, consultative services and practical programs in the food sector

➢ ➢ ➢

➢ ➢

➢

➢ ➢

a section for statistics and studies. Together, these sections carry out the following tasks:  Collect information on food safety from all relevant government agencies in a single database, analyze and issue periodic reports on food safety.  Monitor food poisoning incidents, outbreaks and other food safety problems associated with locally produced food and food manufacturers as well as imported foods.  The use of epidemiological studies and epidemiological surveillance reports to determine the incidence of foodborne illnesses in the community.  Develop programs for the prevention of food poisoning based on risk assessment.  Follow-up international events and developments in this area and provide support to other centres, such as the centre for food rapid alert.

4.3. National centre for monitoring and control of food contaminants The national centre for monitoring and control of food contaminants aims to assess the safety of raw and processed foods available in the local market, whether imported or locally produced. The centre works to reveal the source and types of contaminants associated with each food product of animal and non-animal origin. The centre also monitors food additives, pesticides residues and environmental contaminants in food and feed, as well as the safety of surfaces in direct contact with food. The centre’s specialized laboratories function according to a monitoring programme based on science for the analysis and detection of contaminants and assessment rates. This then assists in the provision and control of imported and locally produced foods in the Saudi markets to ensure their safety. Four specialized laboratories have been established for this purpose, including a highly equipped laboratory for monitoring pesticide residues in food; a laboratory for the analysis of mycotoxins; a laboratory for the assessment of organic contaminants; and a laboratory for the assessment of heavy metals. Laboratory technicians have been trained in local training courses/sessions as well as in international/universal reference laboratories in order to raise their competence to work in the specialized units of the centre. 4.4. Centre for Food Rapid Alert The goal of the Centre for Food Rapid Alert is to protect the health of consumers through the rapid notification of any potential

Scarcity of water & fertile soil to maintain food selfsufficiency Food security approach placed greater reliance on imports It has been suggested that foreign farmland investments can cause political and social tensions, lead to exploitation of farmers and distort trade High import dependence presents a key challenge Vast and widespread land areas and severe/adverse climatic conditions present a challenge for the transport and distribution of food Work culture of many foreign workers (coming from less developed countries) relied on to maintain food industries Expanding tourism industry with unsuitable food catering environments in many tourist areas Political upheaval

food threats, and the immediate withdrawal of any suspected food products from the market. The responsibilities of the Centre include:  Monitoring alerts and reports of food safety threats around the clock to help act rapidly and in a coordinated manner in response to a health threat caused by food.  Coordinating with the relevant government agencies and companies that are importing or manufacturing locally, for the immediate withdrawal of defective products from the market, and to prevent entry and circulation.  Management and follow-up of reports and notifications to ensure the withdrawal of defective products from the market.  Development of legislation and executive regulations for the rapid alert system for food. A database on the alerts and notifications of food is being created to facilitate the rapid alert management and food traceability systems. Work is also underway to link the Centre with the relevant international agencies for continuous access to food alerts and warnings. 5. SWOT analysis of centralizing food control in Saudi Arabia Based on the above evidence, Table 2 shows our analysis of the strengths, weaknesses, opportunities and threats of centralizing the food control system in Saudi Arabia. This analysis uses the principal functions of the Authority in a Single Agency System derived from the New Model Food Law (FAO, 2005) which has been presented earlier above in Section 1. It provides they key characteristics in food control regulatory structures that indicate the elements on which a centralized food control authority might focus. Our SWOT analysis uses these elements (Table 4). 6. Discussion and conclusion The food control system in Saudi Arabia has been characterized by the fragmentation of its organizational structures. The responsibility for food safety has been divided and widely dispersed among several government ministries and agencies, causing duplication of regulatory activity, increased bureaucracy, and lack of coordination and efficiency. The roles of these authorities varied widely and the system has led to frequent gaps and overlaps in food control activities, which officials say have contributed to food safety problems. This has called for major reform of the food control system in Saudi Arabia, where the entire system was transformed by a legislature with a renewed regulatory authority. Reforming food control systems is possible when a consensus exists among

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different government ministries. The government moved towards the centralization of its food control activities, restructuring institutions to establish a national food and drug authority as an independent administration to coordinate and implement all activities related to food control. In many countries, where the shared responsibility for food control among government ministries has lead to problems such as fragmentation and a lack of coordination, there has been a growing tendency to establish a single agency to lead and oversee food control activities. Such agencies/authorities have been established in Belize, Canada, Denmark, Germany, Ireland, the Netherlands, New Zealand and the United Kingdom. Although the countries varied in their approaches and the extent to which they consolidated their food safety systems, according to the US GAO (2005) report, each country has reported beneficial effects as a result of its consolidation. These include significant qualitative improvements in food safety operations that enhance effectiveness or efficiency such as: reduced overlap in inspections; more targeted inspections based on food safety risk; more consistent or timely enforcement of food safety laws and regulations; and greater clarity in responsibilities (US GAO, 2005). Although on its way towards the complete centralization of its food control system, results of the SFDA reorganization have already shown increased coordination and transparency and a more efficient use of resources, reducing fragmentation and overlapping of food control responsibilities. However, the SFDA still remains in its capacity building stages e at an intermediary stage of development where a lot of work still needs to be done. Therefore, it may currently be too early to fully assess the benefits of centralization. Although the Authority has been functioning for almost 9 years, the major reform and the extent of the change which has been going on has resulted in activities progressing rather slowly. The Authority will be formally evaluating whether it is effective in improving the safety of food within Saudi Arabia through Key Performance Indicators (KPIs). This will be necessary to assess the success of a centralized system in optimizing food safety measures, such as reducing foodborne illnesses and/or improving industry compliance rates. While centralization is likely to result in many advantages/ improvements in the long run as shown in the SWOT analysis, most benefits would primarily come from the entire transformation of the system by a legislative overhaul to resolve the system’s inadequacies. The SFDA has carried out major revision of the Saudi food law and a new food safety law has been drafted identifying overlaps and gaps, making necessary changes to help ensure that all imported and local foods conform to local specifications and international standards. Also, by becoming a member of the World Trade Organization in 2005, this has affected the design of the national food law. Saudi Arabia has been committed to achieve global standards in food safety and to reflect this in its national food law by applying/following Codex guidelines for food safety in the revision, updating and enacting of new food laws. The SFDA has also established a WTO enquiry section to ensure continued compliance with WTO rules and international standards. Membership of the WTO has provided an opportunity to enhance the Saudi economy by increasing market access for Saudi agricultural and processed food products through tariff reductions and reduced restrictions on distribution (Rosenthal, 2005). The transition of the Saudi food control system to a new organizational structure has been an enormous management task, in which all the various components of the system, i.e. coordination and administrative procedures; food laws, regulations and policy development; foodborne disease surveillance and investigation systems; inspection services, recall and tracking systems; food monitoring laboratories and information and education activities

for the consumers, moved to operate under one executive authority. According to the (FAO, 2005) Legislative Study, creating a new central governmental authority to coordinate and implement all activities in the food control system, may be considered too dramatic a change where the transfer of human and physical resources from existing ministries and agencies to the newly created organization has its attendant financial costs and disruption of control especially during the early stages of its operation. Although the SFDA commenced its assigned tasks in two fiveyear phases, the time phases for completing the tasks were abandoned and the time frame/deadline was left undecided for when until the Authority has reached readiness. As seen in the SWOT analysis, the SFDA still remains in a transitional phase and this is believed to be due to the creation of new departments to carry out food control activities which did not exist before with the old system. Establishing the SFDA has not only been a matter of moving staff to the central authority to perform their same tasks. Centralization also involved the creation of new sections and tasks that require substantial preparation. In addition, personnel at every level need to be constantly educated, trained and informed of the food safety control methods and procedures. This is a timely process which also requires the establishment of an in-depth understanding among employees together with the promotion of a positive attitude towards collaboration and teamwork. With these major developments, the pre-estimated time scale for completion of tasks may have not been realistic and the authority eventually came to realize that they would not be ready in time for execution of the tasks. With a single central authority carrying out all the tasks for food control, this system is more likely to be much slower than a decentralized organization. However, setting a deadline for completing tasks will help encourage proactivity and commitment to achieve goals, while at the same time reducing the possibility of procrastination. A centralized national food control system requires additional staff to support the significant expansion of the infrastructure as well as the development of needed programmes. This also involves moving food control employees from the various ministries and agencies across the country to the SFDA. One of the main challenges cited by officials was to promote the development of a common organizational culture, to help the employees familiarize with and assimilate into the culture of the new Authority. This is a timely process which requires holding regular meetings, training programmes and workshops. Since its establishment in 2003, the Authority has so far been able to achieve the following:  Establish its organizational structure and resources;  Revise, develop and update regulatory laws to cope with quality requirements and health safety;  Chemical and microbial analysis of food and water samples;  Control and inspect imported food items;  Preparing the standards, procedures and means of inspecting the food products Tasks that are yet to be achieved include the following:  Inspect all agricultural and animal products and goods for customs clearance;  Control and inspect locally processed food items before and during production process in markets, commercial centres, restaurants, and food plants to ensure their abidance by and adherence to Saudi specifications;  Preparing and developing the training programs that would raise the efficiency of those who work in the food sector in cooperation with the relevant authorities;

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 Inspecting all the animal plant products that are meant for human consumption and animal feed;  Inspecting pesticides;  Verifying that the food products produced by the local factories conform to the standards before selling them;  Establishing a database to be used for educational purposes, consultative services and practical programs in the food sector The SWOT analysis shows that the high import dependence in Saudi Arabia presents a key challenge to the authorities. A large proportion of the food consumed domestically is imported, and despite the efforts that have been made to increase food production and to bring a decline in food imports, Saudi Arabia still continues to import around 60% of its food. Moreover, with the plan to terminate local wheat production due to limited water resources, Saudi Arabia’s consumption of imported foods is only expected to rise in the coming years. Also, with the development of tourism in Saudi Arabia, where the Government has focused on developing the religious tourism sector in particular, there has been a need for the availability of a diverse range of foods to meet the demands of pilgrims coming from varying ethnicities and backgrounds. The increasing demand for consumer foods has driven up imports in the Kingdom, and this is also a trend which is expected to continue in the foreseeable future. Increased food import reliance together with the food safety threats that have been occurring in countries from which many foods are imported has increased the likelihood that contaminated food from other countries, may cross Saudi borders. Many hazards can enter the food chain at a variety of points, and with the high imports, the government does not have control over the entire food chain. The SFDA’s capacity building Food Imports Control Program has the potential to eventually provide proper oversight that would help in preventing many food safety risks. However, the reliance on inspection and sampling at ports of entry to determine whether imported foods meet requirements is not alone capable of detecting many of the serious risks to public health. Even with advanced, unified and risk-based inspection and sampling techniques at all ports of entry, as well as adequately trained resources to keep up with a growing demand, there is a need for requiring that imported foods are safely produced at the source, under a quality assurance system. Under the new Saudi food law, the implementation of HACCP or any similar/equivalent quality assurance system has become mandatory for imported foods as well as locally produced foods and food establishments. Overseas and local manufacturers will be required to implement such programs if they wanted to maintain a license to export or sell their products. This will shift the emphasis from measures targeting outcomes to process-based controls where food safety and quality are managed throughout the production process/food chain, eliminating any risks at the source. However, mandatory HACCP may create a number of challenges for food control authorities as seen in the UAE where there would be an increasing need for HACCP training and competencies to be developed (Al-Kandari & Jukes, 2011). With a high import reliance, there may also be difficulties in finding and/or ensuring HACCP certified suppliers. With the HACCP system becoming mandatory, the SFDA is presented with a significant challenge to educate and train food industry personnel as well as regulatory officials to help bring the culture change needed to shift to a more preventative and effective food safety system. Many foreign workers are relied on to maintain the food industries in Saudi Arabia, and this represents another major challenge to the SFDA, created by the language barrier of

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a largely foreign workforce in the food industry. The development of quality assurance systems will need to be a gradual process involving continuous and appropriate training to ensure adaptation and effective implementation. With the vast and widespread land areas in Saudi Arabia, where large quantities of food need to be transported and distributed across vast distances of the Kingdom at adverse climatic conditions, adopting a self-regulatory approach/system by the local industry will play a very important role in minimizing food safety risks. Also with small and medium food businesses representing a large proportion of the food industry, adopting a system of self regulation will help shift the focus of government activity from an enforcement-oriented approach, as it was previously, towards a more collaborative approach involving auditing and oversight. With so many facilities across the entire food supply chain, it is a challenge to carry out consistent inspectional coverage. Therefore, government resources and expertise would be better applied to monitoring the controls exercised by the food industries themselves. The Authority has been acting on the development of a number of departments: the food safety awareness and communication department, the risk assessment department, and the monitoring centres and crisis management department, which will play an important role in enabling food control officials to effectively and promptly assess, educate, communicate, and manage foodborne risks and/or food safety emergencies. The establishment of the SFDA provides several opportunities for regional collaboration within the GCC, encouraging creating effective and efficient food control systems in each country with improved coordinated efforts among the member countries (Alomirah et al., 2010). The establishment of the Saudi Food and Drug Authority may be considered a unique experience as it is comprehensive, bringing under one umbrella all activities relating to food. Its establishment has provided a major opportunity to establish a truly effective food control system in which food safety is given the highest priority. The creation of an authority however, does not immediately solve all the issues and time is needed to build the necessary infrastructure and to fully implement new policies and procedures. While the centralization of food control may be considered the most effective way to achieve an integrated food chain approach to food safety (FAO, 2005), the transformation towards this approach is nevertheless a challenging process. As seen with the experience of Saudi Arabia, it is a timely process which requires government leadership and commitment supported by the political will as well as clear national policies. Political upheaval/instability and its potential impact on the region may give rise to new challenges. However, many of the strengths seen in the SWOT analysis have resulted from the Governments’ initiative and commitment to take the lead in transforming and harmonizing food control. A vital part of the Authority’s work will be to continuously try to adapt to new/ rising challenges.

References Al-Kandari, D., & Jukes, D. J. (2009). A situation analysis of the food control systems in Arab Gulf Cooperation Council (GCC) countries. Food Control, 20, 1112e1118. Al-Kandari, D., & Jukes, D. J. (2011). Incorporating HACCP into national food control systems e analyzing progress in the United Arab Emirates. Food Control, 22, 851e861. Alomirah, H. F., Al-Zenki, S. F., Sawaya, W. N., Jabsheh, F., Husain, A. J., AlMazeedi, H. M., et al. (2010). Assessment of the food control system in the State of Kuwait. Food Control, 21, 496e504. Choi, W.-M. (2010). WTO rules and agricultural development cooperation between developed and developing countries. In Law and development institute inaugural conference, October 2010, Sydney, Australia. http://www.lawanddevelopment. net/img/choi.pdf.

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