Vietnam Food Safety Risks Management Challenges and Opportunities @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. 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: 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 Citation World Bank. 2017. Food safety risk management in Vietnam: Challenges and opportunities. Technical working paper. Hanoi, Vietnam: World Bank. Contents List of figures 8 List of tables 9 Acknowledgements 11 Acronyms and abbreviations 12 Executive summary 15 1. Introduction 19 1.1. Context 19 1.2. Objectives 19 1.3. Methods 19 1.3.1. Round-table discussion and consultation workshop 20 1.3.2. Technical missions 20 1.3.3. Food Safety Working Group (FSWG) 20 1.3.4. Literature review, data analysis and synthesis 20 1.4. Scope of the study 21 1.5. Reading guide 21 2. Institutional setup and capacity for food safety management 23 2.1. Legal framework 23 2.2. Institutional framework 24 2.2.1. Responsibilities between national and provincial levels 25 2.2.2. Coordination 26 2.2.3. National Strategy for Food Safety for 2011 to 2020 and a vision towards 2030 27 2.3. Standards and technical regulations 27 2.4. Inspection, enforcement, surveillance and control 28 2.4.1. Inspection and enforcement 28 2.4.2. Surveillance 29 2.4.3. Import controls 31 2.4.4. Export controls 31 2.4.5. Human resource capacities and challenges 32 2.5. Food safety laboratories 34 2.6. Accreditation of conformity assessment bodies 35 2.7. Food safety training programs at academic level 36 2.8. Key messages from this section 36 Vietnam Food Safety Risks Management - Challenges and Opportunities Page 5 3. Key pork and vegetable value chains in Ha Noi and Ho Chi Minh City 39 3.1. Rationale for value chain selection 39 3.2. Pork value chain in Ha Noi and Ho Chi Minh City 39 3.2.1. Consumption 40 3.2.2. Production 40 3.2.3. Pig processing system 40 3.2.4. Distribution system 41 3.2.5. Food safety risks 42 3.3. Vegetable value chain in Ha Noi and Ho Chi Minh City 43 3.3.1. Consumption 43 3.3.2. Production 43 3.3.3. Distribution 44 3.3.4. Food safety risks 44 3.4. Some implications for the value chains in the case of Ha Noi 45 3.4.1. Responsibilities of different ministries and departments 45 3.4.2. Laws and regulations 45 3.4.3. Surveillance, inspection and preventive approaches 46 3.4.4. Available data 46 3.4.5. Food safety laboratories 46 3.4.6. Training 46 3.5. Food safety production models 46 3.6. Key messages from this section 47 4. Food safety hazards, risk and health impact 49 4.1. Risk-based approach: hazards and risks 49 4.2. Food safety hazards 49 4.2.1. Biological hazards 50 4.2.2. Chemical hazards 51 4.2.3. Physical hazards 55 4.3. Foodborne disease outbreaks 55 4.3.1. Overview of available information 55 4.3.2. Commodities, affected groups, time and locations 57 4.4. Food safety risks and health impact 59 4.4.1. WHO 2015 report and other sources on foodborne disease burden 59 4.4.2. Current knowledge on health impact of foodborne diseases in Vietnam 59 4.4.3. Gaps: Contamination data versus health risks 62 4.5. Key messages from this section 62 6 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 5. Food safety risk communication and management: Challenges, confidence, trust and priorities 63 5.1. Current risk communication challenges: Lack of confidence and trust of consumers 63 5.2. The phenomenon of food scares 63 5.3. Economic impact of food scares 64 5.4. Strategic response 64 5.5. Techniques of risk communication 65 5.6. Communications strategy 65 5.7. Challenges within government 66 5.8. Key messages from this section 66 6. Food safety impacts on trade 69 6.1 Current trade situation and long-term trends 69 6.2. Food safety and trade issues 69 6.3. Major food exports 69 6.4. Safety of exported food 69 6.4.1. Major food safety hazards in food exported from Vietnam 71 6.4.2. Trends in food safety performance 71 6.4.3. Divergence between export and domestic food safety 73 6.5. Major food imports 74 6.6. Safety of imported food 74 6.7. Membership in trade agreements 75 6.8. Key messages from this section 76 7. Recommendations 77 8. References 84 9. Annexes 89 Vietnam Food Safety Risks Management - Challenges and Opportunities Page 7 List of figures Figure 1: Hierarchy of laws in Vietnam presented for the Food Safety Law..........................................................23 Figure 2: Distribution of responsibilities related to food safety................................................................................ 24 Figure 3: The structure of food safety management from central to local level.....................................................26 Figure 4: Food safety laboratory structure in Vietnam............................................................................................. 34 Figure 5: Ministry of Health food safety laboratory system.....................................................................................35 Figure 6: Pork value chain supplying Ha Noi and Ho Chi Minh City.....................................................................39 Figure 7: Vegetable value chain supplying Ha Noi and Ho Chi Minh City.............................................................43 Figure 8: Potential chemical hazards from farm to fork..........................................................................................52 Figure 9: Shigellosis distribution in eight regions in Vietnam every five-year period from 1999 to 2013............ 60 Figure 10: Number of food safety alerts for food exported from Vietnam to the European Union (2005-15)..... 72 Figure 11: Food safety violations for food exported from Vietnam to Japan.......................................................... 72 8 Page Vietnam Food Safety Risks Management - Challenges and Opportunities List of tables Table 1: Non-compliant food products detected during an import inspection, 2014.............................................31 Table 2: Human resources of the Crop Food Safety Management System in MARD and provinces...................33 Table 3: Summary of food sources of major microbial hazards and health effects (in order of the magnitude of health burden in the WHO Western Pacific region B (which contains Vietnam))............................................. 51 Table 4: Origins of selected chemical food hazards in vegetables............................................................................53 Table 5: Numbers of food poisoning outbreaks, cases and deaths in Vietnam, 2006 to 2013................................ 55 Table 6: Numbers of food poisoning outbreaks, cases, hospitalizations and deaths in Vietnam in 2014 and 2015............................................................................................................................................................56 Table 7: Numbers of foodborne disease outbreaks in Vietnam from 2010 to 2015, by cause of outbreak........... 56 Table 8: Numbers of foodborne disease outbreaks in Vietnam in 2014 and 2015, by geographical area.............57 Table 9: Numbers of foodborne disease outbreaks in Vietnam from 2012 to 2015, by location............................57 Table 10: Numbers of foodborne disease outbreaks in Vietnam from 2012 to 2015, by food type....................... 58 Table 11: Numbers of deaths due to foodborne disease outbreaks in Vietnam, by cause of death.......................58 Table 12: Value of major food exports from Vietnam to the European Union and number of food safety notifications (2005-15)........................................................................................................................................70 Table 13: Number of shipments from Vietnam to Japan inspected and in violation..............................................70 Table 14: Hazards found in food exported from Vietnam to the European Union (2005-15)................................ 71 Vietnam Food Safety Risks Management - Challenges and Opportunities Page 9 10 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Acknowledgements This report is the product of the collaborative effort and valuable contributions of international and local partners under the auspices of the Food Safety Working Group in Vietnam. It was written by the World Bank team in partnership with development partner institutions and organizations in Vietnam. It draws on substantial research and analytical background information available to the authors from various sources (both through published research and ongoing initiatives), as well as on proposals and ideas presented at a round-table discussion organized by the World Bank and partners on food safety risk management held in Ha Noi in January 2016 and a consultation workshop in July 2016. The report benefited from two World Bank missions to Vietnam (January to July 2016) and subsequent visits to many food safety stakeholders. Authors and contributors include the following scientists: Hung Nguyen-Viet, Fred Unger and Delia Grace from the International Livestock Research Institute; Pham Duc Phuc, Dang Xuan Sinh, Tran Thi Tuyet Hanh, Luu Quoc Toan, Chu Van Tuat, Tran Cao Son, Duong Van Nhiem, Ngo Thi Hanh and Nguyen Do Phuc from the Taskforce for Food Safety Risk Assessment; Shashi Sareen from the Food and Agriculture Organization of the United Nations; Vien Kim Cuong from the Canadian High Commission in Vietnam and Nguyen Van Doang from the Asian Development Bank. Authors and contributors from the World Bank team include Vo Thanh Son, Stephane Forman, Artavazd Hakobyan, Donald Macrae, Dao Lan Huong, Pham Hoang Van, and Kieu Phuong Hoa. Other development partners who contributed at meetings and technical missions and reviewed the report include Vo Ngan Giang, FAO Viet Nam, Ton That Son Phong from the Livestock Competitiveness and Food Safety Project (LIFSAP); Delphine Viviens and Dinh Tuong Lan from Centre de Coopération Internationale en Recherche Agronomique pour le Développement; An Nguyen from the Australian Centre for International Agricultural Research; the Embassy of New Zealand in Vietnam; Nguyen Thi Phuc and Maho Imanishi from the World Health Organization office in Vietnam; Alexandre Bouchot from the Embassy of France in Vietnam and Hoang Thanh Van from Department of Livestock Production, Ministry of Agriculture and Rural Development. The project was overseen by Vo Thanh Son, Stephane Forman and Artavazd Hakobyan. The views in this report are those of the authors and do not necessarily reflect the views of the World Bank and other development partner institutions. The authors thank many organizations who met the study mission members and provided important information. These include: • Department of Science, Education, Culture and Social Affairs, Department of International Cooperation in Office of Government • National Agroforestry Fisheries Quality Assurance Department, Plant Protection Department, Department of Livestock Husbandry, and the Sanitary and Phytosanitary Office in the Ministry of Agriculture and Rural Development • Vietnam Food Administration, Institute of Public Health in Ho Chi Minh City and the National Institute for Food Control in the Ministry of Health • Department of Science and Technology and Department of Domestic Markets in the Ministry of Industry and Trade • Department of Agriculture and Rural Development (DARD), LIFSAP in Ha Noi • Sub-Vietnam Food Administration, DARD, LIFSAP, Customs in Ho Chi Minh City • Private-sector organizations: Aquatex Ben Tre, Biospring, DABACO, Fresh Studio, De Heus LLC and Mega Cash and Carry (formerly Metro) • LIFSAP farms, wholesale markets and slaughterhouses in Ha Noi and Ho Chi Minh City • Associations: Industrial Feed Association and the Food, Agri and Aqua Business Sector Committee of the European Chamber of Commerce in Vietnam. The report benefitted from discussions with the Food Safety Working Group during the initial writing stages. The authors thank Ms Tezira Lore for editing this report. The authors thank Ms Tran Thi Ngan, Ms Nguyen Thi Thu Thao, Ms Lam Thi Binh, Ms Pham Thi Huong Giang from the Hanoi School of Public Health, Ms Nguyen Le Thanh and Ms Hanh Le from the International Livestock Research Institute for their technical and administrative assistance. We thank LIFSAP and the Center for Public Health and Ecosystem Research at the Hanoi University of Public Health for important logistic support in arranging meetings and field visits of the technical assistance missions. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 11 Acronyms and abbreviations ADB Asian Development Bank AEC ASEAN Economic Community AIDS Acquired Immunodeficiency Syndrome ASF Animal-source food AOSC Accreditation Office for Standards Conformity Assessment Capacity AOSC Accreditation Office for Standards Conformity Assessment Capacity APLAC Asia-Pacific Laboratory Accreditation Co-operation ASEAN Association of Southeast Asian Nations BoA Bureau of Accreditation BSE Bovine Spongiform Encephalopathy BVL Bundesamt für Verbraucherschutz und Lebensmittelsicherheit CFSMS Crop Food Safety Management System CFU Colony-forming units CI Confidence interval DAH Department of Animal Health DALYs Disability Adjusted Life Years DARD Department of Agriculture and Rural Development DCP Department of Crop Production EFET Hellenic Food Authority EFSA European Food Safety Authority FAO Food and Agriculture Organization of the United Nations FAOSTAT Food and Agriculture Organization Corporate Statistical Database FERG Foodborne Disease Burden Epidemiology Reference Group FSWG Food Safety Working Group GAP Good Agricultural Practices GARP Global Antibiotic Resistance Partnership GMP Good Manufacturing Practices HACCP Hazard Analysis and Critical Control Point HIV Human Immunodeficiency Virus HPAI Highly pathogenic avian influenza IAF International Accreditation Forum IAFP International Association for Food Protection IFC International Finance Corporation ILAC International Laboratory Accreditation Co-operation ILRI International Livestock Research Institute IPH Institute of Public Health 12 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Acronyms and abbreviations ISO International Organization for Standardization JICA Japan International Co-operation Agency LIFSAP Livestock Competitiveness and Food Safety Project MARD Ministry of Agriculture and Rural Development MOH Ministry of Health MOHLW Ministry of Health, Labour and Welfare MOIT Ministry of Industry and Trade MONRE Ministry of Natural Resources and Environment MOST Ministry of Science and Technology MRLs Maximum Residue Limits NAFIQAD National Agroforestry Fisheries Quality Assurance Department NIFC National Institute for Food Control NFSL National Food Safety Laboratory OECD Organisation for Economic Co-operation and Development OR Odds ratio PAC Pacific Accreditation Co-operation PGS Participatory Guarantee System ppb parts per billion ppm parts per million QMRA Quantitative Microbial Risk Assessment QSEAP Quality and Safety Enhancement of Agricultural Products project QUATEST Quality Assurance and Testing Centre RAHO Regional Animal Health Office RASFF Rapid Alert System for Food and Feed STAMEQ Directorate for Standards and Quality SPS Sanitary and Phytosanitary TEQ Toxic Equivalent TPP Trans-Pacific Partnership USD United States dollar(s) VEPR Vietnam Institute for Economic and Policy Research VFA Vietnam Food Administration VietGAP Vietnamese Good Agricultural Practices VNCC Vietnam National Codex Committee WHO World Health Organization WTO World Trade Organization Vietnam Food Safety Risks Management - Challenges and Opportunities Page 13 14 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Executive summary In Vietnam, food safety is of great and increasing importance consumed in Vietnam, but intensification is increasing to consumers and policymakers alike. The Government of especially in the poultry and pork sectors. Most food (90%) Vietnam requested the World Bank and other development is sold in traditional, informal markets but purchases in partners for assistance in assessing food safety risks and in supermarkets are increasing. Still, consumers have a strong providing policy recommendations on how to improve food preference for fresh animal-source food (ASF). The fresh safety risk management. To this end, a series of activities, pork value chain is important in terms of diets and food including a literature review, field visits, round-table safety risk. In Ha Noi, smallholder producers and informal discussions and interviews with experts and consultations slaughter and sale predominate while in Ho Chi Minh City, were held between January and July 2016. While food safety large-scale actors are more important. Most leafy vegetables was broadly addressed, the emphasis of this review was on are produced by smallholders and sold in traditional markets. domestic urban markets with a special focus on pork and leafy vegetable value chains supplying Ha Noi and Ho Chi Minh Many approaches have been tried for improving the City. This report presents the key findings to help identify safety of fresh food in Vietnam but there are still priorities and practical solutions to address food safety. challenges in demonstrating improvements in food safety, or sustainability and scalability. Initiatives include modern Media reports, scientific literature, official food safety legislation; vertical integration of supply chains; communications and consumer complaints demonstrate support to modern retail and linking farmers to firms that that food safety is perceived as a major problem by impose private standards; co-operatives to overcome scale consumers, industry and the government in Vietnam and and marketing challenges; compliance with Vietnamese there is emerging evidence that a relatively large share of Good Agricultural Practices (VietGAP) assured by third-party food in Vietnam may be considered unsafe according to certification; basic Good Agricultural Practices (GAP) which widely accepted food safety norms and standards. Most has simplified requirements; community-based certification recently, a representative survey found that food safety was whereby most monitoring, inspection and certification is one of the two most pressing issues for people in Vietnam, done by communities; and Safe Agricultural Zones which more important than education, health care or governance. concentrate production in certain areas. However, after Food safety issues are the result of both widespread soil and more than 10 years of major efforts and investment by water pollution— the legacy of industrial development of state authorities and market actors, the safe production and past decades—and poor practices by agricultural producers, distribution systems have not been able to take a significant food business operators and consumers. Such food safety share of the market (current share is less than 10%), or to issues could cost the country millions of dollars every year consistently show products are safer, or gain widespread from treatment of illnesses alone. From the public health consumer trust. Nonetheless, the demonstrated successes at perspective, the main problems are biological followed by smaller scale indicate promising approaches. chemical hazards, from an economic perspective food scares and safety of exported products are important while from the Vietnam has a modern food safety legislation system, consumer perspective chemical hazards in food are of most but further improvements are needed in food safety concern. Exported food appears to be much safer than food performance. Three ministries have primary responsibility in domestic markets based on more rigid control systems for food safety: the Ministry of Agriculture and Rural implemented, demonstrating that food safety can be achieved Development (MARD), the Ministry of Health (MOH) and in Vietnam as well as indicating duality in the food safety the Ministry of Industry and Trade (MOIT). In addition, the governance system: the effective system directed to ensuring Ministry of Science and Technology (MOST) is responsible exports meet international standards and the less effective and for the development of standards, laboratory accreditation more convoluted system for domestic purposes. There have and the methods for quality control of imported and exported been several important initiatives for improving food safety, goods. MOH has overall responsibility, but not authority, to but further efforts are needed to develop effective, scalable direct other ministries. Moreover, many food safety activities and sustainable solutions. and resources are decentralized to provincial and lower levels. A modern and World Trade Organization-compliant The study focuses on two important and high-risk food safety legislative framework is in place with a national value chains (fresh pork and leafy vegetables) in order strategy, laws, regulations and standards. However, as in to concretely explore the food safety risks and identify many developing countries, there are major gaps between solutions. Small-scale farmers produce most food (80%) regulation and implementation. There is no comprehensive, Vietnam Food Safety Risks Management - Challenges and Opportunities Page 15 systematic reporting for food safety performance or routine Despite a strongly rising trend in exports, notifications have surveillance and current efforts in surveillance of foodborne remained relatively stable over the last 11 years indicating disease are fragmented and weakly coordinated. The current that food safety performance for exported foods is improving. surveillance system is mainly indicator-based or event- Legal food imports are much lower in quantity and value than based. Safety of food exports has been relatively well food exports. Beef, dairy products and temperate fruits are supported but there is less information on imports. There mainly imported from countries with high export standards are several government, academic and private laboratories; and not likely to be of high risk. However, there are probably technical capacities range from fair to good. Most of them large amounts of illegal imports from China and the safety are accredited; however, information on performance is of these is difficult to determine. The high levels of imports limited as is participation in proficiency testing programs. of agricultural inputs also have implications for food safety. Several hundred thousand samples are analysed each year but Based on the experience of other countries, adopting there is no systematic information on the results, reliability risk-based approaches and building capacity is key to of tests or representativeness of sampling. There is good assessing, managing and communicating risk. Several capacity for microbiology and chemical analysis. Capacity developed countries have had successes with whole value for risk assessment and risk communication is limited. chain approaches, industry-led programs and controlling key Vietnam probably has around 5,000 food inspectors. It lacks pathogens on the farm rather than downstream. Modern food a comprehensive, national food safety surveillance system. systems have moved away from the ‘command and control’ There is little information on outbreak response capacity. approach to food safety, based on inspection and punishment, Many biological, chemical and physical hazards have which is still dominant in Vietnam. Instead the focus is on co- been found in food in Vietnam and biological hazards are operative strategies for compliance, prevention of incidents the most important in terms of their known human health and enforced self-regulation by industry. Training farmers impacts. Based on available national and regional data, in good agricultural approaches has been quite effective in biological hazards are probably the most important cause of enabling small-scale producers to export, but experiences foodborne disease. The use of animal and human waste in for domestic markets have been less encouraging (due to the cultivation is a risk factor for important biological hazards. lack of incentives for behaviour change). Several countries in which informal sector actors currently supply most food have The habit of consuming raw and lightly cooked vegetables had successes in training these actors, but these approaches and, among some groups, of consuming raw pork or fish and are often not sustainable or scalable. blood also leads to risks. Use of agricultural inputs, including pesticides and antimicrobials, is high in Vietnam, increasing Risk communication is key to managing food scares the risk of residues in food. Illegal growth promoters appear and building trust in the food system, but, as in many to be commonly used as large amounts are imported, there is countries, there has been little attention to this in Vietnam. no legitimate use in food-producing animals and legitimate It is important to build capacity in the techniques of risk medical use is very low. Heavy metals are problematic in communication, but also to develop over-arching strategies some areas, as are dioxins. While chemical hazards are for dealing with food safety scares as these are likely to common, the immediate disease burden from biological continue. There are also many misperceptions about food hazards should be prioritized. There were 373 outbreaks of safety, not only among the public but also among academics foodborne diseases reported in 2014 and 2015 involving over and the government, and a concerted attempt should be made 10,000 cases and resulting in 66 deaths. Evidence from similar to address these through evidence generation and engaging countries suggests this greatly under-estimates cases in the communication. community as only a small proportion of foodborne disease is ever recorded as outbreaks. Most of the reported incidences The study made a series of recommendations, but given the were caused by pathogens (41%), followed by biological failure in most developing countries to develop effective, toxins (28%) and chemicals (4%), with 34% occurring in the sustainable and scalable models of improving food safety in northern mountainous area alone. domestic markets, these are strategic directions (‘directions of travel’) rather than firm recommendations for actions that Vietnam is one of the world’s top exporters of seafood, will deliver solutions. Although in general, Vietnam has a rice, cashew nuts, coffee and pepper. However, trade solid food safety framework, the division of responsibilities is likely to increasingly compete on quality and safety, across three ministries and the decentralization create areas that Vietnam needs to strengthen. Inspections by challenges for implementation. Revising the food safety importing countries suggest that most safety violations are structure should be considered and a proposed pilot in Ho in fish followed by fruit and vegetables. Most are the result Chi Minh City would help in seeing its workability in the of detection of biological hazards, followed by residues of Vietnamese context. Risk assessment and risk communication agricultural inputs (antibiotics, pesticides and fungicides). are weak and capacity should be built in these domains and 16 Page Vietnam Food Safety Risks Management - Challenges and Opportunities dedicated units established. Risk assessment should be separate from risk management and will generate risk profiles and assessments, which, in conjunction with economic analysis, will allow risks to be prioritized. A systematic, comprehensive surveillance system is needed for foodborne diseases. The inspection and monitoring system should be risk-based but there should also be a move from an ‘inspect and punish’ to a ‘co-operative self-regulation’ model. Laboratory services can be strengthened through networking and proficiency testing. Training and capacity building are important, but behaviour will not change unless there is a change in the current incentive structure. Many initiatives for food safety management have been taken and many show promise, but continued development is needed for these to gain a significant market share and consumer trust. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 17 18 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 1. Introduction 1.1. Context (MOH), Ministry of Agriculture and Rural Development (MARD), Ministry of Industry and Trade (MOIT) as well Food safety is an emerging public health concern worldwide, as the Food and Agriculture Organization of the United especially in developing countries, which bear most of Nations (FAO) (designated focal point among development the burden of foodborne disease. Vietnam has become a partners), Asian Development Bank (ADB), Canadian rapidly urbanizing middle-income country. This has led to High Commission, the Japanese International Co-operation changes in people’s diets, in particular increased demand for Agency (JICA), New Zealand Embassy, Danish Embassy, animal-source food products. The country’s food system is Australian High Commission, the Food, Agri and Aqua increasingly integrated regionally and internationally. In the Business Sector Committee of the European Chamber of region, there are growing concerns about food safety and Commerce, World Health Organization (WHO) and the World different forms and origins of food contamination that may Bank. The government made a priority request for an urgent manifest anywhere from farm to fork. Unsafe food can place assessment of prevailing food safety risks in Vietnam, based multiple burdens on human health, farmer and enterprise on international best practice in risk assessment methodology. viability, international market access, country reputation and This report presents an analysis of the key issues of food attractiveness for tourism. safety in Vietnam with a focus on two main commodities— pork and leafy vegetables—to identify priorities and practical In Vietnam, food safety is of great concern to both consumers solutions to address food safety. and policymakers and frequently appears in the media (Mai 2013; VietNamNet Bridge 2015; VietNamNet Bridge 2016) and in policy discussions (Hung Nguyen-Viet 2015; World 1.2. Objectives Bank Vietnam 2016). This is the result of repeated episodes of adulterated and unsafe food. These include the following: The objectives of this food safety risk management study frequent reports that toxic pesticide residues in vegetables, were to (i) take stock of the food safety situation and food antibiotics and banned veterinary residues are often found safety control systems in Vietnam, (ii) analyse the food safety in meat or suspected to be present1; urea is used for fish risks for selected key food value chains based on international conservation; spoiled animal-source food is salvaged and best practice in risk assessment methodology and, based on consumed and high levels of microbial contamination in meat these findings, (iii) provide recommendations to improve are routinely reported. Food safety issues get a high level food safety. of attention when famous people die of cancer at a young age; the media asks: “Is there something wrong with our food”? The country’s top leaders, too, have discussed food 1.3. Methods safety issues at meetings of the National Assembly. On 1 April 2016, the national television broadcaster launched an A combined approach to collect and analyse data was used official program titled Say No to Contaminated Foods, which for this report. First, a round-table discussion on food safety has been broadcasting daily on two golden time episodes at in Vietnam was organized. This entailed consultation with 0730 hours and 2030 hours on VTV1, VTV8 and VTV9 from leading food safety experts, practitioners, researchers, officials Monday to Friday (Nguyen-Viet et al. 2017). An overview of and businesspeople about their ongoing, past and future key issues on food safety in Vietnam is presented in Annex 1. activities relating to food safety. It also entailed reviewing databases, policies, publications and reports that describe the The World Bank has been working with other development status of food safety systems in Vietnam. A series of visits partners and various ministries and government agencies to were made to government and private-sector institutions scale up support for the food safety agenda. The Food Safety as well as to actors involved in food safety to discuss key Working Group (FSWG) is an initiative to bring together issues on the subject. Finally, a consultation workshop was key government agencies, line ministries and development organized to present the technical report and collect feedback partners for joint policy dialogue and discussions on food from key partners. The final report was summarized into a safety issues in Vietnam. It was created at the request of policy note that serves as key findings and recommendations Deputy Prime Minister Vu Duc Dam and convened under to the Government of Vietnam and other food safety his auspices at a meeting in June 2015. The group benefits stakeholders. The International Livestock Research Institute from the active participation of the Office of Government (the (ILRI) and the Taskforce for Food Safety Risk Assessment designated focal point of coordination), Ministry of Health were commissioned to work with partners to conduct part of 1 Nine tons of salbutamol were legally imported for medical purpose in 2015 but only 10 kg was actually needed for human use; it is likely the rest was used for livestock growth promotion. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 19 the above-mentioned activities of the assignment. This report 1.3.3. Food Safety Working Group also built on past work by the World Bank on the Vietnam Food Safety and Agricultural Health Action Plan (World (FSWG) Bank 2006) and on the Review of Food Safety and Quality The FSWG was established in late 2015 as the result Control under MARD carried out by FAO (October 2015). of interactions between development partners (mainly development banks and research institutions including the 1.3.1. Round-table discussion and World Bank, Canadian High Commission, Embassy of New Zealand, FAO, WHO, JICA, ADB and ILRI), private-sector consultation workshop organizations and the Government of Vietnam (Office of The initial round-table discussion was held on 7–8 January Government, MOH, MARD and MOIT), with the government 2016 in Ha Noi. The aims of this meeting were to (i) provide represented by Deputy Prime Minister Vu Duc Dam. The the World Bank technical assistance mission with an overall overall goal of the FSWG is to contribute to improved picture of the food safety situation in Vietnam, (ii) take stock food safety in Vietnam and increased competitiveness of of food safety risks for selected key food value chains and Vietnamese food products for domestic consumption and (iii) brainstorm priorities and potential solutions to address international trade. The meetings of the FSWG take place key food safety risks. Sixty-six participants across various every two months and discuss food safety issues. The food sectors, institutions, businesses and organizations attended safety risk management study has been discussed by the the two-day meeting and related sessions. The round-table FSWG which has also contributed to the study. discussion had 22 presentations in four sessions: • Food safety: Contamination situation and health impact 1.3.4. Literature review, data analysis • Food safety: Value chains and economic impact and synthesis • Technical and institutional solutions for food safety Information on food safety was obtained by searching • Food safety risk management: Looking forward databases such as ScienceDirect and Web of Science and from local sources in journals, newspapers and reports In addition, there were four specific panel discussions to from governmental organizations (MOH and MARD). The address key issues related to food safety, identify the key information was then analysed and synthesized in terms of commodities and geographical locations and map the way key issues for food safety and recommendations. forward following the in-depth study. A summary of the round-table discussion and abstracts presented are in Annex An important framework within which this analysis has 2. been conducted is the toolkit that the WBG’s Trade & Competitiveness Practice has published on Food Safety A consultation workshop was organised on 27 July 2016 to Reform in 20142 (see Annex 18). Through its eight present the draft study report and policy note and collect Fundamental Pillars, the toolkit serves as a comprehensive comments from food safety stakeholders to improve both checklist of where to get started and how to prioritize when documents. The draft documents were shared with participants undertaking Food Safety reform process. It also contains lots prior to the workshop. At the workshop, key highlights of the of helpful case studies from other countries. It is referred to study were presented to allow the 52 participants to give their as “the WBG toolkit” all along this report and the eight pillars inputs. Questions and comments from the workshop were are the following: (i) Food safety should be secured along addressed in the final report. the entire food chain (plough to plate, farm to fork, stable to table), (ii) Regulation by itself cannot ensure food safety, (iii) 1.3.2. Technical missions In a food safety system, primary responsibility (and liability) for the safety of food rests on food business operators, (iv) Two technical missions were conducted, led by the World The role of consumers is also strongly emphasized, as they Bank and involving several partners including ILRI, ADB, form the most potent force to drive food safety improvements: FAO, Canadian High Commission, New Zealand Embassy, market power, (v) A preventative and risk-based approach Embassy of France, Australian High Commission, the World should be the basis for regulatory reform, decision making, Health Organization (WHO) and Centre de Coopération control, and self-control of food safety, (vi) International Internationale en Recherche Agronomique pour le standards and scientific justification should form the basis Développement. The expert groups conducted a series of of regulatory documents and measures, (vii) The impact of visits to government and private-sector institutions as well food safety reform on trade should be carefully considered, as actors involved in food safety in Vietnam to discuss key and (viii) Food safety regulation will always involve multiple issues on food safety. The list of partners met is in Annex 3. players; co-ordination and collaboration are vital. 2 http://documents.worldbank.org/curated/en/995191474485316487/ pdf/911840WP0Box380od0Safety0Toolkit0IC.pdf 20 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 1.4. Scope of the study 1.5. Reading guide Given the relatively short timeframe and limited resources, it This report has been structured in several sections. Each was important to define properly the scope of the study. The section presents the status and analysis of the respective aspect mission and the Government of Vietnam agreed to focus on of food safety and ends with key messages of the section two major value chains: pork and leafy vegetables. Annual captured in a box. In addition, further information is provided pork consumption in Vietnam is 2.45 million metric tons (or in the set of annexes at the end of the report. At the end, 27 kg per person per year), making Vietnam one of the top recommendations are provided for food safety improvement. countries in the world for pork consumption per capita. Most The report consists of nine sections as described below: pork is produced nationally and 83% comes from very small or small farms. Food safety is an issue along the value chain 1. The introduction provides the context, rationale, from production (including feed and veterinary drug inputs) objectives, method and scope of the study. to consumption and there are both microbiological and 2. The section on Institutional setup and capacity for chemical risks, making it an interesting model to explore risk- food safety management provides key information on based approaches to food safety. Leafy vegetables are also an the arrangement of the food safety management system important part of the daily diet of Vietnamese people. The and capacities to address food safety. main issue of public concern in this value chain appears to be pesticide residues, although production and consumption 3. The section on Key pork and vegetable value chains practices may result in a high risk of microbiological in Ha Noi and Ho Chi Minh City presents the value pathogens. In terms of geographical focus, this report focused chains of two key commodities, namely, pork and leafy on Ha Noi and Ho Chi Minh City, the two biggest cities of vegetables in Vietnam’s two main cities: Ha Noi and Vietnam, and targeted domestic food markets. Ho Chi Minh City. 4. The section on Food safety hazards, risk and health With the recent expansion of Ha Noi City limits, it has now impact presents the concept of hazards and risks and become both a major consumer (7 to 8 million people) and a analyses the key hazards, risks and health impact from major producer (Ha Noi produces around 60–70% of its food food in Vietnam. demand). With similar size as Ha Noi, Ho Chi Minh City is able to supply only 20% of its food demand, with the remaining 5. The section on Food safety risk communication food being ‘imported’ from other provinces. Nevertheless, and management – Challenges, confidence, trust the city has more than 600 Department of Agriculture and and priorities addresses aspects related to risk Rural Development (DARD) inspectors. Like Ha Noi, Ho communication, mainly from a conceptual point of Chi Minh City wants to control food supply through gate view, but adds some practical aspects and details markets and phase out small-scale slaughterhouses. Currently of recent events on food safety communication in and as observed during the mission in 2015, the city has three Vietnam. ‘suitable’ gate markets for meat (one public and two private). 6. The section on Food safety impacts on trade analyses The management model remains the same whether public or the trend of food trade and major food safety issues of private; the owner offers a lease for several years (up to 10 food import, export and economy. years) for counters to wholesalers (26 in the visited market 7. The recommendations highlight a series of possible in February 2015) who receive pig carcasses from identified reforms and capacity strengthening directions and areas slaughterhouses and re-sell them to smaller retailers. The of emphasis for food safety improvement in the short, visited market could at that time process up to 4,500 carcasses medium and long terms. per night. 8. References are then cited. 9. Annexes provide additional background or more specific information on various parts of the report. This also includes an overview on food safety in Vietnam (Annex 1) and a more detailed value chain analysis for pork and vegetables (Annex 17).   Vietnam Food Safety Risks Management - Challenges and Opportunities Page 21 22 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 2. Institutional setup and capacity for food safety management 2.1. Legal framework food chain ‘from farm to fork’, in line with the WBG toolkit Pillar 1. It sets out requirements for the national management The Food Safety Law (2010) was promulgated on 17 June of food safety in Vietnam and covers: 2010 by the National Assembly of Vietnam with the aim of addressing the country’s growing concern on food safety • rights and obligations of organizations and individuals in ensuring food safety risks and problems that impact on trade and human health. This law is a modern framework that aligns with international • conditions for ensuring safety of food in production, standards and approaches to food safety management. It processing and trading assigns food safety responsibilities to three ministries: MARD, MOH and MOIT. Each ministry is assigned control • conditions for ensuring safety of imported and exported of specific products across the entire chain, that is, from food primary production, preparation, processing, storage and • requirements for advertisement and labelling of food import-export to wholesale and retail distribution of these products. MOH, through the Vietnam Food Administration • requirements for testing of food and analysis of food (VFA), has over-arching responsibility for food safety in safety risks Vietnam in addition to its other specific roles. Details of the roles and responsibilities are given in Section 2.2. • prevention and management of food safety incidents • information, education and communication on food safety The food safety regulatory framework in Vietnam is the product of a complex multi-level legislative process. The Food • state management responsibilities Safety Law took effect in July 2011 and subordinate decrees were promulgated by the government to provide details on As new problems arise, subordinate decrees/decisions and how the law is to be implemented. Further elaboration on circulars are developed, resulting in many instruments that implementation, including how tasks are to be delineated become difficult to comprehend. The matrix of laws, decrees, and distributed across national agencies and decentralized to circulars and decisions related to food safety are listed in the local level, was issued in the form of ministerial and/or Annex 4. Many food safety authorities in other countries inter-ministerial circulars and decisions. Figure 1 shows the prefer to focus on general principles and processes rather than theoretical hierarchy of laws. specific situation-dependent rules. Risk analysis provides a general framework for managing food safety and is preferable The law states that food safety management must be conducted to the more prescriptive approach currently applied in throughout the course of food production and trading on the Vietnam. It allows more focus on results and outcomes, as basis of food safety risk analysis, thus covering the entire opposed to processes and outputs. National Assembly: Food Safety Law 2010 Government: Decrees Tasks, implementation, organization, sanctions Ministers: Circulars/Decisions Further elaboration of guidelines Figure 1: Hierarchy of laws in Vietnam presented for the Food Safety Law Vietnam Food Safety Risks Management - Challenges and Opportunities Page 23 2.2. Institutional framework More specifically, MOH is responsible for safety of food additives, food processing aids, bottled drinking water, The Food Safety Law of 2010 assigns food safety natural mineral water, functional food and other foods. MOH is directly responsible for ensuring food safety in restaurants, responsibilities to three ministries: MOH, MARD and MOIT. canteens and other food services. In addition to its leading Each ministry is assigned control of specific products across and coordinating role within MOH, VFA now has direct the entire chain, that is, from primary production, preparation, responsibility for monitoring food safety in the country, processing, storage and import-export to wholesale and retail hygiene and safety regulations, standards, hygiene guidelines distribution of these products. MOH, through VFA, has and labelling. over-arching responsibility for food safety in Vietnam and is responsible for a number of commodities, food ingredients Although MOH is responsible for overall food safety, it does and packaging material. MARD is responsible for food safety not have authority to direct the management of other ministries in agriculture, agroforestry and aquatic products in the food and departments involved in food safety management. This supply. MOIT is responsible for some commodities and for leads to more or less independent activities on food safety control by each ministry and, therefore, no comprehensive retail marketing of food, namely, markets and supermarkets. food control management system in the country. The role The distribution of responsibilities is illustrated in Figure 2. of MOH in this regard becomes one of coordinating and MOH has overall responsibility for the safety of food and collating different reports. In many developing countries, multiple agencies are in charge of assuring food safety with drug production, food hygiene in the domestic market and overlapping (and sometimes conflicting) mandates and unifying food safety policy. MOH through VFA is assigned inadequate resources. There has been interest in re-structuring responsibility for overall coordination in implementing the food safety governance. A single unified structure or an state management activities and is tasked with ensuring integrated system is likely to be more effective, but when unified and effective food safety management which includes it is not possible because of historical or political reasons, organizing the implementation of national strategies and a national food control strategy can identify roles of the the master plan on food safety. Its role includes providing different government divisions involved in food safety (FAO information about the safety of food in the country. and WHO 2003). Primary production Preparation, storage, processing, import-export Distribution Cereals Meat and meat products Fish and fishery products Horticulture and horticultural products (crop, livestock, harvest, catching, capture) Eggs and egg products Raw fresh milk Bee honey and bee honey products Retail (markets, supermarkets and food shops) Primary production Wholesalers Genetically modified food Catering services and street food vendors staurants, food courts and food canteens Salt Other agricultural products (sugar, tea, coffee and cacao) Liquor, beer and beverages Processed milk Vegetable oil Flour, starch and processed products (confectionery) Wholesalers Food additives and processing aids Bottled drinking water and natural mineral water Functional food and micronutrient-fortified food Figure 2: Distribution of responsibilities related to food safety 24 Page Vietnam Food Safety Risks Management - Challenges and Opportunities MOH also has responsibility for setting standards and the domestic sector. This is carried out through the People’s technical regulations on criteria and safety limits; tools Committee. The basic role as per the law is to promulgate local and materials used for packaging and containing food; technical regulations, develop and organize implementation coordinating periodic reports from ministries, branches and of regional master plans and take responsibility for food provincial People’s Committees on the management of food safety controls in respective areas. The framework for such safety; and coordinating public awareness activities including decentralization is not standardized and varies between dealing with food safety emergencies and warnings on any ministries and even departments under ministries (Annex 5a). food poisoning incidents. In the management process, if any As the resources for provincial and lower levels are allocated problem arises that cannot be assigned to a ministry, MOH at the provincial level, the national ministries cannot enforce is responsible for coordinating with MARD and MOIT to the norms or procedures. Accountability at provincial develop joint circulars to bring about clarity. and lower levels is largely horizontal and the reporting of departments is to the relevant government level People’s MARD is responsible for safety of cereals, meat and meat Committee. There is, however, also reporting vertically by products, aquatic animals and products thereof, vegetables, departments to the responsible ministry but this is neither tubers and fruits and products thereof, eggs and products formalized nor aligned across ministries and departments at thereof, fresh milk, honey and products thereof, genetically national level. The structure of food safety management from modified food, salt and other farm products under the central to local levels is shown in Figure 3. government’s regulations. MARD is also responsible for livestock, fisheries and crop production, livestock inspection Specifically with regard to MARD, there are seven and slaughter, post-harvest handling of agricultural products departments at national level and many of these have and wholesale wet markets. sub-departments at local level. In some cases, the sub-departments have been merged at local level as is the Specifically within MARD, Decision No. 670/QD-BNN- case with the Department of Animal Health (DAH) and the TCCB issued on 4 April 2015 assigns the National Agroforestry Department of Livestock Production, and the Department of Fisheries Quality Assurance Department (NAFIQAD) Crop Production (DCP) and the Department of Plant Protection as the contact point in organizing the implementation of (DPP). The decentralization of the food safety responsibilities legislation on quality and safety of agroforestry and fishery of MARD is shown in Annex 5b. FAO recently carried out a products within MARD’s authority. MARD Decision No. review of food safety and quality control under MARD and 1290/QD-BNN-TCCB issued on 17 April 2015 also assigns has proposed a re-structure at the national level. seven departments with the monitoring and inspection of agricultural, agroforestry and fishery food products. At provincial level, there are 63 provincial-level units (58 provinces and five cities: Ha Noi, Hai Phong, Da Nang, Ho MOIT is responsible for safety of liquor, beer, beverages, Chi Minh City and Can Tho) under direct authority of the processed milk, vegetable oil, powder and starch-based central government. Under Decree No. 79/2008/ND-CP, the processed products and other products under the government’s government has established a sub-VFA under each Provincial regulations. The ministry is also responsible for the trade Department of Health with 11 administrative staff; 47 of aspects of exported products. It has direct responsibility for the provinces have established sub-NAFIQAD with 12–15 the safety of some industrial food products. Its legislative role administrative staff while the remaining provinces have concerns the labelling of goods. divisions of quality management with 4–6 staff under DARD responsible for coordinating the management of quality and In addition to the above three ministries, the Ministry food safety. All 63 provinces and cities have a sub-DAH and of Science and Technology (MOST) is responsible for sub-DPP under DARD. laboratory accreditation and the development of standards and methods for quality control of imported and exported At district level, there are 664 district-level administrative goods. The Directorate for Standards and Quality (STAMEQ) units consisting of rural districts, urban districts and cities is responsible for standardization, metrology and the quality under the provincial government. Each district has a district of goods and products. It issues national standards and medical centre which could be used for implementation implements a process of harmonization with international of a national food safety surveillance system. There are standards. Laboratory accreditation is under the auspices of approximately 1,949 people involved in managing food STAMEQ’s Bureau of Accreditation and carried out by the safety and quality, that is, three people per district. Vietnam Laboratory Accreditation Service. At commune level, there are 10,925 commune-level administrative units comprising 9,098 communes, 1,230 2.2.1. Responsibilities between national precincts and 597 rural towns. Each commune has a Commune and provincial levels Health Station which may be used for implementation of surveillance systems. There are approximately 11,516 Food safety management is decentralized between central and people involved in managing food safety and quality with local governments at all levels (from provincial governments approximately one person per commune, although usually to district and commune levels of government), especially for without salary. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 25 GOVERMENT MOIT MOH MARD Specialised Inspection Specialised Inspection liguor, beer, food additives, food Cereals, meat and products beverage, processed processing aids, bottled thereof, aquatic animals and milk, vegetable oil, drinking water, natural products thereof, vegetables, powder and starch mineral water, functional tubers and fruits and products processed products food and other foods thereof, fresh milk, honey and and other products products thereof, genetically modi ed food, salt and other farm products Science VFA NAFIQAB DOL DOC DPP DAH Department of & Market Technol management DOIT DOH DARD Sub-Market management Sub-VFA Sub-DARD Division of Division of DOIT Health and Division of DARD Health station Food safety management at central level Food safety management at provincial level Food safety management at district and commune level Figure 3: The structure of food safety management from central to local level 2.2.2. Coordination MOH and the responsibilities of People’s Committees at all levels, thus completing the state food safety management Coordination of food safety management among the three system from the central to the local level. MOH needs to ministries is done by the Inter-sector Steering Committee co-operate with other ministries to build and issue food safety for Food Hygiene and Safety (chaired by the Deputy Prime management policies and should also implement related Minister and co-chaired by the Minister of Health). The strategies and plans to avoid overlaps in legal documents. committee’s office is located at the Office of the Government but supported by VFA, which is also the national contact point The national and provincial inter-sector steering committees for the Codex Alimentarius Commission, the International on food safety perform very important roles in coordinating Food Safety Authorities Network and the Association of the agencies responsible for food safety. The committees Southeast Asian Nations (ASEAN) Rapid Alert System for provide a forum for linking the three-ministry management Food and Feed. of the food system. The primary focus of the national steering committee has been on the mandates of the three ministries, The country also has a National Target Program for Food the processes they are following and what, if any, additional Safety which has six components: (i) building capacity for legislation is needed to carry out their respective mandates. food safety quality management; (ii) education and advocacy information for food safety quality management; (iii) Further, communication with stakeholders has been primarily building capacity for a food safety quality control system; one-way: from the committee to them. There is not much (iv) prevention of food poisoning and foodborne diseases; (v) transparency about the committee’s activities and the poor assuring food safety and hygienic agriculture, agroforestry progress that has been made in accomplishing objectives such and aquaculture and (vi) assuring food safety and hygienic as those in the National Strategy for Food Safety. Coordination industrial production and trade. The first four components are and communication between the national and provincial led by MOH and the fifth and sixth by MARD and MOIT, steering committees is weak and the national and provincial respectively. issues are addressed in silos and are not mutually inclusive. Under the Food Safety Law, MOH has overall responsibility The primary means of sharing information between them is for food safety management in the country. To improve the through minutes of meetings and other written documents implementation of the law, it was found necessary to develop and no physical meetings or close working relationships are regulations on the responsibilities held by ministries and evident, which does not help to advance food safety in the sectors, the required level of co-operation between them and country. 26 Page Vietnam Food Safety Risks Management - Challenges and Opportunities To strengthen coordination of food safety management and circulars, but also because of unrealistic expectations between the three ministries, Joint Circular No. 13/2014/ of driving food safety operational management down to TTL-BYT-BNNPTNT-BCT was issued on 9 April 2014. It local production and trading. The strategy is currently under deals with the allocation of tasks and co-operation among revision and is being led by VFA and MOH. There is also a regulatory agencies in food safety management, co-operation Sanitary and Phytosanitary (SPS) Action Plan, with a new one in food safety inspection and validation of knowledge of food currently under development through the SPS Office which is safety. under MARD although it has focal points allocated in each ministry with one full-time and one part-time officer. It is In MOIT, the Department of Science and Technology serves important that synergy is maintained between the National as the contact point and coordinates with other departments Strategy led by VFA and the SPS Action Plan led by the SPS within the ministry to develop and issue legal documents Office at MARD. on food safety management, particularly certificates of food safety compliance in retail markets, supermarkets and food shops which are under the jurisdiction of MOIT. The 2.3. Standards and technical MOH-MARD-MOIT Joint Circular No. 34/2014/TTLT- BYT-BNNPTNT-BCT guides the three ministries on the regulations labelling of goods for foods, food additives and packaged food processing aids. However, a key area to be addressed Vietnam has two types of national standards: mandatory is obtaining certificates of origin of farm produce by MOIT and voluntary. National technical regulations, which are from MARD. mandatory, are issued by MOH while Vietnamese national standards are issued by MOST and are voluntary. In addition, each ministry also develops its own voluntary standards, 2.2.3. National Strategy for Food which generally relate to good practices, namely, Good Safety for 2011 to 2020 and a vision Agricultural Practices (GAP), Good Agricultural Husbandry Practices, Good Manufacturing Practices (GMP) and Hazard towards 2030 Analysis and Critical Control Point (HACCP). This strategy has been set out through a decision at the Prime For developing technical regulations, MOH has set up Minister level to (i) ensure safety of food for consumers and committees on which all other ministries and other stakeholders emphasizes the responsibilities and rights of the organizations are represented. The draft standard is first developed and and individuals producing and trading food and of every circulated to the committee. The World Trade Organization citizen; (ii) implement the provisions of the Food Safety (WTO) through the SPS Office under MARD is also notified Law in a synchronized way through inspection, testing and and any comments received are taken into consideration. The management of food safety and (iii) strengthen information comments are then discussed and the standard finalized as and communication on food safety. a Technical Regulation, which is mandatory in the country. The general objective of the strategy is that food safety master Currently, 54 regulations on food products have been issued plans are implemented from production to consumption so covering the following areas: as to improve the food safety situation in the country by 2015. Control of food safety throughout the food supply • Limits of heavy metal contamination in food chain is to be set up and promoted efficiently and actively • Limits of mycotoxin contamination in food in the protection of health and consumer interests, to meet • Limits of microbiological contamination in food the requirements for development and integration of the country’s international economy by 2020. • Specifications for food additives • Maximum levels of food additives allowed for use in Four specific objectives have been laid down as below with foodstuffs specific targets for each: • Micronutrient-fortified food 1. Improve knowledge and practice of food safety among • Safety requirements for food contact material the target groups • Maximum levels of radionuclides in food products 2. Strengthen capacity of the food safety management system • Some products: milk products (milk powder, fluid milk, cheese and butter), drinking and mineral water, soft 3. Significantly improve food safety assurance in food drinks, alcoholic drinks, edible ice, fortifying food and producing and processing facilities iodized salt 4. Effectively prevent acute food poisoning There is no formal manner of carrying out a risk assessment. It is understood that most of the targets laid down under the However, some small-scale research initiatives have carried objectives have not been achieved due in part to the late out risk assessments on heavy metals, aflatoxin in nuts and completion of many subordinate regulations in directives related products and Salmonella in chicken, among others. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 27 The Vietnam National Codex Committee (VNCC) was times a year and are also held during special occasions like established in 1994. The VNCC Board (six members) consists functions and food safety weeks or if a foodborne disease is of leaders from relevant ministries (Health, Agriculture and suspected. In case of complaints or incidents, inter-ministerial Rural Development, Industry and Trade, and Science and inspections are also organized. Businesses are categorized Technology). Members of VNCC (46) include representatives into A, B and C categories jointly by the ministries. from government agencies, food businesses, associations, universities and research institutes. The country’s National While MOH has over-arching responsibility for food safety, Codex Contact Point is with VFA. Other than in the Codex it does not have the authority to direct other ministries Fisheries Committee, participation in Codex meetings is in their work to ensure that highest risk foods are targeted quite limited. Generally, Codex standards are adopted in the and prioritized. Similarly, MOH does not have capacity to country. set requirements for the quality and depth of reporting as this is based on the priorities and programs of the separate VNCC has its own Codex-related website at http://www. departments. The major high-value export streams are given codexvn.org; however, this is only in Vietnamese. It is linked far greater scrutiny and attention than domestic foods and to the international Codex website, FAO, WHO and other food supplies. national websites such as MARD, MOIT, MOST and MOH. MARD follows a risk-based approach for exports with food Sections 10 and 11 of the Food Safety Law regulate food businesses being categorized into A, B and C categories, safety actors to follow national standards and technical depending on whether they meet the stipulated requirements. regulations. Several Vietnamese food safety standards and Focus is then targeted towards improving Category C criteria have been issued and harmonized with international businesses. The export sector is handled at the national Codex standards (pillar 6 of the WBG toolkit). For instance, level by NAFIQAD, while for the domestic sector, MARD the national technical regulations on Maximum Residue develops protocols which are implemented at provincial and Limits (MRLs) of heavy metals (QCVN 8-2:2011/BYT), district levels and monthly reports are sent to NAFIQAD. microbial contamination (QCVN 8-3:2012/BYT) and The level of inspection and monitoring depends on their veterinary drugs (Circular No. 24/2013/TT-BYT) define limits resource availability (finances and personnel). For imports, in animal products (for example, fresh pork or chicken meat) NAFIQAD has worked out risk profiles for products under and vegetables. Those regulations are in compliance with their supervision. It is understood that staff at national international Codex standards and propose amended methods level are trained on risk-based approaches but at provincial for sampling and detection. Other Vietnamese standards level, training on such approaches is still needed (based on and technical regulations on food safety also require the information provided by NAFIQAD). However, at all levels relevant actors to follow standards of, for example, livestock the application and practices of a risk-based approach are still production and evaluation (QCVN 01-14, 15: 2010, 01-79: limited. An overview of the organizational structure of food 2011/ BNNPTNT), transportation (QCVN 01-100: 2012/ safety management under MARD is given in Annex 6a. BNNPTNT), food processing facilities and practices (QCVN 01-05: 2009/BNNPTNT) and packaging materials (QCVN VFA operates through the inspection department at the 12-1, 2, 3, 4:2011/BYT). head office and 63 sub-departments, one in each province. At district level, it has clinics and health centres. There are 2.4. Inspection, enforcement, around 14 members of staff at the head office and around 600 across the 63 provinces. VFA is responsible for monitoring surveillance and control of food safety incidents. Some risk assessments have been carried out but these are scattered research activities (for example, Salmonella in chicken and aflatoxin in nuts and 2.4.1. Inspection and enforcement related foods). Since 2009, they have been using risk-based In general, although a risk-based approach has been specified monitoring based on a plan, which has been developed. The under the law, it has been observed that in practice the three plan for the subsequent year is based on the results of the organizations follow different approaches and have different previous year. Not much work is available on the correlation priorities in their inspection and enforcement strategies and between contamination and public health impact. Data different interpretations of the regulations. While a national on contamination are available but have not been linked target program has been developed under which the minimum to exposure and actual risks. The responsibilities are well target inspections have been laid down for each ministry, categorized and at the national level, VFA oversees imports there is no coordinated national framework or strategy that and large national or transnational food businesses and the addresses the whole of the food chain in a risk- and outcome- quality and safety of bottled drinking water. The provinces orientated approach. MOH coordinates this national target are responsible for enforcement and inspection of larger program and six-monthly reports are collated. For products food business operators who produce food for large-scale under the control of more than one ministry, inter-ministerial distribution and of catering systems and larger restaurants. The inspections are held. Planning for these is decided by the inter- district-level and commune-level food safety enforcement is ministerial steering committee. These are organized three mostly on the small-scale and street food sectors. 28 Page Vietnam Food Safety Risks Management - Challenges and Opportunities MOIT: The Bureau of Market Management under MOIT is and there are limited possibilities to recover costs from the responsible for inspection of areas under its jurisdiction. The private sector. Hence, lack of operational funding is a serious responsibility for large businesses lies at the national level constraint for setting up an effective surveillance system in while the smaller businesses are under the supervision of the Vietnam. Laboratory capacity and funding are not sufficient provincial level. The businesses are inspected and licences for routine surveillance or enforcement of related testing. issued, followed by regular or on-demand inspections. The There are laboratory data on exports and imports and some principle followed for inspections is to have one inspection data from domestic inspection activities under the different per business per year. The standards laid down by VFA are ministries, but there is no overall plan or collation of national followed. Inspection is not risk-based. Samples are drawn by data for analysis and monitoring of foodborne diseases and inspectors and these are paid for; however, in case of non- food safety. compliance, the amount is to be reimbursed by the businesses and this acts as a motivating factor for them to comply with An active food safety surveillance system in Vietnam is at the requirements. These inspectors look at marketing and the formative stages of development, having components of other consumer-related aspects as well as food safety and the integrated food safety surveillance such as market surveillance, latter does not appear to be given priority. surveillance of food business operators in manufacturing and service establishments, surveillance of imported products and Other than for exports where laboratory testing to confirm surveillance of incidences of foodborne diseases. compliance against importing country requirements is common and imports where the cost is covered by the importer, MARD and VFA both carry out surveillance independently, a most domestic inspection and enforcement activities are broad overview of which is provided below. qualitative in nature and not supported by regular laboratory For MARD, residue and contaminant monitoring programs analysis. The laboratories used are those of MARD and MOH are regularly implemented by NAFIQAD for the fishery as well as private accredited laboratories. sector due to its export focus. Programs for meat (pork and At the market level, wholesale markets are under the other), fruits and vegetables have been started recently (in supervision of MARD while retail markets and supermarkets March 2016) in Ho Chi Minh City and Ha Noi. The plan is or convenience stores are covered by MOIT. An area of focus developed by NAFIQAD at national level but implementation is training consumers to identify safe food as only then can is jointly with NAFIQAD at provincial level (sampling is the the good practice schemes be sustainable. As noted by the responsibility of the province and testing is done at country officials, once projects are completed, the initiatives are no level). The main residues tested are β-agonists and veterinary longer implemented. drug residues in meat and meat products and preservatives in processed meats. In fruits and vegetables, the focus is on Further details on inspection for domestic versus import/ pesticide residues. The aim is to focus inspections on areas export market, inspection frequencies and violations are of risk and ensure that corrective actions are appropriately given in Annex 7. These include: taken. The annual national surveillance system does not cover all provinces and all points in the food production value • monitoring of Vietnamese Good Agricultural Practices chain, so there is inadequate data on food safety for planning, (VietGAP), GAP, GMP, HACCP and hygienic conditions investigation and inspection. MARD needs to consider at of compliance what point in the food chain the surveillance and testing for • implementation of inspection on domestic and export residues can be best managed: on farm, at primary processing products or later in the food chain. • level of oversight according to business categories A, B For MOH, surveillance systems for foodborne disease are and C under the authority of VFA. All health staff, whether they • common violations and type of sanctions offer public or private services, are responsible for notifying food safety agencies at district or provincial levels when a suspected foodborne disease outbreak occurs in their area. 2.4.2. Surveillance When cases of foodborne disease are admitted to a health Vietnam still lacks a comprehensive national food safety facility, the facility has to report regularly to a higher-level surveillance system. Efforts in surveillance by different facility and ultimately to VFA. In severe outbreaks or those agencies are fragmented, weakly coordinated and poorly leading to deaths, preventive medicine services, health integrated. The data collected by different ministries through facilities or district food safety agencies are permitted to routine monitoring are not collated for joint use by ministries share data and reports beyond their jurisdictions. Statutory for risk-based food safety surveillance and controls. There still surveillance systems and outbreak investigation reports is a need to ensure that surveillance activities are consistent maintained by public health authorities in Vietnam are mainly with international standards and that reliable information passive. Foodborne and waterborne diseases are reported exchange systems are developed between provincial and from lower-level preventive medicine centres to higher-level national organizations. Surveillance systems are expensive centres and ultimately to the general Department of Preventive Vietnam Food Safety Risks Management - Challenges and Opportunities Page 29 Medicine in the MOH. VFA and food safety agencies mainly receive reports of food poisoning or gastroenteritis outbreaks Box 1: Results of market surveillance at where food transmission is suspected. Most outbreaks are central level detected when severe cases are admitted to health facilities or The following are the results of surveillance of 1,143 when deaths occur. A few events have been reported by district hospitals, health workers or local residents; some events have food samples under 13 food sample groups with 28 been detected via reports in the daily newspapers. Response surveillance objectives, in which 164/1,143 samples capacity and resources at local levels are very limited and in (14.3%) were found to be non-conforming. most instances, central/provincial public health officials are • 15/156 samples (9.6%) of bottled drinking water responsible for supporting outbreak responses. failed in Pseudomonas aeruginosa microbial indicators As at 31 December 2015, the Department of Food Poisoning Surveillance of VFA had developed a detailed plan for • 35/139 samples (25.2%) of canned vegetables surveillance and evaluation of several hazards that contaminate failed in sodium benzoate indicator common food products in the market. Surveillance activities • 45/140 samples (32.1%) of salted shredded meat were implemented by five implementation units, consisting failed, out of which 5/45 samples failed in sodium of four specialized institutes (National Institute for Food benzoate indicator and 42/45 samples failed in Control [NIFC], Nha Trang Pasteur Institute, Institute of cyclamate indicator Hygiene and Epidemiology of Tay Nguyen and Ho Chi Minh City Institute of Hygiene and Public Health) and the • 54/122 samples (44.3%) of salted dried fruits of Testing Centre of Drug, Food and Cosmetics of Thua Thien all kinds failed in cyclamate indicator Hue. The system covers 13 types of food products, including • 3/95 samples (3.2%) of powdered supplementary meat and meat products, vegetables, tubers, fruits, aquatic food/nutrition formula products for infants aged products, milk and dairy products, grains, sauces and spices, under 12 months failed in protein indicators as confectionary, beverages, alcohol and beer, functional foods, specified in the label food additives and prepared foods. Specialized institutes and food safety agencies take samples of food products • 7/122 samples (5.7%) of dried beef failed in based on annual guidelines issued by VFA, with a focus on sodium benzoate indicators; 1/48 (2.0%) samples high-risk foods in each province. Laboratory tests for each of functional food for men’s health failed in type of food product are based on the capacities of each sildenafil indicators institute or provincial laboratory or on quick-test kits. Because • 4/25 (16.0%) samples of functional food for fat of limited budgets, VFA only allocates a small number of food reduction failed in sibutramin indicators samples to institutes and food safety agencies and samples are taken from any convenient market, rather than from strategic For the failed samples, follow-up inspections were locations. ordered. Source: VFA (2015) As at 31 December 2015, the provincial level had monitored 9,685 food samples, of which 85.8% were monitored periodically. Most of the samples monitored were domestic food products (accounting for 99.97%); 59.5% of samples (for example, notifiable foodborne disease surveillance, were tested at the local Centre for Preventive Medicine, syndromic surveillance, behaviour risk factors, complaints 29.5% by rapid tests and 30.0% in regional institutes and and antimicrobial resistance systems) have not been other units. established. Many health professionals are not aware of the importance of notifications, except in the case of severe The results of monitoring are: events. Food inspections are conducted sporadically and depend on the annual budget that VFA allocates to each food • Microbiological hazards: 20.5% of samples were safety agency. contaminated with coliforms, followed by 20.1% with Pseudomonas aeruginosa, 18.3% with Salmonella and The shortages in technical human capacity, laboratory 10.1% with Escherichia coli. equipment and financial resources mean that surveillance • Chemical hazards: 10.6% of frying oil samples did and outbreak investigation data are often incomplete and not meet the standard for oxidized level, 6.6% of food inconsistent. Determinants of foodborne diseases, such as samples tested positive for tinopal and 4.7% and 3.9% of environmental factors, hygiene practices and behaviours, food samples tested positive for borax and formaldehyde, have not been systematically studied in Vietnam. Late respectively. detection of outbreaks, insufficient information on trends of common foodborne diseases and high-risk populations In Vietnam, only reports of outbreak investigations and and limited human capacities all impact response systems. hazard surveillance systems are used to monitor foodborne More material on the operation of surveillance in Vietnam is diseases, while other types of important surveillance systems included in Annex 6b. 30 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 2.4.3. Import controls profiling for all imported products and, based on the same procedures, the levels of checks for imported products are There are both formal and informal imports of food determined. Other than for quarantine controls, there is no commodities into the country. To prevent unsafe products system for pre-export inspection approvals of processors or from entering the country, Decision No. 52/2015/QD- exporters in exporting countries. However, Vietnam accepts TTg of 20 October 2015 of the Prime Minister on the test certificates of laboratories of exporting countries. No management of border trade with neighbouring countries evidence of a common import control procedure based on has been promulgated. In effect, the respective ministries are FAO norms and guidance was evident. Coordination is at responsible for their products. The standards used are those Customs, who inform the relevant departments on the arrival applicable for domestic purposes. The basic issue is that the of consignments. The relevant departments first check for import control process is not very well implemented which compliance with SPS concerns and then for food safety and results in rather limited checks to see whether the imported compliance with Vietnam standards. product meets the standards or not. This causes concern to domestic producers who feel that they are treated unfairly; consumers also do not have confidence in imported products. 2.4.4. Export controls Major food imports are cereals, edible fats and oils, fruit, flour and flour-based products. For exports, the respective ministries are responsible for their groups of products. The standards used are those of There is no systematic reporting of non-conforming products the importing country. Major exports by value are fish and detected at the borders. However, Table 1 gives an example fishery products, coffee, cereals (rice), fruit, processed foods, of non-compliant food products detected during an import vegetables and flour-based products. Each ministry handles inspection and clearance of food import consignments in its export control role differently. 2014. For MOIT-related products, the food manufacturers In the case of MOIT, there is some level of risk-based are responsible for their product outcomes. They apply inspection and if a specific number of consignments are tested for externally audited International Organization for and passed at accredited laboratories they get the benefit Standardization (ISO) HACCP programs. The manufacturers of simplified procedures for the next year; that is, they are are responsible for monitoring of primary raw product only subjected to document checks but no further testing. producers. It is the responsibility of each food business In case of illegal imports, there is zero tolerance and goods enterprise in the value chain, from farm to processor to export are rejected and legally re-imported. MARD applies risk markets, to actively manage food safety through a preventive Table 1: Non-compliant food products detected during an import inspection, 2014 Group of food products Total Non-compliant criteria Quality criteria: Protein lower than the announced rate 57.59mg/6 pills to >100–150 mg/6 pills Vitamin A is not inclusive or lower than the announced rate Functional food, dietary 13 Vitamin E is not inclusive or lower than the announced rate supplements Alpha Lipoic acid (-) to (+) Sibutramin (+) to (-) Total aerobic bacteria: 105 to 103 Packaged, canned or tinned Mooncakes: Aflatoxin B1: from 2.31 µg/kg to 14.23 µg/kg (< 2 µg/kg) food: mooncakes, chili Chili sauce, ketchup, soybean sauce: Total aerobic bacteria: 105 to 107 19 sauce, ketchup, soybean (103–104) sauce, beer Beer: expired Food flavouring, food Expired 3 additives (zinc oxide) Proportion of heavy metals (lead): 790.44mg/kg (49mg/kg) Source: VFA (2015) Vietnam Food Safety Risks Management - Challenges and Opportunities Page 31 risk-based approach so that the next downstream business can maintain food safety. Failures at any stage pass food safety Box 2: Case study – Crop Food Safety risks to the downstream clients. Government inspection Management System ensures manufacturers and primary raw product producers comply with government regulations as well as international Within MARD, the ADB Quality and Safety ISO HACCP programs required by international importers. Enhancement of Agricultural Products project (QSEAP) MARD has placed a high priority on supporting the export conducted pilot studies to set up a Crop Food Safety sector to enhance its competitiveness and expand international Management System (CFSMS) in 13 provinces to trade markets. MARD has good and effective export control facilitate coordination, monitoring and management of systems, especially for products exported to the European food safety from the central level to the commune level. Union such as fishery products, foods of animal origin, fruits and vegetables, to provide the necessary government bodies The institutional structure of the pilot system includes with SPS certifications for exports. NAFIQAD is responsible (i) a lead department for monitoring (NAFIQAD), (ii) for food safety inspection and certification of fish and a lead department for policy formulation, development fishery products subject to official food safety inspection and of standards, accreditation of certification bodies and certification in compliance with Vietnamese and importing countries’ requirements. Further details on the type, level and communication about crop food safety (NAFIQAD, frequency of inspection are provided in Annex 7. PPD and DCP) and (iii) specialized positions at the provincial, district and commune levels responsible Processors and other food business operators (animal feeds, storage, fishing boats and input suppliers) are approved for for the management of the food safety system. At the purpose of exports based on European Union or other provincial level, CFSMS is assigned to one agency country requirements and a risk-based approach is used for such as provincial NAFIQAD sub-department or plant surveillance. Health certificates are issued by NAFIQAD protection sub-department, depending on each province. which uses its own laboratories. Consignments rejected in the The ADB mission to review QSEAP completion received importing country are authorized by NAFIQAD for re-entry to Vietnam. positive feedback on CFSMS from Tien Giang, Lam Dong, Ho Chi Minh City and Thai Nguyen province. 2.4.5. Human resource capacities and Table 2 presents a breakdown of the numbers of staff in challenges the CFSMS implementation units and provinces. In view of decentralization of the responsibility for domestic Source: ADB QSEAP (2015) food safety inspection to the provinces and lower levels of local government, the capacity of local inspectors is very weak with respect to inspection performance and inadequate personnel. There is a lack of resources (personnel, finance and supporting policies) to adequately implement food safety control activities. Therefore, production monitoring 60–70% of its food demand). But most of the inspection is still weak. Food safety inspection and investigation is a personnel are based in the Department of Industry and Trade, specialized activity that requires specific education, training, reflecting when the city was only an urban area. The DARD skills and support systems. There is a need to review the inspection and enforcement system is severely understaffed. compatibility between capacity and food safety management With similar size as Ha Noi, Ho Chi Minh City is able to tasks of related agencies and departments in the agriculture supply only 20% of its food demand, with the remaining food sector from central to local level. The number of officers who being ‘imported’ from other provinces. Nevertheless, the city have been trained and have expertise in food safety gradually has more than 600 DARD inspectors. decreases from the central level down to the local level due to combined assignment of food safety management and The food safety management role at the district and commune product quality management in their professional activities. level is very new and does not have a person in charge. In addition, it is necessary to determine where the greatest There is no legal framework that defines the responsibilities food safety risks lie and to focus resources where they can of the commune people’s committee system on food safety have the greatest impact. enforcement and management. Currently, at the grassroots commune level, food safety control is conducted by The deployment of inspection resources in Ha Noi and Ho provincial and district inspection agencies that are located Chi Minh City has failed to follow major developments of mostly in the city and town far from the production field. It is these cities. With the recent expansion of Ha Noi City limits, recommended that commune people’s committee should be it has now become both a major consumer (7 to 8 million involved in food safety control, with strong coordination with people) and a major producer (Ha Noi produces around inter-level agencies. 32 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Table 2: Human resources of the Crop Food Safety Management System in MARD and provinces Implementation unit and province Total staff Female staff Male staff NAFIQAD 7 5 2 DCP 4 2 2 DPP 4 1 3 Bac Giang 14 1 13 Ben Tre 2 0 2 Binh Thuan 11 5 6 Da Nang 10 1 9 Hai Duong 8 3 5 Lam Dong 11 5 6 Ninh Thuan 8 3 5 Phu Tho 12 5 7 Son La 4 3 1 Thai Nguyen 9 2 7 Tien Giang 5 1 4 Vinh Phuc 13 11 2 Yen Bai 15 4 11 Total 137 52 85 Source: ADB QSEAP (2015) There is a shortage of facilities and equipment for inspection and 1,500 inspectors for the fishery sector. At the district and food safety control activities, such as sampling tools, level, a huge number of inspectors would be needed. food safety quick test kits and laboratory testing. There is a need to provide technical assistance to improve food testing In many provinces, sub-NAFIQAD were newly established capacity in support of the food safety inspection system, but with very limited investment in facilities and equipment, training and equipment to apply a risk-based approach to food unclear assigned tasks and functions as well as limited human safety. Data on inspection resource capacity from the ADB resources (only 12 to 15 permanent officers). Implementation QSEAP3 showed the number of inspectors and personnel of activities faces a lot of difficulties in many aspects and it is working in monitoring, inspection and management of crop production from the central level down to provincial, district not easy to meet the assigned tasks. and commune levels. There are 15 inspectors in relevant Currently MOIT, which is in charge of monitoring and MARD departments (NAFIQAD, DPP and DCP) and an average of 10 to 15 inspectors in each province. There are inspecting all products for sale in markets and supermarkets 1,000 to 1,500 inspectors for crop production management (except the wholesale wet markets), has about 7,000 market from MARD to the local level. Similarly, there are 1,000 to inspectors4 tasked to control and monitor all types of markets 1,500 inspectors for management of products of animal origin throughout the country (Anon 2016). 3 QSEAP final report, 2015 4 Food safety risk management study: Discussion note (25 January to 5 February 2016) Vietnam Food Safety Risks Management - Challenges and Opportunities Page 33 2.5. Food safety laboratories ISO 17025 requirements and provides proficiency testing programs and reference material for food testing laboratories According to the Food Safety Law of 2010, three ministries in order to evaluate the performance of laboratories. are mainly involved in food safety testing, namely, MOH, There are four regional laboratories, namely: MARD and MOIT. Each ministry has its own network of food safety related laboratory systems consisting of ministry 1. National Institute of Nutrition in Ha Noi: covering 28 northern provinces or department laboratories, research institutes, professional centres and university laboratories. Some large provinces have 2. Institute of Hygiene and Public Health in Ho Chi Minh their own experimentation and analytical service laboratories, City: covering 18 southern provinces for example, the Centre for Preventive Health Care and 3. Pasteur Institute in Nha Trang: covering 11 coastal Technical Scientific Services on food safety. In addition, there provinces are private laboratories that provide experimentation and analytical services. The Vice Prime Minister through MOH 4. Tay Nguyen Institute of Hygiene and Epidemiology is in charge of the overall laboratory structure in Vietnam as in Dak Lak: covering four provinces in the Central shown in Figure 4. Highlands The National Food Safety Laboratory (NFSL) network At the provincial level, each of the 63 provinces has a is the main diagnostic arm of MOH and plays the role of preventive medicine centre. The centres generally have reference laboratory in food safety in Vietnam. It consists of limited capacity and lack sophisticated instruments to test laboratory units working at national, regional, provincial and for residues and contaminants. At district level, there are district levels. laboratories in each district with limited test facilities. MOH also uses quick test kits for some tests and is considering NIFC is the national reference laboratory in the area of food providing more of such kits for quick testing for boosting safety under MOH. It is based in Ha Noi and serves as the consumer confidence. The food safety laboratory system of highest authority for food safety testing in Vietnam. The MOH is given in Figure 5. results from the institute help to make the final conclusion in case of a dispute. It provides training for regional and The testing parameters are classified into groups based provincial laboratories in advanced testing methods, supports on the type of food and the technique used. Overall group provincial laboratories in developing and implementing categories are provided in Annex 9. Under MOH, the GOVERMENT Vice Prime Minister (in charge) MOH MARD MOIT MOST NIFC NAFIQAD 1,2,...,6 FIRI QUATEST 1 RAHO 1,2,...,7 QUATEST 2 Regional Labs PPD LAB (N,S) QUATEST 3 Provincial Labs Provincial Labs Provincial Labs Figure 4: Food safety laboratory structure in Vietnam 34 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Food safety lab system in MOH NIFC National lab Institute of Hygience Institute of Hygience Pasteur Nha Trang Pasteur Nha Trang National Institute and Edipiology of and Public Health - IHPH Institute - NPNI Institute - NPNI of Nutrition - NIN Regional labs Tay Nguyen - NIHET PMCs PMCs PMCs Provincial labs Dist. Medical center Dist. Medical center Dist. Medical center District labs Commune health stations Commune health stations Commune health stations Figure 5: Ministry of Health food safety laboratory system provincial laboratories do not regularly perform the tests for contaminants and residues. They may perform the tests 2.6. Accreditation of in groups on organic micronutrients, inorganic minerals conformity assessment bodies and heavy metals but not frequently. There are also various projects and initiatives for upgrading the laboratory system The official accreditation body in Vietnam is the Bureau of Accreditation (BoA) under MOST. It was established in Vietnam. However, the effectiveness of the investment in 1995 and offers accreditation programs for laboratories is not always fulfilled. Too many laboratories allocated to (ISO 17025), medical laboratories (ISO 15189), certification certain ministries do the same tests, resulting in the spread of bodies (ISO 17065) and inspection bodies (ISO 17020). investment especially at provincial level. Examples of MOH- All BoA accreditation programs operate in accordance with related laboratories are given below: relevant international standards with the aim of getting these programs harmonized and recognized internationally. • National laboratories: Well-funded by the government and other bilateral programs, good laboratory facilities BoA is currently a member of the International Laboratory and equipment and ISO 17025 accredited. Accreditation Co-operation (ILAC), International Accreditation Forum (IAF), Asia-Pacific Laboratory • Regional laboratories: Well-funded by the government, Accreditation Co-operation (APLAC) and Pacific adequate laboratory facilities and equipment and ISO Accreditation Co-operation (PAC) and has signed agreements 17025 accredited. on mutual recognition of ILAC, IAF, APLAC and PAC. • Provincial laboratories: Adequate laboratory facilities, By the end of 2015, BoA had accredited 713 laboratories some good equipment but not used efficiently. About half (including testing and calibration laboratories) as per ISO of the laboratories are ISO 17025 accredited. 17025. About one-third of accredited laboratories perform tests on food safety. Details of the samples analysed at the NIFC in Ha Noi and Accreditation Office for Standards Conformity the Institute of Public Health in Ho Chi Minh City by year are Assessment Capacity (AOSC) is a third-party accreditation provided in Annex 10. An account of laboratories under other body in Vietnam established in 2009 and belongs to the ministries, and the private sector, is in Annex 11. Vietnam Union of Science and Technology Associations. It Vietnam Food Safety Risks Management - Challenges and Opportunities Page 35 offers accreditation programs for laboratories (ISO 17025), Ha Noi School of Public Health which offers a three-credit medical laboratories (ISO 15189) and certification bodies undergraduate training course on foodborne diseases and food (ISO 17065). AOSC is currently not accepted by APLAC, safety risk analysis and the Vietnam National Agriculture ILAC, IAF or PAC but is working to fully implement its University which offers a two-credit course on risk analysis. quality management system following ISO 17011, including completing the necessary procedures for being recognized In order to improve food safety risk analysis, public health, regionally and internationally for accreditation. So far, AOSC medical and agricultural universities and institutes should has accredited only a few laboratories. develop and implement official compulsory training courses in this field. In addition, these universities should promote To get accreditation, laboratories are required to implement and strengthen research capacity to provide science-based quality management systems in compliance with ISO evidence to inform policymakers in developing food 17025. This will require the laboratory to report its policy, safety policies and programs in Vietnam, to inform risk organization, training activities, facility, equipment, method communication activities regarding food safety as well as to selection, standard operating procedures, sample treatment be used in training programs and/or case studies. and competence assessment. However, there is a great difference between laboratories in the same category with For the private-sector businesses in Vietnam working on food respect to staffing, qualifications of staff, equipment available safety, it would be useful to use and adapt the International and the amount of laboratory work performed. Finance Corporation (IFC) Food Safety Toolkit which is a tool to help food business organizations in developing Proficiency testing is an important aspect for accreditation. countries manage food safety and comply with food hygiene Currently, there are some organizations in Vietnam that have regulations (IFC 2011). The toolkit is essentially a food established and developed proficiency testing programs and safety management system plan or roadmap as to how the have provided them for several years; these include NFSL food business organizations can manage food safety. It aims of MOH, the QUATEST 3 of MOST and the Reference to guide and assist the organizations throughout the various Testing and Agri-Food Quality of MARD. However, although elements of the manual in a motivational and informative there is high demand for proficiency testing, the number of manner. It also contains examples of case studies, one of proficiency testing providers is limited and that of accredited which investigates the challenges and limits of the ‘single providers even lower. It should be noted that according to ISO agency’ approach on food safety. 17025, proficiency testing is a basic requirement and should be carried out by all laboratories. This, however, is currently not adequately implemented. The capacity on proficiency testing is also limited. 2.8. Key messages from this section 2.7. Food safety training • Vietnam has been an early mover in the region in terms programs at academic level of modernising its food safety regulatory system and has laid the formal foundations for an effective and efficient system. However, the government itself recognises that Foodborne diseases and food poisoning are important public the major reforms of five years ago have still to be made health challenges in many countries including Vietnam. In to work and is itself revising both the Food Safety Law the health sector, there are a number of universities, schools and the Food Safety Strategy. The great progress made in and faculties currently providing training programs on food terms of institutions and regulation need to be matched hygiene and safety for both undergraduate and postgraduate by progress in creating a culture that will make these students. These include Ha Noi School of Public Health, Hai changes work at an operational level. Duong Medical Technical University, Preventive Medicine and Public Health Training Institute (Ha Noi Medical • There is a need to strengthen coordination to ensure a University), Hue Medical Pharmacy University, Thai Nguyen comprehensive food control system. Although MOH has Medical and Pharmacy University and Thai Binh University been assigned the lead responsibility for the Food Law, of Medicine and Pharmacy. These universities and faculties it does not have authority to ensure the implementation have departments of food hygiene and safety which conduct of the food safety strategy and target program and is research and deliver training courses on different aspects of just able to collate information rather than implement a food hygiene and safety for undergraduate and postgraduate comprehensive food control program. students. See Annex 12 for further details of the provision in Vietnam of academic training in food safety. • The Food Safety Law is a modern framework that aligns with international standards and approaches to food Very few universities currently provide specific training safety management, however cannot ensure food safety courses on food safety risk analysis (including food safety in itself (as described in the WGB Toolkit Pillar 2). The risk assessment, food safety risk management and food food laws and regulations are generally prescriptive safety risk communication). Among those universities are the with the aim being to implement the processes and 36 Page Vietnam Food Safety Risks Management - Challenges and Opportunities procedures. It is important that these are made more food currently provide specific training courses on food safety safety outcome-based with flexibility in the manner of risk analysis (including food safety risk assessment, achieving outcomes. Similarly, targets need to be more food safety risk management and food safety risk outcome-based. communication). • At the national level, technical and human capacities are comparatively strong. In contrast, capacities at regional and provincial levels for implementing nationally determined policies and for securing food safety are uneven and exhibit major gaps. At provincial and local levels particularly, capacities are either weak or very weak and have constrained operational funding. • Although risk-based food control management is being implemented in some areas, it is not being done uniformly across ministries, departments and provinces. It is recommended that a risk-based approach be followed across the board to ensure best utilization of resources and lead to an effective food control system in the country. • Currently, the focus is more on end-product inspection and testing for ensuring food safety rather than implementing preventive approaches by food business operators. It should be recognized that end-product testing cannot build safety into a product, nor is it cost-effective. It is important for the government to build in preventive approaches for food safety and use testing to validate the effectiveness of preventive measures put in place by the food businesses. • Each ministry has its own network of laboratories (including research institutes and university laboratories) with different capacities while NIFC acts as the reference laboratory for food safety. National and regional laboratories are usually better equipped and funded than provincial laboratories. The concept of networking of laboratories at national level is needed. There is also need to use the private sector to strengthen the governmental food control activities. • There remain significant weaknesses with regard to implementation of quality management, differences in validation procedures and parameters covered, while testing skills and experience among staff are insufficient. • Currently, data available from governmental and research institutions are not harmonized. Further, the same is not scientifically collected, analysed and used for development of standards and other risk management activities. It is important to organize for better collection of data and its use in a systematic and planned manner. It is also important to implement national residue and contaminant monitoring programs across the country. • There are a number of health sector related universities providing training in food hygiene and safety and seven main public agriculture universities providing training in veterinary, food and animal sciences. Although this significant academic asset exists, only a few universities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 37 38 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 3. Key pork and vegetable value chains in Ha Noi and Ho Chi Minh City 3.1. Rationale for value chain 3.2. Pork value chain in Ha selection Noi and Ho Chi Minh City The rationale for selecting pork and leafy vegetables value The pork value chains in Ha Noi and Ho Chi Minh City are chains is explained in Section 1.4 (Scope of the study). This similar (Figure 6). However, these two cities are differentiated section summarizes the key features of the analysis of the in terms of pork volume flow between players in the chain two value chains. The full description can be found in Annex and their levels of food safety risk. The implementation of 17. The purpose of the value chain analysis is to illustrate food safety management in Ha Noi and Ho Chi Minh City, the findings and statements made in the following sections therefore, has to be tailored to specific local contexts of each (hazards and risks, institutions, trade notably) with concrete city in order to be effective. examples taken all along these two value-chains (see Pillar 1 of the WBG toolkit). It will document the description and analysis of the strengths and weaknesses identified in the Vietnamese Food Safety system and serve as evidence-based to justify the findings and related recommendations. Own SLAUGHTERING HOUSES produced HOUSEHOLD CONSUMERS feed FAMILY-RUN Retail Markets PRODUCERS (HOUSEHOLDSOR FARMS) Wholesale Carcass Traders/Businesses SLAUGHTERING CENTERS or INDUSTRIAL PROCESSING markets FACLITIES Super markets, convenient store Local/Inter-province Pig Organizationa Traders I buyers (Restaurants, hotels) Importers Overseas Local Overseas Traders or animal distributors exporters, feed producers of animal feed domestic suppliers for Piglet Producers (material animal Piglet Traders Figure 6: Pork value chain supplying Ha Noi and Ho Chi Minh City Vietnam Food Safety Risks Management - Challenges and Opportunities Page 39 3.2.1. Consumption With an average annual pork consumption of 27 kg per capita in Vietnam5 and population of 7 million in Hanoi and 8.2 million in Ho Chi Minh City, the total demand for pork is estimated at 630 tons per day in Ha Noi and 730 tons per day in Ho Chi Minh City. This does not include demand from the significant number of daily visitors to the city; hence, in reality, the actual pork consumption may be even higher. Moreover, most Meat inspector in performance studies show that meat consumption is higher in urban areas so we would expect urban Ha Noi to have higher per capita pork consumption than the country average. Consumption of pork outside the home is increasing. In 2012, it was estimated that Vietnam had 430,000 street stalls/kiosks, 7,000 fast-food restaurants, 80,000 full-service restaurants and 22,000 cafeterias/bars. Ha Noi also has a large number of institutional food providers including government, educational, medical and industry canteens. 3.2.2. Production As at October 2014, Ha Noi had more than 1.4 million pigs, accounting for 5.3% of the national herd (26.5 million pigs)6. This contributes more than 500 tons of pork per day for the capital’s residents. Thus, deriving the 630 tons demand A small-scale slaughterhouse in Ha Noi in operation, per day, Ha Noi should be importing more than Photo courtesy of Donald Macrae/WB 100 tons per day from other provinces. In terms of geographical production organization, Ha Noi has four major specialized production zones with 150 tons are also provided by some large companies from their own 120,000 pigs. By production organization, there value chains; Vissan (Vietnam Meat Industries Limited Company), for are 802 pig farms which are normally outside example, sells 70 tons per day to the Ho Chi Minh City market. Thus, residential places and contribute 30.9% of the in light of 730 tons per day consumption as estimated above, it appears whole city’s production. Farm businesses (as that around 100–150 tons are being consumed without going through a opposed to pig rearing in the family backyard) known or reported channel. One of the major issues of pig production are increasing but many would be considered of in Vietnam is that the cost of feed is high and the sector relies on over small or moderate scale7. Organized production 70% of feeds imported from other countries (Viet Nam Alliance for based on value chains, in which traceable Agriculture 2015). linkages between players are systematically set, has been strongly encouraged. By the end of 2014, the supply from this model was estimated 3.2.3. Pig processing system at 11,000 tons, 30 tons per day or 5% of the total While it is now estimated that 93% of the pork meat consumed in consumed in Ha Noi. Ho Chi Minh City has been slaughtered in large slaughterhouses (17 According to DARD, pork production in Ho Chi slaughtering centers processing 682 tons per day), the situation in Hanoi Minh City is 85,000 tons per year, equivalent is different and remains challenging to control with (i) 14 semi-industrial to 227 tons per day. To cover the demand gap, processing 152 tons per day (24%), (ii) five manual processing sites supplementary supply is sourced from other with multiple slaughter places for each (93 tons per day, 15%) and (iii) provinces, that is, 65,085 tons per year or 178 an estimated 2,490 family-run slaughterhouses with capacity of 1–5 tons per day. We estimate a daily amount of 100– pigs a day at each household processing 385 tons per day (61%). 5 IFC Report, Pork and Broiler Chicken Industry Development in Vietnam 6 Vietnam Statistics Office 7 DARD, Ha Noi 40 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 3.2.4. Distribution system about 7.5 tons a day (1.2%)9. There are no data reporting the flow of pork via supermarkets or convenience stores; From the slaughterhouses, pork reaches the end consumers nevertheless, it is generally estimated that 15% of all foods through (i) supermarkets or convenience stores, (ii) are sold at modern trade outlets, suggesting 94.5 tons per day. retail markets, (iii) wholesale then retail markets or (iv) organizational buyers. Here again, the model is different. In In summary, key features of the value chain structure in Ha Ho Chi Minh City, most pork is distributed via the wholesale Noi and Ho Chi Minh, although with important differences market channel: 522 tons per day (72%), which is divided are: between Binh Dien (36%) and Tan Xuan (64%)8. In this • Increasing modern trade outlets such as supermarkets and channel, the wholesalers at wholesale markets sell to other convenience stores agents who retail the meat to end users in retail markets. There are no data reporting the pork sold at supermarkets • Significant demand from organizational buyers, such as and convenience stores. Compared to Ha Noi, the modern hotels, restaurants and schools trade system in Ho Chi Minh City is more advanced and hence may be more important. We estimate that the pork sold • Insufficient production requires supplementary supply of in this system may be 20% of the city’s daily consumption pork from other provinces (about 146 tons). The amount of pork supplied directly from • Retail (wet) markets dominate sale of pork slaughterhouses, inside or outside the city, to retail markets is about 50 tons per day. • Small-scaleproducers and small slaughtering facilities dominate the value chain On the contrary, in Ha Noi, the pork that goes directly from slaughterhouses to retail markets is estimated to be at least While the two first bullet points create a strong demand for 518 tons (82%). The four major wholesale markets (Minh traceability the last three create unfavourable conditions for Khai, Phung Khoang, Den Lu and Van Quan) only channel this to be carried out. Wholesale market, meat section in Ha Noi, Photo courtesy of Donald Macrae/WB 8 Data provided by DARD 9 On average, there are 60 outlets at each market; each outlet trades one pig of 73 kg per day. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 41 3.2.5. Food safety risks • There is an increasing share of large companies that have built up their own value chains to ensure traceability and Food safety control is supposedly more manageable in pork quality. supermarkets or convenience stores and semi-industrial and • Seventy-twoper cent of pork is traded at wholesale manual processing slaughterhouses as concentration in one markets under monitoring and evaluation of the local place can enable better monitoring and evaluation of pork government. safety. In comparison to Ha Noi, the pork value chain in Ho Chi Minh City is theoretically more favourable to food safety However, there is limited evidence that the management control because: of food safety in one location is more effective at reducing food hazards (Grace 2015) and there are some aspects of • Small-scale processing at residential houses is almost concentrating production, processing and retail that can replaced by slaughter centres where the monitoring, increase contamination. During its visits, the team found little control and inspection activity can be conducted more evidence that workers and stakeholders in these larger scale effectively and efficiently. infrastructure adopted better practices to ensure safer food, or that real enforcement of these practices was conducted by • The installed capacity of modern slaughtering businesses the government’s inspectors. Building up and maintaining can well capture the current demand of 8,000 pigs per business credibility creates incentives for supermarkets to day. The additional facilities planned to be launched in develop traceability for products on shelves. However, in 2016, which cover six factories for 10,000–15,000 pigs Southeast Asia, fresh foods sold in supermarkets often do not per day, can also accommodate the demand growth in the have traceability as they are sourced from wholesale markets medium term10. and not from farms. Traditional Meat Market, Photo courtesy of Donald Macrae/WB 10 The growth in consumption of Pork in Vietnam is estimated at 3% per year […] 42 Page Vietnam Food Safety Risks Management - Challenges and Opportunities EXPORTERS Vendors Reail Markets Wholesale markets Traders/ Cooperatives Household Consumers PRODUCERS Super markets, convenient store Processors or Exporters Organizational buyers (Restaurants, hotels) Overseas markets Traders or plant Local distributors protection medicine Overseas of plant producers exporters Figure 7: Vegetable value chain supplying Ha Noi and Ho Chi Minh City 3.3. Vegetable value chain in Ha 3.3.2. Production Noi and Ho Chi Minh City The level of production of vegetables in Ha Noi is nearly 600,000 tons per year or 1,644 tons per day11. With a The vegetable value chain supplying Ha Noi and Ho Chi consumption level of about 1 million tons per year, Ha Minh City is depicted in Figure 7. As for the pork value chain, Noi has to import a substantial amount of vegetables from actors involved in the vegetable value chain are similar in Ha Noi and Ho Chi Minh City although they can be differentiated other provinces. The supplementary supply is mainly from by the volumes channelled through different stakeholders and provinces in the Red River Delta (Vinh Phuc, Hung Yen, Hai sourced from outside the provinces. Duong, Bac Ninh, Bac Giang and Hoa Binh). This is expected to increase in future because of the rapid urbanization process 3.3.1. Consumption that will further shrink agricultural land in the capital. Notably, it is widely reported in the media that a considerable Because of the unavailability of data on the specific market amount of vegetables originate from China, without being demand for vegetables in Ha Noi and Ho Chi Minh City, confirmed by official data. the levels of consumption of vegetables in the two cities was estimated. We assumed an average Vietnamese would Unlike the pork business where the farm model is becoming consume 0.4 kg of vegetables per day. Therefore, the total consumption of vegetables in Ha Noi and Ho Chi Minh City popular, vegetable plantations are dominated by thousands of is projected at 2,800 tons per day and 3,290 tons per day, households. Due to historical reasons, an average plantation respectively. per household is less than 2,000 m2, divided into four to five 11 Source: DARD Ha Noi Vietnam Food Safety Risks Management - Challenges and Opportunities Page 43 slots scattered at different places on the field12. Given around 12,000 hectares of vegetable land and an average of 2,000 m2 per household, about 60,000 households are probably participating in vegetable production in Ha Noi. With 14,500 hectares of land, Ho Chi Minh City generates 366,704 tons of vegetables yearly, reaching 30% of the total consumption of 1.2 million tons. The balance (over 800,000 tons, 70%) is sourced from other provinces. Ho Chi Minh City has signed some inter-provincial agreements with five provinces (Lam Dong, Long An, Tay Ninh, Tien Giang and Cà Mau ) for trading of vegetables and fruits to improve food safety during transport of food between provinces. Safe value chains have been particularly targeted and set up, providing 20,914 tons of safe vegetables and fruits for Ho Chi Minh City13. In addition, concerted efforts have been made to expand VietGAP-certified plantations, but uptake has Vegetables on sale in a traditional market, been rather limited to date. The VietGAP vegetable output Photo courtesy of Donald Macrae/WB achieves 50,929 tons per year, equivalent to only 4% of the total consumption. In both cases, though co-operatives have been formed by to (i) lack of capacity to invest in infrastructure, equipment farmers to address the weakness of small-scale production and training for good practices to produce safe food, (ii) through strengthened horizontal linkages and other collective challenges in inspection of farms for the government and actions, the capacity of such co-operatives generally remains (iii) the misuse of plant protection products and pesticides. weak. VietGAP-certified production is used as a tool to ensure food safety, but remains marginal (only 4% share of Ho Chi Minh City’s consumption, for instance). 3.3.3. Distribution In addition, control of supply from other provinces is Here again, in Ho Chi Minh City, and unlike Ha Noi, the difficult, notably for Ho Chi Minh City which imports 70% available data suggest that vegetables sold at retail markets of its vegetable needs, involving coordination between are almost all from wholesale markets (85%). Supermarkets different agencies on the ground. Tracing of vegetables, in the and modern stores start playing an important role to distribute event a sample tests positive for a specific hazard, is almost vegetables to end consumers, as 15% of the vegetables impossible. Supply from China is not officially recorded, consumed appear to transit through them. although the high frequency of media reports on China- sourced vegetables and fruits suggests a significant import The situation is different in Ha Noi where only 33% is volume from China. Public doubt of food safety is always channelled through wholesale markets, and an additional cast over Chinese products. However, this is not well backed 15% distributed through supermarkets (although there could by the available data and test information. be double counting as some supermarkets get supplied by wholesale markets). It means that a balance of over 500,000 While the flow through wholesale markets can be presumably tons per year of consumed vegetables appears out of control better controlled, the flow that goes directly from vendors or and is believed to be sourced from (i) direct supplies from producers to retailers in open markets cannot be properly producers/vendors (inside or outside Ha Noi) to local markets monitored. In Ha Noi, 491,609 tons of vegetables per year or retail markets somewhere else and (ii) imports from China. are estimated to flow directly from producers or vendors to retail markets where the inspection is fairly loose in 3.3.4. Food safety risks comparison with wholesale markets. This is consistent with the findings from a recent study of the vegetable supply chain Ha Noi and Ho Chi Minh City share common risks at in Ha Noi that 42% of vegetables in Ha Noi are supplied by household level. These include the issues associated with small vendors14 whose products do not pass through the state micro- and small-scale production generating risks related monitoring system. 12 Denis Sautier, D., Dao, T.A., Nguyễn, N.M., Moustier, P. và Phạm 14 Nguyen Thi Tan Loc and Do Thi Kim Chung,2015.Vegetable C.N. 2013. Enjeur de l’agriculture periurbaine et croissance urbaine industry development and solution . Joumal of Science and a Ha Noi. Metropoles aux Suds, Parois, Edition Ketharla. pp. Development 13(4): 850-858 271–285. 13 Report of DARD, Ho Chi Minh City 44 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Vegetable market in action, Photo courtesy of Donald Macrae/WB 3.4. Some implications for the serving of pork and its products, policy coordination and coordinating implementation of food safety measures. value chains in the case of Ha Development of standards for pork and pork products and overall labelling requirements. Noi • The smaller businesses are the responsibilities of An example of an inspection and monitoring scheme of an provincial level agencies while the larger businesses are agriculture value chain (fresh fruit, vegetables and meat) generally addressed at national level. which describes ‘what, who, how and when’ is presented in Annex 8. Pork production is 500 tons per day and supply Issue: At the market level, both MOIT and MARD have a from other provinces is 100 tons per day. Out of 500 tons responsibility. At restaurants and canteens, the responsibility produced in Ha Noi, large farms produce around 30% and lies with MOH but strong coordination is needed with the organized value chains produce 30 tons per day. At the MARD veterinary service. Regarding labelling, again, strong processing level, there are 14 semi-industrial slaughterhouses coordination is required. At the provincial level, coordination producing 152 tons per day (24.1%), 93 manual processing is needed not only among the inter-ministerial departments slaughterhouses producing 93 tons per day (14.8%) and but also within MARD and its local departments: NAFIQAD 2,490 family-run slaughterhouses producing 385 tons per which operates the residue control program, DAH and DARD. day (61.1%). Distribution is through 103 supermarkets (94.5 tons or 15%), four wholesale markets (17.5 tons or 3%) Recommendation: Targets under the Food Safety Strategy and 426 retail markets (516.6 tons or 82%). Based on the will need to focus on food safety outcomes and not only on assessment of the value chains in relation to the institutional processes and process controls. As such, coordination should infrastructure, some further analysis and recommendations center on those outcomes. Ho Chi Minh City has been granted are provided below by sub-sections discussed in this section. the pilot of a single food safety management unit/board, reporting directly to City People’s Committee. It is critical that this pilot is to be carefully monitored, documented, and 3.4.1. Responsibilities of different analysed for lessons. ministries and departments • MARD: Responsible for pig production, inspection and 3.4.2. Laws and regulations slaughter; post-harvest handling including processing In Vietnam, food laws and regulations are generally and wholesale wet markets. It also implements a residue prescriptive with the aim being to implement the processes monitoring program (started very recently), development and procedures. Often, laws are not implemented in a true of VietGAP standards and scheme and its implementation. spirit to ensure safe food. In the pork value chain, levels • MOIT: Responsible for wholesale and retail markets of veterinary drug residues need to be within the criteria including supermarkets and food stores. prescribed; generally, these should not be permitted in feed inputs or should be restricted to the bare minimum levels • MOH: Safety in restaurants and canteens including essential for the purposes of treatment of animals. However, Vietnam Food Safety Risks Management - Challenges and Opportunities Page 45 it was observed that the use of antibiotics in animal feeds is be recognized that end-product testing cannot build safety into the norm and in certain cases farmers were using as many as a product, nor is it cost-effective. Although VietGAP has been 15 veterinary drugs in the feed. Targets under the National initiated, the numbers seen are very limited. It is important Strategy for Food Safety need to be more outcome-based; for the government to build in preventive approaches for however, these are generally in terms of the numbers of units food safety and use testing to validate the effectiveness of implementing HACCP, irrespective of their effectiveness. preventive measures put in place by the food businesses. 3.4.4. Available data As discussed in Section 4 on food safety hazards and health impact, the most prevalent microbiological hazard in pork is Salmonella and a number of studies are quoted in the report. Antibiotic residues and growth promoters are also being used in the pig farms, as evidenced from literature. The data currently available from governmental and research institutions are not harmonized. However, the data are also not scientifically collected, analysed and used for development of standards and other risk management activities. Data linking public health and foodborne illnesses to the food are neither scientifically collected nor coordinated between ministries and departments. There is a need for better data collection including the implementation of national residue and contaminant monitoring programs across the country and use of data in a systematic and planned manner. There is also a need for a focus on hazards and impacts on public health, as well as the development of comprehensive and joint national surveillance programs. Bag of pig feed as seen on field visit 3.4.5. Food safety laboratories Credit: Stephane Forman/World Bank Each ministry has its own network of laboratories with different capacities. The government is now looking at procurement of rapid test kits for testing of products at 3.4.3. Surveillance, inspection and markets so that immediate results may help to allay the fears of consumers and the government. However, this will require preventive approaches significant testing both in terms of products and parameters With the large number of household farms producing pigs, to determine their safety. Further, testing should not be the 2,490 family-run slaughterhouses processing 61% of pork used for food control but to confirm that the implemented consumed in the city and the 518 retail markets distributing activities deliver safe food. It is important to implement the 82% of the meat, even a single visit a year will require a National Residue Control Plan and to consolidate the test large workforce. Even then, the quality and safety of pork are facilities in both government and private-sector laboratories not guaranteed. It is, therefore, absolutely essential to look for better resource utilization and management. The concept into preventive approaches and risk-based surveillance and of networking of laboratories at national level is needed. inspections with responsibilities shared between ministries There is also need to use the private sector to strengthen the and departments. governmental food control activities. Although risk-based food control management is being implemented in some areas, it is not being done uniformly 3.4.6. Training across ministries, departments and provinces. It is recommended that a risk-based approach be followed across As seen from the analysis, small-scale producers and the board to ensure best utilization of resources and lead to an processors produce 70% of the pork supplies. It is important effective food control system in the country. It may also be to train and increase awareness of producers and processors. useful to synergize private-sector initiative in this area. Training is also needed for government agencies, especially at local levels. Consumers also need awareness on food safety Currently the focus is more on end-product inspection and to be able to understand foodborne hazards and risks and testing for ensuring food safety rather than implementing demand hygienic and safe products which will then lead to preventive approaches by food business operators. It should safer production and application of hygienic practices. 46 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 3.5. Food safety production VietGAP: In this ‘field-to-table’ model, good farming practices in producing vegetables and good manufacturing models practices (GMP and HACCP) in packaging, processing, transport and storage with hygiene and management standards High public concern over unsafe foods has clearly indicated are applied to ensure strict control at all stages of food value an unsatisfied demand on the consumer side. Many players in chains. At production level, farmers have to comply with agricultural value chains adopt safety as a core selling point GAP standards and among these is VietGAP, a process of for their products. Emerging models are briefly discussed GAP established and issued by MARD from 28 January 2008. below with more details available in Annex 17. Many supermarkets, canteens and safe vegetable stores now require vegetable products originating from certified safe Vertical integration: Large firms manage all stages in the agricultural zones or produced under VietGAP principles. value chain to enhance traceability and quality assurance. Basic GAP: With technical support from JICA, a project Linkages: In the context of resource constraints to expansion, on improving crop productivity and quality developed and linking with firms that require high quality is perhaps the best evaluated Basic GAP which is specific, simpler and more currently available option. A typical linkage is between well- accessible for farmers to deliver good farming practices known distributors, co-operatives and processing companies. without having to use the term ‘towards VietGAP’. In 2014, For example, many VietGAP-certified products can be now MARD issued a Decision No. 2998/QD-BNN-TT, Basic obtained from Saigon Coop Mart, a prominent modern GAP Guidance for Vegetable Production in Vietnam. distributor that has well established relationships with many co-operatives and companies in Ho Chi Minh City and many Community-based certification: As an alternative to other provinces in Vietnam. VietGAP, in which registration through a certification Co-operatives: Multiple households come together to use organization or body is required, food safety monitoring standardized GAP. This can address issues associated with could be a community-based model. Such community-based small-scale production at households and improve marketing models are effective in many countries, especially in small- capacity. This is the model promoted by MARD through scale production that involves a quality management system the Livestock Competitiveness and Food Safety Project such as Participatory Guarantee System (PGS). In Vietnam, (LIFSAP) supported by the World Bank with the Good PGS has been used by the Agriculture Development Denmark Agricultural Husbandry Practices certification. Asia and VredesEilanden Country Office Vietnam for safe organic vegetable production. Safe Agricultural Zones: Branding of specific production areas as ‘Safe Agricultural Zones’ is intended to assure production of safe agricultural food products in terms of uncontaminated locations, primary processing and trading. Sustainable Safe Agricultural Zones could ensure (i) food safety risks in agro-production are avoided, (ii) production activities are organized and efficiently linked with processing and marketing, (iii) efficiencies from investments in processing and marketing infrastructure are attained and (iv) the climate for encouraging greater investments by farmers and agribusiness is conducive. The ADB QSEAP supported 16 provinces to establish and plan Safe Agricultural Zones. 3.6. Key messages from this section • The food safety related issues and weaknesses vary from one value chain to another. Development interventions to address such are to be tailored to local contexts to be effective. • Ha Noi and Ho Chi Minh City are the largest markets for pork and vegetables. The value chains are characterized by Wet market upgraded through WB-funded LIFSAP an increase in modern trade outlets such as supermarkets Credit: Stephane Forman/WB and convenience stores and significant demand from organizational buyers such as hotels, restaurants and Vietnam Food Safety Risks Management - Challenges and Opportunities Page 47 schools. Insufficient production requires supplementary supply of pork from other provinces. • Eighty per cent of pork and 85% of vegetables are marketed mainly in retail (wet) markets and small-scale producers dominate the value chain. Even though the control of food safety has been improved as a result of increasing intensification of pork production and rapid development of the supermarket system, small-scale production and the flow through traditional/informal markets still dominates in most agricultural value chains and so the food safety risk remains high. • Seventy-six per cent of pigs are processed mainly in small slaughtering facilities with generally poor hygiene conditions. • Characterized by considerable participation of small- scale players along pork and vegetable value chains, a multi-dimensional approach that covers a wide range of various actions, for example, technical training of producers, promoting best practices and government control, is strongly recommended for these value chains (see pillars 3 and 8 of the WBG toolkit). • Given that consumers have a strong preference for fresh animal-source food and fresh fruit and vegetables and most do not store purchased food for long periods, focus should be placed on (i) identifying technological solutions and associated management procedures to enable quick and efficient testing of fresh products, (ii) promoting business models with lean and efficient value chains to deliver fresh products to consumers within a short time and minimizing food safety risk and (iii) raising awareness among end consumers and producer groups. 48 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 4. Food safety hazards, risk and health impact 4.1. Risk-based approach: Hazards are things that have potential to cause hazards and risks harm. In the context of food safety, a hazard can be classified as a substance (biological: Foodborne disease is a significant public health issue in viruses, bacteria and parasites; chemical: growth Vietnam. The contamination of popular foods such as pork promoters, antibiotics and pesticide residues; or and vegetables can occur all along the food value chain. physical) present in food that has the ability or It is important to understand how and where food safety the potential to cause an adverse health effect in issues arise to mitigate and prevent foodborne diseases. Risk consumers. analysis is an approach to managing food safety that answers the questions of concern to policymakers and the public: Is Risk is the chance that a person might be harmed if our food safe? If there are safety risks, how significant are exposed to a given hazard. Risks in food safety are they (risk assessment), what are the best ways of reducing usually referred to as having short-term or long- the risks (risk management) and how do we communicate term effects on human health. these risks to food safety stakeholders (risk communication)? Risk assessment identifies the critical control points and Risk analysis is a process composed of hazard management strategies that need to be applied to eliminate or identification, risk assessment, risk management minimize the risks. Therefore, it is important to differentiate and risk communication between hazards and risks in food safety. However, risk analysis is still not well understood and not much applied in the developing world, including Vietnam. In Vietnam, the national regulation imposes the application safety due to the lack of capacity, resources and an enabling of risk assessment in high-risk products for both domestic environment. and export products, but capacity is still lacking in practical application due to limited resources (financial and human). One of the recent and more coordinated efforts to develop risk The situation is especially urgent in Vietnam’s huge informal assessment for food safety in Vietnam is the Taskforce for Food market sector, where most domestically produced food is Safety Risk Assessment. It consists of researchers working supplied. Therefore, developing a risk-based approach to on risk assessment and food safety as well as representatives food safety is crucial to improve food safety management in of MOH and MARD. A series of hands-on training courses Vietnam and will help generate evidence for policymakers on with a focus on case studies of risk assessment for food safety how risk assessment can be used for food safety management. were organized to strengthen the risk assessment capacity of taskforce members and policymakers. Case studies of food The current enabling environment is supportive for safety risk assessment were conducted and published. The development and application of risk-based approaches to next steps are to enable risk-based approaches to be easier food safety. The Food Safety Law (in effect since July 2011) to use and adaptable to the local context. The taskforce could mandates the application of risk assessment to high-risk benefit from the support of ministries, for example, in its food products intended for both domestic consumption and institutionalization. export. In May 2013, the Government of Vietnam announced its support for the development of a rapid detection system for food safety and MARD issued a circular on using risk 4.2. Food safety hazards assessment in food safety management. However, in reality, risk assessment is rarely applied due to the above stated Vietnamese food safety hazards and origins of food hazards constraints. can be categorized either from each step of the food production chains or each specific food type. Food production What is the actual capacity in risk-based approaches to chains involve various actors who play particular roles in food safety in Vietnam? This capacity is spread among terms of eliminating or introducing the hazards. Depending universities, research institutes, ministries (MOH, MARD on the type of hazard (biological, chemical or physical), their and the Ministry of Natural Resources and Environment potential presence or absence along the food production chain [MONRE]) and the National Codex Committee. Training is low, medium or high. On the other hand, those hazards are has been done with international assistance. However, to the also specified for each food type. Food types (commodities) best of our knowledge, except for the export sector there is are either ready-to-eat or raw food which can be further low systematic application of risk-based approaches to food categorized as of animal or plant origin. The dynamics of the Vietnam Food Safety Risks Management - Challenges and Opportunities Page 49 value chain actors and of the hazards themselves along the between the season and Salmonella contamination with food chain might result in complex challenges related to food higher contamination in spring (21%) than in winter safety risk management. Furthermore, the perceptions among (63%). food chain actors of hazards are also diverse. Therefore, it is important to associate the food hazards with either food For the purpose of comparison, figures from zoonoses production chains or food commodities. monitoring in Germany indicate Salmonella prevalence of 1.4% in pork and 7.6% in chicken (BVL 2010) with a Input suppliers and producers mainly deal with the quality of decreasing trend since 2006. An estimate by the European primary products, such as live animals or on-field vegetables, Food Safety Authority (EFSA) based on data from 2010 whereas traders and collectors play a role in maintaining the concluded that 10.6%, 17.0% and 56.8% of the human good quality of the products. Slaughtering or harvesting steps salmonellosis cases in Europe are attributable to broilers, help to separate the eligible parts and subsequent processing laying hens and pigs, respectively (EFSA 2012). steps enhance the quality of the products. During slaughtering, harvesting and processing, contamination with hazards can Both Giardia spp. and Cryptosporidium spp. were found occur if food safety measures are not well implemented. The contaminating vegetables at the same level, 15.4%. distribution stage maintains appropriate storage practices and Concentrations of Cryptosporidium in samples ranged from conditions for either raw or processed food sources. The end 100 g vegetable samples with a median number of 100 oocysts node at consumption is aligned with preparation and cooking per 100 ml/g (Tram Thuy Nguyen et al. 2016). An earlier steps which could further result in hazards and contaminated study in Ha Noi found Cyclospora spp. in 34/288 (11.8%) of food, with potential risks for consumers. market water and herb samples and 24/287 (8.4%) of farm samples. All varieties of herbs sold at the market and grown 4.2.1. Biological hazards in farms were contaminated with Cyclospora spp. oocysts. A marked seasonal increase in Cyclospora spp. contamination Foodborne pathogens (hazards) which have been recorded was observed before the rainy season from November to in reports as well as described in literature are varied and April (39/288) compared to the rainy season from May to geographically specified. Biological hazards in food chains October (19/268) (p = 0.006) (Tram et al. 2008). Moreover, include parasites, fungi, bacteria, viruses and prions. Among water used to moisten vegetables is a source of E. coli and these causative pathogens, infection mechanisms can be protozoan parasite contamination at markets in Ha Noi (Tram further classified by predominant clinical features (upper and Dalsgaard 2014). Water spinach grown on Nhue River or lower gastrointestinal, neurological, allergic type or was contaminated with E. coli O157:H7 and washing reduced infectious features) or pathogenic mechanism (intoxication, contamination from 3.23 ± 1.64 to 1.42 ± 1.77 colony-forming toxin-mediated infections and infections) (WHO 2008; IAFP units (CFU) per gram. The average count of E. coli O157:H7 2011). Based on data from literature reviews conducted by in river water was 4.77 log CFU/100 ml (Kieu Thanh Truc et ILRI covering tens of thousands of food samples, it appears al. 2014). that a not negligible proportion of food is contaminated with microbes and parasites. However, direct correlation with Analysis of microbial quality of safe vegetables produced by human diseases cannot be currently established and risk VietGAP in Lam Dong province from 2012 to 2014 revealed exposure studies should be conducted. Annex 14 provides an that among 1100 samples, 3% were contaminated with overview of biological food safety hazards in the food chain. Salmonella and 16% with E. coli. This contamination rate While various hazards are listed, only little information is was lower in samples from safe vegetable production farms, available for most of the hazards. However, an important varying from 1–1.08% (MARD 2015). Results from zoonoses hazard is Salmonella in meat with a prevalence level in monitoring in Germany found the absence of Salmonella in some specific studies of 33–43% in pork sold at markets. leaf lettuce (confidence interval [CI]: 0.0–0.4) (BVL 2014). Campylobacter was recorded as an important hazard in chicken. Among various studies on Salmonella contamination Water used for food production—for example, for livestock in pork, details from two studies conducted in Ha Noi are production or irrigation—is an important element for food provided below: safety. Generally, ground water from wells, tube wells or taps is commonly used for livestock production and surface • Prevalence/contamination in pig carcasses in a Ha Noi water from open water bodies for crop production and the slaughterhouse (Phu Thai 2007): Of 356 samples, 49% water quality would be expected to be acceptable. Vietnam of meat swabs and 35% of lymph nodes were Salmonella- achieved the Millennium Development Goals for water and positive. There was some association between farm type sanitation in 2015 (Government of Vietnam 2015). However, and Salmonella prevalence in pig carcasses (lymph node in the case of wastewater, reuse for vegetable production or cuts) with higher prevalence levels in pigs from backyard use of unsafe water to clean or moisten vegetables poses a farms. health risk to producers and consumers (Toan et al. 2014; • Salmonella in minced pork sold at Ha Noi retail Tram and Dalsgaard 2014). Table 3 summarizes the food markets (Pham Thi Thu Hien 2009): Of 251 samples, sources of biological hazards. Most of the hazards are related 37% were Salmonella-positive. There was a correlation to consumption of raw/fresh or undercooked products. 50 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Table 3: Summary of food sources of major microbial hazards and health effects (in order of the magnitude of health burden in the WHO Western Pacific region B (which contains Vietnam)). Organism Food sources Health effects Viruses Noroviruses Raw products, contaminated drinking water, uncooked Diarrhea, throwing up, nausea, stomach pain; fever, foods, contaminated water headache, body aches, urinate less, dry mouth and throat, and feel dizzy. Hepatitis A virus Raw products, contaminated drinking water, uncooked Mild "flu-like" symptoms, such as fatigue and loss foods, contaminated water of appetite, or more serious symptoms: jaundice, nausea, vomiting, diarrhea, fever, stomach pains Bacteria Salmonella Typhi Food or drink beverages that have been handled by a Typhoid fever is a life-threatening illness, high fever person who is shedding or sewage contaminated with (39° to 40°C), stomach pains, headache, or loss of S. Typhi appetite; rash of flat, rose-colored spots Campylobacter Raw and undercooked poultry, unpasteurized milk, Diarrhea and bloody diarrhea, some cases develop jejuni contaminated water arthritis, Guillain-Barre syndrome/paralysis (immune-compromised person) Non-typhoidal Eggs, poultry, meat, unpasteurized milk or juice, Diarrhea, fever, and abdominal cramps; some cases, salmonella spp. cheese, contaminated raw fruits and vegetables the diarrhea may be so severe that the patient needs to be hospitalized Escherichia coli Undercooked beef (especially hamburgers), Diarrhea (often bloody) and abdominal cramps; O157:H7 unpasteurized milk and juice, raw fruits and vegetables more severe, kidney failure-hemolytic uremic (sprouts) and contaminated water syndrome (HUS): fever, abdominal pain, pale skin tone, fatigue and irritability Shigella spp. Raw products, contaminated drinking water, uncooked Diarrhea, fever, and stomach cramps; some people foods, contaminated cooked foods due to infected who are infected may have no symptoms at all food handler Protozoa and parasites Giardia Untreated or improperly treated water, ice; uncooked Diarrhea, gas, greasy stools that tend to float, food (fruit, vegetable) contaminated with Giardia stomach or abdominal cramps, upset stomach or nausea/vomiting, dehydration (loss of fluids) Entamoeba Fresh fruit, ice or vegetables; milk, cheese, or dairy Diarrhea, stomach pain, and stomach cramping, histolytica products contaminated with E. histolytica amebic dysentery, fever Taenia solium Undercooked or raw infected pork, pig blood; drink Lumps under the skin, which can sometimes water or eat food contaminated with tapeworm eggs become tender; seizures and/or headaches, neurocysticercosis, stroke or death Ascaris spp Contaminated food, vegetable and water by Ascaris Often no symptoms, abdominal discomfort, egg due to poor personal hygiene, poor sanitation intestinal blockage and impair growth in children, lose weight Clonorchosis/ Undercooked fish and raw fish Abdominal pain, nausea, jaundice, diarrhea Opisthorchosis (acute); Liver cirrhosis cholangitis, cholelithiasis, pancreatitis, and cholangio carcinoma (chronic) Paragonimus spp. Raw or undercooked infected crab or crayfish, Diarrhea, abdominal pain, cough, discomfort, and freshwater crustaceans low-grade fever, mimic meningitis Source: US Centers for Disease Control and Prevention, US Department of Health and Human Services (2016) and Havelaar et al. (2015). 4.2.2. Chemical hazards consumers to control and identify in contaminated foods (Andrée et al. 2010; Tran Thi Tuyet-Hanh et al. 2015). Figure Chemical hazards in foods, especially in vegetables and meat, 8 describes the process from farm to fork where chemical are the most common hazards of public concern which can contamination may occur; the figure shows there are various negatively affect human health. Toxic chemicals in food can potential chemical hazards that can arise at different stages of be environmental contaminants, natural toxins, allergens, the food production chain. mycotoxins, pesticide residues, veterinary drugs and feed additives, intentional food additives, substances formed Some common potential chemical hazards in foods are during food processing, substances derived from food contact discussed below: materials and adulterants. Chemical hazards in most foods • Heavy metals: lead, cadmium, arsenic and mercury generally arise at the farm or during slaughter/harvesting, storing and processing. Chemical hazards that arise at the • Antibiotic residues: β-lactam (penicillin, farm level are the most important and most difficult for cephalosporin), aminozid – AG, macrozid, n lincosamid Vietnam Food Safety Risks Management - Challenges and Opportunities Page 51 Figure 8: Potential chemical hazards from farm to fork and chloramphenicol. Vi Thi Thanh Thuy (2011) found hydrocarbons (Tran Thi Tuyet Hanh et al. 2015) relatively high proportions of antibiotic residues in meat • Antimicrobial residues: 5.5% positive for tetracycline products, pig kidney and pig liver samples collected in residues (Duong Van Nhiem 2005). Antimicrobial Thai Nguyen, ranging from 10.2% to 39.7% with an resistance analysis by Chu Van Tuat (2007) in retail pork average of 27.4%. La Van Kinh (2009) reported that chlortetracycline antibiotic was widely used in pig feed sold in Ha Noi found 93% of E. coli isolates were resistant in Binh Duong (53.9% of samples) with an average to at least one of 12 tested antibiotics. Both authors concentration of 140 parts per million (ppm) and the reported an increased content of residues (tetracycline) or highest level was 275 ppm, five to six times higher than antimicrobial resistance (of Escherichia coli isolates) in the recommended level for disease prevention and growth meat from suburban versus urban districts (Duong Van stimulation. Nhiem 2005) or from neighbouring provinces versus Ha Noi (Chu Van Tuat 2007). • Carcinogens (sulphamethazine, oxytetracycline, furazolidone) In addition, a detailed overview of selected chemical hazards • Growth promoters: β-agonists (salbutamol, clenbuterol) in crops and their origins is shown in Table 4. in pork. According to a study in Binh Duong province, 4.61% of pig feed samples were positive for β-agonists In Lam Dong province, 3.07% (534/10999) of vegetable with the concentration ranging from 2.12 to 28.4 parts samples collected from 2012 to 2014 had exceeded the per billion (ppb). The proportion of positive samples in MRLs of pesticides (MARD 2015). A 2012 survey in five farm-mixed feed tended to be higher than that in products provinces by the Department for Plant Protection found that from markets. In this province, 7.5% pork samples were farmers who produced vegetables in a traditional manner positive for β-agonists with the concentration ranging used 48 types of pesticides including nine that were banned from 1.15 to 3.42 ppb (La Van Kinh 2009). (Nereistoxin, Imidaloprid, Fenobucarb, Carbosulfan, Cartap, • Dioxins and other persistent organic pollutants: Profenofos, Acetamiprid, Propiconazole and Isoprothiolane). A study by Tran Thi Tuyet-Hanh et al. (2015) found Farmers applying safe vegetable production procedures also elevated levels of dioxins/furans in potentially high-risk used 48 types of pesticides but only three were banned for local foods in Bien Hoa and Da Nang dioxin hot spots, vegetable production (Cartap, Acetamiprid and Nytenpyram). including free range chicken meat (4.6–95 pg Toxic In general, the compliance of farmers using safe vegetable Equivalent [TEQ] per gram), freshwater fish (14.4–86.6 production procedures was higher than that of farmers using pg TEQ/g), freshwater snails (53.6 pg TEQ/g), free-range traditional methods. For instance, 99.8% of farmers in the duck meat (8.2–19.6 pg TEQ/g), free-range chicken eggs safe vegetable group did not use pesticides before a certain (7.3–29.7 pg TEQ/g), free-range duck eggs (15.7 pg time prior to harvest as compared to 45.5% of farmers in the TEQ/g) and beef (3.8–24.6 pg TEQ/g), which were many traditional group. Data from 2014 showed that 6.2% (22/350) times higher than the standard levels. of vegetable samples had exceeded MRLs of pesticides. • Additives: sodium nitrate, sodium nitrite, potassium Herbs tended to have a higher prevalence of pesticide residues nitrate and potassium nitrite (19%), followed by beans (4.3%) and rau ngot (3%) (MARD • Heterocyclic aromatic amines and polycyclic aromatic 2015). 52 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Table 4: Origins of selected chemical food hazards in vegetables Hazards Causes of contamination Pesticide residues higher than Use of not authorized pesticides by farmers are not permitted the permitted levels (MRLs) Pesticides are of poor quality The isolation time is not followed Misuse of devices, not tested before use Pesticide residues in soil from previous crop season Throwing away or dumping excess pesticides into the soil and water Contamination by lubricants, Use of inappropriate chemicals to clean and disinfect sanitizers and cleaners, Leakage of oil, grease and paint on the equipment in contact with product paints, refrigerants, fertilizers, Use of containers of chemicals, fertilizers and petroleum from the previous season adhesives and plastics Pouring chemicals (lubricants and detergents) near the products and packaging materials Concentrations of heavy metals Continuous use of chemical fertilizers, including manure with high levels of heavy (cadmium, lead, copper and metals mercury) in the products exceed Use of inappropriate manure (containing high concentrations of cadmium and mercury) the allowed maximum Lead pollution from car fumes if the farm is near a highway High levels of heavy metals in water High levels of heavy metals in soil from previous crop or near industrial zones Use of contaminated irrigation water Natural toxins – allergens, Storage condition is not suitable mycotoxins, alkaloids and Prolonged storage in poor conditions resulting in mouldy products enzyme inhibitors Storage of potatoes in the light Allergens Some substances that consumers may be allergic to, such as sulphur dioxide used against grape rot Supplements Colourings for ripe fruits, disinfectants Antimicrobial use and resistance Thu et al. (2012) carried out a point-prevalence study with the use of standard published guidelines to evaluate the Antimicrobial resistance is a multi-dimensional threat to appropriateness of the indications for antibiotic prescriptions. human survival, public health, trade, the economy and A survey of 7571 in-patients in 36 hospitals provided the overall regional and global sustainable development. This is following results. The surgery wards had the highest rate also the case for Vietnam with increasing and uncontrolled of antibiotic prescriptions (93.2%) and medical wards the use of antibiotics in the health system and veterinary lowest (48.2%). Among 5,104 patients using antibiotics, medicine and for growth promotion and disease prevention in three types of antibiotics were most commonly used, agriculture, horticulture, livestock and aquaculture (Newman namely, cephalosporin (70.2%), penicillin (21.6%) and et al. 2016). If no actions are taken to address the global aminoglycosides (18.9%). Additionally, almost one-third antimicrobial resistance threat, it will cost an estimated 10 of the patients (n = 1,573) had an inappropriate indication million lives every year worldwide by 2050, that is, more for prescription. Surprisingly, risk factors associated with than the present annual death toll from cancer. Antimicrobial inappropriate indication for antibiotic prescription were seen resistance not only impacts human health today, but can also in hospitals at the national level, obstetrics and gynaecology lead to serious economic implications such as the loss of departments and even surgical wards. workforce. Emerging resistance in Gram-negative bacteria (extended-spectrum beta-lactamase, Klebsiella pneumoniae High prevalence of antibiotic resistance in commensal carbapenemase, New Delhi Metallo-beta-lactamase-1, OXA- Escherichia coli has been reported by Dyar et al. (2012) in 48-like, Carbapenam-resistant and, very recently, Colistin- a study of children in rural Vietnam. Isolates of E. coli from resistant bacteria) is now posing a serious threat to human faecal samples from 818 children aged 6–60 months in Bavi, and animal health. New antibiotics under development will, which is near Ha Noi, were tested. All the daily antibiotic at least for the time being, not be fully effective against these use data of these children were collected three weeks before ‘superbugs’. sampling and analysis. Numerous antibiotics were found Vietnam Food Safety Risks Management - Challenges and Opportunities Page 53 with high prevalence of resistance: tetracycline (74%), co- trimoxazole (68%), ampicillin (65%), chloramphenicol (40%) and nalidixic acid (27%). Two isolates were resistant to ciprofloxacin and 60% of isolates were resistant to three or more antibiotics. Recent sulphonamide use was associated with co-trimoxazole resistance (Odds Ratio [OR] 3.2, 95% CI 1.8–5.7) and beta-lactam use with ampicillin resistance (OR 1.8, 95% CI 1.3–2.4). Isolates from children aged 6–23 months were more likely to be resistant to ampicillin (OR 1.8, 95% CI 1.3–2.4) and co-trimoxazole (OR 1.5, 95% CI 1.1–2.0). Besides that, there were relationships between geographical areas and tetracycline and ampicillin resistance. In a multi- centre study on antibiotic resistance of Staphylococcus aureus, 235 strains of Staphylococcus aureus isolates were used for the antibiotic resistance surveillance. These isolates were obtained by seven clinical laboratories from a variety A private firm producing probiotics for animal feeds, Photo courtesy of Nguyen Viet Hung/WB of specimens collected from in-patients in seven hospitals in Danang, Cantho and Ho Chi Minh City. A 2010 report titled Situation Analysis, Antibiotic Use and Resistance in Vietnam found that the country had the highest would use 42.2 tons [95% CI = 26.2–58.2] and pig production, prevalence of penicillin-resistant (71.4%) and erythromycin- 981.3 tons per year [95% CI = 616.5–1346.0] giving a total resistant (92.1%) Streptococcus pneumoniae, a very of 1023.5 tons per year [95% CI= 642.8–1404.2] (Carrique- common cause of respiratory infections. Seventy-five per Mas 2015). cent of pneumococci are resistant to three or more classes of antibiotics. During 2000-01, 57% of Haemophilus influenzae, MARD recently issued Circular No. 06/2016 dated 31 May another common respiratory bacterial human pathogen, 2016 on promulgating the list of antibiotic content permissible isolated from children in Ha Noi were resistant to ampicillin. to use in animal feed for the purpose of growth stimulus in A study published in 2009 reported 42% of Gram-negative Vietnam. The circular took effect on 15 July 2016, replacing bacteria were resistant to ceftazidime, 63% to gentamicin and the regulations on antibiotics used in animal feed provided 74% to nalidixic acid in the hospital and the community. in Circular No. 81/2009/TT-BNNPTNT dated 25 December 2009. According to this circular, 15 antibiotics are permitted Antimicrobial resistance is increasing. In the early 1990s for use as growth stimulants in livestock and poultry feeds. In in Ho Chi Minh City, 8% of Pneumococcus isolates were addition, the circular contains some principles that should be resistant to penicillin. By 1999–2000, this had risen to 56%. applied when using these antibiotics in livestock and poultry Similar trends were seen in northern Vietnam (GARP – feeds (MARD 2016). Vietnam National Working Group 2010). A promising innovation to replace antibiotics in feed pre- In animals, the wide use of antibiotics in agriculture (for mixes is the application of live bacterial supplements, example, in feed and as preventive/curative drugs) has also contributed to antimicrobial resistance (Nguyen et al. 2013). referred to as probiotics (Viet 2016). For example, such an Although data on antimicrobial use for livestock are limited, advanced technological solution has been recently developed a first attempt to estimate the overall consumption of in-feed by Biospring Vietnam in conjunction with international antimicrobials in Vietnam found that chicken production research institutions. 54 Page Vietnam Food Safety Risks Management A small-scale - Challenges slaughterhouse and Noi Opportunities in Ha in operation, Photo courtesy of Donald Macrae/WB 4.2.3. Physical hazards small proportion of all foodborne disease. For example, in China, reporting of sporadic foodborne diseases is voluntary Physical hazards in foods are foreign objects from the but not required. A population-based study in Gansu Province environment (for example, soil, stones, sticks, weeds or estimated 30 million cases of acute intestinal illness occur seeds), foreign objects from damaged equipment, buildings each year, requiring 22 million medical consultations and 20 or workshops (for example, glass, wood, metal, plastic, hair million courses of antibiotics. Just 400 cases were sent to the or bones) and foreign objects handled or worn by people (for health reporting system (Sang et al. 2014). example, jewellery, hair clips or pens). On the other hand, in Malaysia, it is a requirement by law to Contamination of food with radioactive substances makes notify all cases of cholera, typhoid, paratyphoid, dysentery it harmful to those who eat it. Radioactive contamination and food poisoning. During 1990–2006, annual notifications of the food chain (animals and plants) and the environment for these diseases ranged from 2,934 to 10,416 cases. In can occur through accidental leaks at radiation research contrast, a community study estimated at least 13 million centres and nuclear power plants or through lapses in food episodes of acute diarrhoea annually, most of which are preservation by irradiation. likely to be the result of these notifiable diseases. The figures indicate that cases of acute diarrhoea in Malaysia are grossly Origins of potential physical hazards in foods under-reported, with less than 0.1% of cases being captured by the national surveillance system annually (Gurpreet et al. • Environmental hazards can be mixed into products during 2011; Ngo Thi Hoa et al. 2011). harvest or post-harvest processing • Unclean harvesting containers, equipment and packaging In Vietnam, the food safety situation remains difficult despite materials; packing and transportation equipment substantial efforts of agencies at different levels. Statistics containing foreign objects show that in 2012, VFA registered 167 outbreaks of food poisoning involving approximately 5,500 infections and 34 • Light bulb breakage above exposed food products during deaths (VFA 2016). In 2013, there were approximately 5,300 packing cases of food poisoning reported and the causes of many of • Damaged equipment, buildings or workshops these were unknown. A summary of the numbers of food poisoning outbreaks from 2006 to 2013 is presented in Table • Careless or untrained workers 5. The MOH reporting system is generally believed to under- 4.3. Foodborne disease report the number of cases of food poisoning outbreaks in outbreaks the country as most of the reported cases come from large catering centres like industrial zones, schools and festive events. Many sporadic cases in the communities have not 4.3.1. Overview of available information been reported and no clinical evidence is found after the fact. Foodborne disease outbreaks appear in official reports and Discussions with officers from MOH assume that the can provide insights into the type of risks present but it must estimated number of food poisoning cases in Vietnam is be kept in mind that reported outbreaks represent only a very highly under-reported. Under-reporting (discrepancy between Table 5: Numbers of food poisoning outbreaks, cases and deaths in Vietnam, 2006 to 2013 Year Outbreaks Cases Deaths Outbreaks with more than 30 cases 2006 165 7,135 57 Na 2007 247 7,329 55 Na 2008 205 7,828 61 Na 2009 152 5,212 35 Na 2010 175 5,664 51 Na 2011 142 4,500 27 Na 2012 167 5,508 34 38 2013 163 5,348 28 39 Source: VFA (2016)/na: not available Vietnam Food Safety Risks Management - Challenges and Opportunities Page 55 reported and estimated cases in the population) is even Data on the number of hospitalizations and deaths represent common in developed countries with an expected stronger the occurrence of serious foodborne illness. Including surveillance system in place, for example, only 1/47 cases gastroenteritis, non-gastroenteritis and sequelae, there of campylobacteriosis and 1/58 cases of salmonellosis are were an estimated annual 31,920 (90% CI: 29,500–35,500) expected to be reported in the European Union (Havelaar et hospitalizations due to foodborne illness and 86 (90% CI: al. 2013). The level of under-reporting differs widely between 70–105) deaths due to foodborne illness in 201015. Therefore, European Union countries with estimated 1/7 for Germany it is largely accepted that in Vietnam the under-reporting of and 1/62 for Poland for Salmonella cases reported annually foodborne diseases is important and perhaps captures only a between 2001 and 2005 (Haagsma et al. 2013). low percentage of what actually happens. Studies from other countries (including the United States During 2014 and 2015, there were almost 370 food poisoning of America, China and Malaysia) also suggest only a small outbreaks in Vietnam involving over 10,000 cases and proportion of foodborne disease is ever recorded as outbreaks, resulting in 66 deaths. In 2014 alone, VFA reported 194 food for example, less than 0.1% of cases being captured by the national surveillance system annually (Gurpreet et al. 2011). poisoning outbreaks involving over 5,000 people, almost In another example from Australia, there were an estimated 4,000 of whom were hospitalized and 43 died. The numbers annual 4.1 million (90% CI: 2.3–6.4 million) cases of of food poisoning outbreaks reported in 2015 were lower than foodborne gastroenteritis acquired in 2010, along with 5,140 those in 2014; however, the numbers of cases and of people (90% CI: 3,530–7,980) cases of non-gastrointestinal illness hospitalized were higher (Table 6). and 35,840 (90% CI: 25,000–54,000) cases of sequelae. Approximately 25% (90% CI: 13%–42%) of the 15.9 million During four years of reporting (2012 to 2015), the highest episodes of gastroenteritis that occurred in Australia arose proportion of foodborne disease outbreaks was traced back from contaminated food. This equates to an average of to micro-organisms (42%), followed by natural toxins (28%) approximately one episode of foodborne gastroenteritis per and chemicals (4%) while for 26% the causal agent remained person every five years. unknown (Table 7). Table 6: Numbers of food poisoning outbreaks, cases, hospitalizations and deaths in Vietnam in 2014 and 2015 2014 2015 Comparison; percentages in parentheses Outbreaks 194 179 -15 (7,7%) Cases 5.203 5.552 +349 (6,7%) Hospitalizations 4.160 5.147 +987 (23,7%) Deaths 43 23 -20 (46,5%) Outbreaks ≥ 30 cases 40 44 +4 (10%) Outbreaks < 30 cases 154 129 -25 (16,2%) Source: VFA (2016) Table 7: Numbers of foodborne disease outbreaks in Vietnam from 2010 to 2015, by cause of outbreak Cause of outbreak 2012 2013 2014 2015 Total Micro-organisms 76 82 72 67 297 Chemicals 12 8 4 3 27 Natural toxins 43 26 65 63 197 Unknown 36 47 53 46 182 Total 167 163 194 179 703 Source: VFA (2016) 15 http://www.health.gov.au/internet/main/publishing.nsf/Content/ E829FA59A59677C0CA257D6A007D2C97/$File/Foodborne- Illness-Australia-circa-2010.pdf 56 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 4.3.2. Commodities, affected groups, Most of the reported food poisoning outbreaks occurred at households (about 60% of outbreaks in 2010-14 and about time and locations 40% in 2013-15). Food poisoning outbreaks at households accounted for 50–65% of all cases of food poisoning Regarding the geographical area of food poisoning outbreaks reported. Collective kitchens (canteens and industrial in 2014 and 2015, the northern mountainous provinces of kitchens) accounted for 10–20% of food poisoning outbreaks. Vietnam accounted for the largest proportion (about 30%). Comparatively fewer reported outbreaks of food poisoning Food poisoning outbreaks in other regions of the country (in many years less than 10%) have been related to the were distributed relatively equally (Table 8). consumption of street foods (Table 9). Table 8: Numbers of foodborne disease outbreaks in Vietnam in 2014 and 2015, by geographical area Geographical area 2014 2015 Comparison Northern mountains 72 56 -16 Red Delta river 27 22 -5 North central 16 19 +3 Central coast 27 18 -9 Highland 14 18 +4 South East 14 20 +6 Mekong Delta river 24 26 +2 Total 194 179 -15 Source: VFA (2016) Table 9: Numbers of foodborne disease outbreaks in Vietnam from 2012 to 2015, by location Location 2012 2013 2014 2015 Household 95 70 106 85 Collective kitchen 24 23 41 41 Restaurant or hotel 10 12 6 8 Event (wedding) 15 30 16 12 Street 3 12 8 12 School 10 7 7 8 Others 10 9 10 13 Total 167 163 194 179 Source: VFA (2016) Vietnam Food Safety Risks Management - Challenges and Opportunities Page 57 The types of food responsible in the food poisoning outbreaks With respect to the reported causes of death due to food were relatively diverse. However, a large proportion of poisoning in 2014 and 2015, natural toxins in seafood (puffer the food poisoning outbreaks were caused by food mixes fish, oysters and sea snails) accounted for about 50% of deaths (about 60%), followed by seafood and mushrooms (about followed by natural toxins in mushrooms (17–30%). Alcohol, 15%). Other food types (meat, milk, cereals and vegetables) chemicals and unspecified causes accounted for a very low accounted for a very small percentage of events (Table 10). proportion of deaths from food poisoning (Table 11). Table 10: Numbers of foodborne disease outbreaks in Vietnam from 2012 to 2015, by food type Food type 2014 2015 Comparison Seafood 28 29 +1 Meat and meat products 13 14 +1 Eggs and egg products 2 2 0 Milk and milk products 2 0 -2 Cereals and cereal products 4 1 -3 Vegetables 3 1 -2 Fruits and fruit products 4 1 -3 Mushrooms 24 26 +2 Wine 4 5 +1 Food mixes 105 94 -11 Unknown/others 3 6 +3 Total 194 179 -15 Source: VFA (2016) Source 11: Numbers of deaths due to foodborne disease outbreaks in Vietnam, by cause of death Cause of death 2014 2015 Comparison (number) Traditional alcohol (high levels of methanol) 3 3 0 Natural toxins in mushrooms 13 4 -9 Natural toxins in toads, puffer fish, oysters, sea snails 22 15 -7 Chemicals 0 0 0 Other/unknown 5 1 -4 Total 43 23 -20 Source: MOH/VFA [no date] 58 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 4.4. Food safety risks and agents (one virus, seven bacteria and three protozoa), seven invasive infectious disease agents (one virus, five bacteria health impact and one protozoon), 10 helminths and three chemicals. Refer to Annex 15 for further details on the specific hazards studied, key findings and study limitations. 4.4.1. WHO 2015 report and other Conclusion from a country perspective (Vietnam) sources on foodborne disease burden • The FERG study provides foodborne disease burden Information on health impacts expressed in burden of estimates on a sub-regional level but not for Vietnam foodborne diseases is incomplete; detailed information is specifically at country level. The closest region would not available or limited to selected developed countries, be Southeast Asia Region B which includes Thailand, for example, the United States of America, Canada and Indonesia and Sri Lanka. Diarrhoeal disease agents the Netherlands (Scallan et al. 2011; Thomas et al. 2013; were a major cause of foodborne disease burden for the Havelaar et al. 2015). To address this gap, an initiative Southeast Asia sub-region. was launched by the WHO Foodborne Disease Burden • Countries aiming to build their national food safety Epidemiology Reference Group (FERG) in 2006. Based strategies are advised to combine global estimates with on almost a decade of work by various experts and expert existing national data. panel groups, the group launched its report in December 2015. Apart from the first ever global estimate of foodborne • There is a strong need for foodborne disease studies diseases, the initiative also aimed to strengthen the capacity including disease burden and source attribution on a of countries to assess foodborne diseases. This resulted in a country level. set of national foodborne disease burden studies for Albania, • Food safety issues, studies and policies should be Japan, Uganda and Thailand. Other objectives included addressed in a holistic or One Health approach. increasing awareness and commitment to meet food safety standards as well as encouraging countries to use foodborne Other burden of disease estimates (partly foodborne) include disease burden estimates for cost effectiveness studies on what has been published by the Global Burden of Diseases potential interventions and control measures. Initiative (Murray 2012), the Institute of Health and Metrics Evaluation and the WHO Mortality and Burden of Disease The approach included comprehensive data collection on Unit. More details on those two estimates are provided in estimates of foodborne diseases through the established FERG Annex 16. and in-depth country studies. More specifically, FERG used a hazard- and incidence-based approach to estimate foodborne diseases. One key challenge was to attribute proportions 4.4.2. Current knowledge on health of disease incidences to a specific foodborne transmission impact of foodborne diseases in route as those transmission routes may differ based on the epidemiology of the disease-causing agents. Source attribution Vietnam is also important for identification of effective interventions. While the latest WHO report provides highlights on health While some studies exist, in particular related to water and impacts of foodborne diseases, mainly at global and regional transmission of diarrhoeal diseases, studies on other potential level, information on the health impact of foodborne diseases transmission routes such as soil or direct contact with animals is rather limited at country level including Vietnam. We or humans are lacking. The report indicates that for most report here information from research conducted in Vietnam countries and at the global level, relevant data to attribute and from the literature on the health impact of foodborne foodborne diseases to major transmission routes do not exist biological, chemical and physical hazards. The round- and concludes that source attribution studies are still lacking table discussion of the World Bank and partners in January and if available, only for a few hazards which are mainly 2016 identified the lack of information on health impacts Salmonella and/or Campylobacter and countries or regions of foodborne diseases as a key point to help prioritize food (Pires et al. 2010; Pires et al. 2012; Painter et al. 2013). safety interventions. To address these challenges and data gaps, FERG used a structured elicitation of scientific judgement which consisted Public health impacts of biological hazards in foods of expert panels combined with various mathematical models. Overall, 72 experts were involved across 115 panels. The impact of biological hazards in foods is important. At Provided estimates of global foodborne disease incidence, global level, the greatest health problem associated with mortality and disease burden were calculated in terms of food is infections which result from food contaminated with Disability Adjusted Life Years (DALYs). bacteria, viruses and parasites. The first ever report of the global burden of foodborne disease recently released by WHO Out of a longer list of potential foodborne hazards, which shows that foodborne disease burden is at the level of the ‘big was reduced for practical reasons, the study finally included three’ (HIV/AIDS, tuberculosis and malaria) (Havelaar et al. 31 foodborne hazards consisting of 11 diarrhoeal disease 2015). The Western Pacific region, which includes Vietnam, Vietnam Food Safety Risks Management - Challenges and Opportunities Page 59 ranks second in the world in terms of foodborne diseases. In administered structured questionnaires in 210 households to this region, at least 50,000 people die from food contamination determine consumption of pork and examine cooking and and more than 125 million people become ill from food each eating habits. A health risk assessment was performed for year (Havelaar et al. 2015). Vietnam should be in the group of four scenarios of cross-contamination of Salmonella spp. countries having a large number of foodborne diseases caused from raw meat to cooked food: via hands, knives, cutting by microbial hazards. In fact, Vietnamese foods have a higher boards and full cross-contamination. Salmonella spp. was prevalence of microbial contamination. detected in 25% (18/72) of pork samples. The concentration of Salmonella spp. varied from 100 to 27,500 per 25 grams For example, retail raw pork in Vietnam is often contaminated of pork (mean: 673 per 25 grams). Pork consumption, a with high levels of foodborne pathogens, including Salmonella component of exposure assessment, was estimated by amount spp. (Botteldoorn et al. 2003; Phan et al. 2005; Ha and Pham and frequency. The mean pork consumption was estimated 2006; Van et al. 2007a), Escherichia coli (Ha and Pham 2006; at 86.1 grams per person per day and the mean frequency of Van et al. 2008), Toxoplasma gondii (Huong and Dubey pork consumption was estimated at 219 days per person per 2007), Taenia spp. (Dorny et al. 2004) and Campylobacter year. The risk of infection with Salmonella spp. ranged from (Ha and Pham 2006). Many isolates of E. coli and Salmonella 2.1×10-4 to 4.9×10-4 by single exposure (per consumption). spp. were found to be resistant to one or more antibiotics The annual risk ranged from 4.3×10-2 to 9.5×10-2. Although (Van et al. 2007a; Van et al. 2007b). Contamination of pork this study considered only one stage of exposure in the by harmful micro-organisms may occur at any stage from ‘farm to fork’ chain, the findings show that this stage is production to consumption. critical and represents a potential health risk for consumers. Appropriate practices for pork preparation and consumption A study using Quantitative Microbial Risk Assessment at the household level need to be targeted as risk management (QMRA) estimated the annual risk of salmonellosis from measures (Toan et al. 2013). eating pork in Hung Yen was 17.7% (90% CI 0.89-45.96) (Dang-Xuan et al. in 2016). Another QMRA assessed the Vietnam’s annual per capita pork consumption in 2015 health risk of pork contaminated with Salmonella spp. in Ha (29.1 kg) is among the highest in the world and pork is Noi by analysing 72 pork samples collected from four formal the most widely consumed meat in the country, making up markets in Long Bien District and a survey consisting of self- 56% of the total meat intake (OECD 2016). Up to 80% of Figure 9: Shigellosis distribution in eight regions in Vietnam every five-year period from 1999 to 2013 Source: Lee et al. (accepted) The boundaries, colors, denominations and other information shown on any map in this work do not imply any judge- ment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. 60 Page Vietnam Food Safety Risks Management - Challenges and Opportunities the pork produced is estimated to come from smallholder Public health impacts of chemical hazards in foods farmers and open wet markets are the preferred channels for purchase among consumers (Lapar and Tiongco 2011). While Chemical hazards in foods present an important public health pork production can support food security and improve the challenge in many countries including Vietnam. Descriptions livelihoods of many smallholder farmers, pork production of the health effects of some groups of chemical hazards are can also have substantial health risks. discussed below. Microbial contamination of vegetables occurs if they are Veterinary drugs are compounds used for prevention and grown from waste water or washed with contaminated treatment of animal diseases and include pharmaceuticals, water (Tram et al. 2008; Kieu Thanh Truc et al. 2014; Tram chemicals, vaccines, hormones, some probiotics and micro- and Dalsgaard 2014). A study of the health risks related to organisms used in veterinary medicine. Antibiotic residues consumption of raw spinach estimated the mean amount in foods of animal origin are an important public health consumed at 40.22 grams per person per meal and the mean concern; they can cause antibiotic resistance in humans, frequency of consumption was 1.39 meals per person per affect the immune and respiratory systems and cause cancers year. The diarrhoea risk associated with E. coli O157:H7 (carcinogens such as sulphamethazine, oxytetracycline when consuming raw water spinach washed three times was and furazolidone), kidney disease (Gentamicin), liver 0.25; the diarrhoea risks due to G. lamblia and C. parvum toxicity, reproductive disorders, bone marrow toxicity were 0 and 0.23, respectively (Kieu Thanh Truc et al. 2014). (chloramphenicol) and allergies (penicillin and tetracycline). According to MOH, 40.6% of foodborne disease outbreaks Food additives are nutritive or non-nutritive ingredients that recorded between 2012 and 2015 were caused by micro- are added to food during processing, handling, packaging or organisms. In addition, more than 50% of deaths from food transportation to maintain or improve the food’s character. poisoning are due to toxins produced in seafood (puffer fish, Sodium and potassium nitrates and nitrites are commonly used oysters and sea snails) and toxic mushrooms (MOH/VFA [no to preserve foods. Nitrite is an important precursor of nitrous date]). Food poisoning outbreaks follow a clear pattern with compounds, which can cause cancer and mutation. Nitrate two peaks, one from April to July and another from September salt in the human body is deoxidized in the stomach and to November. Most of the cases are acute diarrhoea (85%) intestines to produce nitrite which reacts with haemoglobin to and poisoning (15%). The causes of identified food poisoning form methaemoglobin, resulting in reduced oxygen-carrying are mainly microbial pathogens (bacteria, virus and parasites; capacity of haemoglobin. However, consumers may not know about 70%), chemicals (10–50%) and natural toxins. of the damaging effects of these salts if consumed at levels that exceed the permissible standard. Due to the harmful Consumption practices are responsible for a portion of the health effects of nitrates and nitrites, the determination of their foodborne disease incidents. For example, Streptococcus levels in food is necessary to ensure the safety of consumers. suis was found to be the predominant cause of acute bacterial meningitis in adults in Vietnam. This pork-based pathogen β-agonists are a group of chemicals that have been is mainly associated with consumption of particular dishes classified as toxic and though banned worldwide for use in such as tiêt canh, a popular cooked pudding dish containing, livestock production, they have been used extensively in pig among other ingredients, raw blood. Although risks might be production in Vietnam in recent years. Chronic exposure occupational or behaviour-bound, those frequently exposed to salbutamol can cause nervousness, tachycardia, muscle to pork were found to be more susceptible to Streptococcus pain, headache, dyspnoea, hyperglycaemia, hypokalaemia, suis infection (Ngo Thi Hoa et al. 2011). leukocytosis, cramps, nausea, indisposed body, appetite loss and hypertension. MOH has 30 years of data records on infectious diseases including shigellosis. An ongoing study examined the Harmful chemical substances formed in food processing: seasonality, trend and statistics of shigellosis (bacillary Heterocyclic aromatic amines and polycyclic aromatic dysentery) in eight regions in Vietnam. Preliminary results hydrocarbons are formed during cooking of grilled meat show that the central regions (highlands and north/south products. Numerous studies have shown that frying, central coast) show relatively high incidence rates compared baking or smoking of meat results in generation of some to North and South regions (Figure 9). hazardous components including mutagens and carcinogens. Epidemiological studies have also shown that the risks of Episodically, threats to poultry farmers and consumers arise. colorectal, breast, bladder, prostate and pancreas cancers are The H5N1 virus, in other words, the highly pathogenic avian higher in people who regularly consume fried or grilled meat. influenza (HPAI), was indicated to be a cause of the continuous occurring outbreaks in poultry and humans in Vietnam. In Heavy metals in foods can have severe impacts on health. 2007, this was highlighted by a serious epidemic, affecting At elevated concentrations, heavy metals like lead, cadmium, 88 communes within Vietnam. Even though the Government arsenic and mercury can form chronic complexes with of Vietnam has recognized the need for prevention strategies, protein and accumulate until they exceed the threshold of by responding with vaccination programs, a number of toxicity. Consequently, this long-term accumulation of heavy incidences remain (Desvaux et al. 2014). metals can cause numerous severe illnesses such as cancers Vietnam Food Safety Risks Management - Challenges and Opportunities Page 61 and neurological conditions. The increasing concentrations of heavy metals in foods are caused by contamination via 4.5. Key messages from this vegetable growing, animal husbandry, seafood aquaculture, section slaughtering environment or from packaging and other production processes. • Levels of micro-organisms, parasites, pesticides and antibiotic residues in food in Vietnam appear to be much Thus, the main reasons for chemical hazards in foods are higher than those in developed countries. misuse of veterinary drugs, misuse of food additives during processing, poor storage of food products and the method • Various studies indicate that the prevalence of biological of cooking of some animal-source foods. These chemical hazards such as Salmonella in food and pork is substances may lead to dangerous acute poisoning if ingested considerable (30% and 15–69%, respectively). at high levels or chronic effects if ingested over a long time (Andrée et al. 2010; Fahrion et al. 2014; Tran Thi Tuyet Hanh • Majority of biological hazards are related to consumption et al. 2015). of raw/fresh or undercooked products. • The status of antibiotic residues and reported resistance is Public health impacts of physical hazards in foods alarming with an increasing trend over time. Physical hazards in food may negatively affect human health • Consumers can play a key role in reducing exposure to through, for example, broken teeth, bone swallowing, choking, hazards e.g. reducing of risky consumptions habits (eg. damage to mucosa of the mouth, stomach or intestines, and raw blood dish) or improved hygienic measures when lung cancer. Therefore, farmers need to minimize this danger preparing food. during harvesting and post-harvest handling in order to ensure food safety. Radioactive contamination in food has • During 2014 and 2015, there were almost 370 food become a priority issue among consumers in recent years. The poisoning outbreaks in Vietnam involving over 10,000 tsunami in Japan in 2011 is a typical example of this risk. The cases and resulting in 66 deaths. This is almost certainly imported food, called ‘Fukushima food’, met with consumer a large under-estimation. Most outbreaks were caused by resistance. The consumers wanted to trace the origin of the microbial pathogens (42%), followed by natural toxins food to know if it had been imported from the disaster area. (28%) and chemicals (4%); in the remaining 26% of Recently, there were thefts of radioactive sources in Vietnam outbreaks, the cause was unknown. Where a single food from Vung Tau province and Cao Bang province. This also source was implicated, this was most commonly seafood created a risk of radioactive contamination in food. followed by mushrooms and meat. 4.4.3. Gaps: Contamination data • Heavy under-reporting of foodborne disease outbreaks is expected as only a small proportion of foodborne diseases versus health risks is ever recorded as outbreaks due to sporadic food inspection, limited notification of foodborne diseases As mentioned above, there have been several studies on by health professionals (mainly restricted to severe foodborne hazards in Vietnam, covering both chemical and outbreaks) and capacity shortages in particular at district biological contamination of food. However, there are few or commune level. studies on the impact of food contamination on health. This is an important gap that limits the evidence for consumers • Based on discussions with officers from MOH, we can to select safe food and policymakers to take action for assume that the estimated number of food poisoning cases in Vietnam might be 100 times higher than the food safety risk management. The main official data on reported data. health risks come from the MOH reporting system as shown in Section 2.4.2. However, the reporting data largely • The WHO FERG report concludes that data on the health under-estimate what actually happens, and this is even impact of foodborne diseases in Vietnam are not available happening in developed countries. Research data on health at country level. risks related to food safety remain scarce and this will need to be strengthened. For example, Dang-Xuan et al. 2016 estimated that the annual incidence rate of salmonellosis was 17.7% (90% CI: 0.89-45.96), mainly influenced by pork handling practice at the household and prevalence in pork sold in the central market. More studies are needed to provide evidence of health risk and complement data on food contamination. 62 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 5. Food safety risk communication and management: Challenges, confidence, trust and priorities 5.1. Current risk slowly and if we do not eat them, we die immediately”. This attitude, however, has been affected by only a few incidents communication challenges: of unsafe food reported in the newspapers, on television and Facebook, but does not really reflect official assessment of Lack of confidence and trust the food safety situation in the country. Risk assessment of chemical, biological and physical hazards in foods is crucial of consumers to provide scientific information on actual risks and to inform official risk communication activities (Tran Thi Tuyet Hanh As described in the pillar 4 of the WBG toolkit, the role et al. 2016). This helps to bridge divided perceptions between of consumers must be strongly emphasized. Food safety, expert analysis of the risk equation on one hand and public especially regarding chemical hazards, is a growing concern reaction and action on the other. We anticipate that the public for consumers in Vietnam as incidences of unsafe foods and can learn about food safety from a variety of sources, ranging an increasing trend of cancer cases are frequently reported from social networks and television to specific government in the media. For example, a Google search carried out on 5 programs (Hallman et al. 2009). Use of these sources varies April 2016 with the Vietnamese search term “chất cấm trong by consumer circumstances. chăn nuôi heo” (meaning “prohibited veterinary drugs in pork”) resulted in over 526,000 hits within 0.28 seconds (Tran Thi Tuyet Hanh et al. 2016). Consumers have become scared and they panic as they frequently encounter information from 5.2. The phenomenon of food different sources about banned chemicals in foods, such as the scares most recent food safety scandal over β-agonist (salbutamol) and some incidences where environmental police officers and Public concern over food safety is a major problem in itself inspectors investigated and discovered feed companies using and should be treated as a major element in the topic of food salbutamol and other banned chemicals in pig feeds. The safety. Food scares are common in many countries because media brought food safety issues in Vietnam to a high level the public are generally sensitive to what they eat16. They feel of attention when famous people recently died from cancer at vulnerable because they have to eat but largely have to trust a young age. The country’s top leaders also have discussed that what they eat will not poison them. Losing that trust in food safety issues at meetings of the National Assembly . one product can lead to a more general loss of trust in food and so the concern increases. Consumers normally do not think about risk in the same way that experts do. People filter risk information through a variety It is easy for commentators to dismiss food scares as just an of lenses that affect what they hear, how they process and come irrational public reaction to something that has little scientific to understand the information, what they conclude and what justification or statistical significance (“The public has just they actually do. For example, biological hazards in some got it wrong”). But the government still has to respond and foods may cause more morbidity and mortality burdens than its response can make a big difference to the level of concern. chemical hazards, but consumers are usually more concerned It can increase it and there can be occasions when the about chemical hazards as these are commonly mentioned in government’s handling of a crisis then becomes a new issue the media. Therefore, for consumers, risk is highly subjective in itself. In 2008, the Hellenic Food Authority (EFET) over- and in Vietnam in recent years, the public have considered reacted to a food scare involving Ukrainian sunflower oil the risks associated with chemicals hazards in foods to be which damaged the sector and worried the public over claims extremely high. An unofficial statement that is commonly that the oil would cause cancer. The Chairman of EFET was made by people is: “We are dying because of these unsafe forced to resign for the mishandling of the incident. However, foods, but we have no other choice. If we eat them, we die there is still a much wider issue, which is economic. 16 The seminal work on this is: Slovic, P. 1987. Perception of risk. Science 236(4799): 280–285. http://heatherlench.com/wp-content/ uploads/2008/07/slovic.pdf 17 https://www.sott.net/article/157293-Greece-recalls-imported- sunflower-oil-in-contamination-scare Vietnam Food Safety Risks Management - Challenges and Opportunities Page 63 5.3. Economic impact of food 5.4. Strategic response scares The government needs to develop a communications strategy to build consumer trust in government advice on food safety The public are also consumers so their concerns are not issues. A strategic response is needed because perceptions only expressed as public anxiety but as buying choices. The and prejudices need to change and that takes time. The consequences are not just a flurry of media activity but are government cannot switch quickly from one position on food also economic. Consumers will stop buying that product safety to another. The public will not believe it and it will almost immediately. How widely they view the threat will make it all the more difficult to change the message later. affect how drastically they change their buying decisions. If the scare was about a brand or a specific company, it could This is a long-term and slow change but it can be done. The affect all products of that company and not just the one that United Kingdom provides good examples: was central to the incident. A study by ILRI found that when pig diseases were reported by the media, the majority of • On 16 May 199020, the United Kingdom’s Minister for Agriculture fed his daughter a burger at a media consumers stopped eating pork, shifted to chicken or went event to emphasise that the public was in no danger to outlets that were perceived to be safer; in Ha Noi, 35% of from bovine spongiform encephalopathy (BSE) (‘mad consumers stopped eating pork18. cow disease’). This has become a classic example of The economic consequences of consumers deserting a disastrous government messaging, as became clear when market sector can be immediate and sustained long enough the BSE crisis deepened and spread. The damage to the to cause damage. They are also unforeseeable, given that they government’s credibility was so bad that a new food are a response to an incident which itself is unforeseeable. safety agency, the Food Standards Agency, was created Nobody knows where the next food scare will come from, and the agriculture ministry was dissolved into a new therefore, the phenomenon is a risk to all food products. The ministry. Chinese ‘melamine in milk’ scandal is still affecting the dairy • However, the Food Standards Agency was focused sector in China although it occurred in July 2008. The infant wholly on consumers and it gradually gained their trust. formula sector in China has barely revived but the scandal For example, in 2003 it started a campaign against affected more than just infant formula and spread to the whole levels of salt in processed food21 which was followed by dairy sector, by association. The impact was also amplified consumers to the extent that the big food producers had globally through economic effects19. There may also be health to change their approach to salt levels in their processed consequences in the substitution of products, for example, a food products. There were no regulations covering levels switch away from infant formula. of salt in processed food but the Food Standards Agency based its actions on science and took the public with it. When Vietnam is more exposed to international markets under From the fiasco of BSE, the United Kingdom government the Trans-Pacific Partnership (TPP), the European Union had learned the importance of consumer trust and had Vietnam Free Trade Agreement and the ASEAN Economic managed to build it. Community (AEC), domestic food scares may result in trade barriers being imposed by trading partners. This could • When the United Kingdom experienced a nationwide amplify the economic consequences considerably. Under outbreak of foot-and-mouth disease in 2001, millions the SPS Agreement, there needs to be scientific evidence of cattle were culled and burned resulting in damage to support trade barriers but a domestic scare can cause an to the rural economy. In 2007, it experienced another immediate response from trading partners that can have an outbreak of the disease which was contained within a impact even if the barrier has to be removed later. few kilometres and the media coverage reduced rapidly. It used risk communication techniques it developed in It is conceivable that a country can face greater economic the two previous years in dealing with avian influenza impact from the consequences of a food scare than from scares22. days lost through foodborne illness. There are no direct comparative studies and there is not the same consistency to In the short term, government messaging in a food crisis the impact of food scares as the impact of endemic foodborne should avoid strengthening negative perceptions. It would be illness but there are enough examples to show that the effect too early to move straight to positive messages but the first and the handling of food scares should be an integral part of step has to be to avoid making the situation worse. The more the study of food safety (Grace and McDermott 2015). the government’s response reinforces negative messages 18 ILRI. 2010. Demand for pork by Vietnamese consumers: 20 http://news.bbc.co.uk/onthisday/hi/dates/stories/may/16/ Implications for pro-poor livestock policy and development agenda newsid_2913000/2913807.stm in Vietnam. Project brief 1. Nairobi, Kenya: ILRI. 21 http://collections.europarchive.org/tna/20100927130941/http://food. 19 See http://irgc.org/wp-content/uploads/2012/04/Emerging_risks_ gov.uk/healthiereating/salt/ Melamine.pdf for an interesting article on risk amplification in 22 https://www.gov.uk/government/publications/foot-and-mouth- relation to food safety scares. disease-2007-a-review-and-lessons-learned 64 Page Vietnam Food Safety Risks Management - Challenges and Opportunities about the context of the issue, the more difficult it will be • FAO and WHO have worked together on risk to change. These scares usually relate to specific incidents communication since 199826 and have developed training and are not necessarily representative of a wider context of courses in risk communication specifically for food hazard. The government may not want to be positive in any safety27. They have now produced a new joint handbook way about the actual incident but it can try to avoid the effect on risk communication applied to food safety28 which is spreading to the rest of the sector. Reactions such as saying also available in Vietnamese and was used at a training that it will impose harder penalties on food businesses that course organised by WHO in Ha Noi on 12–13 May provide unsafe food damages all food businesses by joining 2016. FAO also organized a training program on risk them in the blame for the one incident and it further reduces communication in May 2015; the report of the same public trust in food. covering the training material is available at http://www. fao.org/3/a-i4850e.pdf 5.5. Techniques of risk • The International Risk Governance Council has pioneered a lot of work on ‘emergent’ risk and in 2010 at a Scientific communication Colloquium hosted by the European Union, the Food Safety Authority presented a study on risk governance of Risk communication is the process of exchange of emergent food safety risks29. information and opinion among risk managers, risk assessors, communicators, researchers and other parties. There needs to There is no shortage of material for training courses on risk be good evidence on which to base future communications in communication for food safety but that is different from order to be trustworthy but being trusted involves other skills preparing a strategic approach for how to move government as well. It is not just about evidence. In addition, interactive messaging from one that reinforces the negative perception of exchanges about consumer understanding and food risks food safety to one that is trusted and can calm concerns. The and benefits can help consumers make informed decisions General Department of Preventive Medicines of Vietnam has (Fischhoff 2009). been applying a strategy for risk communication in relation to emerging diseases since 2013, as part of a three-year strategy. There have been various projects in the past to find a better way of managing a crisis. Both the public and media specialists in Vietnam are important audiences for food safety education and risk • In 2008, the United Kingdom’s Better Regulation communication. Risk communication on food safety issues Commission was re-formed as the Risk and Regulation should be integrated into the recommended risk-based food Advisory Council23, leading an 18-month project to learn safety management system as specified in Vietnam’s Food how to manage ‘public risk’. This term was defined as Safety Law of 2010. “those risks that may affect any part of society and to which the government is expected to respond” which includes food scares. 5.6. Communications strategy • It was succeeded by a more ambitious four-year program under the Government of the Netherlands, the Risk and The communications strategy should also link with an Responsibility Program, which tried to deal with the economic strategy for the role of consumers in strengthening ‘Risk Regulation Reflex’24. Again, it was concerned with markets. The main economic impact of a food scare is the reactions to critical incidents and it developed a toolkit for negative buying decisions made by consumers. The first policymakers and politicians for managing response. Half objective of a strategic approach to the problem is to reduce of the program was focused on this phenomenon at local that impact by having fewer consumers withdrawing their government level and not just at national level. One of its support from part of the market. As mentioned earlier, the first proposals was the use of a ‘concern assessment’25, to run stage is to avoid widening the negative effects from the specific in parallel to a risk assessment, which would analyse the product, brand or establishment to the rest of the sector. If the factors in the public concern. scare is justified, there is no need to defend those responsible for the incident but if the scare is a misunderstanding, it should also be an objective of the strategy to reduce damage in that case also by removing the misunderstanding. 23 http://webarchive.nationalarchives.gov.uk/20100104183913/http:/ 26 http://www.fao.org/docrep/005/x1271e/x1271e00.HTM www.berr.gov.uk/deliverypartners/list/rrac/index.html 27 http://www.fao.org/documents/card/en/c/c8eb9bcd-afb9-47d8-a89f- 24 https://www.government.nl/documents/reports/2015/01/21/ 0297725ea694/ understanding-and-addressing-the-risk-regulation-reflex 28 http://www.auv-ks.net/repository/docs/2016_01_28_141028_Final_ 25 https://www.government.nl/documents/publications/2014/06/19/ version_Handbook_28-11-2014.pdf managing-a-political-crisis-after-a-disaster 29 https://www.efsa.europa.eu/sites/default/files/event/documentset/ colloque101012-ax5.pdf Vietnam Food Safety Risks Management - Challenges and Opportunities Page 65 But the strategy can also move beyond these objectives communication effectively will be a real test of collaborative to developing enough trust with consumers to be able to working and trust between ministries if the government is to guide their buying decisions in positive ways. The example keep pace with fast-moving crises. The rise of social media mentioned earlier of the campaign by the Food Standards has made the pace even harder to manage. Agency against salt levels in processed food was a case of the regulatory agency guiding consumers to demand lower salt There is a saying in crisis management that you should stick content. In Vietnam, as with many other low- and middle- with peacetime practices but do them faster. Having a totally income countries, consumers are reluctant to pay a premium different set of practices for a crisis is artificial and can be for safer food (although they are also angry when the food confusing. Speeding up good normal practice is usually seen as turns out to be unsafe, as in these food scares). The absence the answer. But that means developing good normal practices. of a readiness to pay that premium is a key reason for a lack of It means that information exchange, collaboration and incentive on the part of small-scale producers to adopt better transparency have to become the norm. Risk communication food practices. should be this normal exchange of information and analysis of risks and not reserved to describe crisis techniques. This Indeed, these small-scale producers not only lack incentives is also tested in social media where employees are also to adopt better practices but current consumer behaviour individuals on social media and find it difficult to avoid being also acts as a perverse incentive to adopt or maintain bad dragged into discussions. This endangers a strictly top-down practices, such as accelerating growth or adding colouring. approach to messaging, where there are potentially thousands Many consumers are suspicious of innovative methods in of spokespersons. What this should lead to is internalising the traditional settings, such as metal or ceramic tables in markets good practices in normal work across all the organizations so instead of wood (or even just the ground). If consumers see that the messaging from individuals in a Facebook discussion food business operators wearing a hat or gloves, they often is consistent with the overall approach. Because of the think they are suffering from a medical condition. In many increasing exposure to global markets, it must be recognised hot countries, there is a suspicion of food kept in chilled that the audience for future food scares will be international. compartments. So consumers can also weaken food safety That means being able to communicate in English, with good measures by making it difficult for businesses to adopt better quality websites in English. practices. At present, there are a few strategic decisions being made in The risk communication strategy, therefore, in addition to relation to food safety, with a review of the Food Safety Law, communication within ministries and departments, also a review of the Food Safety Strategy and a proposal for a new needs an element of public education in food safety, hygiene National SPS Action Plan. A risk communications strategy and nutrition issues. Before being able to guide consumers should be added to these activities. The first key decision is towards purchasing decisions that will shape markets for where to locate it. the better, they need to reduce the damage to good practices already being done by consumers. Ultimately, it should be consumers and not enforcement agencies that drive food 5.8. Key messages from this safety. section • Public concern over food safety is a major problem in itself 5.7. Challenges within and should be addressed as a major element in the topic government of food safety through appropriate risk communication (pillar 4 of the WBG toolkit). Another set of behaviours that a risk communication strategy will need to tackle is those of the staff in ministries and • Messages from the government related to food safety risk should be consistent, based on genuine collaboration for other agencies. Above all, messages from ‘government’ communicating in one voice. A communications strategy have to be totally consistent. Any differences will be picked is needed to build consumer trust in government advice up and built on by the media. This means that the current on food safety issues. government bodies will have to have genuine collaboration and coordination to communicate in one voice with all • While this requires a long-term change, in the short term, affected parties during food safety crises so that the public government messaging in a food crisis should avoid and all related stakeholders receive timely, clear and accurate strengthening negative perceptions. information from recognizable sources to avoid unnecessary panic due to miscommunication (Tran Thi Tuyet Hanh et al. • The communications strategy should link with an 2016). There are enough challenges in communicating at economic strategy for the role of consumers in high speed across both horizontal and vertical organizations strengthening markets (instead of weakening them). in order to get the necessary information and evidence about what is really happening in the incident without • The risk communications strategy also needs an element doing it in parallel and even in competition. Managing risk of public education in food safety, hygiene and nutrition 66 Page Vietnam Food Safety Risks Management - Challenges and Opportunities issues. Ultimately, it should be consumers that drive food safety. • It is important to meet the needs of the media. In addition, risk communication messages to the mass media and reporters must be timely and clear to avoid misunderstanding, distrust and miscommunication, which may lead to severe consequences. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 67 68 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 6. Food safety impacts on trade 6.1. Current trade situation Improvements in safety of food intended for domestic markets could be driven by perceptions of higher safety of and long-term trends imported foods and improve the competitiveness of domestic food vis-à-vis imported food. Globally, there has been an increase in world agricultural trade; this is likely to continue. Trade in animal-source foods, produce and processed foods is growing at a faster 6.3. Major food exports rate than for other food, mainly as the result of rapid growth in consumption of these foods, especially in developing Vietnam’s major food exports are seafood, rice, cashew nuts, countries. This in turn is driven by increasing global incomes fruits and vegetables. Cassava exports are substantial—worth and changing dietary preferences (Popkin et al. 2012). 1.1 billion United States dollars (USD) in 2014 and growing in importance—but they are intended for manufacture of Vietnam’s import and export has been growing rapidly since feed and starch rather than for human consumption and thus major economic reforms were launched in 1986. Agricultural will not be discussed in this report. In overall terms, Vietnam products are an important part of exported goods; Vietnam is consistently produces impressively large volumes but low- one of the world’s top exporters of seafood, rice, cashew nuts, value products. It is also facing increasing challenges to coffee and pepper. In 2014, agricultural and aquatic goods sustain and improve competitiveness in an integrated global made up 17.6% of the value of total exports and 11.5% of economy. Across a broad range of commodities, Vietnamese the total value of imports (WTO 2016). Animal feed and feed exporters realize prices ranging from 15% to 50% lower than ingredients are major imports. peers from other countries. Farmers are not fully benefitting from Vietnam’s overall export success due to high production In the agribusiness sector, Vietnam is known for producing costs and low prices and they are very vulnerable to changes large volumes of low-value products. It lacks its own brands in market prices. Finally, increased agricultural exports have and instead provides bulk products which are incorporated come at a cost to the environment due to the extensive use of into other brands. For example, Vietnam is the world’s second natural resources including inefficient water use as well as largest exporter of coffee but Vietnamese coffee brands have over-reliance on fertilizers, chemicals and growth promoters. no international impact. 6.4. Safety of exported food 6.2. Food safety and trade Safety of exported food is verified by importing countries, issues but only a proportion of food is checked. Some countries have higher standards and more rigorous checks than others Food safety has implications for trade and trade has (countries in the European Union are typically more rigorous implications for domestic food safety (see pillar 7 of the than Japan and the United States of America, which in turn WBG toolkit). The implications of trade liberalization on are more rigorous than the Middle East and other Asian food safety are both negative and positive. On the negative countries). A global analysis in 2013 of 3,400 food safety side, increased food trade may introduce new safety hazards, events ranked Vietnam sixth, being responsible for 5% of revive previously controlled risks and spread contaminated events. The top offenders were India, China, Mexico, France food widely (Hawkes et al. 2015). On the positive side, food and the United States of America and the most problematic that is legally imported from high-income countries is usually food was seafood (23%), a major Vietnamese export (Food of high safety levels and may indeed be safer than food sold Safety News 2014). on the domestic markets. In the case of Vietnam, Australia and France are important exporters, often of high-value foods. In the European Union, detailed information is available However, if food is illegally imported it will by definition from reports to the Rapid Alert System for Food and Feed escape rigorous inspection and may be unsafe. For example, (RASFF). A published analysis of food safety notifications there is concern in Vietnam about food imports from China, between 2006 and 2010 found that Vietnam ranked eighth in but little solid data on hazards and risks associated with this the number of food alerts (the top five were China, Turkey, trade. the United States of America, India and Iran, in that order); however, adjusting for the value of food exported, Vietnam Improvements in food safety also have implications for trade. was not in the top 10 (Committee on Strengthening Core Improving export food safety, alongside improvements in Elements of Regulatory Systems in Developing Countries et quality and reputation, could allow Vietnamese products al. 2014). For this report we analysed data from January 2005 to penetrate new and maybe higher-value markets. to April 2016 (Table 12). Vietnam Food Safety Risks Management - Challenges and Opportunities Page 69 As for the other analyses, seafood, fruits and vegetables were in Table 13 (MOHLW 2015). As in the case of exports to the most problematic foods in terms of notifications. Fish and Europe, these are dominated by seafood. fish products are intrinsically prone to contamination and this is augmented by the high levels of chemical contamination Although Vietnam has a better food safety record than some and bacterial loads found in Vietnamese waters (Chea et al. competitors, its food safety performance is worse than that of 2016). most high-income exporters. Poor safety of exported food can act as a barrier to higher value markets and result in exports Detailed records are also available for Japan. These being rejected from markets that are accessed. In addition, cover the number and total weight of food shipments, the foodborne disease can jeopardize established export trade. proportion and weight of shipments that are inspected and the For example, the 1991 cholera outbreak in Peru caused by proportion of these for which violations are found. In terms consumption of water and seafood contaminated by Vibrio of shipments, 25% of exports from Vietnam are checked. cholerae resulted in losses of exports of fish and fish products This is a much higher rate than for shipments from Europe worth over USD 700 million. More recently, in 2005, (7%) or Oceania (4%) but similar to India (17%). Of those malachite green was found in Chinese eels resulting in export checked, 0.43% of Vietnamese shipments were in violation; losses worth at least USD 860 million. In several cases, once this was again higher than for Europe (0.38%) and Oceania trade markets were lost they were never fully regained, even (0.26%) but lower than India (1.15%). The inspection records after safeguards had been put in place to prevent recurrence for commodities exported from Vietnam to Japan are given of food contamination (Grace 2015). Table 12: Value of major food exports from Vietnam to the European Union and number of food safety notifications (2005-15) Billion USD export- Number of RASFF RASFF notifications per billion USD ed in 2014 notifications exported in 2014 Seafood 7,8 608 80 Rice 3,0 5 1,7 Cashew nuts 2,0 9 4,5 Fruits and vegetables 1,5 90 60 Pepper 1,2 33 28 Other 105 Source: European Union RASFF alerts between January 2005 and April 2016 (RASFF 2016) Table 13: Number of shipments from Vietnam to Japan inspected and in violation Number of shipments Number of inspected shipments Number of shipments in violation Frozen fish 6.030 5.665 18 Fresh fish 3.314 2.996 11 Coffee 1.254 87 5 Seasoning 727 30 0 Alcohol 735 33 0 Source: MOHLW (2015) 70 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 6.4.1. Major food safety hazards in 6.4.2. Trends in food safety performance food exported from Vietnam The records from MOHLW in Japan show that while food exports from Vietnam have risen considerably between In food exported from Vietnam to Europe from 2005 to 2016, 2004 and 2014, the proportion of shipments and weight of biological hazards were the hazards most commonly notified food products inspected remains the same. There is a trend and most of these were due to bacteria (Table 14). Next in of decreasing number of shipments found in violation, but importance were alerts over chemicals and antibiotic residues. no marked change in weight of products found in violation. Chemicals are relatively more important in processed foods, The data from RASFF are similar. Despite a strongly rising antibiotic residues in fish, biological hazards in fish and herbs trend in exports, notifications have remained relatively stable and spices, agricultural chemicals in fruits and vegetables, over the last 11 years, indicating that while food safety and mycotoxins in nuts. performance for exported foods is improving, a similar A similar picture emerges for Japan in the 2014 inspection number of violations are detected each year. This finding of records (MOHLW 2015), except that antibiotic residues were stable or decreasing number of notifications and weight of relatively more prominent. There were 28 violations because food in violation implies that export food safety performance of antibiotic residues (all fish), 18 because of microbial is improving (Figures 10 and 11). contamination (15 in fish and three in fruit), five because of decay or mould (all coffee), three because of pesticides (all vegetables), three because of chemicals (two aquatic and one starch), two because of food additives (processed food) and one because of biotoxins (fish). Table 14: Hazards found in food exported from Vietnam to the European Union (2005-15) Number of Type of hazard Main hazards detected alerts Biological 293 Salmonella, Listeria, E. coli Chemical (processing or other) 119 Food colours, polycyclic aromatic hydrocarbons Antibiotic residues 117 Tetracycline, nitrofuran Metals 131 Mercury, cadmium Agricultural chemicals 69 Insecticide, fungicide Bad hygiene/abnormal appearance 54 Spoilage, damage Illegal preservation 54 Carbon monoxide irradiation Biotoxin 37 Histamine Process violation 36 Incorrect certificate labelling Mycotoxins 26 Aflatoxin, ochratoxin Physical hazards 20 Suffocation risk, glass Mould 17 Novel food/genetically modified food 11 Insects 7 Source: European Union RASFF alerts between January 2005 and April 2016 (RASFF 2016) Vietnam Food Safety Risks Management - Challenges and Opportunities Page 71 Figure 10: Number of food safety alerts for food exported from Vietnam to the European Union (2005-15) Source: RASFF 2016 Figure 11 : Food safety violations for food exported from Vietnam to Japan Source: MOHLW 2015 72 Page Vietnam Food Safety Risks Management - Challenges and Opportunities A fish processing factory, Photo courtesy of Donald Macrae/WB A fish processing factory, Photo courtesy of Donald Macrae/WB 6.4.3. Divergence between export and These are not barriers to trade but are justified under the SPS chapters of the free trade agreements domestic food safety For these reasons, if Vietnam is to progress from exporting In general, exported food is probably safer than food in the volume to exporting quality, it needs to build confidence in domestic market. Deficiencies in domestic market food safety export markets that it has an effective food safety control may affect exports in three ways: system. • The new trading environment being created by free trade agreements (see Section 6.7) is likely to be one where While poor food safety in domestic markets is a threat to safety and quality demands ratchet up. As such, perceptions export markets, theoretically, improved food safety for of the domestic food safety system may adversely affect export markets could also benefit domestic markets if higher export. This will be particularly important when there standards for exports catalyse improvements in the domestic are highly publicized scandals about bad food practices industry. However, this is a difficult aim to realize for simple or environmental damage causing food contamination. economic reasons. For example, Vietnam has been successful Already, trade organizations in some countries draw in some specific markets, such as prawns in the Australian attention to food safety issues with imports from Vietnam market, but export markets provide premium prices that (www.shrimpalliance.com). cannot be obtained in the domestic market. Without that • While export chains are to some extent isolated from premium, it is difficult for the practices used for export domestic chains (a two-tier system), it is difficult to avoid products to spill over into production for domestic markets. any spillover. Assuming food safety continues to decrease in domestic markets (as may be the case) while safety This is also the finding from research studies on spillover demands continue to increase for export markets (likely health benefits of participating in export markets in other to be the case), there is increasing risk that hazards from countries. For example, one study in Kenya found that the domestic market may be detected in exports resulting farmers who had been given training in food standards and in bans and reputation loss. monitored for compliance used safer chemicals and had fewer • As markets expand, so do the rewards for shifting to reported health problems. In contrast, a study found that markets of higher value. However, these markets are more workers participating in export seafood chains in Brazil did likely to apply strict testing for food safety and labelling. not receive any health benefits (Unnevehr and Ronchi 2014). Vietnam Food Safety Risks Management - Challenges and Opportunities Page 73 A fish processing factory, Photo courtesy of Donald Macrae/WB 6.5. Major food imports information on the prevalence of hazards in imported feed. If there are no effective controls in place, there is a risk that In Vietnam, food imports are less important than exports. sub-standard feed could be targeted to Vietnam. Most beef and milk are imported, as are temperate fruits such as apples and oranges. Dairy products (worth USD 448 million) and frozen meat (worth USD 141 million) are 6.6. Safety of imported food mainly imported from prospective TPP partners. Vietnam Setting and implementing standards for food imports and also imports unprocessed seafood, pepper and cashew nuts improved agricultural practices in countries may prevent for processing and export. dumping of sub-standard food in developing country markets. Significant quantities of beef, nuts and frozen poultry are Inspection for import and export are discussed in Section exported to Vietnam but much is believed to be trans-shipped 2.4.1. to other countries. For example, poultry from the United States of America faces high tariffs in China stemming from anti- dumping duties while beef products are prohibited because of Box 3: Illegal trade in poultry between BSE. While these products from the United States of America China and Vietnam also face tariffs in Vietnam, they may find market access to China via the border-trade route through Vietnam. Much of By its nature, illegal trade is difficult to study and the global beef exports to Vietnam likely go to China. In one assess, but concerns over avian influenza led to a such example, 40% of India’s beef exports are reported to be relatively robust characterization of poultry trade sent to Vietnam, but the majority of that beef is believed to between China and Vietnam. Each year, hundreds of ultimately end up in China (Arita and Dyke 2014). millions of spent hens and tens of millions of day- Vietnam imported over USD 3 billion worth of animal feed old chicks and ducklings are imported from China. in 2014. Imports include energy sources (corn, wheat and Spent hens are imported because of the higher price tapioca) and protein sources (soybean and fish powder). fetched in Vietnam whereas chicks and ducklings are Imports related to animal feed are growing by 20% per imported because Vietnamese farmers believe they year. Various expert groups have considered hazards in feed have better performance (higher genetic potential). and there is a broad (although not exact) consensus on the Another driver is consumer demand, which at certain contaminants most important to food safety (FAO 2008; times of the year—such as the Têt celebration (Lunar Codex Alimentarius Commission 2013). These include: New Year)—cannot be satisfied by the national • Fungal toxins: aflatoxin and other mycotoxins supply. • Microbiological hazards: Salmonella and Brucella Nguồn: Desvaux et al. (2014) • Persistent organic pollutants: dioxins and organochlorines • Veterinary drug residues: antimicrobials • Heavy metals: lead, cadmium and arsenic The long border with China makes import control challenging and even the border posts are subject to leverage by the Chinese In terms of risks to human health, the most important appear in ways that are not covered by the bilateral agreement, such to be Salmonella, aflatoxins, dioxins and heavy metals, in as leaving perishable products too long in the sun while decreasing order of importance. However, there is little processing paperwork. There are concerns about dumping 74 Page Vietnam Food Safety Risks Management - Challenges and Opportunities of products by China and much of the agri-chemicals that and others by the TPP which includes the United States of have damaged the quality of Vietnamese products have America and 11 other Asia-Pacific partners including Canada, been dumped from China. Other low-income countries that Japan, Australia and New Zealand (but not China). The TPP border China, such as Mongolia and Kyrgyzstan, have similar will create the world’s largest free trade area accounting for experiences and share a widespread perception of imported nearly 40% of global gross domestic product and 25% of Chinese food as being unsafe, yet they continue to buy it global trade (VEPR 2015). Negotiations have been concluded because it is cheap. There is no evidence from any of these and the agreement is awaiting ratification by the parties, with countries that imported Chinese food is generally unsafe, an aim of starting in 2018. Negotiations are also complete on but there is little reliable data on the quantity or quality of the European Union–Vietnam Free Trade Agreement and it is imports. also planned to take effect in 2018. It will eliminate 99% of tariff barriers imposed by the European Union within seven years and Vietnam will similarly eliminate its tariff barriers Implications of imported agricultural within 10 years. inputs for food safety When completed, the TPP would eliminate tariff barriers There is concern over imports of agricultural inputs that may across the parties, which will present Vietnam with both an compromise food safety or create other risks to human health. opportunity and a threat. While Vietnam is expected to be one For example, salbutamol is illegally used to increase the ratio of the largest overall beneficiaries of the proposed agreement, of lean to fat meat in pork. One study found that only 10 kg the gains may be more limited for agriculture (Arita and Dyke out of the total 6,000 kg salbutamol sold in the market in 2014). This important agreement is likely to greatly expand 2015 was for the correct medical purposes while the rest were exports, boosting fish, horticulture and nut exports. presumably sold to be used in pig feeds (Duan and Huong 2016). Because just a few active ingredients of pesticides are However, Vietnam may face competition from imports from produced domestically, most pesticides used in Vietnam are other TPP countries. The production price of meat and milk imported, amounting to around half a billion dollars a year; is higher in Vietnam than in several export-oriented TPP China, Singapore and India are the main suppliers (Pham et countries and Vietnam experts believe that, as a result of trade al. 2011). MOIT estimates around 30–35% of pesticides used agreements, exports of pork and chicken may increase from are imported illegally (Pham Thi Thu Hien 2009). The high the United States of America, Brazil and Canada (current levels of imports are related to high levels of use and this in tariffs are 45% for frozen pork and 40% for frozen chicken) turn to high levels of residues in marketed foods. Whereas while Australia and New Zealand may be competitive for many other countries have greatly reduced pesticide use in beef and dairy products (current tariffs are 7% for frozen the last decades, use in Vietnam remains high (FAOSTAT beef and 10% for milk). Although animal industries depend 2015). According to one source, around 23% of antibiotics on imported feed, import tax is relatively low (around 5%) used in animals are imported; there is little information on so feed costs will not be greatly reduced (Khoi 2016). On the other hand, Vietnam’s domestic livestock industry may the type or quality of imports. However, use of antibiotics benefit from easier access to genetic resources, technologies in livestock and fish production seems to be high in Vietnam and production models as well as increased foreign direct relative to other countries (Van Cuong et al. 2016) and this investment as a result of a generally improved environment may contribute to the high level of antimicrobial-resistant for trade. infections in Vietnam. The combination of AEC, TPP and the European Union– 6.7. Membership in trade Vietnam Free Trade Agreement over the next 10 years will expose Vietnam to far greater competition than at present but agreements will also allow unrestricted access to these important markets. This is not something that happens only at international level Vietnam has been a member of WTO since 2007 and since Vietnam has to bring its regulations in line with those ASEAN since 1995. The ASEAN Food Safety Network was of its partners, including the very stringent European Union established in 2003 to be a channel for ASEAN member food safety regulatory system. These agreements will also states to exchange information relevant to food safety. The limit economic interventions in domestic production systems AEC is intended as a single market within ASEAN and was if they are disguised barriers to trade through preferential launched on 31 December 2015. It is expected to increase treatment. The agreements have some scope for genuine trade and economic growth. geographical differences and it is easy to overstate the extent of the limitations but the government will have slightly less In recent years, Vietnam has pursued free trade agreements room to design interventions to support domestic production. and 16 have been signed between 1995 and 2016 (including ASEAN, ASEAN–China, ASEAN–Japan, ASEAN–Australia Improving food safety standards imposes costs on exporting and New Zealand, ASEAN–India, Vietnam–Japan, Vietnam– firms; in some cases, adoption of standards leads to improved Chile, Vietnam–Laos, Vietnam–Korea and Vietnam– efficiency that can partially offset costs (Unnevehr and Ronchi European Union). Some will be superseded by the new AEC 2014). International trade studies have found evidence that Vietnam Food Safety Risks Management - Challenges and Opportunities Page 75 the fixed costs of meeting standards tend to favour established exporters and lead to a greater reduction in developing- 6.8. Key messages from this country exports relative to those in developed countries (Unnevehr and Ronchi 2014). Participation in export markets section benefits some farmers but many do not benefit and there is • The next 10 years will see a significant increase in a tendency for smaller farmers to drop out, as they lack the competition in global markets. human and financial capital needed to participate in highly demanding markets. In the 2000s, both Kenya and Uganda • Food export is important for the Vietnamese economy and saw major declines (60% and 40%, respectively) in small- there is potential for growth but there are also threats to scale farmers participating in export of fruits and vegetables current exports as meeting importers’ safety and quality to Europe under Global GAP (Graffham et al. 2007). standards will most likely become increasingly important (pillar 7 of the WBG toolkit). To maximize the benefits and minimize the risks associated with a changing trade environment, IFC advises that Vietnam • Food importers face complex and changing regulations, will need to focus on, among others, the following: some related to food safety and quality. • Improving the performance of domestic markets. • Food safety issues are especially salient for aquaculture Strengthening market institutions for a more productive and produce export; the main problems are biological and domestic private sector with stronger linkages to foreign chemical hazards, veterinary drug residues and heavy direct investment. This will include removing unnecessary metals. sector regulations, ensuring a level playing field for all types of businesses regardless of their ownership and • Food safety issues associated with import include not improving regulatory transparency and predictability. only dumping and illegal imports but also the legal import • Promoting and attracting high-value-added and of agricultural inputs which may jeopardize the safety of environmentally sustainable investments, both foreign Vietnamese products. direct investment and domestic investment, which can • Food imports and exports are trending upwards, along help improve food system performance including food with increasing urbanization, which may change diets safety. and domestic markets. • Diversifying into high-value products to increase the range of exports and increasing sustainable productivity • Vietnam food exports need to move from providing and value addition in the agribusiness sector. A key quantity to ensuring product quality. counter to the perceived low value of agricultural outputs is, for instance, a focus on third-party certification and standards work such as the Rainforest Alliance. • Identifying appropriate project interventions with private-sector players to demonstrate the business case for adopting practices that increase quality, safety and sustainability. • Developing strategies to leverage global integration/ trade agreements, including TPP and other free trade agreements, and to monitor their benefits and risks. 76 Page Vietnam Food Safety Risks Management - Challenges and Opportunities 7. Recommendations Given the widespread failure to develop effective, sustainable 3. Significantly improve food safety at facilities for and scalable models of improving food safety in domestic producing and processing food markets, these are strategic directions (‘directions of travel’) 4. Significantly improve food safety at retail rather than firm recommendations for actions that will deliver solutions. It will be important to institute an experimental and 5. Effectively prevent acute food poisoning learning approach to changes in the food system, with frequent assessments of progress and consequent adjustments. The overall recommendation is to develop a risk-based system using the principles of risk assessment, risk The recommendations are also provided keeping in mind two management and risk communication as set out by WHO/ important points: FAO Codex Alimentarius framework and pillar 5 of the WBG toolkit. • Safe food should be delivered by the private sector, whether micro- or large-scale, and by all actors in value Risk assessment is the scientific evaluation of known or chains, from input suppliers and producers to processors potential adverse health effects resulting from human and food distributors, through the use of good practices and exposure to foodborne hazards. Current, credible adapted technologies (pillars 1 and 3 of the WBG toolkit). information on food safety is a prerequisite for risk The mandates of public authorities are to (i) provide an management and communication. Actions to improve risk enabling environment so that safe food can be delivered, assessment could include: entailing proper legislative and policy framework, institutions/incentives to empower the private sector to 1. Strengthen national food safety monitoring and deliver safe food, promoting good practices and offering surveillance: This should cover domestic markets and compliance support and (ii) establish and implement a specifically address the imbalance in surveillance and well-designed and balanced control and enforcement control for export versus domestic market. As efforts system to ensure that food is safe and build confidence in surveillance by different agencies are fragmented among consumers while minimizing undue interference and insufficiently coordinated and integrated, a with market functions; this includes a network of well- comprehensive and joint National Surveillance Plan trained food inspectors; proper, coordinated and science- should be developed, keeping in mind that foodborne and risk-based food safety surveillance plans; recognized diseases are preventable and because prevention starts laboratory networks (public and private) providing timely at the farm, surveillance needs to cover the entire value and quality-assured tests and risk communication capacity chain. and strategies. The recommendations below attempt to address both functions of the public authorities. 2. Improve data management: There is a need to • The current food production system in Vietnam, mainly develop better evidence on risks, impacts, and costs relying on a multiplicity of micro- and small-scale of foodborne disease and the efficacy and cost benefit producers, operators or businesses, makes it challenging of interventions. Evidence from the ministries is still to assure the delivery of safe food in the very short limited and it is advisable to use independent available term. Consolidation of production systems to reduce data, notably from research and academics as well as reliance of the supply chain on micro-producers will from the private sector, in order to help understand and facilitate the process but will take time. However, that manage risks. should not prevent the government and private sector from taking measures immediately. Therefore, these 3. Create a culture of evidence-based decision making: recommendations are structured around interventions that This will require strong leadership and capacity can start immediately and those that must be envisaged in building to build a culture whereby decision makers the medium to long term. proactively seek and use evidence. There is also a need to establish a database system, collection of data from Below are the recommendations. province/district, for the purpose of more effective and The National Strategy for Food Safety sets out five targeted surveillance planning, trace-back and trace- major objectives, with which these recommendations are forward capacity – including investing in technologies aligned: and equipment. 1. Improve knowledge and practice on food safety Risk management is the process of selecting appropriate 2. Strengthen capacity of the food safety management prevention and control options for improving food safety. system It is based on risk assessment. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 77 4. Establish a performance management system: This In addition ‘appropriate’, intermediate technologies should set, implement and monitor delivery of Food (e.g. at slaughterhouse) should be also considered, Safety outcomes by the three ministries. This would as most expensive practices will be more difficult to require jointly agreeing outcomes, plans and targets, maintain. regularly reporting on progress, and adjusting actions in response to information on outcomes. Redirect some 9. Strong consumer preference for fresh animal source of the resource from inspection of imports of product food: Given that preference and that most of consumers from reputable countries and operators to its domestic do not store purchased food for long periods, focus supply. should be placed on identifying technological solutions and management procedures to enable quick and 5. Develop a “farm to fork” food chain approach: efficient tests of fresh products, promoting business This should include inputs, production, transport, models with lean value chains to deliver fresh products processing, retail and waste. This can start with higher within shorted time and awareness raising on end- value “safer and trusted” products building on current consumers and producer groups. initiatives (e.g. LIFSAP, VietGAP, PGS, Fresh Studio “TracePigs”, etc.), with an emphasis on providing 10. Training efforts: Training of actors, e.g. farmers, on incentives for adoption of better practices. good practices and food safety is recommended but noting that evidence has shown this to be most useful 6. Prioritise farm inputs: Misuse and overuse of pesticide when there are clear incentives for changing practices. and antimicrobials is a key concern in Vietnam, and the legislative framework on this remains very permissive. 11. In the long term, the progressive consolidation It is recommended to start immediately developing a of production systems to reduce reliance of the results-oriented, participatory and progressive plan supply chain on micro-producers could facilitate aiming at (i) decreasing the overall use of chemical all interventions listed above. At the same time, inputs in production (notably antibiotics in animal consolidation can also multiply the hazards and spread production), with targets; (ii) removing antibiotic as illness more effectively, and hence requires more growth promoters in animal feed. Innovations, such as careful and effective monitoring than the traditional the recently introduced replacement of antibiotics (e.g. sector. It is also associated with less healthy diets and by probiotic bacteria) could be promising approaches rise in non-communicable disease. The current efforts currently promoted by the private sector, if science- undertaken by the Government of Vietnam to promote based and well documented; (iii) optimizing the use cooperatives, and build their capacity goes in the right of pesticides and antimicrobials at the farm level, direction. However, there are many roads to food using Good practices such as GAP, GAHP, GVP; and safety and innovative approaches based on upgrading (iv) promoting farming systems, other integrated pest value chains, empowering small holders and small- management techniques (IPM), encouraging organic scale retailers, and farmer’s markets should also be production that are resilient to low use of pesticides considered. and antimicrobials. 12. Complement end-product testing with a focus on 7. Improve traceability along the chain: Traceability is an process quality: Testing of products at the downstream essential part of “farm to fork” approaches. Again it end of the food chain is important to ensure consumer’s can start with high-value and high-risk products, e.g. confidence but, alone, will not necessarily deliver safer vegetable, indigenous pork products. The methods, food. Efforts should be refocused towards (i) promoting application, and awareness of all value chain actors on good practices and creating incentives to sustain them, traceability should be adapted to context and expanded (ii) testing at different points of the product chain based gradually. First attempts, already made by some large on risk-based approaches; and (iii) end-products testing or medium scale business in Ho Chi Minh City and only used cautiously and ultimately to check if the food Hanoi, should be monitored in terms of challenges, and safety system is reliable and integrated into the proper lessons learned. food safety National Surveillance Plan mentioned above. At the same time, hazard testing of food is an 8. Align Infrastructure upgrading with practice change: important part of building and maintaining consumer Research and lessons learnt from experience bring trust and providing incentives to the private sector. caution in assuming that provision of upgraded and modern infrastructure will necessarily reduce 13. Develop risk -targeted recommendations: Performance foodborne disease and deliver safer food. Current improvement plans should be developed for major agri- national policy on slaughterhouses network food sectors taking into account their characteristics consolidation and use of Gates Wholesale Markets and risks must prioritize good practices and behaviour change of related actors towards hygienic practices including a. The large-scale private sector has significant incentives rather than focusing on infrastructure only. experience in meeting food safety criteria through 78 Page Vietnam Food Safety Risks Management - Challenges and Opportunities ‘farm-to-fork’ approaches. Efforts should be made consumer trust in government advice on food issues. to leverage the potential of large scale national and While this requires a long term change, in the short foreign companies to contribute to attaining food term, government messaging in a food crisis should safety. This may entail reconsidering the current avoid strengthening negative perceptions. As already legal framework (through Circulars) limiting mentioned above there is a need for good evidence on foreign companies to link directly with producers. which to base future communications in order to be However, careful monitoring is required to ensure trustworthy. The communications strategy should link the benefits of this do not exceed the costs, with an economic strategy for the role of consumers including jeopardizing employment and food in strengthening markets (instead of weakening them). security benefits of the small-scale private sector. Consumer education and awareness also needs to be imparted so that they are aware of food safety practices b. Trade and export: Vietnam has been very successful at the consumer end but also better understand common in exporting food products but these products risk. predominately pertain to low risk commodities. Expanding its export portfolio to include more 15. The communication strategy’s development will require high quality, branded products alongside the a mix of international expertise and local knowledge mainly lower value and undifferentiated products about the Vietnamese context. It should have the which currently dominate exports could increase following key features: foreign earnings and decrease the risk inherent in a narrow portfolio. This needs to be aligned with not a. It should use means, instruments and channels only effective food safety systems but with visibly adapted to the targeted beneficiaries and that safe systems that start to build more international are mostly country-specific. For instance, in confidence in Vietnamese food products. Vietnam, the role of social media and web-based communication is fast growing and therefore may c. Address the informal sector context: Seek to be a good medium to use (i.e. the MoH website has upgrade rather than replace the informal food sector. specific pages on Food Safety, FAQ sections, use of Consider other models e.g. the farmer’s market Facebook and other social media, etc.). approach rather than the supermarket approach and pilot these. Some approaches may be better suited b. It should cover, and set the framework for, the three to large scale farms but given the predominance of following aspects: (i) day-to-day communication small producers and the importance to livelihoods aimed at rebuilding enough trust with consumers and nutrition in Vietnam, it is also important to to be able to guide their buying decisions in develop “light” approaches suited to small farmers positive ways (see Chapter 5.6 for more details and processors. In particular approaches that and examples); (ii) guide reactions and responses are based on working with the existing situation for regular food safety criticisms/issues that are and gradually improving it, have shown success. sometimes biased and not necessarily documented Continue to develop interventions but place more and/or backed with evidence, to re-establish emphasis on understanding what works and what the truth; and (iii) crisis communication when doesn’t such as develop lighter approaches to GAP legitimate food safety issues arise that does not which may have greater uptake. . hide facts, nor defend those responsible for the incident, but highlight the actions being taken by Risk communication is the interactive exchange of the Government and other stakeholders, including information and opinions among risk assessors, risk all the efforts undertaken to mitigate the event’s managers, consumers, industry, the academic community impacts (including allaying the public concerns). and other interested parties, including the explanation of risk assessment findings and the basis of risk management c. It should increase the Government and other decisions. Actions to improve risk communication include. stakeholders’ preparedness with pre-designed protocols and procedures that will increase 14. Improve risk communication: To address public responsiveness, and ensure that they are country- concerns over food safety and the problem that risk specific and adaptable to the Vietnamese context. perception is often not well aligned with reality there is an imminent need to educate the public and decision 16. Use successful examples to motivate change: Vietnam makers not only on risks but on the psychology of risk food exports are rapidly growing as the result of uptake perception which means they are often worrying about of general modern processing. These follow GMP, the wrong thing. This should include that messages HACCP, ISO and other standard processes. Despite from the “government” related to food safety risks existing challenges for some commodities in meeting have to be consistent based on genuine collaboration international standards there are also successful and coordination. To support this the government examples (e.g. 95% compliance for prawns exported to needs to develop a communication strategy to build Australia). Over time, compliance has improved. Efforts Vietnam Food Safety Risks Management - Challenges and Opportunities Page 79 should be made to replicate these also domestically. Committee and works as “coordinator” for food safety The recent decision to give authority to NAFIQAD in the city, it would be important to establish a strong to scale up its residue monitoring system to pork and monitoring and evaluation system of this pilot. It will poultry value chains is a good first step. Leveraging be crucial to learn from this experience to assess the on private sector initiatives to improve food safety and pros, cons, and unexpected bottlenecks and analyse its government giving better and formalized recognition suitability and replicability in the Vietnamese context. to such controls by private sector should be further Indeed, as demonstrated in the Module 4 of the WBG promoted (eg. TracePig by Fresh Studio and De Heus Food Safety Toolkit30 (and Table 15 below) there is LLC, VinGroups and other large Vietnamese Groups no “perfect” institutional structure and the decision investing in agriculture). to go for single versus multiple agencies (both having several “sub-models”) will notably depend on (i) Optimising risk assessment, risk management and risk capacities of agencies (level of expertise, number of communication can be facilitated by building capacity staff, equipment), (ii) constitutional organization of and improving co-ordination between actors. This may be the country, (iii) level of decentralization, (iv) number facilitated by the following actions: of premises to be inspected, and (v) the level of development of the food safety system overall. 17. Build capacity in risk-based approaches including risk assessment, risk profiling and risk categorization to 19. Improve networking, consensus building and ensure that limited resources are used most effectively consistency among institutions, relevant authorities and for monitoring and control of foodborne disease. labs, in particular when attached to different Ministries, The capacity in risk assessment is spread across as well as strengthening the sampling capacity of lab universities, research institutes, ministries (MOH, personnel. Build capacity in diagnostics, and laboratory MARD, MONRE), CODEX. Training has been carried quality assurance, harmonization of standards and out with international assistance. However, more focus approaches among food testing labs and surveillance must be put on systematic application of a risk-based system (national and regional). approach to food safety in which the private sector should take a leading role – while the Government 20. Develop inter-connected food safety strategy and SPS keeps its core function of regulating and enforcing action plans: Begin a phased process by which to the legal framework given the insufficient capacity, facilitate and ensure that the Food Safety Strategy and resources and enabling environment for successful the SPS National Action Plan are closely coordinated application. and aligned. Given that the coordinating ministries are different, these two strategic documents must be 18. Institutional re-arrangement: Although undertaking a written / updated synergistically to ensure that the major reform of the legal and regulatory framework is proposed objectives, results and interventions are well not considered to be an urgent priority, it is recommended aligned and complementary. to continue to identify mechanisms by which to enhance implementation arrangements and overall 21. Strengthen the implementation of food safety regulations coordination to ensure greater food safety outcomes. and give more responsibility to food producers and In light of the decision by HCMC municipality to retailers.. It is important to shift from a system where move forward with piloting a “Board” constituted by government has responsibility for food safety towards some fulltime staff from DOH, DARD, DOIT, among a system where the private sector is empowered and others, and that reports to the Chairman of the People’s takes greater responsibility. 30 https://openknowledge.worldbank.org/bitstream/ handle/10986/25204/911840WP0Box380od0Safety0Toolkit0IC. pdf?sequence=1&isAllowed=y 80 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Table 15: Roles and responsibilities of “food safety” institutional structure and comparison with Vietnam’s case Type of Reform Examples Vietnam’s Progress 1 Streamlining Creating a lead agency for Food Safety is the In Vietnam, institutional responsibilities for administrative most common model and it comes in different food safety controls are divided between structures variations. However, many countries fail to three ministries. While majority of OECD integrate at levels below national (e.g. UK). countries maintain several agencies in charge of food safety, the trend in emerging economies has been to consolidate food safety to one government agency (e.g. China, Kazakhstan). This reflects the desire to reduce barriers for collaboration between multiple agencies. Through such consolidation, governments expect to reduce institutional battles for spheres of influence. The other scenario in many countries is sharing of responsibilities on food safety control between ministries but with greater focus on strengthening the coordination mechanism with a view to developing a comprehensive food control system rather than independent systems within ministries (e.g. Philippines, Thailand and Mongolia). 2 Coordination Coordination can be an alternative to creating In Vietnam, the concept of a food safety across a lead agency (e.g. Germany). Nevertheless, commission, namely Inter-sector Steering inspection it is also used to direct collaboration Committee for Food Hygiene and Safety bodies between all major inspection bodies (e.g. (chaired by the Deputy Prime Minister and Dutch Inspection Council and “Domain” co-chaired by the Minister of Health, is system). The UK has a looser system under present at the national level, headed by DPM a special government department, the Better and is being replicated at provincial level Regulation Delivery Office. In China, the in all cities and provinces. The VFA serves concept of a ‘Food Safety Commission’ as de-facto secretary of this commission. is present at all levels from national to However, the coordination may still be a village, and it provides coordination rather challenge as VFA capacity to effectively than direction but engages with local consolidate food safety related issues at communities. Joint inspections between higher level is challenging. relevant agencies are common. 3 Risk profiling Detailed risk criteria developed for both food In Vietnam, a risk-profiling system seems of businesses products and types of business, and then to exist but it is relatively weak and is not combined with compliance record to form applied across the board. The challenge is a risk assessment matrix to allow precise that most of the catering is done through calibration of risk levels presented by any micro-enterprises which are very difficult to company. Some best practice examples can monitor. be found in the Netherlands and UK. The A/B/C/D system in Catering has been in use for many years in China, Singapore, US cities (New York, Las Vegas) but it is based only on the last inspection. China is trying to extend this system to processing level. Vietnam Food Safety Risks Management - Challenges and Opportunities Page 81 Type of Reform Examples Vietnam’s Progress 4 Risk-based Inspections are targeted at High Risk Frequency and order of inspections can planning of businesses and even High Risk is then be determined by business profile but not inspections prioritized individually. Low Risk businesses prioritized within each category. Frequency are largely ignored. Unplanned inspections of inspection still high and unpredictable. reduced through applying same risk criteria Contrary to good practice, there the system of when responding to complaints. One of inspections is not planned, as demonstrated the best studies of problems of unplanned by a high ratio of unplanned to planned inspections is from Mongolia. inspections. 5 Resource Risk-based targeting allows reduction in Resource constraints are important factor for reduction resources since only a small number of moving to a risk-based inspection system. businesses need to be inspected. Also, There is significant resource constraint in political pressure to reduce the burden NAFIQAD, after decision has been taken to on businesses has driven the reduction in charge it with new responsibilities for pork inspections in many countries. Poland has value chain. shown dramatic results in reduction without losing effectiveness. 6 Application of Regulatory organization is focused on This is at very rudimentary level and at times risk treatment delivering public goods through managing is not observable. strategies risks on behalf of the public. Uses strategies other than enforcement to manage these risks (e.g. compliance assistance, co-regulation, consumer empowerment). The USA, Canada and Australia have good examples of compliance management systems. 7 Performance Regulatory organization has clear strategic Objectives and targets should be set annually management and annual objectives, with specific in terms of inspection, sampling and testing performance indicators linked to risk criteria. plans, rather than outcomes in terms of public These are reflected in performance indicators health results. Performance management at for staff that drive staff behavior in line with individual staff level not known and more the organization’s objectives (e.g. raising research needed. compliance levels rather than imposing penalties). The UK is particularly strong on this approach but Estonia has shown how well it can be applied in recently developed economies. 8 Providing The accepted good practice is whereby Inspectors do not assist businesses through assured advice regulator assist business through advice compliance advice. on request in order to ensure compliance. Can be at inspector level or at corporate level or telephone help line. Best examples in UK and Lithuania. 82 Page Vietnam Food Safety Risks Management - Challenges and Opportunities Type of Reform Examples Vietnam’s Progress 9 Personalized The UK’s “Primary Authority” scheme So far, this model is unique to the UK but is regulation approves a partnership between a regulatory being closely looked at by many countries. body to a large company with many outlets Could have some potential for development and both agree on detailed compliance plans. in Vietnam, especially in the context of large The company ensures compliance with the agri-holdings. detailed plan and all other regulators have to consult its partner before taking action. 10 Export-led Benefits of compliance seen as allowing drive to raise access to new markets, especially foreign standards and markets. Domestic inspection then becomes encourage supportive to help meet foreign standards. compliance Source: IFC, authors Vietnam Food Safety Risks Management - Challenges and Opportunities Page 83 8. 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Annexes Annex 1 Overview of food safety in Vietnam Annex 2 Round-table discussion on food safety risk management in Vietnam and abstracts presented Annex 3 People met during the technical missions Annex 4 Matrix of laws, decrees, circulars and decisions related to food safety Annex 5a Food safety governing system in Vietnam Annex 5b Decentralization of MARD food safety responsibilities through province and district levels Annex 6a Further details on organizational structure of food safety management under MARD Annex 6b Additional material on surveillance and monitoring Annex 7 Further details on inspection for domestic versus import/export market, inspection frequencies and violations Annex 8 Fresh fruits, vegetables and meat inspection model Annex 9 Classification of laboratory testing parameters under MOH in terms of food and technique used Annex 10 Overview of samples analysed by year at NIFC in Ha Noi (2014-15) and IPH in Ho Chi Minh City (2011-15) Annex 11 Laboratory organization beyond MOH Annex 12 Provision of academic training in Vietnam related to food safety Annex 13 Procedure of audit of VietGAP certification Annex 14 Biological food safety hazards in the food chain Annex 15 Food safety hazards included, key messages and limitations of WHO FERG burden of disease estimates from a global perspective Annex 16 Burden of disease estimates (partly foodborne) other than those of WHO FERG Annex 17 Pork and vegetable value chains in Ha Noi and Ho Chi Minh City Annex 18 WBG T&C Food Safety Toolkit: Guiding Principles of Food Safety Reform All the annexes are available at: http://www.worldbank.org/en/country/vietnam/publication/food-safety-risk-management-in- vietnam-challenges-and-opportunities Vietnam Food Safety Risks Management - Challenges and Opportunities Page 89 World Bank Vietnam - Country O ce Contacts Hanoi, +844 3934-6600 8th Floor, 63 Ly Thai To, Hanoi, Vietnam