At the forum on food safety organized by the Cambodia Restaurant Association at the end of July at the Sofitel in Phnom Penh, Mr. Sin Sindeth, Deputy Director of the CCF at the Ministry of Commerce, was the first to open the proceedings after the introductory speech by the association’s President, Mr. Arnaud Darc. A very long speech, during which the Deputy Director addressed several subjects: the objectives of the law, the factors which influenced its creation, controls, the role of the press and the responsibilities of the players in the sector, the government, but also the consumer.
The CCF, formerly known as CAMCONTROL (Cambodia Import-Export and Fraud Repression Directorate-General), has been the Consumer Protection Competition and Fraud Repression Directorate-General since 2020.
Objectives of the law
Mr. Sindeth began by recalling that it had taken six years for the food safety law to be finalized and adopted. The difficulty lay mainly in the fact that a large number of relevant ministries had to examine, discuss and debate the content of this law. In total, it comprises 11 chapters and 43 articles. The aim of this text is to ensure effective application through the participation of several key players: the government, entrepreneurs and restaurant operators, from the producer, collector, manufacturer and transporter-deliverer of foodstuffs right through to the consumer’s table.
“Indeed, when a consumer has a problem with food, such as food poisoning, they must report it to the organization responsible so that the authority can take steps to investigate and ensure that this type of incident does not happen again.” asserts Mr. Sin Sideth.
According to the deputy director, the main aim of the law is therefore twofold. Firstly, to guarantee consumer health and safety. Secondly, to facilitate local trade and the export or import of foodstuffs:
“If we can guarantee total respect for the application of the law, then everything will be safe. And then, you know, for the consumer, if we say the word food or meal, it has no legal connotation.”
“It’s just something you put in your mouth, isn’t it? But in the law, the definition is that food is everything, absolutely everything we consume. In addition, we also have to take into account certain substances, such as chemical additives and preservatives that are added to food to give it more taste, to make it keep longer, to make it look good, to give it a good color, to make it smell attractive,” he explained, adding:
“Another point concerns the definition of food safety. What is food safety? In fact, it refers to the preparation, processing and cooking of food, each stage of which must be free from any risk of contamination.”
“In other words, food must not contain prohibited chemical substances, must not be used more than once, and must not present any physical risk. If we manage to avoid these really dangerous aspects, we can say that food will now be safe for the consumer. The third category is that of commercial players, such as restaurant operators, food producers, animal breeders, collectors, transporters, vendors, restaurants and their staff. They are all subject to inspection by the competent authority. I believe that most of the participants in this forum are considered “food operators”. Your participation is therefore vital for the government to help us guarantee maximum safety, even if we don’t yet dare speak of 100% food safety”, said Mr. Sin Sideth.
The deputy director went on to mention the need for teamwork in law enforcement: “We recognize that human error, poor treatment or bad practice can be at the root of food insecurity. So we must all work together.
“There are three factors that can make food unsafe for consumers. The first is a physical risk. What is a physical risk? It could be any external object or another piece of glass or plastic, a piece of metal or a fish bone or bone that you can physically see, which is a physical hazard that you can see with your own eyes,” he continued, adding:
“It’s also important, even if there isn’t necessarily any danger, that the customer can enjoy the dish and appreciate it, isn’t it? For example, if you’re having dinner or lunch and you chew on a bone or an “object – intruder”, it’s not dangerous for you, but you’re not enjoying your meal. Also, some objects such as small metal fragments can still be found in food. That’s why food production lines are now equipped with metal detectors.
“Secondly, there are restaurants. Hair or insects falling into the food, or flies, are in a way physical risks, but also incidents likely to give a very bad image of the establishment and even the restaurant business in our country. In other developed countries, like Europe, if you find a cockroach in your chicken, your restaurant will be closed for treatment for a week or two”.
“Among the undesirables, we have to mention chemicals. When we use the word ‘chemical’, there are countless substances. We can’t list them all, but we can classify them into three categories. The first is the residual agricultural chemical that remains on food through chemical sprays or pesticides produced by some farmers, which they overuse or use illegally, which is very dangerous. Yes, the laws allow it, but you have to respect the dosage and also take into account the space needed to spray the substance, the number of days before consumption, because you can’t simply spray the substance and have a vegetable ready the next day. There are also what we call heavy metals, i.e. substances affecting vegetables grown on an industrial site, or heavy metals that spill onto the surface of water. Let’s take the example of the Fukushima accident, yes, when the explosion at the nuclear power plant occurred, fish from the region couldn’t be sold because the consumer in Japan is afraid of radiation or being contaminated.”
“And the next problem concerns hormone doping of livestock. In European countries, 25,000 consumers die every year from complications caused by this practice. In addition, certain hormonal substances have been banned. Yes, some of them are authorized by law, but the dosage and safety of use must be taken into account. There are also what we call naturally occurring chemicals, such as certain cashew nuts and other natural nuts, which can be harmful. In Cambodia, a tropical country, some foods, if not stored properly, turn into mushrooms or toxins that are really dangerous and harmful to the liver”.
“And if you can’t store or dry these fruits and vegetables properly, the fungi will grow. That’s why, in our country, we need silos, facilities, safe and long-term storage places. So the farmer or user has to sell his product quickly on the market because he doesn’t have the facilities to store it”.
“In Cambodia, we now have a mechanism for preventing food incidents. Firstly, we consider the human factor. Anyone who processes food, produces it, packages it and introduces dangerous substances or chemicals into it will have problems with the authorities. Secondly, responsibilities are shared. The first party responsible is the Ministry of Agriculture, Fisheries and Forestry, from the stage of primary production, agriculture, breeding, animals, slaughterhouse, etc. The second party is the Ministry of Agriculture, Fisheries and Forestry, from the stage of primary production, agriculture, breeding, animals, slaughterhouse, etc., to the stage of primary production, agriculture, breeding, animals, slaughterhouse, etc. The second part is the Ministry of Industry and Innovation Technologies, which means we have to have hygiene standards. Then, the Ministry of Commerce carries out random checks or market inspections. First of all, we have to identify high-risk, medium-risk and low-risk foods. We focus mainly on high- and medium-risk foods, such as vegetables imported onto the market.
We have a mobile laboratory and use test kits. If we detect a problem, we send the product to a laboratory where it is tested.
We then examine the brand or logo, provenance, packaging and labelling. We also take into account storage conditions. Normally, food on the market is exposed and placed on the ground, which is unhygienic and presents a risk for the consumer, especially during the rainy season.
Then we have the Ministry of Health, which is responsible for inspecting food hygiene, particularly in restaurants, and issues the certificate of conformity, as a grade A, B, C, depending on the restaurant’s compliance and practices. Finally, the Ministry of Tourism issues a license or permit to entrepreneurs, in accordance with the certificate issued by the Ministry of Health. So, the Ministry of Tourism and the Ministry of Health work together in terms of issuing certificates and licenses”.
“So all the responsibilities are divided between the different actors and different parties, but before we can ensure implementation, we first need the law. Each ministry has to develop its own legal instrument, from sub-group to dissemination, like the Ministry of Health, which has its own dissemination on food hygiene and hygienic practices in restaurants. So it’s the responsibility of the Ministry of Health, and the restaurant operator has to comply with it”.
“Yes, it’s true. Sometimes food poisoning is just a small case, just a specific place, but because of certain media that spread the news immediately, without verification and sometimes exaggerated, the public panics.”
“This can be damaging, both locally and abroad, because we also have responsibility in terms of exports. We have to comply with a large number of health regulations, depending on the country. For example, suppose a company wants to export its rice to Europe. We have to comply with European standards and regulations. If we want to export our fish to China, we have to comply with Chinese regulations and legislation. The producer must therefore comply with all requirements, regulations and laws. Each country has different standards, and some apply very strict standards, which makes exporting difficult”.
“Some media are unprofessional and spread an incident without consulting us or interviewing the person in charge of the establishment. Other, more professional media call me and ask about the origin of the food poisoning. I ask them not to spread the news until I have the test results.
Role and responsibility of operators..and consumers
“All operators in the food sector must obtain a license from a specialized authority, such as the Ministry of Health or the Ministry of Tourism. Operators must ensure that the food they sell is safe, hygienic and fit for consumption, and that it complies with Cambodian legislation, regulations and the provisions of the relevant ministry. If food poisoning occurs, we’ll open an investigation. The official will then take a sample of each suspect ingredient or food product. In this way, we take steps to identify only the root cause of the incident. We don’t systematically take immediate action or impose a ban on all products in the restaurant, as it may be an isolated case involving one or more imported products, rather than bad practices”.
“Sometimes the poisoning doesn’t come from the food, but from the consumer, who may have his or her own health problem. In Cambodia, we recognize the difficulty of detecting bacterial poisoning. Our technical resources are currently limited in terms of detection. Only chemicals that we can easily identify, such as wine or methanol poisoning, can be easily identified. For bacterial poisoning, however, it’s still a tedious task for Cambodia.
Consumers therefore also have their share of responsibility and must avoid consuming products which they are aware could cause problems due to allergies or health issues”.