Certain general observations have been made and the following are some of the points made:

• General: "We favour a risk based approach to hygiene controls and their enforcement, and believe such an approach should facilitate significant simplification of hygiene directives and lead to the removal of prescriptive requirements wherever possible. We believe it should be possible to consolidate hygiene legislation into a single instrument, keeping in view that legislation should be shown to be necessary, proportionate to risk and take account of SME interests."

• Scope: "The Guide makes no mention of the interrelationship between the general and the product specific hygiene rules. In order to achieve a successful continuum of legislation from "farm to fork", we would suggest the common provisions be aligned with the general food hygiene directive. This would be more efficient and reassuring for consumers in public health terms because there would be greater transparency, consistency and user-friendliness in the legislation. It would also help industry and enforcement agencies to have a clear understanding of their respective roles in ensuring safe food."

• Own Checks: "We welcome the greater emphasis on own checks, based on the principles of HACCP, which correctly places more responsibility on producers to control and monitor hygiene and safety within establishments. It should therefore be possible to remove some of the more prescriptive requirements in the text, or at least to introduce greater flexibility in the need to follow them absolutely. On this basis, we believe that structural and equipment requirements could be further rationalised.

  "Own checks provisions should be flexibly cast to reflect more closely the Codex approach - which recognises that full documentation may not always be necessary for smaller businesses. Documentation should be available at the time of inspection - there is no need for it to be submitted to the authorities."

• Official Checks: "The greater emphasis on own checks should be accompanied by a reappraisal of inspection procedures. Where risk based control systems are in place the focus of any check should be on the control system. A main purpose of visual or physical examination should be to confirm that critical points have been correctly identified and that controls are in place. We welcome the recognition that the frequency of official checks should be related to risk, and believe that better focused, more risk related enforcement, which takes account of the controls that exist within the establishment, will provide more effective public health protection."

Copies of the complete comments may be obtained from the Ministry.