Introduction: In the new national dairy standard finalized by the Ministry of Health last year, the maximum allowable bacterial count for raw milk was set at 2 million per milliliter, which was blasted as the worst standard in the world. Now, a similar situation is facing consumers, as the new national standard for frozen foods, which is about to be implemented, has relaxed the testing standards for pathogens. What is the reason for this situation? Who is really in charge of setting China's food safety standards?
Who is in charge of formulating China's food safety standards?
The "Measures for the Administration of National Food Safety Standards," passed in September 2010, stipulate that the Ministry of Health is responsible for the development (and revision) of national food safety standards. The Ministry of Health organizes and establishes the National Food Safety Standards Review Committee, which is responsible for reviewing drafts of national food safety standards.
Looking at the list of members of this review committee, among the 14 people holding leadership positions of Deputy Secretary-General or higher, 9 are from the Ministry of Health and its subordinate China Center for Disease Control and Prevention (China CDC), 3 are from the Ministry of Agriculture and the Chinese Academy of Agricultural Sciences, 1 is from the Chinese Academy of Inspection and Quarantine, and 1 is from the Standardization Administration of China.
What stages does the introduction of a food safety standard go through?
The drafting unit of the standard was ultimately not disclosed.
After the "melamine incident," it became a consensus to re-formulate the national dairy safety standard. In December 2008, led by the Ministry of Health, a coordination group was established with the participation of the Ministry of Agriculture, the Standardization Administration of China, the Ministry of Industry and Information Technology, the State Administration for Industry and Commerce, the General Administration of Quality Supervision, Inspection and Quarantine, the State Food and Drug Administration, and other departments, as well as the China CDC, the China Federation of Light Industry, the China Dairy Industry Association, and the China Dairy Association, to integrate and improve the dairy safety standards.
The various departments of the coordination group recommended nearly 70 experts to form an expert group, with Wang Zhutian, Deputy Director of the Institute of Food and Nutrition at the China CDC, as the group leader.
In the "Chinese Journal of Food Hygiene" in April 2010, Wang Zhutian introduced that the coordination group was responsible for deciding on major issues in the work, the expert group was responsible for proposing dairy safety standards, and a secretariat was also established to handle specific organization, coordination, and daily work. It is reported that during this period, nearly 600 person-times participated in the research and discussions of various working groups, drafting groups, and the expert group.
In February 2010, the first National Food Safety Standards Review Committee held meetings of its subcommittees to review the draft national dairy safety standards. After review by the director's meeting, 66 national dairy safety standards were passed. The new national dairy safety standards were approved and published by the Ministry of Health on March 26.
Zeng Shouying, Deputy Director of the Dairy Industry Committee of the China Dairy Association, attended the above-mentioned standard discussion meetings four times. According to his recollection: "The number of participants in the first few meetings was close to 100, with representatives from relevant ministries, dairy associations, well-known dairy companies, universities, and research institutions."
Regarding the proportion of participating representatives, Wei Ronglu, Executive Vice President of the Western Dairy Association and a professor at Southwest University for Nationalities, who attended the discussions three times, had some opinions: "1/3 of the participating representatives came from foreign-invested enterprises."As for the specific drafting units and individuals, in the 2010-published dairy standards such as for raw milk and sterilized milk, as well as in government announcements, there was no specific introduction. However, in the hygienic standards for pasteurized and sterilized milk published by the Ministry of Health and the Standardization Administration of China in 2005, the preface publicly stated that the drafting units were 9 local health and epidemic prevention stations such as Nanjing, Tianjin, and Nanning, and the main drafters were 9 people including Tang Shishu.
Two key standards overturned at the last minute
Recalling the formulation process of the new national dairy standard, Wei Ronglu feels somewhat regretful: "To this day, I still don't understand why some key standards in the draft that was repeatedly discussed were finally overturned?"
Also confused, like Wei Ronglu, is Zeng Shouying, who has worked with milk for nearly 60 years. According to Zeng Shouying, he graduated from Nanjing Agricultural College in the 1950s and worked at the Nanjing Milk and Meat Management Bureau, and later retired from the Nanjing CDC.
In 1962, Zeng Shouying began to participate in the formulation of milk standards. In previous standard formulations, Zeng Shouying had served as the deputy head of the National Milk and Dairy Products Standardization Group of the Ministry of Health.
In May 2009, Zeng Shouying began to get involved in the formulation of the new dairy standard. "The internal draft showed that the first draft of the pasteurized milk standard was drafted by Mengniu Dairy Group, the raw milk standard was drafted by Yili Group, and the yogurt standard was drafted by Bright Group."
He said, "I am not familiar with all aspects of the introduction of the new national dairy standard. I only participated in a few meetings in the mid-to-late stages. In the early stage, enterprises drafted the internal draft, and in the final stage, how it was operated and why the key standards in the draft for review were overturned, I am not clear."
The "key standards" mentioned by the experts above refer to the total bacterial count and protein content, which later attracted widespread public attention.
On August 19, 2009, Wei Ronglu attended the last dairy standard discussion meeting. "The meeting was small, with only about a dozen people. Su Zhi, then Deputy Director of the Supervision Bureau of the Ministry of Health, attended on behalf of the ministry leadership, Wang Zhutian chaired the meeting, and experts such as Zeng Shouying and Gu Jiasheng (former Deputy Secretary-General of the Shanghai Dairy Association) also attended. At this meeting, I did not see representatives from enterprises."
At this meeting, under the strong advocacy of several dairy experts, a consensus was reached on the standards of not more than 500,000 colonies per gram of raw milk and not less than 2.95 grams of protein per 100 grams of raw milk, forming the final draft for review. After this, Zeng, Wei, and Gu were no longer involved in the dairy standardization work.
However, the plan officially announced in March 2010 relaxed the bacterial count to 2 million and lowered the protein to 2.8 grams. As to at which stage the draft for review was changed and why, Wei Ronglu and Zeng Shouying said they were not clear.
After the new national dairy standard was announced, it was blasted by the media and the public: "China's dairy standard has created the worst standard in the world, and the standard formulation has been hijacked by large enterprises."
In interviews, many dairy experts who had participated in the standard formulation discussions chose not to comment: "I have nothing to say now." "What's the use of speaking?" This was their reply to the reporter.
Relevant experts call for the disclosure of meeting minutes
Regarding disputes over food safety standards, dairy is by no means the only one.
Recently, the three major dumpling brands,思念 (Sisi),三全 (Sanquan), and湾仔码头 (Want Want), were all found to contain Staphylococcus aureus. Subsequently, the national food safety standard for frozen flour and rice products was issued, allowing the presence of Staphylococcus aureus. Consumers were confused for a moment: Another standard has been rolled back?
The Ministry of Health came forward to explain that during the formulation of the standard, multiple seminars were held to extensively listen to the opinions of various relevant departments, industry associations, and enterprises, and public comments were solicited on the Ministry of Health's website.
A similar explanation was also given for the national dairy safety standard. This standard had successively "held more than 20 work meetings, solicited public comments on the draft for 60 days, and notified the World Trade Organization. During this period, more than 2,000 feedback comments were received from home and abroad."
However, the explanations from the authorities seem difficult to fundamentally eliminate the doubts of some experts and the public.
As to why the standards for raw milk bacterial count of 500,000 and protein of 2.95 were finally overturned, Wei Ronglu once asked someone to find out. "It is said to be the result of coordination among various ministries, but we don't know how it was coordinated," he said.
An expert who participated in the discussion on the new national dairy standard and did not want to be named said that the Ministry of Health had meeting minutes at the time, including who attended the meeting, what opinions were raised by whom, how the debate went, and the whole process was clear.
"If the organizing party is willing to disclose this information and show the reasons why certain conclusions in the final draft were overturned, as long as it can convince everyone, the voices of doubt will not be so loud," said the expert above.
"A more democratic and transparent process is an important way to eliminate public doubts," said Ying Songnian, President of the Administrative Law Research Society of the China Law Society.
He also pointed out, "Openness and transparency are not omnipotent, and public sentiment is not entirely rational. If in the discussion process, an expert proposes that a certain indicator is harmful, but after a lot of argumentation and research, it is proven to be harmless, and the final standard adopts the relatively scientific opinion. In this case, even if the whole process is transparent, the public may still question: Why not adopt that expert's opinion? Why not adopt a stricter standard?"
Ying Songnian emphasized that experts in the industry are knowledgeable, and the entire standardization process should at least be fully transparent to them. Once they are convinced, they will not produce opinion leaders who oppose it, and the implementation of the new standard will be smoother. If there is a major disagreement between the decision-makers and the experts, a new symposium should be held to avoid the suspicion of "black box operations."