Name of recommendations: Recommendation on comments construction to theInspection Regulation Draft of "Requirementson food safety for business establishments (specialized) agricultural, forestry and fishery products"

Status: Responded

Recommended by units: TheSupport Center for Small and Medium Enterprises

Official letter: No 0742/PTM - VP, dated: 2019-04-12

Recommended contents:

The Ministry of Agriculture and Rural Development issued an Official Letter No. 310 / QLCL-CL2 dated February 26, 2019 on collecting comments contribution to the National Technical Regulation Draft on "requirment of food safety assurance (food safety)  for business establishments (specialized business) of agricultural, forestry and fishery products ". After studying the draft, the Center recognized that the introduction of national technical regulations on "the requirement of ensuring food safety for business establishments (specialized) of agricultural, forestry and fishery products" was necessary and important for the establishment of processing and processing of agricultural, forestry and fishery products having a basis for comparison and compliance aimed to contribute to providing products and ensured food safety for consumers.

However, in order to create favorable conditions for food processing and processing establishments to understand, grasp and strictly abide by provisions of the technical regulation, the VCCI requested the Drafting Committee to clarify and concretize more regulations defined in the Draft, for example: Section 2.1.1.1: in the draft, the requirement was that "There was a safe distance from the area of ​​risk of pollution": it was recommended to clarify how far the distance was called safe; Section 2.1.2.1: In the draft, the requirement was that "business establishments must have an appropriate area, the business area must be suitable to the scale and type of business": Please clarified. Was the area appropriate or suitable?

These rules were not specific, which may lead to different interpretations. Although there were references in the draft, however, the Drafting Committee should make necessary and specific regulations from those references to directly include them in this Draft to help state management agencies and food processing and processing facilities could have the same reference base for management (for State agencies) and compliance (for preliminary processing and processing facilities).