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Food Control 68 (2016) 192e199

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Food Control

journal homepage: www.elsevier .com/locate/ foodcont

Food safety and quality management regulatory systems inAfghanistan: Policy gaps, governance and barriers to success

Sayed Mohammad Naim Khalid *

a r t i c l e i n f o

Article history:Received 21 November 2015Received in revised form8 March 2016Accepted 15 March 2016Available online 21 March 2016

Keywords:Food lawFood safetyFood inspectionFood sectorAfghanistan

E-mail address: sayednaim@outlook.com.* Held the role of Food Technical Advisor between

icine and Food Board, Ministry of Public Health, 10th

http://dx.doi.org/10.1016/j.foodcont.2016.03.0220956-7135/© 2016 Elsevier Ltd. All rights reserved.

a b s t r a c t

Afghanistan has significant competitive advantages in agribusiness. Much has been said about Afgha-nistan's unrealized potential in this sector over the years and many specialists have highlighted chal-lenges in infrastructure, access to finance, and inadequate legislation as barriers to growth in the sector.Many have also pointed to its potential productivity increase as a way to help alleviate food securityissues. With adequate access to finance and infrastructure, Afghanistan should in theory be a topexporting country in all agricultural sectors. The potential also exists for Afghanistan to be a top exporterof high-margin products like fruits, meat, dairy and vegetable processing. In order to realize this po-tential, however, stronger food safety control needs to be in place to export to markets. In Afghanistan,food safety practices are still based on experiences from the late 1970s. Companies face constant pressurefrom the crisis, market competition from importing companies, pricing pressure from retailers, andseemingly endless inspections from government bodies. In fact, there are three main state agencies(Ministry of Public Health, Ministry of Agriculture, Irrigation and Livestock, and Municipalities) thatregularly inspect food companies, often performing the same functions and loading these already cash-strapped enterprises with unneeded administrative burden. There are still important issues to beaddressed within the food safety system of Afghanistan, such as: complete harmonization of legislationwith the regional (legislation and standards mainly), improvement of coordination among authorities;ability to ensure impartiality of inspection work; thorough training of inspectors and implementation ofskills, especially towards risk-based inspection control; reform of sampling schemes for food of non-animal origin and imported food commodities; strengthening surveillance of foodborne diseases, con-trol of adulterated foods; and supporting the introduction of self-inspection systems based on HACCPprinciples and good hygienic practices.

© 2016 Elsevier Ltd. All rights reserved.

1. Introduction

Since 2001, Afghanistan has made many changes in food sectorand food safety inspection: from the no control at border entrypoints to current control mechanism by both Ministry of PublicHealth (MoPH) andMinistry of Agriculture, Irrigation and Livestock(MAIL). The process of negotiations with the World Trade Organi-zation (WTO) has improved coordination between different in-stitutions in the way of more frequent meetings and discussions ofa food safety law. MAIL has responsibility for control of raw foodproducts and MoPH has responsibility for control of processed food(Quraishi et al., 2012; MoPH & MAIL, 2012). The mandate of theMoPH and MAIL in relation to food relates mainly to risk

2013-2015 in National Med-District, Kabul, Afghanistan.

assessment and risk communicationwhich are not well interpretedfrom policy into action. The Public Health law just states that MoPHis responsible for preventive health (MoPH, 2009) which is notfurther interpreted in the policy, strategy and implementing levelclearly.

Food safety is a shared responsibility (Khalid, 2015). Govern-ments establish food safety policies and they put in place andmanage a system of controls that cooperatively aim to assure thatnational food safety goals are met. National food safety regulationsand standards are a fundamental part of the food control system.The modern idea of food control places direct responsibility forensuring the safety of food on all operators in the food chain (CEC,2000). They must be able to demonstrate to regulatory authoritiesthat their operations are in line with national guidelines and codesof practice and that their products meet national standards (WHO,2012). Consumers also play a role in functioning of national systemsof control beyond the actual safe handling of food that they

S.M.N. Khalid / Food Control 68 (2016) 192e199 193

purchase or otherwise obtain: their choices and concerns influencedecisions of government and the food industry (FAO, 2006).

The aim of this study was to understand the different functionsof involved authorities in food sector, understand the current ini-tiatives of private sector in food safety and as a result propose so-lutions to the government on problems in the sectors which willimprove our existing food regulatory system at policy and imple-mentation level.

1.1. Development trend of food sector in Afghanistan

Before 2001, Afghanistan was a country with even not havingaccess to enough food. The regulatory infrastructure was ruinedand the Mullahs were regulating the food sector. After the inter-vention of international society in 2001, the food sector boomedonce again. The exports and imports of food commoditiesincreased. Travels of Afghans and the foreigners into Afghanistantook place. The economy of people was slowly improving. All ofthese resulted in change in the food sector regulatory aspects, tradelegal compliance requirements and consumer awareness aboutwhat to eat and where/how to buy it. Afghanistan started to getmembership of international organizations like World Trade Or-ganization, signed agreements with Food and Agriculture Organi-zation andWorld Health Organization on food affairs. This resulteda change of mind in both policy making people, consumers andsuppliers. In the policy level, MoPH decided to have a food and drugregulatory authority by 2020 (NMFB, 2013; MoPH, 2012) and thereis commitment from the higher officials of government. Along this,traders are getting HACCP, ISO 9001, ISO 22000 and other certifi-cations to comply with the market requirement. The same is theconsumers, who look for label of food products, quality and safety isprioritized now (Khalid, 2012).

2. Methodology

The present study is based on the secondary data published byvarious agencies and organizations, interviews and direct site ob-servations. The visits as tour were planned for 34 locations. Thedifferent locations/institution are categorized into 4 groups. Aseparate questionnaire is developed for each category. The ques-tionnaire was completed by one of the Food Committee memberswhich was finally used for generating the tour report. The mainquestions included (1) who do what in food value chain in terms ofregulations?, (2) what is controlled and what is not controlled infood sector?, (3) what are the duplications of responsibilities? Thetour took 15 working days based on the schedule betweenMayeJuly 2014. The visit from each location resulted into a list ofrecommendation for improvement of practices and at the end allrecommendation were presented to National Medicine and FoodBoard for general action on the policy level. In addition, a technicalworking group assigned by National Medicine and Food Board,worked on SWOT analysis of the sector.

3. Results/findings

As per the scheduled plan the team was supposed to meet 34locations but due to time limit only 28 were visited. During the tour14 government regulatory institutions, 10 private sector companiesand 4 government academic intuitions which are busy in foodscience education directly or indirectly, were visited.

The main findings of the tour are categorized in as follow:

3.1. Findings on regulatory functions

I. Ministry of Agriculture, Irrigation and Livestock - According tothe Memorandum of Understanding (MoU) MAIL is responsiblefor the control of raw food products (MoPH & MAIL, 2012).Though, there is no specific definition for raw product. Becauseon market level vegetables and fruits are not controlled forpesticide residue and other disease (Rahman, 2011). Based onthe discussion with MAIL staff, we found out that there are twomain directorates involved in the food safety affairs, though itwas said that in past MAIL had a quality control directoratewhich is now thrown away from the organizational structureand its functions are divided between Directorate of AnimalHealth and Plant Protection and Quarantine Department.

There are two Directorates involved in Food Safety in MAIL:

A. The Animal Health Directorate - responsible for regulationwithin which the veterinary inspection activities are conductedand control for animal health, safety and hygiene of productionof food of animal origin as well as the disposal of animal by-products is done. Inspection covers border and inland inspec-tion with state veterinary inspectors, border veterinary in-spectors. Almost all provincial agriculture directorates (DAILs)has animal health officer, carrying out the function of inspector.The educational capacity of these people is to be a Doctor ofVeterinary Medicine or technicians in veterinary/livestock pro-duction or management.B. Plant Protection and Quarantine Directorate e in charge ofregulation, and, within it, the Division of Pesticides and Phyto-sanitary Inspections controls plant protection products in pri-mary production and plant health at the border and inland. Theprimary products are to be controlled but the directorate doesn'thave infrastructural, technical and financial capacity to performthe required tests.

II. Ministry of Public Health

A. Environmental Health Directorate is responsible for regula-tion and control of food safety for products of processed food.Control is exercised in production, retail and import. The totalnumber of sanitary inspectors in the country is 53.We found outthat the Preventive Health Directorate stopped this directoratenot to go for inspection to market. The post market surveillanceis now delegated to the Provincial Public Health directorates(Hussaini & Rasooli, 2014; MoPH, 2014a,2014b; MoPH, 2011b;MoPH, 2011a).B. Public Nutrition Department is responsible for dieteticproducts, food fortification, enforcement of fortification regu-lations, and production of fortified foods and market surveil-lance for those foods. In addition, it carry out supplemental foodprograms and other nutrition activities for solving public healthnutrition problems (Aminiee, 2014).C. Quality Control Directorate is responsible for testing thequality of food and medicine. The team found out that bizarreand strange decisions are made there. Food and water areanalyzed by pharmacists. Mostly the tests are by acidity, phys-ical tests, smell, color and some other basic tests. The calibrationsystem is not in place, lab is not certified though it is nationalcentral lab which may function in future to accredit others.Overall, the decision made are compromised. The lab has 7employees and have tested around 800 food samples (Faqiri,2014; Sultani, 2012a, 2012b).D. Health Law Compliance Directorate is responsible forensuringwhether health related laws of MoPH are implemented

TabSum

A

AF

Im

F

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GImPPAPR

FFFF

FF

D

ROBPIr

S.M.N. Khalid / Food Control 68 (2016) 192e199194

well or not (Kamil & Barin, 2014). But there is no clear functionslist or terms of references for them in terms of food. Theyactually go to market and companies and function the same likethe Environmental Health Directorate (Hussaini & Rasooli,2014). The employees who perform this function are eithermedical doctors, pharmacists or nurses (Kamil & Barin, 2014).

III. Municipalities - responsible for regulation and inspection ofwaste (solid and water) (Khalid, 2014a,2014b). In addition, it hasa directorate of Environmental Health which functions the samelike EHD of MoPH. There is no law which clarifies its duties andset a red line between the two. The employees are medicaldoctors (Hussaini & Rasooli, 2014).IV. National Medicine and Food Board and Food Committee. TheNational Board is established based on Article 3 of Medicine Law(MoJ&MoPH, 2006) which is only covering themedicine affairs.But due a request by the Minister of Public Health the food af-fairs are also ad-hocked to it. The board has two committees i.e.food and medicine. The main tasks of the food committee andboard in relation to food is policy level decision making andadvice to the minister of public health. In addition, they providescientific opinion to regulators and the public. Collaborationamong inspection services occurs through their monthlymeetings. The board try to be very transparent and accountablebut sometimes it sticks to the bait of politics and external forceswhich avoid it to be independent (NMFB, 2014; NMFB, 2013).Table 1 presents the summary of the functions of food regula-tory sector (see Tables 2 and 3).

le 1mary of food regulatory functions in Afghanistan.

rea Inspection authority

nimal Health Animal Health Directoood of animal origin If raw Animal Health D

If processed, Food Quaport of animals and food of animal origin If raw Animal Health D

If processed, Food Quaeed stuffs and animal nutrition- import Animal Health Directo

National Environmentaeed stuffs and animal nutrition- production Nonnimal byproducts Animal Health Directoeterinary medicines authorization and distribution Livestock General Direeterinary medicines residues Nonood and Food hygiene If raw MAIL e Plant Pr

If processed MoPH e Eenetically modified organisms No oneport of food of plant origin Plant Protection Direct

lant protection products' authorization and sale Plant Protection Directlant protection products' residues No onenimal welfare No onelant health Small percentage contestaurants, shops Municipalities, Provinc

Environmental HealthSelf-control

ortification/Fortified food Public Nutrition Deparood Regulatory support National Medicine andood trade Ministry of Commerceood wastes By law NEPA, but in pr

EHD of MoPH also playraudulent foods Legally it is not alloweood Additives and contaminants Based on the MoU, Mo

measure the risks fromietary supplements, sea food, wild game, grading of fruits andvegetables and advertising

Not controlled

ole of parliament and senate No clear rolen farm oversight No oneiotechnology and GMO of food No one, no capacity atackaging No one, no capacity atradiation in food No one, no capacity at

3.2. Findings related to food safety

3.2.1. A shortage of food safety knowledgeAll interviews described a lack of knowledge, expertise and

experience. This shortage was identified to be amongst thoseworking in industry in both large and small businesses, as well asamongst inspectors, trainers, consultants and those working ingovernment or equivalent.

3.2.2. A paucity of good advice and guidanceGuidance documents were felt to be too basic and not to address

practical issues. In addition a lack of agreement between auditors,enforcers and consultants was identified as a source of confusion.The literature review identified the provision of internationalguidance for food control and HACCP is aimed at government orequivalent responsible agencies rather than at businesses.

3.2.3. Low levels of basic food hygieneDuring the interviews and the site visits showed to us that low

levels of basic hygiene in some businesses can present a challengeto effective implementation of national food safety strategy. Basicfood hygiene is a prerequisite for food safety and HACCP. PoorHygiene practices are the potential barrier fors effective HACCPimplementation. If those involved in the development and imple-mentation of national food safety policy decisions are aware of lowlevels basic hygiene in industry they can develop national decisionsthat addresses this (Hussaini& Rasooli, 2014; Azizi&Osmani, 2014;Etifaq Biscuits, 2014; Khalid., 2013, 2014a, 2014b; Hussaini &Rasooli, 2014).

rate of MAILirectorate of MAILlity Control Directorate of MoPHirectorate of MAILlity Control Directorate of MoPHrate of MAILl Protection Agency-NEPA

rate, MAILctorate, MAIL

otection Directorate and Livestock General Directoratenvironmental Health Directorate and Quality Control Directorate

orate of MAILorate of MAIL

rol by Plant Protection Directorate of MAILial Health Directorates,Directorate of MoPH

tment, MoPHFood Board, Food Committee, MoPHand Industriesactice Municipality collect them.role, does not have specialists

d but no authority has technical capacity to detect fraudulent food.PH is the lead but there is no technical and institutional capacity to identify/additives and contaminants

this time.this timethis time

Table 2Working principles of food quality assurance certification systems in Afghanistan.

Weakness/threats Strengths/opportunities

Set up a new quality system High cost Developing slowlyInstitutional frame Inefficient capacity High interest from the institutionsConsumer oriented Unknown consumer attitudes Increase in consumer demandsProducer oriented Low interest from producers Food industry is gaining powerAccess period to the WTO Very slow process Adaptation of legislation is sustained

Table 3SWOT analysis of food regulatory sector in Afghanistan.

Strengths� Available organizational structure (NMFB, EHD, QC, HLIED,

VD, PPQD)� Availability of some legislative documents� Policy and strategic guidance.

Weaknesses� Fragmented regulatory structure (overlapping of activities)� No clear division of activities and responsibilities between ministries� Lack of legislative documents (e.g. import regulations, implementation and control regulations)� Wide variations in how legislation is implemented by different agencies/services and in different parts

of the country� Poor coordination and reporting systems� Lack of technical documents (SOPs, procedure, guidelines …)� Lack of proper and sustainable public financial system� Lack of technical HR� Lack of evidence base information� No clear guidelines for accountability and transparency� No appealing system� External stakeholders (consumers, food enterprises) are poorly informed about food law and

regulations� Lack of analytical expertise to assess compliance with available legislation� Low capacity of QC lab in terms of technology and HR� Lack of surveillance system

Opportunities� Availability of ANSA for adopting new standards� Government/stakeholders commitment and willingness� Availability of technical and financial support from donors� Globalization and increase in technical capacity of food HR� Easy access to new information and facilitations of technical

exchanges� Support of government from the private investments� Membership of international societies (WTO, Codex,

INFOSAN, IHR …)� Increasing consumer interest in safety and quality issues

Threats� Open borders (import of low quality products)� Expansion of market and market players� Internal resistance to legislative reform from some parts of the government� Lack of public awareness and commitment� Lack of support in the enforcement of regulations from stakeholders� Lack of support for the government NPPs by donors� Insecure financial support from donors (low sustainability)� Vulnerability of system against corruption� Increase and complexity of levels of adulteration, counterfeiting, falsification in food technologies and

products� Security� Limited confidence of foreign consumers and governments in the safety and quality of food and

produced domestically� Competing development priorities e limited resources from central budget

S.M.N. Khalid / Food Control 68 (2016) 192e199 195

3.2.4. Inaccurate perceptions of the costs/benefits of food safetysystem

It was found out that businesses believe food safety system iscostly, difficult to implement and not actually necessary. It wasrecognized that effort must be made to make food safety systemslike GMP and HACCP acceptable to businesses by better commu-nicating the advantages food safety system implementation maybring.

3.2.5. System on paper but not in practiceIt was emerged that government believes, businesses often have

food safety system on paper but not implemented in practice. Therewas reference to completion of documentation and records tocreate the pretense of a system when in reality it was not used inpractice. The phenomenon of businesses having the system onpaper but not implementing it in practice was linked to lack ofregular and effective enforcement.

It was found in most of the interviews that both governmentsand businesses implement GMP, HACCP, ISO 9001 and ISO 22000primarily to increase trade.

3.2.6. Role of private standards in food safetyPrivate food standards are playing an increasingly important

role in determining market access in international trade (Khalid,2012). The scope and objectives of these standards vary widelyaccording to the nature of the entities developing and adoptingthem: they commonly address food safety, food quality or socialand environmental issues along the production to marketing con-tinuum. Within the 4 private sector food businesses were visited 2of them had ISO 22000:2005, HACCP, ISO 9001 and ISO 14001certification (Azizi & Osmani, 2014). We found out that govern-ment, especially ANSA is not able to accredit any certification body.So generally there is very less understanding of the private stan-dards within government in relation to food safety.

The brief linkage of working principles of food QA certification ispresented in Table 2.

3.2.7. Codex contact point and national codex committeeDuring several meetings held in MoPH with WHO and FAO

representatives, we found out that Afghanistan has not specific CCPand NCC yet. According to WHO representative, there is plan thatAfghanistan will establish its own NCC in the near future. In pastthere were CCP from both MAIL and MoPH who are not now insame positions to represent Afghanistan in Codex meetings.

S.M.N. Khalid / Food Control 68 (2016) 192e199196

3.2.8. Pending food safety lawThe rules governing food safety and quality in international

trade are provided within the SPS and TBT Agreements of theWTO.The SPS agreement, in turn, refers to the standards of the CodexAlimentarius Commission as the benchmarks for food safety ininternational trade and calls for harmonization of national stan-dardswith Codex as an important strategy for facilitating trade. Anyincrease in stringency of official standards as compared with thecorresponding Codex standard must be justified on the basis ofscience. Since Afghanistan is supposed to join WTO, therefore,there is a requirement that Afghanistan must have certain laws inplace, in which food safety law is one. This law is pending due tolack of coordination and influence of involved government officialconcerning their personal interests in the current non legal system.It is in draft since 2009/2010 (Khalid, 2014a,2014b).

3.2.9. Consumers interest in food safety and qualityConsumers are increasingly aware of food and food systems and

their impact on health. They are particularly concerned about foodsafety. Almost everybody in the market speaks of food quality,media, government officials and private sectors are all talking aboutthe quality of imported foods.

3.2.10. Misuse of specific logosDuring the visit we found out the companies are using packages

with logo of Halal, terms of ISO certified, Healthy and so on. So incase of logo of Halal the company was not certified for that and theterms are also not controlled neither by government nor by theprivate sector itself. This actionwas cheating the customers and theproducts were the result of a fake and fraudulent activity (EtifaqBiscuits, 2014).

3.2.11. Product recall and tractability systemDuring the visits from all the 28 intuition, we didn't find out any

data and even knowledge of product recall and traceability system.The private companies were very confidently saying that thereproduct will never be a problem. Just one company had experienceof rejection of its product in Europe due to high level of pesticides.

3.2.12. Data on foodborne illnessesThere is no specific system available neither in MAIL nor in

MoPH to clearly articulate food safety related data i.e. foodborneillness and food recalls (Hussaini & Rasooli, 2014). Though, there isHealth Management Information System (HMIS) in MoPH and asystem in MAIL which record the zoonotic disease.

3.2.13. How are food businesses registered?There is no central register of Food business operators; each

ministry (MoPH, MoCI, MAIL, andMunicipality) has its own register(Hussaini & Rasooli, 2014). Afghanistan maintains no coordinatedcontrol plan or coordinated monitoring plan and inspection is notyet done on a risk basis. According to obligations Afghanistanassumed in the process of membership to theWTO, food safety lawhave to be developed in accordance with SPS requirements in orderto identify the real threats for food safety. Until the new Law onfood safety will be issued, both sanitary and veterinary inspectionswere controlling areas of production of food of animal origin.

3.2.14. What is the frequency of control and its fee?Both ministries have their annual monitoring plan. Inspectors

visit each food business operator at least once a year and there is nofollow up visit for identifying non-compliances with regulations.Inspection visits last from some minutes to some hours, dependingon the type of inspection. Veterinary inspectors are stamping thecarcass of slaughtered animals only if the meat is safe after physical

observation. Coordination between inspections is performedthrough the Food Committee of NMFB, but there is no direct co-ordination especially at the provincial level. The inspections arefinanced from the central budgets. MAIL sets fees for veterinary-sanitary checks, health protection and the issuing of animalhealth certificates. All the money from this income goes to centralaccount of government.

3.2.15. How is quality of imported and domestic productscontrolled?

In ideal situations, one of the roles of the State Inspectorate is tocontrol the performance of inspections according to legal re-quirements and financial output. However, in Afghanistan theaforementioned objective is not obtained. Quality assurance sys-tems in inspections dealing with food safety have to be imple-mented and regularly assessed to obtain the highest level ofobjectivity in inspection work and provide a basis for furtherimprovements.

3.2.16. How is food sampling done?Sampling is performed by veterinary and sanitary inspectors.

Importers pay for the cost of laboratory analysis of samples takenby inspectors in import control. The testing of samples in produc-tion and retail, on the other hand, is paid for by the respectiveministry, with exemptions when samples fail to conform to regu-lations, in which case producers or retailers pay the laboratory fees.Samples tested for purposes of the annual monitoring plan arefinanced from the budget of the ministry (either agriculture orhealth, depending on which took the samples). There is no trans-parency in the system in terms of clearly indicating the totalnumber of food samples. Since Afghanistan is a food importingcountry, there need to be more food samples around the year, butwe found out that MoPH has only 600e700 food samples (Hussaini& Rasooli, 2014; Faqiri, 2014; MoPH, 2013).

3.2.17. What is educational capacity of food inspector and foodsector staff?

In Afghanistan there are two educational institution whichprovide Bachelor level education in food science and technology i.e.Kabul Polytechnic and Nangrahr university. In other universitieswhich teaches agriculture, subjects related to food process, post-harvest operations, cereal processing, food analysis, food hygieneand some other subjects are taught in different departments.Specific food safety education doesn't exist in the country. Tobecome employee of MoPH e EHD, one needs to be a medicaldoctor. Food safety and quality education is not criteria. Food an-alyst are Pharmacists. If you are a food scientist you will not beallowed to work in the MoPH public labs. There are several shortterm courses provided through donor funded activities, whichdoesn't seem to be very effective and sustainable. In MAIL for ani-mal and plant health/safety activities, Bachelor in VeterinaryMedicine and/or Bachelor in Agriculture are required. But generallythere is no analytic and specific food safety and phyto-sanitarytrainings and education.

Knowledge of HACCP is limited. Since it is not a requirement,some companies have HACCP in place through donor supportedactivities but continuously upgrading and maintaining therequirement were lacking.

3.2.18. How transparent is the food regulatory system?There is no annual reporting. The data collected rest with the

relevant department. Annually throughout the country several in-spections take place, seizures, recalls, closure may happen butnothing goes to public. The decision are made in both MAIL andMoPH in hidden the decisions are not declared or put on internet

S.M.N. Khalid / Food Control 68 (2016) 192e199 197

for public. Sometimes, wrong or low quality products are said to bereleased tomarket indicating that, “Not to damage national income,let's allow it for one time” (Khalid, 2015).

3.2.19. Why and what the afghan government must think onprioritizing food safety?

The obvious problem, in relation to this range of activities that inprinciple merit public support, is where to find the resources. Theafghan governments faces numerous demands, and have onlyinadequate capacity to respond. Where does food safety fit inamong the range of concerns? This question can be asked from twostandpoints: food safety as an instrument of public health, and as atool for economic development. In the public health arena, thecriterion for resource allocation is generally one of cost effective-ness e for a given level of resources, how many lives can be saved,or days of illness reduced, by devoting attention to a range ofimportant public health problems. Here, the value of spending onfood safety resources would need to be weighed against that ofprograms to combat diseases such as AIDS and malaria, and otherpublic health problems like water and sewage systems. For eco-nomic development programs, the convention is to consider thereturns to spending among alternative activities i.e. to weigh bothcosts and benefits of different uses of public resources. Here, foodsafety expenditures would be judged in terms of the benefits theygenerate (in terms of keeping markets open or generating newmarkets) per unit of cost, in relation to other economic projectsreceiving public support (export promotion, industrial develop-ment, certain types of infrastructure, etc.). It is easy to see, in thiscontext, why much of the focus in the food safety area has been onthe export-oriented sector. On the one hand, the lack of riskassessment work means that there is little knowledge about thestakes of food safety from a public health perspective inAfghanistan (lives lost, morbidity rates). Meanwhile, it is fairlystraightforward to make some positive assumptions about howimproved food safety will generate benefits for specific exportsectors. If there are positive spillovers to the domestic food supply,this also generates public health benefits.

Let us consider the different arenas in which public support isconsidered crucial. First, it is noteworthy that in the developingcountry context, governments appear to play a critical role inhelping industries e even well-developed ones e to make thetransition to meeting new international standards. A second themeconcerns the interface between the public sector and the public atlarge. If consumers are to be able to play a more effective role inprotecting themselves from foodborne diseases, health education isessential. A third area for public sector action is research. Theresearch needs of Afghanistan in the food safety area are multiple,and cover the entire range of risk assessment and quality assuranceactivities. The fourth and final area where an important publicsector role is stressed, is in the international arena. Afghanistan isnot actively present in the WTO and the international standardsettling bodies like the Codex Alimentarius Commission are unableto support its domestic food industries. As the Boutrif et al. argue,this is a critical area for developing countries, both to help deter-mine the agenda of work done on standards, and to defend theirindustries in the WTO dispute resolution process, once specifictrade problems crop up (Hanak, Boutrif, Fabre, & Pineiro, 2002).

3.2.20. General challenges of the food safety system in Afghanistan

� Inefficient use of state funds and dissipation of resources andloss of focus on control;

� Duplication of functions and lack of coordination among stateagencies involved in control;

� Nonexistence of many labs, as which are incapable of testing upto food safety standards;

� Inability to develop an efficient plan for food safety control thataddresses all problematic issues.

� Lengthy development process and adoption of regulatorydocuments

� In other countries one of the basic principles of food safety isthat the primary responsibility for ensuring compliance withfood law, and in particular the safety of the food, rests with thefood business but in Afghanistan neither the government northe private sector are responsible, because food safety lawdoesn't exist.

� Lack of food safety self-control culture in the whole country� In most food product Afghanistan is only importer and theexporter is just imposing its own requirement therefore, there isless innovation

� Lack of a uniform national program of training food safety in-spectors. At this time medical doctors, stomatologist, pharma-cists and nurses are responsible for food safety which is not theright way of doing food safety practices.

� Lack of co-ordination between different actors in the controlsystems

3.2.21. Challenges in government

� Poor government structure for food control� A lack of effective national food safety strategy� A lack of management commitment at government level� A lack of knowledge, expertise and experience in government� Novel products are not controlled by neither MAIL nor MoPH� Lack of harmonized procedures on how to deal with irregular-ities and infringements as well as penalties and follow upprocedures

� No clear job description of food inspectors for different au-thorities including MAIL, MoPH and Municipalities.

3.2.22. Challenges in industry

� A shortage of HACCP knowledge, expertise and experience inindustry

� A shortage of appropriate and accurate advice and guidance forbusinesses

� Poor levels of basic food hygiene in some businesses� Inaccurate perceptions of the costs and benefits of HACCP� A lack of management commitment in business� A proportion of businesses have HACCP on paper but notimplemented in practice

� Low levels of literacy and use of multiple languages amongstthose working in the food industry

� Poor infrastructure� Government recognize a high proportion of the challengesbusiness experience

3.3. SWOT analysis

SWOT Analysis of the regulatory sector of food affairs is also aresult of continuous work and several meetings of Food Committeeand representatives of WHO, FAO and SPS/MSH.

The detailed SWOT analysis is presented in Table 3.

S.M.N. Khalid / Food Control 68 (2016) 192e199198

4. Recommendations

4.1. General recommendations

1. A single food control agency is the most effective way to delivertransparent, consistent inspections based on food safety andconsumer protection.

2. Training of all inspectors is continuous and in accordance withclearly defined regulations to ensure risk-based inspections atall times

3. A central register of food business operators promotestransparency.

4. Certificates issued by authorities are in accordance with WTOrequirements and internationally accepted practices.

5. Sampling of imported and domestic goods is performed ac-cording to international standards and regulations with defined“triggers”

Recommendation One e Think about consumers first: Thegovernment of Afghanistan should ensure that the needs of con-sumers in relation to food safety. The Government should workwith industry and regulators to:

� Maintain consumer confidence in food;� Prevent contamination, adulteration and false claims aboutfood;

� Make food crime as difficult as possible to commit;� Make consumers aware of food crime, food fraud and its im-plications; and

� Urgently implement an annual targeted testing program basedon horizon scanning and intelligence, data collection and well-structured surveys.

Recommendation Two - Zero Tolerance: Where food fraud orfood crime is concerned, even minor dishonesty must be discour-aged and the response to major dishonesty deliberately punitive.The Government should:

� Encourage the food industry to ask searching questions aboutwhether certain deals are too good to be true;

� Work with industry to ensure that opportunities for food fraud,food crime are proactively controlled

� Support the development of whistleblowing and reporting offood crime;

� Urge industry to adopt incentive mechanisms that rewardresponsible procurement practice;

� Encourage industry to conduct sampling, testing and supervi-sion of food supplies at all stages of the food supply chain;

� Provide guidance on public sector procurement contractsregarding validation and assurance of food supply chains; and

� Encourage the provision of education and advice for regulatorsand industry on the prevention and identification of food crime.

Recommendation Three - Intelligence Gathering: There needs tobe a shared focus by Government and industry on intelligencegathering and sharing. The Government should:

� Work with the EHD and QC directorate (to lead for the Gov-ernment) and regulators to collect, analyze and distribute in-formation and intelligence; and

� Work with the industry to help it establish its own ‘safe haven’to collect, collate, analyze and disseminate information andintelligence.

Recommendation Four - Laboratory Services: Those involved

with audit, inspection and enforcement must have access to resil-ient, sustainable laboratory services that use standardized, vali-dated approaches. The Government should:

� Facilitate work to standardize the approaches used by the lab-oratory community testing for food authenticity;

� Work with interested parties to develop ‘Centers of Excellence’,creating a framework for standardizing authenticity testing;

� Facilitate the development of guidance on surveillance pro-grams to inform national sampling programs;

� Foster partnership working across those public sector organi-zations currently undertaking food surveillance and testingincluding regular comparison and rationalization of foodsurveillance;

� Work in partnership with MoPH and local authorities with theirown laboratories to consider appropriate options for an inte-grated shared scientific service around food standards; and

Recommendation Five - Audit: The value of audit and assuranceregimes must be recognized in identifying the risk of food crime insupply chains. The Government should:

� Support industry development of a modular approach toauditing with specific retailer modules underpinned by a corefood safety and integrity audit to agreed standards and criteria;

� Support the work of standards owners in developing additionalaudit modules for food fraud prevention and detection incor-porating forensic accountancy and mass balance checks;

� Encourage industry to reduce burdens on businesses by carryingout fewer, but more effective audits and by replacing announcedaudits with more comprehensive unannounced audits;

� Encourage third party accreditation bodies undertaking foodsampling to incorporate surveillance sampling in unannouncedaudits to a sampling regime set by the standard holder;

� Work with industry and regulators to develop specialist trainingand advice about critical control points for detecting food fraudor dishonest labeling;

� Encourage industry to recognize the extent of risks of food fraudtaking place in storage facilities and during transport;

� Support development of newaccreditation standards for tradersand brokers that include awareness of food fraud; and

� Work with industry and regulators to introduce anti-fraudauditing measures.

Recommendation 6 - Government Support: Government sup-port for the integrity and assurance of food supply networks shouldbe kept specific, measurable, attainable, realistic and timely(SMART). The Government should:

� Support ANSA, MAIL and MoPH's strategic and coordinatedapproach to food law enforcement delivery, guidance andtraining of local authority enforcement officers;

� Support the relevant authorities to develop a model for co-ordination of high profile investigations and enforcement andfacilitate arrangements to deal effectively with food crime;

� Ensure that research into authenticity testing, associated policydevelopment and operational activities relating to food crimebecomes more cohesive and that these responsibilities areclearly identified, communicated and widely understood by allstakeholders;

� Re-affirm its commitment to strengthen the authorities; and� Engage regularly with authorities at a senior level

Recommendation Seven - Leadership: There is a need for clearleadership and coordination of effective investigations and

S.M.N. Khalid / Food Control 68 (2016) 192e199 199

prosecutions relating to food fraud and food crime; the public in-terest must be recognized by active enforcement and significantpenalties for serious food crimes. The Government should:

� Ensure that food crime is included in the work of the Govern-ment Intelligence Network and involves ANSA, MAIL and MoPHas the lead agency for food crime investigation;

� Support the creation of a new Food Crime Unit hosted by ANSAoperating under carefully defined terms of reference, andreporting to a governance board;

� Support ANSA in taking the lead role on national incidents,reviewing where existing legislative mechanisms exist, whilearrangements are being made to create the Food Crime Unit

Recommendation Eight - Crisis Management:Mechanismsmustbe in place to deal effectively with any serious food safety and/orfood crime incident. The Government should:

� Ensure that all incidents are regarded as a risk to public healthuntil there is evidence to the contrary;

� Urge ANSA and MoPH to discuss with the President Office intheir role as coordinating body for Councils of Ministers in theplanning and organization of responses to incidents;

� Urge ANSA, MoPH and MAIL to implement and put in placecontingency plans at the earliest opportunity; and

� Work closely with ANSA,MAIL, MoCI andMoPH to ensure clarityof roles and responsibilities before another food safety and/orfood crime incident occurs.

5. Conclusion

In order to be able to compete for new food markets and in-crease food safety, the Afghan system of food safety control needsto become more effective and efficient. In other words, it requiressubstantial reform. A clear understanding of who is responsible andhow the country ensures and guarantees food safety is crucial toachieving these goals. Reform of the Afghan system of food safetycontrol, regardless of the chosen direction, requires understandingand clear vision among decision-makers, both regarding thedevelopment of the reform strategy and in its implementation. It isobvious that the transformation of the current system will be acomplicated, demanding and resource-consuming process. That iswhy commitments from government officials, political support andsubstantial preparation are vital. Such reform assumes not onlyinstitutional transformation, but also significant changes to theconcept of control, shifting from focus at the final stage (when theproduct is ready and the only possibility to prevent food accident isits utilization) to a new focus on prevention throughout the entirefood chain. In addition, legislation must be developed, updated andbrought into compliance with international standards.

Acknowledgment

Special thanks to Phar. Wahidullah Karwar, Phar. Basir Ahmad,Phar. Noor Ahmad Zulal, Phar. Friba Nasery, Phar. Farid Sarwary, Dr.Zafar Omari, Dr. Safiullah Nadib and Mr. Shafi Noorin for theircontinues recommendation, advices and information sharing.

Thanks to SPS project for financially supporting Food Committeetour consisted of the visits.

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