JOINT FAO/WHO FOOD STANDARDS PROGRAMME
CODEX ALIMENTARIUS COMMISSION
Twenty-Third Session, FAO Headquarters, Rome, 28 June -3 July 1999
Agenda Item 9
CODEX COMMITTEE ON FOOD ADDITIVES AND CONTAMINANTS
DRAFT STANDARD FOR HEALTH RELATED LIMITS FOR CERTAIN SUBSTANCES IN THE CODEX STANDARD FOR NATURAL MINERAL WATERS
Comments of the
INTERNATIONAL ASSOCIATION OF CONSUMER FOOD ORGANIZATIONS
IACFO urges that the draft standard be amended to provide consumers with the highest levels of protection from contaminants in natural mineral water. The draft standard adopts contaminant levels for 16 substances in natural mineral water based on standards established by the World Health Organization (WHO). However, in some cases the WHO standards allow for greater levels of contaminants than those permitted by certain member countries. For example, for three contaminants the WHO standard allows significantly higher levels than are allowed by the U.S. Food and Drug Administration: lead (.01 mg/l versus .005 mg/l), manganese (.5 mg/l versus .05 mg/l), and nitrate (50 mg/l versus 10 mg/l). Instead of using the WHO standards as a convenient compromise, the Commission, should, for each of the 16 contaminants, adopt an international standard that is based on either the WHO standard or any current national standard, whichever provides the greatest degree of protection to consumers.
IACFO also notes that in addition to scientific factors, national traditions and cultural values play a major role in determining the acceptable level of risk from contaminants in natural mineral water. Because such traditions and cultural values vary, the adoption of any international standard for natural mineral water is inappropriate.
We therefore urge that this draft standard for health-related limits be revised to better protect consumers, or, in the alternative, that the current standard for natural mineral water be withdrawn and the matter left up to the discretion of national authorities.