Page 32 - FoodFocusThailand No.175 October 2020

SPECIAL TALK BY FDA
SPECIAL TALK BY FDA

The Most Recently Enforced Food Regulations
Notification of the Ministry of Public Health

Re: Standards for Contaminants in Food

Recently, the Notification of the Ministry of Public Health No.98 B.E.2529 (1986) Re: Standards for
Contaminants in Food (the Notification of MOPH No.98) is the main regulation laid down Maximum Levels
(MLs) for contaminants in food, which has been used for over 30 years to control the safety of both imported
and domestically food produced. Although there is the revised version in B.E.2546 (2003) and several the
Notification of MOPH has been established the ML of certain contaminants for certain food products, most of
these standards are outdated, cannot protect consumer health and causes trade barrier sometime.

In order to ensure the regulation of contaminants in food complying the standards elaborated within the Codex Committee on Contaminants
can protect consumer health and avoid the creation of in Food (CCCF). Therefore, the ML of some contaminants may not be assigned
unnecessary barriers to international trade, Thai Food and Drug to some food item(s) due to it may contain at very low levels with have no public
Administration has readjusted the Maximum Levels (MLs) of health concern or it may be in the process of conducting research to propose
food contaminants by revoking the Notification of MOPH No.98 the ML. Levels of contaminants in food required by this Notification are prescribed
and several MOPH Notifications regarding to the ML as follow:
requirements in food products and replace them with the new (3.1) The level of a contaminant in a food must not be greater than the
MLs complying to the Codex General Standard for Contaminants corresponding amount listed in Annex I attached to this Notification.
and Toxins in Food and Feed; CODEX STAN 193-1995. So, To allow maximum levels to be applied to primary processed, dried, or diluted,
there are two new Notifications of the MOPH have been where no specific MLs have been established, food business operators
announced in the royal Thai government gazette on the 20 of (manufacture or importer) should provide the specific concentration and dilution
th
May 2020 and will be enforced on the 16 of November 2020. factors accompanied by the appropriate experimental data justifying the factor
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The main contents of these two notifications are summarized proposed to calculate the maximum concentration. Calculation may also be
as follows: based on the extraction rate or the moisture content information which published
• Notification of the Ministry of Public Health (No.413) in journals or databases such as Thai Food Composition Database 2015 published
B.E.2563 (2020), issued by virtue of the Food Act B.E.2522 by Institute of Nutrition, Mahidol University (https://inmu2. mahidol.ac.th/thaifcd/
(1979), Re: Amendment of several Notifications of the home.php) and the Technical Conversion Factors for Agricultural Commodities
Ministry of Public Health Prescribing Standards for published by the FAO (http://www.fao.org/economic/the-statistics-divisioness/
Contaminants in Food, which the MLs of contaminants for 19 methodology/methodology-systems/technical-conversion-factors-for-agricultural-
food items (Table 1) have been listed in this Notification are commodities/en/).
repealed and will be replaced by the new MLs which are listed Food product with have no specific ML with highly processing for example
in the Notification of the Ministry of Public Health (No.414) High-fructose corn syrup or contains 2 or more ingredients which the ML of that
B.E.2563 (2020), issued by virtue of the Food Act B.E.2522 ingredient(s) has been listed in the Annex 1, level of contaminants in food shall
(1979), Re: Standards for Contaminants in Food. be as low as reasonably achievable (ALARA) through Good Manufacturing
• Notification of the Ministry of Public Health (No.414) Practice (GMP) following an appropriate risk assessment. Therefore,
B.E.2563 (2020), issued by virtue of the Food Act B.E.2522 manufacturer or importer shall have the measure to control raw materials and
(1979), Re: Standards for Contaminants in Food will be the must demonstrate documents such as an analysis report or a certificate of
main regulation for food contaminants which; analysis (COA) of raw materials to the officer on inspector when needed. In
1. The Notification of the MOPH No.98 prescribed the MLs addition, the analysis report for final food product may also be conducted either
for all food products and its revised version, the Notification of to verify the raw material control measure or to determine product specifications.
the Ministry of Public Health (No.273) B.E.2546 (2003) Re: In case of both finished goods and raw materials have no specific ML of
Standards for Contaminants in Food (No.2), are repealed. contaminants, an analysis report must cover the concentration of tin, lead,
2. The definition and scope of the terms “Contaminant” and mercury, arsenic, and aflatoxin which the MLs of these contaminants has been
“Maximum Level” are established as in page 28: established for all food other than food items with specific ML as following:
• Maximum Level is a maximum concentration of that • The ML of tin shall not exceed 250 milligrams per 1 kilogram of food
substance contaminant in edible part(s) of a food or food as • The ML of lead shall not exceed 1 milligram per 1 kilogram of food
consumed except there is some specific requirement of portion • The ML of mercury shall not exceed 0.02 milligram per 1 kilogram of food
of the product was described. • The ML of arsenic shall not exceed 2 milligrams per 1 kilogram of food
3. MLs only be set for food in which the contaminant may • The ML of aflatoxin shall not exceed 20 micrograms per 1 kilogram of food
be found in amounts that are significant for the consumer health

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