THE NATIONAL EXECUTIVE CODEX COMMITTEE
FOOD AND AGRICULTURE WORLD
OF THE UNITED NATIONS REPUBLIC OF KENYA ORGANIZATION
30th JULY 2009.
CODEX COMMITTEE ON FOOD HYGIENE
Electronic Working Group on the Review of the Need for the Revision of the
Recommended International Code of Hygienic Practice for the Collecting,
Processing and Marketing of Natural Mineral Waters (CAC/RCP 33 - 1985)
DRAFT DISCUSSION PAPER
1. Kenya would like to support the draft proposal received from the e_WG on the above mention
code of Natural mineral codex standard and would also recommend that the Natural Mineral
Water Codex Committee to look into the standard and deliberate on it exhaustively as expert
and also make reference to the existing codex standard if need be or as quoted in the project
2. We would also like to amend or propose the additional issues to be considered when
revising the code as indicated under ‘purpose and scope of the work’, ‘Main Aspects to be
The 40 session of the Codex Committee on Food Hygiene (CCFH) which took place in Guatemala
City, Guatemala, from 1 to 5 December 2008 agreed to establish an Electronic Working Group
(E-WG) led by Switzerland to consider the revision of the Recommended International Code of Hygienic
Practice for Collecting, Processing and Marketing of Natural Mineral Waters (CAC/RCP 33-1985).
1. PURPOSE AND SCOPE OF THE NEW WORK
The purpose of the proposed new work is to revise the Recommended International Code of Hygienic
Practice for Collecting, Processing and Marketing of Natural Mineral Waters (CAC/RCP 33-1985). This
guidance will be supplemental to the Recommended International Code of Practice - General Principles
of Food Hygiene (CAC/RCP 1-1969, Rev. 4 (2003).
The scope of the new work will be the revision of the Code in order to take into account the latest
developments in food safety and food hygiene, such as HACCP principles, which have been adopted
since the Code’s adoption in 1985. In particular, the revised Code should comply with the requirements
of the Recommended International Code of Practice - General Principles of Food Hygiene (CAC/RCP
1-1969, Rev. 4 (2003). Furthermore, it should be ensured that the structure of the current Code of
Hygienic Practice for Bottled/Packaged Drinking Waters (Other than Natural Mineral Waters) CAC/RCP
48-2001 forms the basis for the revision of the Recommended International Code of Hygienic Practice
for Collecting, Processing and Marketing of Natural Mineral Waters (CAC/RCP 33-1985).
Kenya propose the additional as follows:
The microbiological criteria in the revised Code on NMW should further be aligned with the
microbiological criteria found in the Principles for the Establishment and Application of Microbiological
Criteria for Foods (CAC/GL 21 – 1997) and the Codex Standard for Natural Mineral Waters, CODEX
STAN 108-1981). COMMENT – we propose that the code should make reference to codex stan 108;
these micro-organisms [gardia, cryptosporidium, vibrio-cholerae, salmonella species] are missing yet
they occur in open spring water. The sources of these micro-organisms are human/animal activity in the
area of exploitation. These micro-organisms should be included in stan 108 during revision.
3. MAIN ASPECTS TO BE COVERED
The proposed revision will address the entire NMW Code (CAC/RCP 33-1985), but in particular
Sections 2 and 4 and Section 3 as appropriate. The revision will further focus on the review and update
the microbiological criteria in the NMW Code in order to standardise the microbiological criteria found in
the Code of Hygienic Practice for Natural Mineral Waters, CAC/RCP 33-1985 and the Codex Standard
for Natural Mineral Waters, CODEX STAN 108-1981).
KENYA PROPOSES THE FOLLOWING TO BE CONSIDERED IN THE NMW CODE:
Section 2: – under Definition on NMW should read ‘all waters meeting the requirements of codex
standards on NMW codex standard 108 amended in 2007’.
Section III: Authorization should include specification of the site with geological report of the site; water
shed survey that identifies and evaluates potential sources of contamination and describes the
catchments operation. A plan for monitoring the identified contamination and any corrective action that
may be taken. A report detailing the development of the source, method of construction including
well/spring design, well installation, surface catchments intake structures.
Section IV. 3.11 – Building and facilities, amend after disinfected insert ‘or highly absorptive materials
such as wood should be avoided unless its use will clearly not be a source of contamination’. When the
use of wood is unavoidable a wood policy should be put in place.
Section V – 6.1 add ‘bait stations should be secured and identified, a baiting plan of the plant should be
drawn indicating the position of all bait stations and these should be periodically monitored/inspected’.
V. 6.3 PEST CONTROL substances the establishment should maintain material safety data sheet for all
pest control chemicals [pesticides used]’
Section VII :–Establishing hygiene V.7.1 storage of hazardous. We propose to add ‘substances the
establishment should maintain material safety data sheet for all pest control chemicals [pesticides
Hygiene processing requirement – VII.5.2 we propose the additional statement as follows, ‘any
container used for packaging NMW water should be fitted with closures designed to avoid any
possibility of adulteration, contamination, or at least be able to give evidence of tampering.
VII.10 sampling and lab control procedures – ‘the code should address the timeframe [6 – 12 hrs]
between sampling and commencement of analysis if not appropriate handling [refrigeration] of the
sample should be initiated.
KENYA PROPOSES THE FOLLOWING TO BE CONSIDERED IN THE NMW CODE
RESPONSE TO Q5-Do you have any other relevant information or data that should be
considered in the code of Hygiene practice for Natural Mineral Water?
We agree with the initial proposal to include an additional sub-section under section 5:
Control of operations in order to address treatment process such as ozonation & U.V since;
Being natural mineral water and considering possible natural variations at source and in
addition to the current concern of food safety and food systems such HACCP and ISO 22000.
It would be prudent to include an operational prerequisite plan in place within the process
that would control, reduce or eliminate potential hazards identified but may only occur in
isolation especially during natural climatic variations. In practice such variations would
effectively be controlled by treatment such as ozonation or U.V.
However, appropriate labelling requirement may be applied for such authorized treatments on
natural mineral water if need be and where there is proven natural variations in relation to
microbiological and unstable constituents of the source water.
Our justification for the proposal:
Neither ozone nor U.V treatment would alter the mineral (constituents) composition of the
water. We propose that the usage of ozone and U.V can be used mainly during rainy season or
when there is flood to reduce potential harzards.
2. The code should introduce a requirement/practice for establishments to document an
emergency preparedness and response plan/procedures. This will address food safety
issues related to or that arise possible emergencies situation such as but not limited
Floods, spills, fires, storms , heavy rains, earthquakes, intentional or unintentional
contamination of sources and bottling plants. The procedure shall basically identify
applicable emergency situations and responses or action taken during and after their
occurrence so as to give assurance to the safety of natural mineral water upon resume
3. The code should include requirements for the voluntary recall/withdrawal and
traceability procedures for natural mineral waters that have left the bottling
establishments to warehouses or the market but do not comply to specifications.
Establishments would also institute mock recalls programmes to verify their
4. To align the code with other codes and specifically food safety the establishment
5. Should implement controls or control combinations on the basis of HACCP
program,as part of the plants’ food safety plan. They should address natural mineral
water safety with respect to the seven principles of HACCP Plan. The plan should
address but is not limited to;-
i) Results of hazards analysis of the plant’s process from source to the market
ii) Location of each CCP in the process including but not limited to supplies,
in-process, final products, equipments, process environment etc.
iii) The critical limits at each CCP
iv) Details of monitoring process established at CCP
v) Description pf corrective actions to be taken when limits are exceed.
vi) Description pf the plant’s HACCP verification system.
vii) Description of the plant’s HACCP record keeping system
In support of HACCP programme SSOP and other appropriate SOPs should be
developed and maintained by natural mineral water bottling establishments.
KENYA PROPOSES THE FOLLOWING TO BE CONSIDERED IN THE NMW IN STAN 108
We would like to recommend that the NMW codex standard 108 to be amended to include
the following microbiological criteria and to be in line with other codex standards.
The code usually does not give the specific microbiological limits to be met or to be
implemented but concentrate much on guidelines for the producer and competent authority
6. Microbiological Creteria.
The code should include microbiological parameters as below;-
1. Parasites:- Gardia lamblia) and Cryptoporidium (purvum)
2. Total Coliforms
3. E. coli
4. Faecal streptococci
5. Pseudomonas aeroginosa
6. Sulphite reducing bacteria