Food Safety and Quality Regulatory System Review. This article is a review of the current status of the food regulatory system in Afghanistan (But now the country has its food law).

1. Food safety and quality management regulatory systems in
Afghanistan: 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 2015
Received in revised form
8 March 2016
Accepted 15 March 2016
Available online 21 March 2016
Keywords:
Food law
Food safety
Food inspection
Food sector
Afghanistan
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 security
issues. With adequate access to finance and infrastructure, Afghanistan should in theory be a top
exporting country in all agricultural sectors. The potential also exists for Afghanistan to be a top exporter
of 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 pressure
from the crisis, market competition from importing companies, pricing pressure from retailers, and
seemingly 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) that
regularly 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 be
addressed within the food safety system of Afghanistan, such as: complete harmonization of legislation
with the regional (legislation and standards mainly), improvement of coordination among authorities;
ability to ensure impartiality of inspection work; thorough training of inspectors and implementation of
skills, 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 HACCP
principles and good hygienic practices.
© 2016 Elsevier Ltd. All rights reserved.
1. Introduction
Since 2001, Afghanistan has made many changes in food sector
and food safety inspection: from the no control at border entry
points to current control mechanism by both Ministry of Public
Health (MoPH) and Ministry 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 of
a food safety law. MAIL has responsibility for control of raw food
products and MoPH has responsibility for control of processed food
(Quraishi et al., 2012; MoPH & MAIL, 2012). The mandate of the
MoPH and MAIL in relation to food relates mainly to risk
assessment and risk communication which are not well interpreted
from policy into action. The Public Health law just states that MoPH
is responsible for preventive health (MoPH, 2009) which is not
further interpreted in the policy, strategy and implementing level
clearly.
Food safety is a shared responsibility (Khalid, 2015). Govern-
ments establish food safety policies and they put in place and
manage a system of controls that cooperatively aim to assure that
national food safety goals are met. National food safety regulations
and standards are a fundamental part of the food control system.
The modern idea of food control places direct responsibility for
ensuring the safety of food on all operators in the food chain (CEC,
2000). They must be able to demonstrate to regulatory authorities
that their operations are in line with national guidelines and codes
of practice and that their products meet national standards (WHO,
2012). Consumers also play a role in functioning of national systems
of control beyond the actual safe handling of food that they
E-mail address: sayednaim@outlook.com.
*
Held the role of Food Technical Advisor between 2013-2015 in National Med-
icine and Food Board, Ministry of Public Health, 10th District, Kabul, Afghanistan.
Contents lists available at ScienceDirect
Food Control
journal homepage: www.elsevier.com/locate/foodcont
http://dx.doi.org/10.1016/j.foodcont.2016.03.022
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Food Control 68 (2016) 192e199

2. purchase or otherwise obtain: their choices and concerns influence
decisions of government and the food industry (FAO, 2006).
The aim of this study was to understand the different functions
of 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 will
improve 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 having
access to enough food. The regulatory infrastructure was ruined
and the Mullahs were regulating the food sector. After the inter-
vention of international society in 2001, the food sector boomed
once again. The exports and imports of food commodities
increased. Travels of Afghans and the foreigners into Afghanistan
took place. The economy of people was slowly improving. All of
these resulted in change in the food sector regulatory aspects, trade
legal compliance requirements and consumer awareness about
what to eat and where/how to buy it. Afghanistan started to get
membership of international organizations like World Trade Or-
ganization, signed agreements with Food and Agriculture Organi-
zation and World Health Organization on food affairs. This resulted
a change of mind in both policy making people, consumers and
suppliers. In the policy level, MoPH decided to have a food and drug
regulatory authority by 2020 (NMFB, 2013; MoPH, 2012) and there
is 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 the
consumers, who look for label of food products, quality and safety is
prioritized now (Khalid, 2012).
2. Methodology
The present study is based on the secondary data published by
various agencies and organizations, interviews and direct site ob-
servations. The visits as tour were planned for 34 locations. The
different locations/institution are categorized into 4 groups. A
separate questionnaire is developed for each category. The ques-
tionnaire was completed by one of the Food Committee members
which was finally used for generating the tour report. The main
questions included (1) who do what in food value chain in terms of
regulations?, (2) what is controlled and what is not controlled in
food sector?, (3) what are the duplications of responsibilities? The
tour took 15 working days based on the schedule between
MayeJuly 2014. The visit from each location resulted into a list of
recommendation for improvement of practices and at the end all
recommendation were presented to National Medicine and Food
Board for general action on the policy level. In addition, a technical
working 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 34
locations but due to time limit only 28 were visited. During the tour
14 government regulatory institutions, 10 private sector companies
and 4 government academic intuitions which are busy in food
science 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 to
the Memorandum of Understanding (MoU) MAIL is responsible
for the control of raw food products (MoPH & MAIL, 2012).
Though, there is no specific definition for raw product. Because
on market level vegetables and fruits are not controlled for
pesticide residue and other disease (Rahman, 2011). Based on
the discussion with MAIL staff, we found out that there are two
main directorates involved in the food safety affairs, though it
was said that in past MAIL had a quality control directorate
which is now thrown away from the organizational structure
and its functions are divided between Directorate of Animal
Health and Plant Protection and Quarantine Department.
There are two Directorates involved in Food Safety in MAIL:
A. The Animal Health Directorate - responsible for regulation
within which the veterinary inspection activities are conducted
and control for animal health, safety and hygiene of production
of 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 of
Veterinary Medicine or technicians in veterinary/livestock pro-
duction or management.
B. Plant Protection and Quarantine Directorate e in charge of
regulation, 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. The
primary products are to be controlled but the directorate doesn't
have infrastructural, technical and financial capacity to perform
the 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 total
number of sanitary inspectors in the country is 53. We found out
that the Preventive Health Directorate stopped this directorate
not to go for inspection to market. The post market surveillance
is 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 dietetic
products, 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 food
programs and other nutrition activities for solving public health
nutrition problems (Aminiee, 2014).
C. Quality Control Directorate is responsible for testing the
quality of food and medicine. The team found out that bizarre
and strange decisions are made there. Food and water are
analyzed by pharmacists. Mostly the tests are by acidity, phys-
ical tests, smell, color and some other basic tests. The calibration
system is not in place, lab is not certified though it is national
central lab which may function in future to accredit others.
Overall, the decision made are compromised. The lab has 7
employees and have tested around 800 food samples (Faqiri,
2014; Sultani, 2012a, 2012b).
D. Health Law Compliance Directorate is responsible for
ensuring whether health related laws of MoPH are implemented
S.M.N. Khalid / Food Control 68 (2016) 192e199 193

3. well or not (Kamil & Barin, 2014). But there is no clear functions
list or terms of references for them in terms of food. They
actually go to market and companies and function the same like
the Environmental Health Directorate (Hussaini & Rasooli,
2014). The employees who perform this function are either
medical doctors, pharmacists or nurses (Kamil & Barin, 2014).
III. Municipalities - responsible for regulation and inspection of
waste (solid and water) (Khalid, 2014a,2014b). In addition, it has
a directorate of Environmental Health which functions the same
like EHD of MoPH. There is no law which clarifies its duties and
set a red line between the two. The employees are medical
doctors (Hussaini & Rasooli, 2014).
IV. National Medicine and Food Board and Food Committee. The
National Board is established based on Article 3 of Medicine Law
(MoJ & MoPH, 2006) which is only covering the medicine 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 and
board in relation to food is policy level decision making and
advice to the minister of public health. In addition, they provide
scientific opinion to regulators and the public. Collaboration
among inspection services occurs through their monthly
meetings. The board try to be very transparent and accountable
but sometimes it sticks to the bait of politics and external forces
which 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).
3.2. Findings related to food safety
3.2.1. A shortage of food safety knowledge
All interviews described a lack of knowledge, expertise and
experience. This shortage was identified to be amongst those
working in industry in both large and small businesses, as well as
amongst inspectors, trainers, consultants and those working in
government or equivalent.
3.2.2. A paucity of good advice and guidance
Guidance 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 international
guidance for food control and HACCP is aimed at government or
equivalent responsible agencies rather than at businesses.
3.2.3. Low levels of basic food hygiene
During the interviews and the site visits showed to us that low
levels of basic hygiene in some businesses can present a challenge
to effective implementation of national food safety strategy. Basic
food hygiene is a prerequisite for food safety and HACCP. Poor
Hygiene practices are the potential barrier fors effective HACCP
implementation. If those involved in the development and imple-
mentation of national food safety policy decisions are aware of low
levels basic hygiene in industry they can develop national decisions
that addresses this (Hussaini & Rasooli, 2014; Azizi & Osmani, 2014;
Etifaq Biscuits, 2014; Khalid., 2013, 2014a, 2014b; Hussaini &
Rasooli, 2014).
Table 1
Summary of food regulatory functions in Afghanistan.
Area Inspection authority
Animal Health Animal Health Directorate of MAIL
Food of animal origin If raw Animal Health Directorate of MAIL
If processed, Food Quality Control Directorate of MoPH
Import of animals and food of animal origin If raw Animal Health Directorate of MAIL
If processed, Food Quality Control Directorate of MoPH
Feed stuffs and animal nutrition- import Animal Health Directorate of MAIL
National Environmental Protection Agency-NEPA
Feed stuffs and animal nutrition- production Non
Animal byproducts Animal Health Directorate, MAIL
Veterinary medicines authorization and distribution Livestock General Directorate, MAIL
Veterinary medicines residues Non
Food and Food hygiene If raw MAIL e Plant Protection Directorate and Livestock General Directorate
If processed MoPH e Environmental Health Directorate and Quality Control Directorate
Genetically modified organisms No one
Import of food of plant origin Plant Protection Directorate of MAIL
Plant protection products' authorization and sale Plant Protection Directorate of MAIL
Plant protection products' residues No one
Animal welfare No one
Plant health Small percentage control by Plant Protection Directorate of MAIL
Restaurants, shops Municipalities, Provincial Health Directorates,
Environmental Health Directorate of MoPH
Self-control
Fortification/Fortified food Public Nutrition Department, MoPH
Food Regulatory support National Medicine and Food Board, Food Committee, MoPH
Food trade Ministry of Commerce and Industries
Food wastes By law NEPA, but in practice Municipality collect them.
EHD of MoPH also play role, does not have specialists
Fraudulent foods Legally it is not allowed but no authority has technical capacity to detect fraudulent food.
Food Additives and contaminants Based on the MoU, MoPH is the lead but there is no technical and institutional capacity to identify/
measure the risks from additives and contaminants
Dietary supplements, sea food, wild game, grading of fruits and
vegetables and advertising
Not controlled
Role of parliament and senate No clear role
On farm oversight No one
Biotechnology and GMO of food No one, no capacity at this time.
Packaging No one, no capacity at this time
Irradiation in food No one, no capacity at this time
S.M.N. Khalid / Food Control 68 (2016) 192e199194

4. 3.2.4. Inaccurate perceptions of the costs/benefits of food safety
system
It was found out that businesses believe food safety system is
costly, difficult to implement and not actually necessary. It was
recognized that effort must be made to make food safety systems
like GMP and HACCP acceptable to businesses by better commu-
nicating the advantages food safety system implementation may
bring.
3.2.5. System on paper but not in practice
It was emerged that government believes, businesses often have
food safety system on paper but not implemented in practice. There
was reference to completion of documentation and records to
create the pretense of a system when in reality it was not used in
practice. The phenomenon of businesses having the system on
paper but not implementing it in practice was linked to lack of
regular and effective enforcement.
It was found in most of the interviews that both governments
and businesses implement GMP, HACCP, ISO 9001 and ISO 22000
primarily to increase trade.
3.2.6. Role of private standards in food safety
Private 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 widely
according to the nature of the entities developing and adopting
them: they commonly address food safety, food quality or social
and environmental issues along the production to marketing con-
tinuum. Within the 4 private sector food businesses were visited 2
of them had ISO 22000:2005, HACCP, ISO 9001 and ISO 14001
certification (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 is
presented in Table 2.
3.2.7. Codex contact point and national codex committee
During several meetings held in MoPH with WHO and FAO
representatives, we found out that Afghanistan has not specific CCP
and NCC yet. According to WHO representative, there is plan that
Afghanistan will establish its own NCC in the near future. In past
there were CCP from both MAIL and MoPH who are not now in
same positions to represent Afghanistan in Codex meetings.
Table 2
Working principles of food quality assurance certification systems in Afghanistan.
Weakness/threats Strengths/opportunities
Set up a new quality system High cost Developing slowly
Institutional frame Inefficient capacity High interest from the institutions
Consumer oriented Unknown consumer attitudes Increase in consumer demands
Producer oriented Low interest from producers Food industry is gaining power
Access period to the WTO Very slow process Adaptation of legislation is sustained
Table 3
SWOT 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

5. 3.2.8. Pending food safety law
The rules governing food safety and quality in international
trade are provided within the SPS and TBT Agreements of the WTO.
The SPS agreement, in turn, refers to the standards of the Codex
Alimentarius Commission as the benchmarks for food safety in
international trade and calls for harmonization of national stan-
dards with Codex as an important strategy for facilitating trade. Any
increase in stringency of official standards as compared with the
corresponding Codex standard must be justified on the basis of
science. Since Afghanistan is supposed to join WTO, therefore,
there is a requirement that Afghanistan must have certain laws in
place, in which food safety law is one. This law is pending due to
lack of coordination and influence of involved government official
concerning 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 quality
Consumers are increasingly aware of food and food systems and
their impact on health. They are particularly concerned about food
safety. Almost everybody in the market speaks of food quality,
media, government officials and private sectors are all talking about
the quality of imported foods.
3.2.10. Misuse of specific logos
During the visit we found out the companies are using packages
with logo of Halal, terms of ISO certified, Healthy and so on. So in
case of logo of Halal the company was not certified for that and the
terms are also not controlled neither by government nor by the
private sector itself. This action was cheating the customers and the
products were the result of a fake and fraudulent activity (Etifaq
Biscuits, 2014).
3.2.11. Product recall and tractability system
During 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 there
product will never be a problem. Just one company had experience
of rejection of its product in Europe due to high level of pesticides.
3.2.12. Data on foodborne illnesses
There is no specific system available neither in MAIL nor in
MoPH to clearly articulate food safety related data i.e. foodborne
illness and food recalls (Hussaini Rasooli, 2014). Though, there is
Health Management Information System (HMIS) in MoPH and a
system 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, and Municipality) has its own register
(Hussaini Rasooli, 2014). Afghanistan maintains no coordinated
control plan or coordinated monitoring plan and inspection is not
yet done on a risk basis. According to obligations Afghanistan
assumed in the process of membership to the WTO, food safety law
have to be developed in accordance with SPS requirements in order
to identify the real threats for food safety. Until the new Law on
food safety will be issued, both sanitary and veterinary inspections
were 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 no
follow up visit for identifying non-compliances with regulations.
Inspection visits last from some minutes to some hours, depending
on the type of inspection. Veterinary inspectors are stamping the
carcass of slaughtered animals only if the meat is safe after physical
observation. Coordination between inspections is performed
through the Food Committee of NMFB, but there is no direct co-
ordination especially at the provincial level. The inspections are
financed from the central budgets. MAIL sets fees for veterinary-
sanitary checks, health protection and the issuing of animal
health certificates. All the money from this income goes to central
account of government.
3.2.15. How is quality of imported and domestic products
controlled?
In ideal situations, one of the roles of the State Inspectorate is to
control the performance of inspections according to legal re-
quirements and financial output. However, in Afghanistan the
aforementioned 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 of
objectivity in inspection work and provide a basis for further
improvements.
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 taken
by inspectors in import control. The testing of samples in produc-
tion and retail, on the other hand, is paid for by the respective
ministry, 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 are
financed from the budget of the ministry (either agriculture or
health, depending on which took the samples). There is no trans-
parency in the system in terms of clearly indicating the total
number of food samples. Since Afghanistan is a food importing
country, there need to be more food samples around the year, but
we 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 food
sector staff?
In Afghanistan there are two educational institution which
provide Bachelor level education in food science and technology i.e.
Kabul Polytechnic and Nangrahr university. In other universities
which teaches agriculture, subjects related to food process, post-
harvest operations, cereal processing, food analysis, food hygiene
and some other subjects are taught in different departments.
Specific food safety education doesn't exist in the country. To
become employee of MoPH e EHD, one needs to be a medical
doctor. Food safety and quality education is not criteria. Food an-
alyst are Pharmacists. If you are a food scientist you will not be
allowed to work in the MoPH public labs. There are several short
term courses provided through donor funded activities, which
doesn't seem to be very effective and sustainable. In MAIL for ani-
mal and plant health/safety activities, Bachelor in Veterinary
Medicine and/or Bachelor in Agriculture are required. But generally
there is no analytic and specific food safety and phyto-sanitary
trainings and education.
Knowledge of HACCP is limited. Since it is not a requirement,
some companies have HACCP in place through donor supported
activities but continuously upgrading and maintaining the
requirement 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 but
nothing goes to public. The decision are made in both MAIL and
MoPH in hidden the decisions are not declared or put on internet
S.M.N. Khalid / Food Control 68 (2016) 192e199196

6. for public. Sometimes, wrong or low quality products are said to be
released to market 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 on
prioritizing food safety?
The obvious problem, in relation to this range of activities that in
principle merit public support, is where to find the resources. The
afghan governments faces numerous demands, and have only
inadequate capacity to respond. Where does food safety fit in
among the range of concerns? This question can be asked from two
standpoints: food safety as an instrument of public health, and as a
tool for economic development. In the public health arena, the
criterion 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 of
important public health problems. Here, the value of spending on
food safety resources would need to be weighed against that of
programs to combat diseases such as AIDS and malaria, and other
public health problems like water and sewage systems. For eco-
nomic development programs, the convention is to consider the
returns to spending among alternative activities i.e. to weigh both
costs and benefits of different uses of public resources. Here, food
safety expenditures would be judged in terms of the benefits they
generate (in terms of keeping markets open or generating new
markets) per unit of cost, in relation to other economic projects
receiving public support (export promotion, industrial develop-
ment, certain types of infrastructure, etc.). It is easy to see, in this
context, why much of the focus in the food safety area has been on
the export-oriented sector. On the one hand, the lack of risk
assessment work means that there is little knowledge about the
stakes of food safety from a public health perspective in
Afghanistan (lives lost, morbidity rates). Meanwhile, it is fairly
straightforward to make some positive assumptions about how
improved food safety will generate benefits for specific export
sectors. 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 is
considered crucial. First, it is noteworthy that in the developing
country context, governments appear to play a critical role in
helping industries e even well-developed ones e to make the
transition to meeting new international standards. A second theme
concerns the interface between the public sector and the public at
large. If consumers are to be able to play a more effective role in
protecting themselves from foodborne diseases, health education is
essential. A third area for public sector action is research. The
research needs of Afghanistan in the food safety area are multiple,
and cover the entire range of risk assessment and quality assurance
activities. The fourth and final area where an important public
sector role is stressed, is in the international arena. Afghanistan is
not actively present in the WTO and the international standard
settling bodies like the Codex Alimentarius Commission are unable
to 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 their
industries in the WTO dispute resolution process, once specific
trade 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 and
loss of focus on control;
Duplication of functions and lack of coordination among state
agencies involved in control;
Nonexistence of many labs, as which are incapable of testing up
to food safety standards;
Inability to develop an efficient plan for food safety control that
addresses all problematic issues.
Lengthy development process and adoption of regulatory
documents
In other countries one of the basic principles of food safety is
that the primary responsibility for ensuring compliance with
food law, and in particular the safety of the food, rests with the
food business but in Afghanistan neither the government nor
the private sector are responsible, because food safety law
doesn't exist.
Lack of food safety self-control culture in the whole country
In most food product Afghanistan is only importer and the
exporter is just imposing its own requirement therefore, there is
less 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 the
right way of doing food safety practices.
Lack of co-ordination between different actors in the control
systems
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 up
procedures
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 in
industry
A shortage of appropriate and accurate advice and guidance for
businesses
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 not
implemented in practice
Low levels of literacy and use of multiple languages amongst
those working in the food industry
Poor infrastructure
Government recognize a high proportion of the challenges
business experience
3.3. SWOT analysis
SWOT Analysis of the regulatory sector of food affairs is also a
result of continuous work and several meetings of Food Committee
and representatives of WHO, FAO and SPS/MSH.
The detailed SWOT analysis is presented in Table 3.
S.M.N. Khalid / Food Control 68 (2016) 192e199 197

7. 4. Recommendations
4.1. General recommendations
1. A single food control agency is the most effective way to deliver
transparent, consistent inspections based on food safety and
consumer protection.
2. Training of all inspectors is continuous and in accordance with
clearly defined regulations to ensure risk-based inspections at
all times
3. A central register of food business operators promotes
transparency.
4. Certificates issued by authorities are in accordance with WTO
requirements 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: The
government of Afghanistan should ensure that the needs of con-
sumers in relation to food safety. The Government should work
with industry and regulators to:
Maintain consumer confidence in food;
Prevent contamination, adulteration and false claims about
food;
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 based
on horizon scanning and intelligence, data collection and well-
structured surveys.
Recommendation Two - Zero Tolerance: Where food fraud or
food 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 about
whether 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 of
food crime;
Urge industry to adopt incentive mechanisms that reward
responsible 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 contracts
regarding validation and assurance of food supply chains; and
Encourage the provision of education and advice for regulators
and industry on the prevention and identification of food crime.
Recommendation Three - Intelligence Gathering: There needs to
be a shared focus by Government and industry on intelligence
gathering 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 and
intelligence.
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 testing
including regular comparison and rationalization of food
surveillance;
Work in partnership with MoPH and local authorities with their
own laboratories to consider appropriate options for an inte-
grated shared scientific service around food standards; and
Recommendation Five - Audit: The value of audit and assurance
regimes must be recognized in identifying the risk of food crime in
supply chains. The Government should:
Support industry development of a modular approach to
auditing with specific retailer modules underpinned by a core
food safety and integrity audit to agreed standards and criteria;
Support the work of standards owners in developing additional
audit modules for food fraud prevention and detection incor-
porating forensic accountancy and mass balance checks;
Encourage industry to reduce burdens on businesses by carrying
out fewer, but more effective audits and by replacing announced
audits with more comprehensive unannounced audits;
Encourage third party accreditation bodies undertaking food
sampling to incorporate surveillance sampling in unannounced
audits to a sampling regime set by the standard holder;
Work with industry and regulators to develop specialist training
and advice about critical control points for detecting food fraud
or dishonest labeling;
Encourage industry to recognize the extent of risks of food fraud
taking place in storage facilities and during transport;
Support development of new accreditation standards for traders
and brokers that include awareness of food fraud; and
Work with industry and regulators to introduce anti-fraud
auditing measures.
Recommendation 6 - Government Support: Government sup-
port for the integrity and assurance of food supply networks should
be kept specific, measurable, attainable, realistic and timely
(SMART). The Government should:
Support ANSA, MAIL and MoPH's strategic and coordinated
approach to food law enforcement delivery, guidance and
training of local authority enforcement officers;
Support the relevant authorities to develop a model for co-
ordination of high profile investigations and enforcement and
facilitate arrangements to deal effectively with food crime;
Ensure that research into authenticity testing, associated policy
development and operational activities relating to food crime
becomes more cohesive and that these responsibilities are
clearly identified, communicated and widely understood by all
stakeholders;
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 clear
leadership and coordination of effective investigations and
S.M.N. Khalid / Food Control 68 (2016) 192e199198

8. prosecutions relating to food fraud and food crime; the public in-
terest must be recognized by active enforcement and significant
penalties 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 MoPH
as the lead agency for food crime investigation;
Support the creation of a new Food Crime Unit hosted by ANSA
operating under carefully defined terms of reference, and
reporting to a governance board;
Support ANSA in taking the lead role on national incidents,
reviewing where existing legislative mechanisms exist, while
arrangements are being made to create the Food Crime Unit
Recommendation Eight - Crisis Management: Mechanisms must
be in place to deal effectively with any serious food safety and/or
food crime incident. The Government should:
Ensure that all incidents are regarded as a risk to public health
until there is evidence to the contrary;
Urge ANSA and MoPH to discuss with the President Office in
their role as coordinating body for Councils of Ministers in the
planning and organization of responses to incidents;
Urge ANSA, MoPH and MAIL to implement and put in place
contingency plans at the earliest opportunity; and
Work closely with ANSA, MAIL, MoCI and MoPH to ensure clarity
of roles and responsibilities before another food safety and/or
food 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 needs
to become more effective and efficient. In other words, it requires
substantial reform. A clear understanding of who is responsible and
how the country ensures and guarantees food safety is crucial to
achieving these goals. Reform of the Afghan system of food safety
control, regardless of the chosen direction, requires understanding
and clear vision among decision-makers, both regarding the
development of the reform strategy and in its implementation. It is
obvious that the transformation of the current system will be a
complicated, demanding and resource-consuming process. That is
why commitments from government officials, political support and
substantial preparation are vital. Such reform assumes not only
institutional transformation, but also significant changes to the
concept of control, shifting from focus at the final stage (when the
product is ready and the only possibility to prevent food accident is
its utilization) to a new focus on prevention throughout the entire
food chain. In addition, legislation must be developed, updated and
brought 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 their
continues recommendation, advices and information sharing.
Thanks to SPS project for financially supporting Food Committee
tour consisted of the visits.
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