This framework must allow for participation by consumer representatives at all levels and all stages of the standards-writing process. Greater co-operation between government officials is also required to agree on essential safety requirements, which should be applied to international standards. Other, quasi-governmental organizations like the Codex Alimentarius must also be reformed to give consumers and equal voice with industry in the process. We reject the notion of functional equivalence . In Europe, equivalency decisions have been a conspicuous failure that has eventually resulted in the writing of over 5,000 new European standards with some 8,000 more on the way.
Standards provide a bright line test whereby precise comparisons can be made.
The very notion of equivalence allows for imprecise, subjective comparisons that are not appropriate when dealing with issues as important as public health and safety. However, given that equivalency decision between nations are moving forward with increasing frequency, we must develop strict rules for making equivalence determinations. A standard or a regulatory system should be determined equivalent only if it provides the same or greater level of substantive protection for health, safety or the environment. Criteria for determining equivalency should be clearly outlined and equivalency proposals should have substantive public input before they reached. To this end we recommend readiness criteria under which potential MRA and equivalency agreement must be reviewed.