The Malaysian Association of Environmental Health Officers and Assistant Environmental Health Officers (MyEnvHeat) takes note of the proposal in the Food (Amendment) Bill 2026 [D.R.23/2026] to specifically name Food Technologists (PTM) as Authorised Officers (PDK) under the Food Act 1983.
MyEnvHeat objects to the proposal because it could combine enforcement and investigation functions with industry guidance, laboratory analysis and expert testimony.
PTM play an important role in the Food Safety Assurance Programme (PJKM), including providing guidance and advisory services to industry, conducting food analysis, verifying and certifying analytical results, and acting as expert witnesses.
If the same profession is also authorised as PDK to conduct inspections, investigations, sampling and enforcement actions, this could create actual, potential or perceived conflicts of interest, including the risk of self-review and questions regarding impartiality.
MyEnvHeat believes that a system with integrity must clearly distinguish the following functions: enforcement investigates, laboratories analyse and certify, and experts provide independent testimony.
MyEnvHeat also emphasises that environmental health officers (PKP) and assistant environmental health officers (PPKP) already have core functions in inspection, intelligence gathering, investigation, sampling, handling exhibits and preparing investigation papers.
Granting comprehensive PDK powers to PTM could create overlapping functions and unclear accountability.
Accordingly, MyEnvHeat requests that the proposal to specifically name PTM as PDK under Clause 2(g) of D.R.23/2026 be reconsidered before the Bill is finalised.
MyEnvHeat supports strengthening the Food Act 1983 and multidisciplinary cooperation in food safety. Such cooperation must, however, be based on a clear division of functions, appropriate competencies, and checks and balances that protect the integrity of the national enforcement system.
This press statement was issued by the Assistant Secretary 2 on behalf of the president of MyEnvHeat.
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