House of Commons - Agriculture

Select Committee on Agriculture Fourth Report

II. THE FOOD SAFETY PROBLEM

Imported food

43. Thirty per cent of the food consumed in the UK is imported[113], and imported foodstuffs have been associated with a number of outbreaks of food poisoning in recent years[114]. Produce of animal origin entering the UK directly from non-EU countries may only enter through approved Border Inspection Posts (BIPs) following prior notification. Enhanced controls also exist on nuts, dried figs and their products, because of the potential presence of aflatoxin. All other produce from outside the EU is subject to the more general provisions of the Food Safety Act 1990 and the Imported Food Regulations, but there is no requirement on importers to land at designated ports or to provide advance notification to the Port Health Authorities responsible for enforcing controls. Food entering the UK from another EU member state, whether it originated in that state or from a third country, is not subject, under the Single Market, to the same controls or surveillance, unless an identifiable problem emerges[115]. The Association of Port Health Authorities (APHA) were not satisfied that the existing system for controlling the importation of food provided adequate safeguards for public health, and argued that "there needs to be a uniform system of checks on all foodstuffs entering the EU and not just for products of animal origin"[116]. There have been several large-scale food poisoning outbreaks in the US in recent years associated with hepatitis A virus, Cyclospora and E.coli O157 in imported fruit and vegetables. The importance of ensuring conformity in standards and traceability of imported foodstuffs was graphically illustrated in one such outbreak connected with raspberries imported from Guatemala. One of the factors which made it possible for the Food and Drug Administration to identify the source of the contamination, deal with the farming practices that gave rise to the problems, and prevent a recurrence, was its ability to trace the source of the contaminated fruit back to six individual farms.

44. Dr Cunningham rejected the notion that the Food Standards Agency would impose disproportionate costs and burdens on the British food industry which would disadvantage it in relation to producers in Europe and elsewhere. He said that legislative safeguards would ensure that there were no burdens on British producers, whether farmers or others, that were "not justified on public safety grounds"[117]. We have no evidence to suggest that imported food in general is now, or is likely to become in the future, any less wholesome and safe than UK produce. Multiple retailers, for example, audit and inspect their foreign suppliers on the same basis as their UK suppliers. We do consider, however, that the arrangements for surveillance of food imports, and for ensuring their traceability on an absolutely equal basis with domestically-produced food, will be important issues for the new Food Standards Agency to address, both at the EU level and with local port health authorities. The Agency cannot afford to have domestic producers feeling that the "playing field" is not level. Nor can it rest content with any inspection regimes in other countries which are not as thorough as in the UK.

Economy products

45. In food production and processing there may often be financial costs involved in securing higher standards of food safety. The PHLS, for example, argued that measures to improve poultry meat hygiene would increase the cost of poultry meat[118]. The Federation of Fresh Meat Wholesalers, pointing to the range of regulatory costs already faced by the red meat slaughtering business, emphatically stated: "We cannot accept further increases in our costs... Any further increase in costs will inevitably result in significant increases in cheaper, and less controlled, meat being imported for sale to our consumers"[119]. It would indeed be highly ironic, and undesirable, if British consumers were to switch to less safe imported foods in preference to safer but dearer UK produce. The Government's White Paper itself acknowledges that "in many circumstances the public is unlikely to be willing to pay the cost of achieving the maximum theoretical level of safety (whether that cost is manifested in higher food prices or in restrictions in freedom of choice)"[120]. In analogous "level playing field" cases, concerning animal welfare standards, for example, we have some sympathy with UK producers, but the highest reasonably achievable standards of food safety are, in our view, non-negotiable on financial grounds, and it is unacceptable for the UK food industry to set itself any other than the highest standards. We would hope and expect that the imprimatur of safety and quality, which will come to be accorded to UK food as public confidence in our regulatory systems grows, will provide a marketing advantage which will outweigh price considerations in many cases.

46. In this context, we were concerned to hear evidence from the PHLS that survey work had shown that cheaper compound meat products on sale in the UK, such as burgers and sausages, were more likely to be contaminated with Salmonella[121] than such products which were of higher quality and price. Mr William Jermey of the BMMA said that these lower-priced products were outside the control of the Association[122]. Some retailers were setting price specifications too low[123], and this led to "under the railway arches" meat manufacturing operations[124]. The BMMA called for greater regulation and enforcement of hygiene at the lower price end of the meat manufacturing industry[125]. We agree with the BMMA, and others who gave evidence to us, that all consumers have a right to expect their food to be safe from contamination, irrespective of price[126]. It will be a major test of the Food Standards Agency to raise the safety standards of lower-priced food, meat and non-meat products alike, to those of more expensive and controlled foodstuffs.

Non-microbiological food safety risks and potential risks

Pesticides

47. Microbiological hazards account for the vast majority of acute food poisoning cases in the UK, but there is a wide range of other risks which are of actual and potential concern to the public, even leaving aside the question of the long-term effects on health of the nutritional quality of diet. As with microbiological safety, the Government and, in the future, the Food Standards Agency, will need to make a careful assessment of all non-microbiological risks and the regulatory systems in place to minimize and, where feasible, eliminate such risks. We received a substantial amount of evidence on the potential risks from pesticide usage and the techniques of genetic modification which are increasingly being developed for food production purposes. In the former case, it is well-established that pesticides are toxic and the regulatory systems in place for obtaining approvals to market pesticides, and for surveying levels of pesticides residues in food, are designed to ensure that this toxicity is not permitted to harm human health. These systems are fully explained in the evidence supplied to us by the Government and the Pesticides Safety Directorate, the Executive Agency of MAFF which is responsible for the regulation of pesticides[127]. The previous Agriculture Committee also carried out an in-depth inquiry into the Pesticides Safety Directorate in 1995[128].

48. Mr Peter Riley, Food and Biotechnology Campaigner for Friends of the Earth, presented a well-argued case against the level of usage of pesticides in intensive farming, and made a number of telling criticisms of the current system for regulating pesticides approvals and usage. He did concede, though, that it was "very, very difficult"[129] to link particular illnesses in people to consumption of residues of pesticides in food. This does not mean that absolutely no risk exists, for it is never possible to be fully certain of the extent to which exposure to pesticides in food may be a contributory factor in long-term chronic illnesses such as cancer. The absence of proven risk does not mean there is an absence of risk. Instances of misuse of pesticides by farmers and growers do occur, and some have been identified by pesticides residues surveillance: for instance, 3 lettuce growers have been successfully prosecuted over the last 3 years for misuse of fungicides in winter lettuce[130]. This does not, however, imply any tangible danger to the public because of the wide safety margins built into pesticides residue limits[131].

49. The Food Standards Agency White Paper proposes to leave responsibility for the evaluation of food safety aspects of pesticides with the Pesticides Safety Directorate, contrary to Professor Philip James's advice that it should have been transferred to the FSA. The White Paper states that "The food safety evaluation of pesticides and veterinary medicines is part of an integrated process which is designed not only to protect the consumer but to safeguard the user of the product, neighbours and bystanders, the environment and - for veterinary medicines - the target animal as well"[132]. The Government does however propose a number of mechanisms through which the FSA will be able to act to influence the pesticides evaluation process, including an effective veto on pesticides approvals. Surveillance of residues will remain with the PSD (and, in the case of veterinary medicines, with the Veterinary Medicines Directorate), but the White Paper proposes that the FSA should work closely with the PSD and the VMD in drawing up their surveillance programmes and should have powers to undertake its own surveillance "should it consider it necessary to supplement the PSD/VMD programmes"[133]. We consider that public confidence in the safety of food in respect of pesticides and veterinary medicines residues would be enhanced if the surveillance programmes were carried out by the FSA wholly independently of the authorities responsible for product approvals. We further consider that the Agency should actively promote the results of its surveys in the consumer media.

Genetically-modified organisms

50. Techniques of genetic modification used in food production are subject to considerable public mistrust, combined with a low level of knowledge about biotechnology (the lowest in Europe, according to a Sainsbury's poll cited by Mr Riley of Friends of the Earth[134]). Friends of the Earth stated that "The introduction of genetically modified organisms [GMOs] into the human food chain has been done without adequate public debate concerning the need, ethics and risk involved. It is important that the debate takes place in the light of full information before any further releases or approvals for GMOs are made"[135]. Others vigorously questioned the need for genetically-modified foods, and called, at the very least, for labelling and segregation of all such foods[136].

51. Advice on approval and labelling requirements of foods containing genetically-modified organisms or derived from GMOs is the responsibility, in the UK, of the Advisory Committee on Novel Foods and Processes (ACNFP), which assesses their safety, and the Food Advisory Committee, which considers labelling requirements for such foods. These functions are carried out in accordance with the provisions of the EU's Novel Foods Regulation. In essence, the Government's position on labelling is that "The UK is pressing for all foods which contain genetically-modified ingredients to be clearly labelled so that consumers know what they are buying. In the case of refined products obtained from GM sources, such as oils, which contain no genetic material and are equivalent to existing food products, the UK accepts that labelling is not required"[137]. In cases where genetically-modified crops are commingled with conventional crops, and the presence of GMOs in the final product cannot be ruled out, the Government supports the labelling phraseology "this product may contain genetically-modified organisms"[138]. Dr Cunningham saw no sign that genetically-modified foodstuffs currently on the market presented any danger to the public, or to the environment, though he stressed the need for continued vigilance[139]. Professor Pennington, a microbiological rather than a biotechnological expert, described GMOs as "a very difficult issue", though he was less worried about them than about antibiotics as a food safety hazard[140]. The number of genetically-modified food products on the UK market is currently limited but is likely to grow quite fast. During our visit to the USA we encountered strong resistance amongst politicians and industry to the mandatory labelling of GM products on the grounds that such labelling implied a risk over and above conventionally-produced foodstuffs where they firmly believed that no such additional risk existed. It is our view that consumers have a right to know if foods contain genetically-modified organisms, or if there is a possibility that they may contain them, and we fully support the Government's labelling policy for such foods. GMOs also have potential environmental consequences, but these matters lie outside the scope of this Report. We strongly support Dr Cunnningham's call for continued vigilance both on the food safety and environmental consequences of GMOs. These are issues to which we may return in a later inquiry.