Select Committee on Food Standards First Report


Submitted by the British Hospitality Association

  1. The British Hospitality Association is the national trade association for over 25,000 hotel, restaurant and catering establishments in the United Kingdom. We are responding to the invitation to comment on the draft legislation for establishing a Food Standards Agency, and the proposed scheme for recovering some of the associated costs via a levy.


  2. We welcome the creation of an independent body, which we see as an important step towards improving food safety through better education and enforcement of existing legislation throughout the food chain, thereby restoring public confidence in food offered for sale by both caterers and retailers.

  3. We strongly support the decision not to license catering premises; we have always contended that current food safety regulations, where correctly and consistently enforced, are sufficient to ensure the provision of safe food and a consequent reduction in the incidence of food poisoning.

  4. We support the guiding principles and the proposed scope of the Agency in providing high standards from "plough to plate". As end users of the final product, caterers have often been held responsible for shortcomings in food safety which occur earlier in the food chain, and over which they have little or no control. The existence of salmonella in poultry is one example.

  5. We would wish the Agency to act transparently and the Government should act promptly on the advice given by it. The Agency should consult with the food service industry which, like the general public, requires clearly presented information to make informed choices. We believe that co-ordination of the Public Health Laboratory Service should be brought under the direct control of the Agency.

  6. We are concerned that there is no mention of the functions currently covered by the Local Authorities Co-ordinating Body on Food and Trading Standards, which fulfils an important role in relation to food safety policy in local authorities, making a significant contribution to consistent and even handed enforcement of legislation on a national basis. In this context, we also have some concern about future enforcement in the devolved administrations in Scotland and Wales. It would be an unfortunate outcome if catering businesses operating in, say, both England and Scotland had to comply with two different food safety regimes, with different requirements for staff training.

  7. We would wish to see an equitable balance of representation in the Agency's membership, with the inclusion of people with practical and experienced knowledge of the food industry.


  8. We recognise that the Agency will attract additional costs, but, since it will be carrying out public health functions, these should be funded out of general taxation. Certainly, the capital (start up) costs, at the very least, should be funded from that source. We do not believe that it is ethical to require private sector businesses to bear the cost associated with property, IT systems or redundancies resulting from duplication. We also have reservations about the accuracy of the estimate of £90, rounded up from £84, since this has been calculated on the basis of there being 340,000 registered catering outlets in the UK. In our view the real number may be 300,000, many of which may be exempt for various reasons, so that the £90 would, in practice, be significantly increased.

  9. Should it be decided however, contrary to our submission, to make direct charges, we firmly believe that these should be shared "plough to plate", and not by the catering and retail sectors alone, particularly since the Agency's remit includes the disposal of radio active waste, waste at sea and animal feed standards, none of which have a direct connection with the food service sector. If there is to be a levy, the costs should be equitably shared by those industries which will benefit from the functions to be carried out by the Agency. It is not only the catering and retail sectors which are required to be licensed and/or registered, thus the collection of a proportion of the Agency's running costs from producers, manufacturers, importers and wholesalers could just as easily be effected through Uniform Business Rates.

  10. We propose that finance allocated to local authorities for food safety enforcement should be ring-fenced and demonstrably used to improve and maintain such safety at the point of production, as well as at retail and catering premises.

  11. If a levy were to be introduced and applied to catering businesses, we believe that in the interests of creating a level playing field, it should also apply to small hotels and guest houses with less than four letting bedrooms, which are currently exempt from registration. We would however, be opposed to complicating matters further by applying different rates of levy according to the size of the business; this would considerably increase bureaucracy.

  12. In the longer term, we are concerned that the Government's undertaking to recover no more than £50 million from the levy will cease to apply leaving the catering and retail sectors to bear an even greater share of the costs of food safety enforcement. Given that the reasoning for applying any levy is highly questionable, we would strongly urge that the levy proposal is withdrawn.

March 1999

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