Submitted by the Institute for Animal
The Institute for Animal Health (IAH) is a major
provider of basic and applied strategic research on the infectious
diseases of farm animals. This research is of direct relevance
to the remit of the FSA since it is concerned with ensuring continuity
of the food chain through the supply of healthy animals farmed
under high standards of welfare, freedom of animals from zoonotic
pathogens and residues and the development of tests to assist
in the detection of disease pathogens. Its main customers are
MAFF and the BBSRC. Other important customers include the Department
of Health, the Medical Research Council and the European Union.
1. The results of the IAH's research are of
considerable importance to the Agricultural and Health Departments
and to the food industry. The work on salmonella and E. coli
0157, the transmissible spongiform encephalopathies (scrapie,
BSE and CJD) and mastitis are especially pertinent.
2. The comments that follow on the draft legislation
are largely related to the IAH's concern to maintain an excellent
UK science research base to underpin and inform government policy
in relation to food. However, we note that clauses 2 and 3 fail
to identify a role for England in the FSA. The legislation establishing
the FSA will run for the most part in a post-devolution United
Kingdom, yet there appear to be no guarantees that the English
nation will be represented in the membership of the Agency. This
exclusion is the more extraordinary in that the need for an advisory
committee for England is considered in clause 5 of the draft Bill.
3. Clause 9 covers the development of food policy
and the provision of advice to public authorities and clause 10
addresses the provision of advice, information and assistance
to other persons. In a rapidly evolving area such as food (cf
genetically modified food crops) these functions need access to
up-to-date research information and need to be able to commission
research which is seen to be independent of commercial interests
to answer specific questions or issues as they arise. The FSA
needs a competent research community to support its policy and
advisory roles and the legislative framework needs to make provision
for this. The co-ordination of an underpinning research base for
food standards requires a long-term commitment and can not be
sustained satisfactorily on short-term needs.
4. Clause 12 covers the need to acquire and
review information and to monitor developments in science. While
it is certainly an important function of a FSA to be fully conversant
with current knowledge about food matters, this is essentially
a reactive strategy and many major food problems emerge quite
unexpectedly and require extensive pro-active research to find
5. The IAH notes (clause 12.2b) that the FSA
will be empowered to carry out, commission or support (whether
by financial means or otherwise) research on "those matters,"
which will include "diseases" (clause 12.2a). However,
the clauses that follow (13 to 16) deal, in depth, with monitoring
and surveillance matters but there are no proposals dealing specifically
with research matters. This implies that, within the context of
this legislation, the term "research" is seen only in
terms of the collection and analysis of data generated through
routine tests and hygiene checks. Surveillance is an important
part of any food monitoring activity, but it can only allow identification
of problems; it does not necessarily help determine what to do
about the problem. That insight can only come from properly designed
and controlled research.
6. If, on the other hand, "research"
encompasses that activity recognised by this, and other, Institutes,
i.e., innovative, strategic investigations into matters relating
to disease processes, control of infections (by, for example,
vaccines, selective breeding for resistance, epidemiological modelling),
then additional clauses will be required to ensure that the Agency
has available to it the necessary independent expertise at its
disposal to draw up requirements, assess proposals and to assess
the results of that commissioned research.
7. However, the IAH would note that there are
already, in the area of food standards, research commissioning
departments in support of policy in the Chief Scientist's Group
(CSG) of MAFF and the Department of Health and, in support of
the basic underpinning science, in the Biotechnology and Biological
Sciences and Medical Research Councils. It would be important
to ensure that, if an additional research commissioning Agency
were to be introduced, this would not be at the expense of existing
8. Work on infectious disease, in the animal
at least, is inevitably pre-farm gate. Some diseases of relevance
for animal welfare are of no concern for the safety of food for
humans, but are important in ensuring continuity of food supply.
Other diseases which are of crucial importance in ensuring safety
of food for humans are of no disease consequence for farm animals.
It would be prudent, therefore, to co-ordinate all work of this
nature within a single commissioning mechanism, either using a
single commissioning agency or having a single body overseeing
the co-ordination of research. To give dual or split responsibility
in this area, for example to MAFF and the FSA, could lead to a
lack of co-ordinated strategy with no long-term objectives, major
gaps in research capability and responsiveness in some areas and
inefficient duplication of effort in others.
9. The Institute does not feel it is competent
to comment on the matter of the levy and methods for raising it.
It does wonder, however, if the target figure for new income is
realistic. Despite the high profile of food safety in the public
mind at present, the IAH believes that the current policy of reducing
research on the diseases of food animals is short-sighted and
sends the wrong signals to the public. Whether the much-needed
additional funds come via the Agency or directly into the CSG
of MAFF, is of little importance, the restoration of funding
levels should be seen as a minimum target.