Select Committee on Food Standards First Report


Submitted by the Institute for Animal Health

  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 solutions.

  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 research capability.

  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.

February 1999

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