Submitted by Jeremy C Leach
1.1 I am an Environmental Health Manager working
for Wealden District Council in East Sussex. I qualified in 1978
from the University of West of England (formerly Bristol Polytechnic)
and have been involved in food law enforcement and education for
the majority of the last 19 years. Since qualifying I have gained
a Bachelor of Arts Degree in Psychology and for the past four
years I have been studying for the Degree of Doctor of Philosophy
at the University of Brighton. The subject of my research is public
and professional perceptions of food hygiene in public eating
places. I am a Corporate Member of the Chartered Institute of
Environmental Health and a Fellow of the Royal Society of Health.
1.2 The views expressed in this evidence are
those of the author and not the Wealden District Council.
1.3 I have decided not to comment section by
section of the Bill, but to make more generalised comments which
I hope will be useful, with a particular focus on the proposals
for a levy scheme for recovering costs from the food industry.
2. GENERAL COMMENTS
2.1 I broadly welcome the proposals concerning
the setting-up of a Food Standards Agency. In particular I welcome
the main objective of the Agency being to protect public health.
2.2 I have no objection to the proposals that
the Food Standards Agency will have powers to monitor and regulate
the performance of local authorities in respect of enforcement
work, this is considered essential. However I would not welcome
any subsequent developments in relation to a centralised inspection
service. The current arrangements work well, a locally based inspection
service is more accountable to the people they serve. The status
quo is also in-line with the Government's White Paper, "Modern
Local GovernmentIn Touch with the People" (Cm 4014).
This White Paper adds strength to an approach based on the close
relationship between local government and the communities they
2.3 In my view there must be a mechanism for
links to be made between the proposed Food Standards Agency and
the Department for Education and Employment. This should be featured
in the Bill or agreed at Ministerial level. There is a considerable
weight of evidence and argument for food hygiene education to
be introduced uniformly in schools.
3. COMMENTS ON
3.1 I am opposed to the introduction of an annual
levy scheme on food businesses. The principal reason for the setting-up
of a Food Standards Agency is to end the conflict of interest
which it is said the Ministry of Agriculture, Fisheries and Food
may have, and to restore public confidence in the Government to
provide safe food. The credibility of the new Food Standards Agency,
in my view, will be diluted, if a major part of its funds emanate
from the food industry. The public will evidence that as influence.
Once those seeds of doubt are sown it will be difficult to stop
3.2 The collection of the levy will impose further
administrative pressure on already hard pressed local authority
environmental health departments and be an added source of conflict
between those departments and local businesses.
3.3 If the Government is minded to introduce
a levy then it is noted that the proposed levy does not apply
to all groups of food businesses, for example food manufacturers,
this in my view is inequitable.
3.4 It is not clear how the proposed levy will
affect butchers shops which may also be subject to a licence fee
later this year, when Regulations are to be introduced.
3.5 There is no attachment to the levy of improved
standards which in my view is an opportunity missed. Consequently
there are no rewards for premises demonstrating high standards
of food hygiene over those with lower standards.