Select Committee on Food Standards First Report


Submitted by Marks & Spencer

  Following the request for written evidence to the House of Commons Food Standards Select Committee, we are pleased to reply as follows.

  Essentially our views have not changed from the notes which we sent in response to the original White Paper in early 1998. We recognise that our comments at that time on licensing have not been carried through in the draft Bill, but this in no way diminishes our support for the creation of an independent Food Standards Agency.

  We believe the contents of the Draft Bill represent a significant initiative which will improve food safety standards in the UK.

March 1999



  We welcome the publication of the recent White Paper "The Food Standards Agency—a Force for Change" and we endorse the majority of its proposals.

  We agree with the Guiding Principles set out in the White Paper—in particular that any decisions or action taken by the Agency should be in proportion to the risk, paying due regard to the costs as well as the benefits to those affected, and without raising unjustified alarms. This measured approach reflects our own experience of risk management in the food supply chain.

  This initiative presents an opportunity for significant improvements to the structures that help to assure a supply of safe and wholesome food in this country.

  We are particularly pleased to note that the Agency's Commission will consist of people with relevant experience and will not simply give representation to any particular interest group.

  We will not raise again issues on which we have previously commented, such as nutrition, and where we are not in full agreement with the proposals in the White Paper.

  We believe the priority now must be to make the Food Standards Agency a success and we will give it our full support. We endorse the view that there is no need to wait for the formal establishment of the Agency—changing of attitudes must start at once.

  We would like to respond to some specific issues raised in the White Paper as follows:


  We are not aware of any significant areas where existing legislation in relation to food safety is deficient. We repeat our earlier comments calling for a greater willingness by enforcement authorities to use their existing powers to stop unsafe food practices on a consistent basis across the country. A firm drive is needed to ensure that existing premises and people involved in food businesses are "fit for purpose" to meet the required standards.

  The White Paper acknowledges that the scope for legislation may be limited by our European obligations to maintain the Single European Market. In this situation where legislation may not be possible, we think it is important to remember that any calls for voluntary action must not place our customers or UK producers at a disadvantage with respect to foods imported from abroad which might not be obliged to follow such guidelines.


  We have previously commented on the essential need for technically competent staff to be responsible in every food business for managing food safety controls. This principle applies equally to every element in the food chain, no matter how large or small—from farm to plate.

  We are attracted therefore to a scheme where a licence is required to operate a food business and which is conditional on having appropriately trained and qualified staff, together with premises adequate for the purpose intended.

  In every case, the level of qualification demanded should be proportionate to the potential risks associated with a particular kind of food business. Many of the elements of this approach are already in place under existing legislation—for example the obligation to carry out a risk assessment and to provide adequate training for staff involved with food handling.

  What seems to be missing is a legal requirement that the managers of a food business have an understanding of why these measures are important and a commitment to ensure they are observed.

  This approach will, in turn, focus attention on the competence of enforcement authorities and their own ability to assess compliance with requirements of any operating licence.


  We recognise the arguments about the funding of the new Agency. Clearly, the money available to the Agency must be adequate to ensure its success. At the same time, the priorities of the Agency must be set in the light of any budgetary requirements.

  We believe the way in which money is raised to fund the Agency must be by the most efficient and fair means, avoiding an expensive bureaucracy. Whatever the outcome of this debate, the customer must be given value for money, and will ultimately have to pay the cost.


  We generally support the proposals concerning the sharing of research commissioned by the Food Standards Agency with the existing structures.

  We do however believe it is particularly important for the Agency to identify gaps in the research strategies of existing groups in relation to food safety. For example, more recognition should be given to the need to improve scientific knowledge of the links between animal health and food safety. The recent events concerning E. Coli 0157 contamination of meat underline this point.

  The Agency should also have a role to identify unnecessary duplication of research and bring a national focus to work involving food safety.

  We hope that our comments will be helpful and we are of course prepared to provide any additional information that may be needed.

  We look forward to participating in and contributing to the success of the Food Standards Agency.

February 1998

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