Select Committee on Food Standards First Report


Submitted by The National Farmers' Union of England and Wales



  The National Farmers' Union of England and Wales (NFU) supported the concept of a Food Standards Agency (the Agency) in our responses to the James Report and to the White Paper: The Food Standards Agency: A Force For Change. We welcome the move to have legislation in place by the beginning of next year and continue to wholeheartedly support the objectives of the Agency in protecting public health in relation to food.

  We have already welcomed the guiding principles for the Agency laid down in the White Paper. The success of the Agency in meetings its responsibilities will also depend upon the calibre and cohesiveness of its Chairman and members, and the effectiveness of its Chief Executive. The Agency must act, and be seen to be acting, openly and in full consultation with the whole food chain from producers to consumers.

  The NFU therefore welcomes the requirement upon the Agency to "prepare and publish a statement of general objectives it intends to pursue, and general practices it intends to adopt".


  We have three specific areas where we would like to comment on the interpretation of the White Paper into the draft Bill:

  First the main objective of the Agency. The NFU agrees that the main objective of the Agency should be to protect public health from risks which may arise in connection with the consumption of food. However we would question the words "and otherwise to protect the interests of the consumer in relation to food" which first appear in clause (2) and are repeated elsewhere in the Bill. This seems to be too wide-ranging and may detract and distract from the basic objective of public safety in relation to food. The core functions of the Agency must be focused. We are not convinced that words in the draft Bill achieved this. We would prefer to see something along the lines of: "and otherwise to protect the interests of consumers in relation to the safety of food and their ability to make informed choices."

  This would enable the Agency to offer advice to consumers without being too prescriptive whilst informing them of choices available.

  Secondly, the the White Paper emphasis, particularly in the Guiding Principles, was given to the Agency's assessment of food standards and safety should be based on the best available scientific advice, provided by experts invited in their own right to give independent advice. We are doubtful that this principle been clearly translated into the draft Bill and advocate that reference should be made to information based on best available scientific advice in clause 10 and 12 (3).

  We believe that it is vital that the main source of advice is obtained from the advisory committees to avoid any perception that it might be based on a subjective approach. All advisory committees should act in an open and transparent manner, with the necessary skills and expertise from science, industry, consumers and the wider public interest.

  Thirdly, it follows from the transparency and openness with which the Agency will give advice and information, that consumers should be given the opportunity to make informed choices and that this should be coupled with advice on risk assessment in relation to cost/benefit. We welcome that the Agency has this remit and that it will need to be able to supply the necessary information in this area.


  As already stated, the Chairman, Members and Chief Executive of the Agency must be seen to be people of proven ability and high standing, untainted by vested interests, who will be able to ensure a successful performance and image by being seen to act in an effective and cohesive manner. A good communications strategy will enhance the work of the Agency and ensure that it maintains the confidence of the general public and the whole food sector.

  The question of how the Agency will deal with the unsubstantiated media reports of food safety issues, which can be attended by a fuelling of public emotion, also needs to be addressed. The Agency will need to act proportionately and with relevant speed to ensure public confidence in the Agency is maintained and strengthened and to independent offer advice with a "minister hovering in the background". We would reiterate our response to the White Paper that research and surveillance is an area where scientific progress and technological developments must be updated. We welcome this inclusion in the draft Bill (clause 12(2) as in the past agriculture and horticulture have been damaged by announcements which at a later stage were unconfirmed or even reversed. We see the Agency as having an important role in ensuring a better system of communicating these issues to the public.

  Excellent communication between the Ministry of Agriculture, Fisheries and Food and the Agency will be important. We welcome that consultations that will have to take place between Ministers and the Agency on veterinary medicinal products; the control of pesticides and regarding genetically modified organisms. This should ensure that any consumer concerns are taken on board.

  With regard to the Agency's functions on nutrition policy it is noted that concordats between the Agency and the UK health departments will set out their respective responsibilities. Good communication of intelligible, scientifically-based information to the general public is vitally important. Confusion about who gives the right message on diet and health and reigned for too long.


  The NFU is firmly of the view that the Agency should be financed by government. This will ensure that the Agency will be seen as acting in all consumers' interest. Finance from any part of the food chain will be seen by many consumers as threatening its independence. Moreover, any charges within the food industry would almost inevitably be passed onto the final cost of the food. Funding out of general taxation would therefore both improve the standing of the Agency and be fairer in that spending on food and drink consumption is a higher proportion of poorer consumers' total income.

  The option put forward by Ministers, a flat rate for retail and catering outlets, although relatively simple to collect and covering imported as well has home produced food, would be widely regarded as inequitable. This is particularly pertinent to small village and rural shops, including farm shops, which are struggling to offer a service to rural communities and yet would face the same charges as large retail and catering outlets.

  The discussion paper on the forthcoming Rural White Paper highlights the importance of these outlets to rural communities; if Ministers proceeded with a levy, despite the misgivings expressed above, then consideration should be given to extending the exemptions to these outlets.

  Finally the NFU is concerned that the imposition of a levy on food outlets would act as a deterrent to food premises registering with local authorities. Outlets were assured at the time of the Food Safety Act 1990 that registration was being introduced to identify outlets to assist control in, for example, a food scare. However if registration now carries a form of taxation it will be a serious deterrent to smaller or temporary outlets to register. As one London authority is reported to have "lost" a large number of food premises that should be on its register, a levy opens the prospect of the main purpose of the register—to assist food safety enforcement—being progressively undermined. This reinforces our call for total financing of the Agency to be undertaken from central funds.

March 1999

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