Select Committee on Food Standards First Report


Submitted by the National Heart Forum


  1. The National Heart Forum (NHF) is a alliance of over 35 national organisations—from the medical, health and public interest sectors—and individual expert members, all involved in preventing coronary heart disease—the leading single, yet preventable, cause of death and disability in the UK.

  2. It is the NHF's hope that the Food Standards Agency will play a significant role in the formulation of the nutrition policies which would assist with the prevention of chronic diseases such as coronary heart disease. Diet and nutrition are key factors in the development of coronary heart disease, as well as in stroke and in other chronic diseases such as cancer. As our 1997 Looking to the Future conference report states: "there is considerable evidence that the composition and the quantity of our dietary constituents are critical, possibly fundamental factors, in the development of atherosclerosis and coronary heart disease.1" Current figures set premature deaths from food poisoning at around 74 per year. In contrast, nutrition is believed to underlie the majority of the 150,000 deaths from coronary heart disease annually2.

  3. The rate of decline of coronary heart disease has been slower in the UK than in other similar developed nations, such as Australia, Sweden and the US. Medical and health professionals believe that the failure to implement a successful nutrition policy is a significant factor in the UK's lower rate of decline. There are two clear instances where nutrition policies are not working: intakes of fat and saturated fat in the UK are still substantially above the Government's recommended levels; and intakes of vegetable and fruit are still too low at only three of the five portions (400g) recommended daily, and even less in Scotland, northern England and among children and low income groups3.

  4. We are very concerned that, as the draft Bill stands, the opportunity to make a real impact on food standards, including nutrition, will be missed.

5. Our main concerns are that:

    —  the FSA should be given an appropriate remit to promote as well as to protect the public's health;

    —  the FSA should have the power to address nutrition, and formulate nutrition policy, as well as food safety issues;

    —  public health professionals should be appropriately represented in overseeing the work of the Agency;

    —  funding arrangements for the FSA should not have a negative impact on the diets of low income consumers.


  6. The NHF welcomes the draft Food Standards Bill, to establish the Food Standards Agency ". . . to protect public health from risks which may arise in connection with the consumption of food . . ." (Clause 1(2). However, we are concerned that the protection it offers will be interpreted in a narrow, safety-only context, and not with the longer term prevention of food—and nutrition—related disease. For the Agency to play a genuine role in improving public health, it must be concerned with both promotion and protection of public health.


  7. We have always argued that nutrition should have a high status within the Agency, and to some extent this was reflected in the White Paper, but we are concerned that this has not been translated to the draft legislation. Whereas the White Paper specifically mentions "nutrition" within its proposals (5.6 to 5.15) and, the primary guiding principle states that the essential aim of the Agency is the protection of public health in relation to food and nutrition; nutrition is still not explicitly mentioned in the draft Bill.

  8. We are concerned that, if nutrition is not specifically mentioned in primary legislation then the interpretation of the Bill concerning nutritional aspects will be ambiguous and its implementation weak, because those clauses which are meant to encompass nutrition are not sufficiently inclusive. We believe that if this draft Bill is given assent, then the Agency runs the risk of being left without sufficient power to deal with those issues and aspects of nutrition which were proposed in the White Paper.

  9. The NHF therefore strongly recommends that the draft Bill be amended to include the word nutrition in the main objectives of the Agency, so that "The main objective of the Agency in carrying out its functions is to protect and promote public health from risks which may arise in connection with the consumption of food . . . and other wise to protect the interests of consumers in relation to food and nutrition".[Clause 1(2)]


  10. The Agency should be established as the much-needed, co-ordinating hub for food and nutrition policy in the UK. In order to do this we believe that the draft Bill must, again, explicitly mention nutrition—and that this should also be extended to be included in its information provision and research and policy development remit.

  11. The Agency should therefore also have responsibility for:

    —  the surveillance of the nutritional status of the population;

    —  the definition of the health education message on nutritional issues;

    —  and policy formulation and advice to Ministers.

  12. The latter is of particular importance when considering the development of nutrient standards, especially in the light of increased processed and prepared foods.

  13. The NHF also recommends that, in order for the Agency to fulfil its nutrition responsibilities effectively as a main function, these must be more clearly defined than those currently set out in the draft Bill. This could be done by including "nutrition" in Clause 9(1)(a) on the function of the Agency: will develop policies ". . . relating to food safety or other interests of consumers in relation to food and nutrition."

  14. On the basis of the nutrition role set out for the Agency in the White Paper, and implicit in the Bill, we recommended that the Government reconsider its proposal to the Committee on Medical Aspects of Food Policy (COMA) to be jointly controlled by the Agency and the Department of Health, and that COMA should report directly to the Agency. This will also ensure that COMA's advice is free from political pressure which could arise by having a secretariat spanning both bodies.

  15. This shift of responsibilities would mean that the Agency had the primary responsibility for the formulation of nutrition policy.


  16. The NHF welcomes the draft Bill's stipulation that links between different government departments will be promoted. However, we hope that the Agency will work in consultation, not competition, with other government departments.


  17. The NHF is pleased to note that the Agency's membership will represent a reasonable balance of relevant skills and experience [Clause 2 subsection (2)], and that certain members will have a particular knowledge and experience of food safety or other interests of consumers in relation to food. In recognition of the Agency's public health remit, we recommend that this should be extended to include experience in public health and/or nutrition and that public health professionals are involved in numbers and positions sufficient to inspire confidence in the decision-making and priority setting processes.


  18. We are aware that a separate consultation document has been published on the Government's proposed schemes, to raise funds for the Agency, and we will be responding to this in due course. However, the NHF would like to stress our concern that any levy or fee-scheme on the industry will not result in the costs being passed on to consumers through an increase in the price of food. For low income consumers in particular, who spend a greater proportion of their income on food, this will be detrimental, and act in direct contradiction to the Government's overall aim of reducing health inequalities in society.


  19. The creation of a Food Standards Agency presents the best opportunity of recent years to formulate a national food and nutritional strategy, developed by an independent body where nutrition and safety are regarded as co-equal in terms of function and staff expertise. But for nutrition and safety to be so regarded, the nutrition functions of the Agency should be strengthened beyond those inferred by the draft Bill.

March 1999


  1 National Heart Forum (1997): Coronary Heart Disease Prevention; Looking to the Future.

  2 British Heart Foundation Health Promotion Research Group/Statistic Database (1997).

  3 National Heart Forum: At Least Five a Day; Strategies to Increase Vegetable and Fruit Consumption. The Stationery Office. 1997.

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