MEMORANDUM 32
Submitted by Dr Richard A E North
EXECUTIVE SUMMARY
1. The Bill sets the agency objectives it cannot
achieve. It may thus be faced with dilemmas similar to those which
have confronted Ministers, where it is forced on to the defensive,
seeking to explain why it has not acted—or acted effectively
(2.02-2.03).
2. There should be included in the Bill a statutory
duty for the Agency to consult with interested parties (which
should include food producers) in the formulation of policy, and
to involve food producers where necessary (2.04).
3. The Bill fails to recognise that, in assisting
the producer in key areas, it would also improve the lot of the
consumer (4.02-4.11). The Quality of information produced
by the Agency is paramount. To that effect, a central part of
the Agency needs to be an independent, multi-disciplinary review
body, charged with the sole function of quality assessment (4.12-4.13).
4. It will be essential that the Agency consults
with industry when offering advice and embodies in its procedures
provision for reviewing and amending advice in the light of technical
and scientific developments. There should also be provision for
a formal challenge of advice given with a statutory right for
interested parties to be heard (4.14).
5. The absorption of the Meat Hygiene Service
(MHS) will compromise the independence of the Agency. It cannot
set its own standards and then monitor its own performance in
achieving them. Nor can it monitor other agencies without inviting
suspicions that it is seeking to expand its own enforcement activities
(5.03-5.07).
6. There are other agencies responsible for
monitoring local authorities. The Agency cannot assume such a
role without first clarifying the roles of other bodies (5.07-5.08).
7. It is essential to review not only quantitative
aspects of any enforcement activities, but also qualitative performance.
This will require a strong field presence by experienced officials,
for which no provision seems to have been made (5.09-5.10).
8. There is a serious constitutional question
in relation to local authority enforcement activities in that
unelected members of the Agency may interfere with the decisions
of elected public representatives. Directions must be reserved
for the minister (5.11-5.12).
9. There is an urgent need to reform the structure
of expert advisory bodies. In the Agency, the opportunity exists
to set out statutory requirements for the selection, recruitment
of members, their methods of working and other matters relating
to their functioning (6.01-6.12).
10. The effect of the charging regime will be
to reduce consumer choice, increase prices and reduce food safety.
If the agency is required to improve public health, then the public
should pay for it . . . through general taxation (7.01-7.06).
1. INTRODUCTION
1.1 This author is a qualified environmental
health officer with over 25 years of practical experience
of food safety issues, covering all aspects of food production
from the farm to the plate. After a local authority appointment
as a senior environmental health officer specialising in food
hygiene and safety, I worked nationally as an independent food
hygiene consultant advising hotel and catering groups on hygiene
standards.
1.2 Additionally, I developed a specialist contract
cleaning operation, and took an active role in developing industrial
cleaning techniques in food premises, culminating in my writing
what is the only current book on cleaning professional kitchens.
1.3 I have worked in a consultancy role for
a commercial company developing disinfectants for food premises,
for a chemical manufacturer producing cleaning products for the
food industry, and for an equipment manufacturer producing machines
for food premises cleaning.
1.4 In the 1980s, I joined a project management
group designing and developing major cook-chill operations, mainly
for the NHS, including the development of operational and hygiene
strategies. From there, I moved on to work for the egg industry
during its troubles in the post-Edwina Currie era and then undertook
a five year research project culminating in the award of a PhD
following submission of a thesis on the "Quality of Public
Sector Food Poisoning Surveillance".
1.5 Concurrently, and subsequently, I worked
for two groups of small abattoir owners, and for specialist cheese
makers, representing them on legal and technical issues.
1.6 I am a registered food hygiene examiner
with the Royal Institute of Public Health and Hygiene, and am
a frequent lecturer on advanced food hygiene courses. I teach
post-graduate students on food safety matters and have recently
completed a book for the Chartered Institute of Environmental
Health on food premises inspection techniques. I am frequently
employed as an expert witness in court proceedings and gave evidence
to the Fatal Accident Inquiry on the Lanarkshire E. coli
outbreak.
1.7 Currently, I am working on a major (private
sector funded) research project on "the management perspective
of food-poisoning causation".
1.8 It should be made clear that I am fundamentally
opposed to the concept of a food standards agency. However, since
it is clearly the Government's intention to proceed with this
venture, this submission is offered with a view to ensuring, as
far as is possible, that the agency will be of some value.
1.9 An analysis of the key provisions of the
Bill, and related issues, forms the basis of this submission.
Specific issues addressed are: (1) the agency objectives; (2)
development of policy; (3) the acquisition and provision of information;
(4) setting standards and the monitoring of enforcement action;
(5) the role of advisory bodies; and (6) charging.
2. THE AGENCY
OBJECTIVES
2.1 Effectively, the main objectives of the
Agency are expressed in Clause 1(2) of the draft Bill, which is
as follows:
The main objective of the Agency in carrying
out its functions is to protect public health from risks which
arise in connection with the consumption of food (including risks
caused by the way in which it is produced and supplied) and otherwise
to protect the interests of consumers in relation to food.
2.2 There appears to be a fundamental problem
in the phrasing of this Clause, in that it sets the agency objectives
it cannot achieve. The problem is that the primary responsibility
for the production of safe, wholesome food rests with the producers,
processors, manufacturers, distributors, etc., of that food. No
agency can reach out into the factories, farms and kitchens of
the food "industry" to ensure that safe food is produced.
At best, external agencies can only create a climate (inter
alia through regulation, enforcement and the provision of
information) which will encourage the "industry" to
produce safe food—and punish its members when they fail
to do so.
2.3 In framing the Agency's objectives thus,
the government is in danger of turning the Agency into a hostage
to fortune, as it cannot "protect the public health from
risks . . . etc., ". With such a broad remit, the Agency
may be seen as (and, in fact, will be) assuming responsibility
for something which it cannot achieve. When or if failures occur,
it may wrongly be criticised for failure to act in matters over
which it has no control. Without the power to contain risks, the
Agency may then be faced with dilemmas similar to those which
have confronted ministers, where it is forced on to the defensive,
seeking to explain why it has not acted—or acted effectively—with
the attendant loss of credibility.
2.4 Without in any way seeking to weaken the
remit of the Agency, therefore, this author suggests that the
Clause might be better framed in terms of encouraging and
promoting the production of safe food. And rather than
"protecting" the interests of consumers in relation
to food, it might best address consumer needs by representing
their interests, notwithstanding that the true representatives
of the "consumers" are their elected Members of Parliament.
3. DEVELOPMENT OF
FOOD POLICY,
ETC.
3.1 It is axiomatic that the development of
(good) policy with regard to food safety will require accurate,
timely and complete (or as complete as possible) information,
especially if policy initiatives result in legislation or other
control models which require industry participation or compliance.
3.2 Policy development should be regarded as
a free-flowing process in that the result of any such development
should represent that which is both necessary and practicable.
To that effect, the Committee is enjoined to take note of the
comments of the 1989 House of Commons Agriculture Committee (Salmonella
in Eggs) and, in particular page xxi (paragraph 73) the relevant
part of which read:
"Whatever legislation is passed by Parliament,
a problem as complex as salmonella will only be solved if there
is a co-operative approach on the ground: the Government cannot
simply lay down rules and punish people for breaking them".
3.3 The essence of co-operation is extensive
(and meaningful) consultation with all affected organisations,
including producers of food. This is not a matter of favouring
the producer over and above the interests of the consumer but
a pragmatic, intelligent strategy for enhancing consumer safety.
3.4 However, in the consultation document, there
is a paucity of reference to any relationships with food producers.
Yet without the active involvement (and support) of food producers,
it is unlikely that policy initiatives can be successful. Therefore,
there should be included in the Bill a statutory duty for the
Agency to consult with interested parties (which should include
food producers) in the formulation of policy, and to involve food
producers where necessary.
4. ACQUISITION AND
PROVISION OF
INFORMATION AND
ADVICE
4.1 In pursuit of it's objectives, it is clear
from the draft Bill that the major thrust of the Agency's activities
is focused on the provision of information, assistance and advice.
Nevertheless, the emphasis is very much on the provision of information
to government and public authorities, and to the public. Provision
of information and advice to the producers of food is not specifically
mentioned except in terms of conveying "information and developments
in food science . . .".
4.2 However, in relation to microbiological
hazards, the food industry is faced with constantly changing threats.
New pathogens—or variations on existing pathogens—are
constantly emerging, and changes and developments in processes
constantly involve the new risks. Therefore, it is essential that
the "industry" is fully appraised of developments in
the epidemiology of food-borne disease, comprising accurate, well-presented
and timely information, with which to develop and refine control
models. Of particular value are accurate data on food poisoning
causation, drawn from food poisoning investigations.
4.3 Moreover, if such information is conveyed
to the food industry, most responsible food producers will respond
positively.
4.4 This much was put by this author to the
House of Commons Agriculture Committee in oral evidence on 15
December 1993 (Report, page 144) when, as a representative of
the egg industry, I told members:
". . . We continually ask for information.
We continually put a lot of money and time and effort into trying
to analyse that information fairly and we find over the years—and
it is a progression over the years—that the availability
of information now is less by a substantial degree that it ever
was . . .. There is so little information now compared with a
few years ago that it is valueless. So in fact the authorities,
far from actually increasing our sum of the information, are actually
closing down all our avenues of information and we are less informed
than we ever have been, so that in response we try, but we find
this glass wall, this brick wall, preventing us getting near the
information.
If we get good informtion and we know what to
do, we will direct our members to whatever is appropriate, reasonable
and scientific in terms of control. What we cannot tolerate is
being fed spoonfuls of information which may or may not be correct
based on data which almost certainly is skewed by authorities
we do not trust. That is the situation we are in".
4.5 Six years on, the situation is hardly different
and it is in the provision of information useful to the industry
that the Agency could make the difference. However, in my PhD
thesis (1995), I carried out an assessment of the "Quality
of Public Sector Food Poisoning Surveillance in England and Wales".
In this I referred to work by US researchers Bryan, Bartleson,
Cook, et al (1991), who had written that surveillance is
needed:
. . . to identify relevant public health issues,
new hazards, information on risk assessment and factors which
had contributed to outbreaks. Its purpose is to inform the scientific
community, the public, homemakers, and the food industries,
enabling all those involved in the production of food, whether
directly or indirectly, to better formulate and implement food
safety precautions and strategies (my italics).
4.6 Crucially, their view (which this author
endorses) was that the provision of (surveillance) information
to "those involved in the production of food" is an
essential part of the surveillance function. However, the central
finding of my PhD study was that the surveillance agencies failed
to provide that information, mainly because they did not recognise
that food producers were legitimate "consumers" of the
information they produced. Essentially, the agencies were inwards-looking,
servicing their own needs, without reference to the needs of the
industry.
4.7 In this, it has to be said that no responsible
food producers will knowingly produce food which is harmful to
health; nor would they profit from so doing. To a very great extent,
the interests of producers and consumers coincide. In order to
"protect the consumer" therefore, it is essential that
surveillance information, in a useable form, is provided to industry.
4.8 Here, there are serious problems with the
framing of the Agency objectives and functions. The Bill formalises
and institutionalises the largely artificial split between producers
and consumer, "siding" with the consumer against
the producer. It fails to recognise that, in assisting the producer
in key areas, it woud also improve the lot of the consumer.
4.9 That is not to say that the agency should
be pro-producer—in the way that MAFF is so often (wrongly)
accused of being. But it should be pro public health, distributing
information to all those who have need of it, with a view to improving
public health generally. Food producers are essential recipients
of that information, and it should be a central part of the Agency's
remit to ensure the industry is properly serviced.
4.10 This presages another problem in that—as
far as the routine provision of information is concerned—the
Agency will not be the primary generator, but simply the recipient
of information produced by others. In terms of food-poisoning
epidemiological data, the primary producers are local authorities
(environmental health departments) and the Public Health Laboratory
Service (PHLS), over which the Agency will have no direct control.
4.11 Yet, in my PhD work, I found that the inadequacies
of information provision was compounded by serious and multiple
inadequacies in the conduct of food-poisoning investigations,
arising at least in part from the lack of training and relative
inexperience of investigators, the whole conditioned by interdisciplinary
rivalry between the professional groups staffing the different
agencies. In addition, there was a failure to exploit or develop
epidemiological technologies, which affected the ability of investigators
to resolve uncertainties identified.
4.12 Therefore, not only is the provision of
information important. The quality of information is paramount.
Neither government, public authorities, the public nor producers
of food are best served by low grade or inaccurate information.
So important is it to the public health interest that good quality
information is provided that it should be a central function of
the Agency to assess, on a continual basis, the quality of information
provided by itself and public sector agencies, and to promote
the acquisition and delivery of high quality information.
4.13 To that effect, a central part of the Agency
needs to be an independent, multi-disciplinary review body, charged
with the sole function of quality assessment. The Agency needs
to take a pro-active stance, actively fostering improvements in
the quality of information and should not fall into the trap of
accepting, uncritically, that which information-gathering agencies
chose to supply. It should dictate (and have power to dictate)
the nature of the information supplied. In short, the Agency must
address the quality issue, and improve the quality of information
provided. Within the structure of the draft Bill, it is not clear
as to how it can do this.
4.14 As regards the provision of advice, it
will be essential that the Agency avoids the temptation to offer
dogmatic, unrealistic or impractical advice. To that effect, it
is essential that it consults with industry and embodies in its
procedures provision for reviewing and amending advice in the
light of technical and scientific developments. There should also
be provision for a formal challenge of advice given, with a statutory
right for interested parties to be heard.
5. SETTING STANDARDS
AND THE
MONITORING OF
ENFORCEMENT ACTION
5.1 There can be no question that the independent
monitoring of enforcement activities could form a valuable and
constructive role for an independent agency, a role which neither
the Department of Health nor the MAFF have been able to perform
satisfactorily.
5.2 However, it is understood that the Agency
will absorb the staff and functions of the Meat Hygiene Service
(MHS)—which is a major enforcement enterprise. Therefore,
a significant function of the Agency will be enforcement (within
the meat industry). From the outset, therefore, the independence
of the Agency will be compromised as it will combine the roles
of an enforcement agency and a monitor of enforcement standards.
5.3 It offends against the very principle of
independence that any organisation should be able to set its own
standards and then monitor its own performance in achieving them.
This means that another body must set the standards and monitor
the performance of the Agency in respect of its MHS operations.
5.4 Then, at the very least—if there is
any question as to the performance of the MHS—authorities
subject to agency monitoring may well question the moral authority
of the Agency to review their performance when its own activities
may be substandard. This in turn will create considerable pressure
on the Agency to conceal any shortcomings in its own activities,
for fear of prejudicing its authority to criticise other authorities.
5.5 Basically, the relationship between the
MHS and the Agency has not been thought through. Either the Agency
is to be a monitoring agency or it is to be an enforcement agency—it
cannot perform both tasks adequately.
5.6 If, in the case of the MHS, the MAFF veterinary
service is to continue its auditing, there will then be a situation
where an operational arm of the independent Agency is to be "independently"
checked by staff of the very ministry which it is replacing, because
that ministry itself is not to be trusted with food safety matters.
Then, if the veterinary service continues to have responsibility
for public health matters—such as TB in cattle—which
fall within the remit of the Agency, we could then have a situation
where the agency is auditing the service which in turn is auditing
the Agency. Clearly, this could be a problematical arrangement.
5.7 As regards the Agency monitoring local authority
enforcement, this too is problematical. In the first instance,
there abounds amongst local authority officers a strong (and well-founded)
suspicion that the Agency—with its absorption of the MHS—is
an embryonic national hygiene service, planning to take over functions
from local authorities on similar lines to the Health and Safety
Executive. On this basis, as long as the MHS is part of the Agency,
there will be a suspicion that any findings or criticisms of local
authority activities by the agency will simply reflect its "hidden
agenda". The Agency will not be seen as an independent arbiter.
5.8 Assurances by the Minister as to the continuance
of local authority services are of little value. Ministers come
and go, and policies change. What one Minister might promise,
another Minister can change. Unless there are statutory limitations
on the enlargement of agency functions, its motivations will always
be suspect.
5.9 Furthermore, there are already two agencies
which have some responsibility for monitoring local authority
enforcement—LACOTS (the local authority co-ordinating body)
and the Audit Commission. The Agency therefore will enter into
an already crowded field where there is scope for disagreement
and discontinuity. Rather than improve matters, therefore, the
Agency may well create disruption and confusion, adding yet another
voice to the cacophony. The Agency cannot assume such a role without
first clarifying the roles of other bodies.
5.10 As to the detail of any monitoring, it
is essential to review not only quantitative aspects of any activities,
but also qualitative performance. This cannot be a paperwork exercise,
and will require a strong field presence by experienced officials,
who are able to assess performance on the ground. This will require
a cadre of experienced and senior enforcement officials, for which
no provision seems to have been made.
5.11 Unless plans are made to that effect, the
Agency will be in the position of assuming a responsibility for
which it has no means of delivering.
5.12 Furthermore, there is a serious constitutional
question to address in relation to local authority enforcement
activities. In that these are carried out by multi-functional
departments' the effort and resource devoted to food safety is
often a local political decision made by elected authorities.
Local elected bodies, for instance, may determine that housing
or other aspects of public health may have greater priority than
the issues concerning the Agency.
5.13 The members of the Agency, however, are
to be unelected and the situation may therefore arise where unelected
officials are interfering with the decisions of elected public
representatives. This is constitutionally unsound. Therefore,
any directions which may impact on the policy decisions of elected
authorities cannot be made by the Agency. To maintain constitutional
boundaries, any such directions must be reserved for the Minister.
6. ADVISORY BODIES
6.01 On the basis of Clause 6, it appears that
the Agency will take over and rely upon the existing structure
of expert advisory committees upon which Ministers currently rely.
If the agency relies on the current structure, it will be a mistake
and a lost opportunity. There is an urgent need to reform the
structure of expert advisory bodies.
6.1 As it stands, members of advisory bodies
tend to be appointed officials (either or both from the Department
of Health of MAFF). Lists of eligible persons are not declared,
the selection process is secret and the results are not open to
challenge. Furthermore, the posts are often unpaid, effectively
excluding persons who are not already remunerated from other sources.
6.3 Inasmuch as Ministers are heavily reliant
on advice from their expert committees, and the agency will similarly
be reliant—on what will be the same people—any expectations
of a new approach from the Agency may well be unfulfilled.
6.4 The importance of the need for change can
be demonstrated by Mr Blair's statement on Saturday 20 February
in The Daily Telegraph, when he claimed that he could not
ban GM foods ". . . that our independent scientific advisors
tell us are safe . . . ".
6.5 Clearly, he was acting on advice from his
experts in the Advisory Committee on Novel Foods and Processes,
but he cannot have been aware that, in 1998, the EU published
a formal recommendation on the procedures to be adopted in assessing
novel foods (97/618/EC). It observed that: "Conventional
toxicological evaluation methods cannot be applied to foods, because
foods present particular difficulties not encountered with the
testing of food additives and contaminants in vivo and in vitro".
It considered that "the ultimate strategy . . . will extend
from initial tests in vitro and in vivo studies in animal models
to studies in humans if needed" (my italics).
6.6 Therefore, presumably on advice from his
experts (or in the absence of complete advice), Mr Blair failed
to tell us that there are no known methods of testing certain
GM foods to determine whether they are safe. Crucially, the traditional
toxicological protocols—applicable to drugs and pesticides—have
no validity when assessing novel foods and it is, therefore, impossible
to confirm that any are actually safe.
6.7 The EU document then goes on to say that
"to compensate for the inability of employing reasonably
adequate safety factors any subchronic or chronic animal feeding
studies require supplementation by absorption and metabolism studies
in animals and eventually in humans (my italics again).
It adds that the "appropriate information should be derived
by combined nutritional and safety post-market surveillance".
6.8 What this is saying is that, given the inability
to carry out initial safety testing, the only way safety can in
fact be assessed is to release the product for general sale and
then monitor the population to see if anyone gets ill. In other
words, as far as GM foods go, the human population is definitely
the guinea-pig. Testing on the consumers is part of the official
experimental design—that is what is meant by "post-market
surveillance". This means testing hundreds, if not thousands
of people, for several decades, before the all-clear can be given.
6.9 The interesting thing about the ACNFP is
that one of its sub-groups has already conducted two meetings
on this issue—in March and December of last year—to
determine the nature of any post-marketing surveillance. But,
from the published minutes, there is no way the reader could gain
any impression that this process is in fact an essential part
of the safety testing.
6.10 Instead, the group—chaired by Professor
Bainbridge—"considered it particularly important to
try to identify any potential health effects from data submitted
for the pre-market approval . . .". As to post-market surveillance,
it considered that its role was only to ". . . offer additional
reassurance that unexpected or unpredictable adverse effects could
be picked up". According to the EU, however, this is not
true. Post-market surveillance is an essential part of the long-term
safety clearance."
6.11 Yet it is Professor Bainbridge and her
colleagues who are saying—if we are to believe Mr Blair—that
GM foods are safe. Mr Blair has not told us that they cannot be
tested for safety without being fed to the population at large
and, as Professor Bainbridge is telling us that post-marketing
surveillance is simply for "additional reassurance",
it is not surprising that Mr Blair seems to have missed this vital
point.
6.12 This is but one example of where the system
of advisory committees does not seem to be functioning effectively.
Given the vital role of the advisory committees, it is essential
that the Government takes the opportunity to set out statutory
requirements for the selection, recruitment of members, their
methods of working and other matters relating to their functioning,
to be administered by the Agency.
7. CHARGING
7.1 The Committee will already be aware that
a significant part of the Agency's income will be derived from
fees charged by the Meat Hygiene Service—eventually amounting
to some £80 million a year. It would seem that the meat industry
alone is to subsidise a significant part of the Agency's operations.
7.2 Notwithstanding the EU requirement for charging—and
the proposals for imposing license fees on butchers—the
levying of fees fundamentally changes the relationship between
regulatory authorities and those they regulate. Necessarily, where
the regulators are reliant on the regulated for their income,
they cannot be insensitive to the needs and demands of those who
pay their bills.
7.3 This relationship is more subtle than is
generally recognised. Power will be exerted most by those who
pay most, and by those who have the ability to withdraw funds
(by moving abroad or other means) or to take (or defend) legal
action taken by the authority.
7.4 However, an even more subtle relationship
is also at play. Larger operations are aware that the most economic
way of increasing market share (compared with, say, television
advertising) is by regulation—the effects of which are always
disproportionately felt by smaller operations.
7.5 In this, the larger operations have common
cause with the regulators which—in being paid for the amount
they regulate—are incentivised to maximise the amount of
regulation. Together this "nexus" will tend to present
"improved" regulation as in the interest of the public
health but, in fact, it is more often in the interest of the "players".
Otherwise, the call may be for a "level playing field"
although as Alan Duncan MP observed[7].
"When a business man calls on government
to create a "level playing field" through tax or regulatory
changes, it is a sure sign that he is looking to the State to
castrate his competitors".
7.6 Through diverse and subtle mechanisms, therefore,
the net effect of a charging regime will be to increase the concentration
of the food industry, driving out small producers and other small
businesses. The effect of this will be to reduce consumer choice,
increase prices and, inasmuch as the spread of contamination is
a function of the size of an operation, reduce food safety. It
cannot be a valid function of the Agency to bring this about.
If the Agency is required to improve public health, then the public
should pay for it . . . through general taxation.
8. CONCLUDING REMARKS
8.1 The role of the Agency is variously cited
as being to improve food safety or to restore public confidence
in the safety of food. These two roles are not necessarily mutually
inclusive. It is possible to achieve one without the other or
to achieve one despite the other.
8.2 In relation to improving food safety, it
is germane to note that the figures for salmonelloses in man for
1998 represented a ten-year low, at just over 23,000 cases compared
with around 30,000 a year for the last nine years. Advocates of
the Agency privately admit that the fall has come two years too
soon. They would have preferred the fall to have come after
the establishment of the Agency, thus justifying its formation.
8.3 Neither is the fall in salmonella food poisoning
difficult to explain. The summer of 1998 was very poor and there
has long been established a relationship between hot summers and
high food poisoning—and vice versa.
8.4 Furthermore, post-BSE, there has been a
substantial recovery of beef sales—and a corresponding decrease
in poultry meat sales. Additionally, the poultry industry is getting
to grips with zoonotic salmonellas, and is reporting record falls
in the incidence of salmonellae in live poultry. Since salmonelloses
in man are most often associated with poultry products (and less
so with beef), it is not surprising that there should have been
such a substantial fall in this type of food poisoning. Incidentally,
owing to the activities of a Delia Smith, eggs sales staged a
remarkable recovery in 1998. For the first time in 10 years, consumption
did not fall.
8.5 Nevertheless, advocates of the Agency have
been remarkably muted about the good news and tend to refer to
the 100,000 annual cases of food poisoning which, it is often
claimed, is increasing. The Committee should be aware,
however, that this figure relates to gastroenteritis reported
by doctors as suspected food-poisoning, without laboratory
confirmation. The bulk of these cases is campylobacter enteritis
and it has never been demonstrated that sporadic campylobacter
enteritis (which forms the larger part of the notifications) is
in fact food-borne.
8.6 All of this suggests that the Agency may
have limited room for manoeuvre in reducing food-borne disease,
to which effect it may be a bureaucratic white elephant.
8.7 As regards BSE, some care should be taken
before this epidemic is used as a justification for the Agency.
The Government has invested a considerable amount in a wide-ranging
inquiry on the circumstances of the epidemic, and it seems premature
to pursue the idea of an agency when the findings of the inquiry
have yet to be prepared and which may well influence its development
and remit.
February 1999
7 Alan Duncan and Dominic Hobson (1995) Saturn's Children.
London: Sinclair Stevenson. Back
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