MEMORANDUM 34
Submitted by PTF (Provision Trade Federation)
1. INTRODUCTION
1.1 PTF's members are companies of all sizes
involved in supplying bacon and ham: chilled and processed meats:
dairy products of all kinds, including milk powders, cheese, butter,
yogurt and other dairy desserts; and canned foods. Our members
include importers and exporters of these products, as well as
processors. The combined turnover of our membership in relation
to these products is in the region of £4-5 billion.
1.2 Food quality and safety are critically important
to our members who must play their part in ensuring that the foodstuffs
or ingredients in which they deal comply with all relevant food
legislation, as well as establishing and maintaining their reputations
with their customers in the UK, the rest of EU and third countries.
1.3 PTF is committed to helping its members
to meet the standards demanded in relation to food safety and
all other areas proposed for inclusion in the Food Standards Agency
remit which are relevant to our members' areas of business. To
this end, we welcome the introduction of the Food Standards Agency.
2. FUNDING OF
THE AGENCY
2.1 We are disappointed that, despite considerable
opposition, the Government is continuing to propose that some
of the costs of the new Agency should be recovered by means of
a levy on selected sectors of the food industry. We are of the
view that a persuasive argument for industry funding has not yet
been made, and therefore oppose anything other than full government
funding.
2.2 In our previous submissions to the Government
on this subject, we have requested more information on how the
proposed additional industry funds will be deployed and why existing
funding would not be sufficient. The Government's consultation
paper on the proposals for a levy scheme includes provisional
figures for one-off costs and new recurring costs, but no supporting
documentation to illustrate how the Government arrived at these
figures. A detailed budget clearly identifying the basis of the
provisional costs must be made available for public scrutiny if
the Government is to satisfy those who object to the proposed
funding scheme and to meet its objective of being open and transparent
in all areas.
2.3 The Government's consultation document on
funding the Agency proposes that a charge of £90 would be
levied on food retail and catering premises. However, the draft
Bill does not limit the charge or the sector, and permits the
Secretary of State to make regulations that provide for the imposition
of a levy in respect of "such food premises as may be prescribed
in the regulations". This is equivalent to demanding that
the food industry supply the Government with a blank cheque to
fund the Agency.
2.4 We note that the proposed £90 fee is
provisional and "will need to be revised to take account
of further detailed discussions with local authorities on the
costs to them of operating the levy scheme". As the Government
has not yet ascertained the collection costs of the proposed scheme,
this begs the question as to how the Government can estimate a
proposed fee or guarantee that the proposed levy scheme is cost-effective.
3. APPOINTMENT OF
MEMBERS OF
THE AGENCY
3.1 The draft Bill states that before appointing
a member of the Agency, consideration must be given to whether
that person has any financial or other interest which is likely,
in the opinion of the appropriate authorities, to prejudice the
exercise of his duties. We question how this judgement could be
made in practice. For example, would anyone employed by the food
industry be deemed to have a financial interest? We would not
wish to see potential applicants who have valuable food safety
experience excluded from membership of the Agency on the grounds
that they currently work within the food industry. In order to
ensure that the Agency is able to adopt a sensible, balanced position
on food safety and standards issues, its members must be selected
from all sectors with an interest in food, including the food
industry itself.
3.2 We welcome the fact that the "governing
body" of the Agency will not be called the Commission. Use
of the name "Commission" would have become confusing
as many documents refer to the European Commission as the "Commission".
4. MONITORING OF
ENFORCEMENT ACTION
4.1 We welcome the proposal that the Agency
should monitor the performance of enforcement authorities in enforcing
legislation. We believe that a rigorous review of the enforcement
system is needed to address perceived inadequacies in areas such
as intensity and consistency of enforcement.
March 1999
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