MEMORANDUM 36
Submitted by the Public Health Laboratory
Service
1. INTRODUCTION
The overall aim of the Public Health Laboratory
Service (PHLS) is to improve the health of the population through
diagnosis, surveillance, prevention and control of infections
and communicable diseases in England and Wales, continuing assessment
of which is based on laboratory, clinical and epidemiological
information from a variety of sources.
Within this remit the PHLS comprising the Communicable
Disease Surveillance Centre, the Central Public Health Laboratory
and the Group network of 48 public health laboratories, co-ordinated
by PHLS Headquarters, identifies outbreaks and sporadic cases
of human food-borne infection. Supported by reference laboratories
and specialist food, water and environmental laboratories, investigations
are carried out in collaboration with Local Authority Environmental
Health and Port Health Officers, Consultants in Communicable Disease
Control, Regional Epidemiologists and others.
National epidemiological and microbiological
surveillance of foods is also carried out. Currently the PHLS
examines approximately 200,000 food and dairy samples per annum.
2. RESPONSE TO
THE CONSULTATION
DOCUMENT
The PHLS welcomes the publication of the Government's
consultation document on draft legislation relating to the proposed
Food Standards Agency.
Part I: Introduction, Summary and Consultation
Document
Page 9—Section 31—Notification of
Food Borne Illness
The PHLS supports the proposal that notification
of laboratory test results for specific food-borne illnesses should
become a statutory responsibility. This measure is essential for
improving public health and food safety policy. Laboratory test
results should refer both to clinical specimens from patients
with possible food-borne illnesses and the results of testing
of foods and environmental samples.
(a) The protection of the public from food-borne
disease depends on the reporting of clinical diagnoses and laboratory
reports which are rapidly collated, analysed and the resultant
"information for action" provided to those with responsibilities
for the prevention and control of communicable disease. Timely
reporting and analysis is critical for the rapid detection of
outbreaks of infection so that investigations can be initiated
to determine the vehicle and source of infection and to implement
the necessary control measures.
(b) In the investigation of outbreaks of
infection, it is important to note that many organisms transmitted
by food may also be transmitted by other means. The following
are examples of organisms which can be transmitted by food or
by:
— Person to person spread, e.g., Small
round structured viruses (SRSV).
— Exposure to animals, e.g., E.
coli O157.
— Exposure to water or other animal
sources, e.g., Cryptosporidium, Campylobacter.
(c) Thus the ability to collate and analyse
the information and to respond to outbreaks of infection must
be organised in a coherent and consistent way until the vehicle
of infection has been identified.
(d) At present, the PHLS has responsibility
for:
— Regional and national surveillance
of communicable diseases.
— Co-ordination of investigation of
regional and national outbreaks of infection.
— Providing operational support (laboratory
testing and field epidemiological investigations) to those with
statutory responsibility for the control and prevention of infection,
including food-borne disease at district level.
The PHLS enables data collected at the national
level to be delivered to Consultants in Communicable Disease Control
(through CoSurV and in the future through labBase2) in individual
Health Authorities and this facilitates the detection of national
incidents. In addition, the PHLS has the expertise and communication
systems to disseminate alerts (nationally and internationally)
and to provide practical guidance and assistance not only in the
management of food-borne outbreaks but also non food-borne outbreaks.
(e) Given the requirements of the surveillance
and response capability essential for the appropriate investigation
of outbreaks of infection, it would appear that the current framework
meets the necessary criteria for rapid response. In addition,
the PHLS surveillance systems enable long term trends in infection
to be assessed as well as relevant monitoring of control measures.
(f) Thus, the concept of setting up potentially
duplicate and parallel reporting systems is likely to lead to
confusion and not best value for money as well as confusion over
responsibilities.
(g) Within an overall concept of "connected
problems needing joined up solutions" the protection of the
public health in relation to the surveillance of food-borne disease
would be best served by close liaison between the FSA and PHLS
with commissioning of additional information and other support
where necessary.
(h) The PHLS fully supports the principle
of statutory reporting of appropriate clinical laboratory results
to ensure the fullest coverage of the communicable disease state
of England and Wales. This notification must first and foremost
serve the local control and prevention of communicable disease
i.e., any system must deliver data to the local CCDC as well as
to the national centre.
Part II. The Draft Food Standards Bill
Pages 2 and 3—Clauses 4 and 5—advisory
committees for Wales, Scotland, Northern Ireland and England.
The PHLS notes that not only are there to be
Advisory committees for Wales, Scotland and Northern Ireland but
also the possibility of separate committees for England or any
region of England. It is important to emphasise that food products
are widely distributed, that food-borne pathogens are no respecters
of geographical boundaries and that outbreaks of food-borne disease
cross regional, national and international boundaries. It is important,
therefore, that there should be a fully co-ordinated approach
throughout the UK and that the establishment of separate advisory
committees should not give rise to fundamental differences of
approach in the handling of food safety issues.
Page 4—Clause 10—Provision of advice,
information and assistance to other persons.
It is not clear in this clause who will issue
guidance to food producers, caterers and retailers with regard
to food safety issues, e.g., warning notice on the use of raw
shelled egg.
Page 5—Clause 13(4)—Powers to carry
out observations.
The taking of samples should include food, water
and the environment. As written, however, it does not appear to
give the authorised person the authority to take measurements,
e.g., the temperature of the food or storage facilities.
Page 10—Clause 19(2)—Consideration
of objectives, risks, costs and benefits.
One of the key words here is "risk".
The term is used both colloquially and technically and may need
defining.
Page 13—Clause 26—Arrangements for
sharing information about food-borne zoonoses.
This is a key clause relating to the activities
of the PHLS but we appear to be omitted from the list of authorities
to which this section applies. The PHLS should be a key partner
in the provision and sharing of information on food-borne zoonoses.
Will birds, fish and shellfish be included under "animals"?
Page 14—Clause 28—Animal feeding
stuffs.
The PHLS supports the change in responsibility
for animal feeding stuffs. This will enable the emergence of antibiotic
resistance to be monitored more fully, allow recognition of new
pathogenic strains of bacteria and will be an integral part of
zoonoses control.
Annex: Draft Regulatory Impact Assessment
Page ii—Clause 5(ii)—Issues of equity
and fairness
This clause states that existing central funding
of government work on food issues will be transferred to the Agency.
We assume that this refers to work directly commissioned by the
Department of Health and the Ministry of Agriculture, Fisheries
and Food. However, for the avoidance of doubt, we draw the attention
of the Committee to the fact that key roles of the PHLS include
the identification, investigation and control of food-related
outbreaks and research and development priorities. Care should
be taken not to impair the excellent track record of the PHLS
in these fields. The activities of the PHLS in surveillance, reference
testing and research and development work on food-borne and non-food-borne
gastro-intestinal illnesses are inextricably linked, as are the
microbiological examination of clinical samples and samples from
food, water and environmental sources. Any attempt to divide the
funding streams for these activities would seriously disrupt this
essential work.
However, there is also a need for a mechanism
for fast tracking the approval and funding process for surveys
of foods of public health importance. The current situation in
which urgent microbiological surveys with a public health component
have to be funded from existing PHLS resources is no longer tenable,
as PHLS central funding has been progressively reduced.
GENERAL COMMENTS
The Bill does not make clear which part of Government
will have the responsibility of negotiating food safety matters
in Brussels. Will these powers rest with the Ministry of Agriculture,
Fisheries and Food, the Department of Health, or will they be
devolved to the Agency?
The PHLS intends to meet the food safety challenges
ahead by maintaining and enhancing the six strategies that form
the traditional role of the Service: the diagnostic excellent
of its network laboratories in England and Wales supported by
its unique specialist reference centres at the Central Public
Health Laboratory and elsewhere; comprehensive surveillance of
human infections through CDSC and its Regional Epidemiologist
network; microbiological and epidemiological surveillance of foods
and food poisoning; education and training; research and development;
and good communication locally, nationally and internationally.
The Service is well placed to continue to provide a positive lead
in all of these areas and looks forward to a close and very successful
relationship with the proposed Food Standards Agency.
The Agency and the PHLS have a common goal of
protecting the population from infection—food poisoning
is a preventable disease and it can and must be prevented.
March 1999
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