Select Committee on Food Standards First Report


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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Prepared 12 April 1999