Select Committee on Food Standards First Report


Submitted by M J Savill


  I have recently used the Internet to study the approvals procedures for novel foods, and the BSE enquiry. I am a qualified chemist, environmental scientist—and also have a degree in business and many years carrying out management science in industry. There appears to me to be very legitimate reason for public concern that the procedures for assessing food safety are inadequate, and need further strengthening to prevent another BSE disaster. The weaknesses I have identified are detailed below.

  1. A lack of use of management science techniques. The techniques of decision analysis under uncertainty, cost/benefit analysis and risk analysis (a much misused term), should be used to illuminate the true balance of benefits, costa and risks associated with producing and consuming foods. This would require a new professional input to the procedures.

  2. A lack of experimentation. If sufficient good experiments had been carried out on animal feeds, we would not have had 35 deaths from CJD/BSE and possibly thousands to come. The Advisory Committee on Novel Foods and Processes (ACNFP) has published a paper on the MAFF Internet site describing procedures for toxicological testing of novel foods. This paper makes it clear that most GM foods have not, and will not, be given any long term animal feeding tests, because of the difficulty carrying out such experiments and interpreting the results. In addition there are no long term tests carried out on human volunteer test groups. This policy seems foolhardy in the extreme—when a foods DNA is modified (for example in the case of Monsanto Soya with genes from a virus, a bacterium and a plant) the new organism (never before seen on this plant) makes a new mix of chemicals and proteins. This mix cannot be predicted or reliably analysed, therefore the only way to determine its safety reliably is through scientifically designed experimentation. The principle of "equivalence" outlined in the paper is scientifically very suspect—it pays to beware of scientists arguing the case for not doing experiments because they are too difficult! If it really is impossible to carry out meaningful animal testing, then clearly human testing must be carried out before allowing the whole population to consume these foods for life.

  3. Allergies. The whole question of allergy to novel foods has not been adequately explored. In another paper on the MAFF site, the advisory committee argues that merely notifying consultant allergy specialists, and allergy support groups, of the approval of foods containing lupin genes is sufficient safeguard. This is clearly not the case since sufferers from lupin allergy are very unlikely to inform their consultant (if they have one), or allergy support groups. Even if some sufferers to a particular allergy are alerted in this fashion, they may not in practice be able to avoid exposure. Soya, be example is extremely widespread in processed and restaurant food. The presence of genetic material from a wide variety of sources, including bacteria, fungi and viruses clearly raises the possibility of severe allergic reactions in consumers—this must be properly tackled as a safety issue—which can, I believe, only be reliably and definitively studied if human consumption trials are included in the scientific procedures.

  4. Scientific consultation. Politicians should have alarm bells ringing when there is scientific disagreement on issues of health and food safety—as clearly demonstrated by the Professor Lacey/BSE saga. There is usually only significant disagreement in real science when there is a lack of understanding in the area concerned, which in turn implies that policy makers should be extremely cautious. I know some improvements have been made in this area, but I think advisory committees should be required to consult widely, and tackle the issues raised during consultation in a transparent fashion.

  I hope the Select Committee sees fit to investigate the approval procedures for novel foods in detail (including GM foods not defined as "novel" in the legislation).

February 1999

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