Select Committee on Food Standards First Report


Submitted by The Sugar Bureau


  The Sugar Bureau welcomes and supports:

    —  The principle of creating an effective Food Standards Agency focused on the protection of public health by improvement of food safety throughout the food chain.

    —  The proposals for the structure, accountability and consultative arrangements of the Agency.

    —  The Guiding principles under which the Agency will operate (with the reservations emphasised below).

    —  The absence of any indication that the Agency will seek to limit the diversity of research funding mechanisms currently available in Food Safety, Standards, Authenticity and Nutrition.

    —  The provisions for wide consultation before the Agency takes action.

    —  The intention to ensure that the public will have adequate, clearly presented information in order to allow them to make informed choices; and the aim to avoid raising unjustified alarm.


    —  We wish to reiterate our concern that the arrangements proposed for handling the specific subject of Nutrition are less than ideal and may conflict with the Agency's other areas of responsibility. They are also, in our view, inappropriate for this subject, and likely to lead to confusion and replication of effort.

    —  The current proposals are also insufficiently clear as to the balance of expertise among the members of the Agency; the use of scientific evidence; the publication of Advisory Committee and the Agency reports and advice; and the separation of scientific advice from policy formulation.

    —  In addition, it is not clear how the Agency will engender consumer confidence without falling prey to undue influence from the media or unrepresentative single-issue pressure groups.


  The Sugar Bureau was established as a trade association over 30 years ago. Since 1990, we have been promoting nutrition research and increasing awareness amongst academics, health professionals, the media and the public, of the scientific evidence about the role of sugars, and other carbohydrates in the diet.

  Our staff of 10 includes well-qualified scientists, nutritionists and dietitians. Monitoring developments in science and nutrition forms an important part of our work, and we liaise regularly with independent academics from across the world.

  The Sugar Bureau supports the response to the consultation provided by the Food and Drink Federation. We wish to add some further points, however, and to reiterate the key issues raised in our response to the White Paper that have not been reflected in the current draft.


  The relevant section of the Guiding Principles states that "The Agency's assessments of food standards and safety will be based on the best available scientific advice, provided by experts invited in their own right to give independent advice." Unfortunately, these provisions will not, in themselves, ensure unbiased assessments. This is especially the case when the evidence available is incomplete or conflicting.

  A number of methods have been developed to reduce the likelihood of subjective bias in the assessment of scientific data. The use of these methods should be mandatory for the Agency. Specifically:

    —  Evidence should be collated comprehensively.

    —  Systematic review procedures should always be used.

    —  Issues should be revisited at predetermined intervals.

    —  Evidence should be judged against consistent and predetermined quality criteria.

  A further influence on the manner in which the Agency reacts to scientific evidence will be the need to engender consumer confidence in its decisions. It will be essential that the Agency establishes a mode of operation that avoids an undue influence being exerted by unrepresentative single-issue pressure groups or the media. Careful consideration will need to be given to the means of ensuring that the Agency can continue to deliver judgments that are objectively based on the scientific evidence in the face of intense media pressure. The independence of the Agency in this regard should be explicit in its constitution and reflected in its choice of Members.


  These scientific review procedures are particularly important when considering evidence in the field of Nutrition, since the data in this field is often incomplete, of widely variable quality, and subject to strong opinions.

  We remain persuaded, however that Nutrition is a subject that can no longer be viewed solely from the perspective of food. The influence of genetic factors, physical exercise and other lifestyle variables needs to be considered. The inclusion of responsibility for public advice on diet within the Agency's remit, therefore could lead to a narrowness of perspective unless carefully co-ordinated with other relevant inputs.

  The highly controversial nature of many current nutritional theories could make it difficult for the Agency to issue advice without damaging its credibility. In addition an adequate research programme to verify even a small proportion of these theories would be prohibitively expensive and could therefore restrict research funding for more immediate priorities.

  For these reasons we remain of the opinion that Nutrition should remain outside the remit of the Agency. If the Government wishes to continue with these current proposals, the opportunity should be taken to reduce the replication of effort in this field, while, at the same time, avoiding the potential for future confusion.

  As currently proposed, the Bill will create a third source of advice to the public on Nutrition and Diet. Both the Health Education Authority and COMA will continue independently to seek scientific opinions from advisors and offer guidance to the public (usually through the media). Now, in addition, the Agency will seek input from COMA, interpret this input using its own communication experts, and advise the public as it sees fit. Recent experience suggests that these three routes may not always lead to the same outcome.

  A single body should take the lead in interpreting the science, and a single body (not necessarily the same one) should take the lead in informing the public. If it is considered that a number of players should remain active in public information, then, at the very least, they should use the same "hymn sheet".


  It is essential that the 12 "Members" of the Agency should include individuals who can demonstrate, not only independence and integrity, but also competence in the highly technical issues that will come before them. It would, therefore be unwise to limit the pool of available talent by excluding otherwise acceptable candidates merely because they are employees of a company engaged in a food-related business.


  Issues relating to the way in which scientific evidence should be considered have been raised above. In addition, there are two further connected points that should be stressed. These concern transparency and competence.

  The Bill as presently drafted conveys powers to the Agency to publish its advice to Ministers. It does not mandate it to publish, nor to do so promptly. Similarly, the reports the Agency receives from its advisory committees are not required to be made public. Both the inputs (advisory committee opinions) and outputs (advice to Ministers) will need to be made public, in all but the most exceptional circumstances, if the agency is to command the confidence of all the major stakeholders and to avoid selective leaks. In most cases, transparency is to be preferred to secrecy.

  A further issue concerns competence. One important weakness of the current system of developing science-based policy decisions in the UK is that, too often, scientists are asked to step outside their area of expertise into areas of policy. A scientist will, in general, have no special competence in the construction of policy options arising from his (or her) scientific judgments. More importantly, those scientific judgments will inevitably be biased by, at the same time, considering the practicability of the likely policy options. This is not a comment on the integrity of the scientists but on human psychology.

  It will be of paramount importance that the Agency rapidly develops a reputation for sound science and also for good policy judgments. This can only be reliably achieved by separating these two functions, preferably in time and space. Certainly different individuals must be involved. For once, the European Commission model is more effective than our own. Scientific advice is the responsibility of a separate Directorate (DG XXXIV) while policy is formulated in the other relevant Directorates.

  From time to time, the Agency will undoubtedly come under intense pressure from single-issue pressure groups (through the media) to change its advice on both scientific and policy issues. In order to be seen to retain public confidence, the temptation will be for the Agency to tailor its judgments to pre-empt such clarion calls. The inevitable consequence of this persistent pressure could easily be a tendency to excessive caution, inhibiting innovation and restricting personal choice more than is justified. It is essential that the Agency is able to remain objective even when the media are campaigning for a particular point of view. Such objectivity will be assisted by maintaining an arms-length relationship with the pressure groups.

March 1999

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