Examination of witnesses (Questions 500
- 519)
WEDNESDAY 1 NOVEMBER 2000
MS HELEN
BROWNING, MR
PATRICK HOLDEN,
MR CHARLES
PEERS and MR
JOHN DALBY
Chairman
500. A steam cleaned sword?
(Mr Peers) I would hope so and well sterilised. In
an ideal world which we are looking for the answer is yes. We
in Organic Farmers and Growers are very concerned about certain
issues within setting standards and we are only actually comfortable
going with the EC and UKROFS regulation because we feel that in
the present climate and having had experience of many years of
farming that when we try to be better than anybody else we fall
and we have failed basically in British agriculture for many reasons,
that being one. The organic movement is talking collectively with
each other and we are looking at ways of making it but it certainly
would make it a lot simpler for people. We are not ready for that
yet.
Mr Marsden
501. Should there not be some sort of urgency
here? If the organic sector is going to increase from 2.5 per
cent to 20 per cent over the next five years as projected by the
Soil Association now, if that is correct, consumers are very quickly
going to get very confused. Surely now is the time to start sorting
it out in terms of some sort of common standardisation of the
organic standards.
(Ms Browning) There are two issues here: one is standards
and one is certification bodies. We do have eight certification
bodies but we probably are operating on fewer than that in terms
of standards because not all of those certification bodies actually
do set their own standards above and beyond the UKROFS regulation.
We have felt it very important to have the capacity to set standards
which do rise above the EU minimum and there have been many examples
over the last few years where our inability to do that would actually
have jeopardised the whole of the organic market. We talked earlier
on about the fact that we put in place precautions against BSE
back in the early 1980s and once BSE became a threat we put in
place, and were able to do that very rapidly, an exit strategy
already getting rid of risk animals way in front of MAFF's regulations
in this area. The same thing happened with genetic engineering.
We were able to move much more rapidly on that. Conservation standards
is an area where we are making a lot of progress and it is very
important for the environmental benefits of that to be absolutely
cast in stone. Where there were grey areas in areas like pigs
and poultry where UKROFS did not have a detailed regulation and
there was no EC regulation in force either, it was very important
indeed that we could move ahead there. The strength we have in
those sectors now, particularly with pigs, has been very much
due to our ability to go ahead of the game. Organic farming is
an attitude. It is about trying to move ahead. We know that we
are not yet a fully sustainable closed system. We have aspirations
which are way beyond where we are at today. Standards need to
be able to evolve as rapidly as possible to meet those aspirations
of the organic movement, which is why the consumer is buying it.
The consumer knows that there are flaws in what we are trying
to achieve. The system is not perfect but we have to be able to
move as quickly as possible towards getting closer to those goals
and I am thinking particularly of areas like energy which we must
start to tackle in a much more concerted way; food miles, those
sorts of areas, are going to be areas where standards will need
to develop over time quite rapidly. We want to work to try to
make sure that there is no divisiveness in the organic movement
over standards. The bottom line is that if we do not keep the
consumer confidence in what organic farming represents we shall
not have a market in five or ten years' time.
502. Is that not the point that if you have
eight certification bodies with those sorts of different standards,
to one degree or another, within them some of them obviously then
could be split apart because you could then argue about why one
has slightly tougher standards than the next one. Surely for the
sake of the consumer it would be far better, I would argue, to
have one certification body with one set of standards.
(Mr Dalby) I am John Dalby, Certification Officer
for Organic Farmers and Growers. The fact that we have eight certification
bodies reflects conventional commercial practice. In all other
food quality schemes there are several certification bodies competing
with each other who offer a service. The standards may be set
by an external body but they will offer inspection services and
that is what we do. We have got into the situation where effectively,
for historical reasons, we have three levels of standards in this
country, the UKROFS being the base level, to which OF&G and
other bodies operate. The Soil Association set their own level
and at the top end perhaps the Bio-dynamic Agricultural Association
which takes the organic standards and adds the Demeter/Rudolf
Steiner approach to that as well. We have three levels of standards.
I agree that having eight certification bodies is unnecessary,
it is an historical fact, it is going to get worse, because more
bodies are trying to muscle in or come in to take advantage of
the business opportunities. In Denmark there is one body which
is a state organisation, in Holland there is one body, it is a
private trade association which is being delegated by the government
to operate the system. It has a number of advantages in terms
of resources: eight certification bodies in the UK setting up
eight separate databases is enormously expensive; one body setting
up one database would have saved an awful lot of money. I am aware
that government policy over the last few governments has been:
privatise, let the market sort itself out. I suppose we are at
the forefront of that, trying to sort ourselves out as certification
bodies. It does not necessarily work and the railways embroglio
is a good example of it not working in practice. Organic Farmers
and Growers would in fact be in favour of coalescing certification
bodies into a neutral UK-Organic-Certification-Limited type body.
We would be keen to take part in that but the farmer still must
have the option to decide which standard he would like to work
to. The consumer will still have the option to decide which standard
they would like to buy to because obviously different standards
set different production costs and different retail costs.
503. That is the point. I welcome what you are
saying and I am very interested. It sounds as though there are
moves afoot now to start to move towards a coalition or maybe
you are simply writing a speech there for your abolition. I am
not quite sure. Either way that then leads to the question of
farm assurance schemes and throws that into the melting pot. If
you take all this from a consumer's point of view, whoever walks
into the supermarket and is faced with all these different logos,
all these different symbols, all they want to do is buy good nutritional
food, hopefully to some sort of common organic standard and they
just want to know where to find it. At the moment you can spend
a whole hour looking at different labels.
(Ms Browning) In an ideal world one standard would
be fine as long as it was the right standard. That is where the
tensions have been in that the Soil Association has been more
aspirational with its standards. We are aware that we must maintain
the confidence of the consumer we are dealing with and we have
been aware also of the time delays and the difficulties of trying
to move any new regulation or even an UKROFS interpretation of
that and that is why we have been keen to maintain our own ability
to stay ahead of the game. If we had the right standards and we
were able to be light enough on our feet to move those upwards
as rapidly as we could, then you are right, in an ideal world
you would have one logo. We would also incorporate, which we are
doing at the moment, the assurance schemes within that so that
you are looking at a one-stop shop for farmers and one symbol
that the consumer is going to have to take notice of.
Chairman
504. So one set of inspections.
(Ms Browning) Yes.
(Mr Holden) I agree, we think there is a fair convergence
but I should just like to make a plea: do not stifle the innovative
ability of the organic movement. You could argue that most of
the developments in the marketplace and indeed in certification
have happened despite rather than because of government involvement.
There is a certain health about the independence and the grassroots
nature of the organic movement which does represent a coming together
of consumers and producers. The forthcoming review of UKROFS,
which is perhaps going to give an opportunity to prevent the proliferation
of more certification bodies, could help us try to organise ourselves
in a more sensible way to avoid the sort of confusions which,
I think you are right, could happen in the marketplace. If you
do what the USDA is proposing to do and what the Irish Government
are proposing to do, which is to put a ceiling as well as a floor
on these standards, in the long run that will actually put the
whole development of the organic market into reverse. Ms Browning
has rightly pointed out that standards are constantly developing.
The private certifiers, with their standard-setting processes—eight
standard setting committees now—are in a good position to
do that. We have to work in partnership with the regulators but
it is extremely healthy that both exist. We need to have fewer
certifiers working more closely together but we still need the
right to be able to set our own standards and then use that as
leverage to bring the regulatory floor up.
Mr Mitchell
505. That is more confusing for the consumer.
When Ms Browning talks about the more aspirational end of food
standards, what she really means is that the more quirky, picky,
cranky end is setting standards.
(Mr Holden) Yes. The issues around agricultural practice
are complex. We have to educate the public and take the public
with us on this. The old order was not to tell the public anything
that was going on and then we ran into problems. Now there are
lots of debates, whether it is on the overprocessing of food or
animal systems and they do give rise to discrepancies in the organic
standards. We cannot crush that debate and the necessity to evolve
standards on the grounds that it is going to confuse the consumer,
but we have to involve the consumer and enable them to take part
in the debate and actually assist us in setting the standards.
506. The debate is not important compared with
the need for one regulator, one set of inspections, one set of
assurances.
(Ms Browning) I do not agree with that at all. You
talk about a quirky, picky consumer, but if we can harness the
consumer to want to make agriculture much more energy efficient
for instance, or much more environmentally benign or much more
welfare friendly, those are not quirky, picky features.
507. But the customers are not interested in
that. They are interested in a good product, guaranteed quality
at buyable prices.
(Ms Browning) Our whole role in the organic movement
is to educate the consumer so that they are interested and will
make their purchasing decisions based on issues around welfare,
environmental care, energy efficiency, all of those issues. We
are an educational charity and a fundamental part of our deal
with the consumer is that we are going to move in a sustainable
direction and we are not just going to cop out and give them something
that whitewashes over the real issues. That is not the role of
the organic sector.
Mr Todd
508. There is clearly a distinction between
standard setting and certification and I entirely follow the train
of thought you have expressed which is that standard setting moves
on and that setting it in stone or demanding that the Government
does is the wrong approach. Competitiveness in certification is
also desirable surely as well to ensure that service meets the
highest possible standards but at the lowest reasonable cost to
those buying into it. Is there not an opportunity for some acquisitions
or mergers within the certification bodies to achieve a more efficient
outcome while retaining a competitive marketplace?
(Mr Holden) I think we would probably say yes.
Mr Jack
509. In the Soil Association's evidence you
say, "However, we are concerned that UKROFS has neither the
resources nor the capacity to continue with standards development
work, which is becoming increasingly complex and technical and,
as the market grows apace, increasingly urgent". Would you
just like to expand on that and tell us (a) what you think UKROFS
ought to be doing and (b) what the deficit is in its resources?
(Mr Holden) I am probably not the best person to talk
about the deficit in UKROFS' resources because there are several
other witnesses to give evidence on that.
510. But you said that in your evidence.
(Mr Holden) Having been a member of UKROFS for 12
years I was constantly aware of the enormous pressure on the small
number of officials who were processing far too much information
and the growing number of applications for certification. We are
also aware that the standard setting committee did not have the
capacity or the expertise to do the job that needed to be done
in the development of standards. What I think happened, during
much of the time I was on UKROFS anyway, was that the private
certifiers, including the Soil Association, developed standards
and then presented dossiers to UKROFS which were then reviewed
by the board and adopted or otherwise. There is a case in the
review to recognise that process has been going on for years,
that it incurs costs and that it is quite healthy and that the
Government perhaps ought to recognise that some of these costs
ought to be funded centrally.
511. For the sake of getting some feel for that
can you give us proportion, money, people? How can we quantify
that?
(Mr Holden) I mentioned earlier that we had eight
standards setting committees and our standards development budget
in the Soil Association this year is more than £200,000.
So you can see that we are carrying quite a lot of the cost of
standards development ourselves at the moment.
512. One other point of clarification. In the
same paragraph of your memorandum you say "We", that
is the Soil Association, "are currently developing an alternative
standards setting model". Was that the one you described
earlier as the one-stop shop approach for assurance as well as
standard setting?
(Mr Holden) No, there is increasing cooperation between
the certification bodies. We have invited the other certification
bodies to join us in our standards development process and have
had a number of meetings where we have been exploring that recently.
This would enable perhaps, I cannot guarantee this but it could
enable us, to be more unified in the way that we develop standards.
513. Does that address Mr Mitchell's concern
in the sense that you say "more unified" and Mr Todd
is going for diversity? Can we square the circle with that approach?
(Mr Holden) No. You are very right to identify the
tension there. There is a tension there. If we only had one standard
and that was the regulation which some people want, that would
solve the problem of consumer confusion but it would also stifle
the ability of the organic standards to be involved. Equally,
if we had so many standards that consumers were completely confused,
this would be undesirable too. What we have to do is to strike
a balance. You have already said that it is incumbent upon us,
the certifying bodies, to try to cooperate more. We are on the
case. Equally the Government can help.
(Mr Dalby) I am just concerned about our reliance
on the consumer. If you pick up two consumers from the street
outside, I am sure you will get two different answers to the questions
you give them. If you ask a consumer who goes to Sainsbury's to
buy organic product in Sainsbury's they will give you a very different
view of the world from the consumer who goes to Iceland or Waitrose
to buy organic product there. The consumer is far more sophisticated
than we take them for. We are squabbling over logos or symbols
and whether we should have one UK symbol. Eighty per cent of our
organic consumption is imported. A lot of that comes in with logos
from certification bodies all over the world, agri-bio co-op in
Italy, Naturland in Germany, the American bodies and so on. The
consumers ignore those essentially and go for the word "organic",
go for the word "biological", go for the word "ecological".
That is what we can look for. I suspect that the logo issue is
almost a red herring, it is a side issue. The fact that different
standards are involved does not interest most consumers. Those
who are will do the research and they will investigate, they may
buy copies of the standards or whatever. Most consumers, and my
wife and myself and our family are part of this, just look for
the word "organic". We have an interest because we are
involved in the industry and we have a professional interest in
what the logo is, but I suspect if we were not in the industry
we would not be bothered. As long as we can afford it we would
buy it. We really ought to get away from the logo wars in which
we have become involved as sector bodies in this country.
Mr Marsden
514. Just as a matter of interest, how many
consumers do you ask about logos? How often do you carry out market
research on this subject.
(Mr Holden) We carry out a MORI survey regularly so
we know about brand awareness.
515. I was directing the question to Mr Dalby.
(Mr Dalby) We are not a policymaking body, we are
a certification body and we do not have the resources to carry
out research.
516. I put it back to you that before you make
too many judgements about the consumers perhaps you should ask
them a little more what they would like. Unfortunately I do have
to move on.
(Mr Peers) With respect, that is done by the supermarkets.
517. Exactly; that is the point I was making,
that they are confused.
(Mr Peers) To go back to a previous point, that is
why we have so many logos because that is the line they are pushing
us down.
518. As long as everyone keeps the consumer
in their focused mind. Witnesses have also criticised the lack
of scientific basis for organic standards and I can give you two
examples. Professor McKelvey believes that there is no logic in
the withdrawal periods of antibiotics which are simply doubled
over the conventional period and the head of HRI has said, ".
. . among growers and scientists, there is a suspicion that protocols
can be generated expeditiously and `on the hoof'". My question
to both your bodies is this: what scientific basis do you actually
seek out before agreeing standards for organic production bearing
in mind of course that we have different standards?
(Mr Holden) I am sure there will be four different
answers to this.
519. Why on earth would the consumer get confused?
(Mr Holden) Having been involved with standards development
for a very many years and having participated in the decision
to ban the feeding of animal protein to ruminants, it would be
fair to say that the criteria which are used for standards development
include what you might call evidence-based and non-evidence-based
elements. I do not think we should make any apology for that.
When standards are developed we obviously try to set them using
as much evidence as we can draw from whatever sources. There are
occasions when gut feeling, intuition, ethical considerations,
and consumer attitudes will drive standard-setting decisions.
I have recently submitted a paper suggesting that in the area
of food safety the Government needs to develop non-evidence based
criteria for the assessment of new technologies in food and agriculture
and their approval, to sit alongside evidence-based criteria for
policy decisions. We have to an extent blazed a trail in that
area. We have been ridiculed for it in the past but there is no
need to do that now. If you want we could discuss in more detail
how we came to the conclusion about genetic engineering but it
would probably take too much time.
(Ms Browning) In addition to that Mr Holden has already
mentioned the eight standard setting committees which we run and
we fund. We have made a lot of effort to make sure that we bring
some scientific expertise onto those committees as well as consumers,
so we are trying to bring in what expertise there is to bear.
In some of these areas you are having to take some fairly interesting
decisions. There is the one mentioned about the withdrawal period
of antibiotics. Talking to vets about that, those decisions were
made with veterinary involvement but every drug is different in
terms of the way it is metabolised, every animal is different
in the way it metabolises a drug, so at the end of the day you
do have to come up with an arbitrary level of withdrawal which
is going to give you a substantial safety margin, given all those
unpredictable elements within the way different drugs and animals
work together. Some of those areas are very difficult but we are
trying to make sure that we can afford to bring in good standards.
(Mr Peers) Very quickly: search me.
(Mr Dalby) I would endorse what Ms Browning and Mr
Holden have said entirely. I have been involved in standard setting
since 1981. The standards which have evolved to date until the
last year or so were evolved by the producers, by the farmers
themselves. They knew what was desired, they knew what could be
achieved. It was a difficult compromise very often between the
two. The farmers set the pace and they set the pace as fast as
they could achieve it. More recently the consumers and the regulators
have started to take over that role. If I could just give you
an example of the withdrawal period, which I was involved in about
eight years ago, the cheesemaker who buys milk from an organic
farm to make cheese was very concerned that the withdrawal period
for antibiotics for mastitis was not long enough because it was
ruining his cheese. He could not make cheese based on the standard
normal recommended withdrawal period. He insisted that the Soil
Association at least maintained a double withdrawal period and
I think it was three times because as a cheesemaker it was ruining
his business. That is the sort of empirical, pragmatic approach
that we had to adopt. Scientists are wonderful but they will only
give you a risk assessment: 50 per cent, 80 per cent. You as parliamentarians
have to make decisions based on the advice you are given by the
scientists, as have we the standards-setting people. You have
to make very difficult decisions and the scientists may not agree
but at some stage we have to come to an arbitrary conclusion.
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