APPENDIX 2
Memorandum submitted by the Food Standards Agency (F4)
INTRODUCTION
1. The impact of Foot and Mouth Disease has led to considerable public concern about imported food, in particular about the possibility that illegal imports of food may have the potential to spread disease which may affect animal health. Foot and Mouth Disease is not a public health issue. However, imported food has the potential to affect food safety and the issue is therefore relevant to the work of the Food Standards Agency.
2. Imports of food are important to provide consumer choice and help meet nutritional requirements. The volume and speed of movement of goods enables products to go on retail sale throughout the UK, in a fresh and wholesome condition. This trade in imported food is also important to the UK economy.
3. Most food for importation is fully compliant with the law. However, as with any system of official controls, the current system of import controls cannot provide a 100 per cent safeguard. It would not be possible to carry out physical checks on all consignments of food entering the UK, without huge staffing resources for enforcement agencies and significant changes to infrastructure to allow increased storage facilities at points of entry to the UK. It would slow down movement of goods at ports and airports to the detriment of travellers, importers and the economy. Currently, there is no evidence that this would be proportionate to risk. Government therefore has to be realistic about what can and should be done to provide an appropriate and proportionate response to public concerns in this area.
4. The Food Standards Agency fully supports the measures proposed in the Government Action Plan, in particular to identify risks and to target import controls. We also see the value of providing information and education to stakeholders, and the importance of ensuring the adequacy of enforcement systems in place to provide appropriate and proportionate controls on imported food at air and sea ports, as well as at inland authorities.
IMPORT CONTROLS AND THE SINGLE MARKET
5. There is a comprehensive system of controls for imported food designed to protect public health, animal health and plant health. These are enforced in the UK by a number of different agencies, both at ports of entry and inland authorities. Controls over food imported into the UK are designed to detect food products that do not meet EU or UK standards and remove them from the food chain.
6. The controls on imports of products of animal origin, such as meat and dairy products, from third countries are based on European Directives. The focus of these controls is based on preventative controls, where the country of origin carries out its own checks on food product, and monitors enforcement agencies. Standards are prescribed to ensure that food is produced in accordance with hygiene and safety requirements. These standards are the same for both Member States and third countries, and imports of such products are only permitted when produced to standards at least equivalent to those required within the EU. The European Commission's Food and Veterinary Office (FVO) carries out inspections to ensure that standards are being maintained in third countries.
7. Products of animal origin from third countries can only enter the EU through authorised Border Inspection Posts (BIPs), accompanied by the required documentation. At the BIP, the products are subject to 100 per cent documentation and identity checks and a specified level of physical checks, eg, at least 20 per cent or higher according to the type of food.
8. Food which is not of animal origin, such as fruit and vegetables, from third countries is not in the main subject to harmonised EU legislation. As such, other Member States will operate their own control arrangements which may be different to those in the UK. In the UK, food which is not of animal origin is subject to food safety import controls under the GB Imported Food Regulations 1997 and their equivalent in Northern Ireland. Such imports are subject to checks on the basis of risk assessment by local port health authorities and local food authorities at the point of entry to the UK.
9. It follows that the system of import controls in the UK is dependent on other Member States enforcing EU or national controls to ensure that imports from third countries comply with the relevant legislation. Once third country imports are accepted into the EU, there is free movement of goods, and more detailed identity, documentation and physical checks may not be possible. Food may be widely distributed in the food chain, and it is more difficult to identify, trace and control.
10. Food coming to the UK from other EU Member States, including that imported from third countries, is in free circulation within the EU and is not subject to routine checks at UK ports. Such food can only be subject to import checks where there is information to support such action. All foods of animal origin produced in the EU must be produced in accordance with EU law, and it is the responsibility of the European Commission to ensure that Member States fulfil their obligations. The Commission's FVO send inspection Missions to all Member States to check on this.
11. Imports of meat from other Member States are subject to checks by the Meat Hygiene Service (MHS) at licensed meat cutting plants, or by food authorities in meat plants under local authority supervision. Following problems over the presence of Specified Risk Material (SRM) in imported meat, in contravention of BSE rules, the Food Standards Agency has instructed the MHS to inspect every consignment of imported carcass beef, and take appropriate action in the event SRM is identified, to prevent SRM getting into the human food chain.
What are illegal imports?
12. Illegal imports include:
— Foods which are imported through the proper channels, but which are found not to meet all the legal requirements. This would include beef bearing Specified Risk Material (SRM) in contravention of BSE controls, or products which fail to carry the required Health Mark.
— Imports of products of animal origin, such as meat or meat products, from third countries that have not been brought into the UK in accordance with legal requirements:
— if this food is for commercial use, consumers will not be protected by the safeguards provided by import controls. The consumer is not in a position to make an informed choice about the safety of food purchased where food is deliberately imported and is known not to comply with legal requirements;
— where it is a personal import by consumers for their own use, consumers could argue that they are making a choice about the food that they eat. However this is based on the assumption that cooking or other treatment will render the product safe. Some people are prepared to take this risk, as the food may have particular cultural or social significance.
13. Greater opportunities for foreign travel has increased the public desire for a wider range of products, and there may be financial incentives for illegal food imports of an exotic nature in particular in contravention of the Convention on International Trade in Endangered Species (CITES).
THE FOOD STANDARDS AGENCY AND IMPORTED FOOD
14. The Food Standards Agency has responsibility for protecting public health and consumer interests in relation to food. The Agency therefore has a key interest in matters of imported food as it does in matters of domestic food.
15. As a result of consumer concern about UK controls on food imports, and recognising its role in the Government-wide Action Plan, the Food Standards Agency has:
— taken an active role in cross-Whitehall initiatives (including information gathering and dissemination) led by the Department of Environment, Food and Rural Affairs (DEFRA) aimed at improving the UK's ability to prevent and to detect illegal imports, and has contributed to developing the Government Action Plan published by DEFRA in March 2002.
— issued guidance letters to local food authorities, including at ports and airports, to ensure there is continued vigilance and checks on imported products both at the point of import and at the retail level.
— carried out a programme of visits in April 2001 to a number of ports, local authorities and imports warehouses to assess the effectiveness of current import controls and the scale of illegal imports of animal products.
— produced a paper on food imports which was approved by the Agency's Board at its meeting in October 2001. This included the following ten recommendations to improve the effectiveness of controls on imported food:
1. Bring imports of products of animal origin under the Agency.
2. Improve liaison with enforcement authorities and central government on food safety.
3. Establish an electronic information database for port health authorities with relevant local authority access.
4. Revise guidance for port health authorities and local authorities.
5. Improve training of port health officers.
6. Fund for specific sampling and monitoring.
7. Improve local authority administration for Heathrow.
8. Increase powers for port health officers over personal imports.
9. Restrict points of entry to UK for products which are not of animal origin.
10. Consider introduction of prior notification of imports of products which are not of animal origin.
16. Many of these recommendations link with the Government Action Plan published by DEFRA, such as improving co-ordination between the central and local government bodies with responsibility for imported food controls, and increasing powers for port health officers.
17. In order to take the ten recommendations forward, the Agency is establishing a dedicated Imported Food Branch with particular responsibility for co-ordination of import work within the Agency and liaising with other Government Departments.
SURVEILLANCE
18. The Food Standards Agency carries out surveillance on food to help obtain estimates of exposure of UK consumers to chemical, microbiological or radiological contaminants in food, and to identify foods most likely to be contaminated and possible causes. Imported foods may be specifically targeted if, as a result of either EU-wide or national measures, they are identified as being at risk from contamination, such as if there are contamination problems in particular countries. Recent examples are surveys of Chinese honey for veterinary residues and Chinese peanuts for mycotoxins.
19. Imported foods may also be specifically targeted if they contribute significantly to dietary exposure, that is, if they are likely to contain higher levels of a particular contaminant or if they are consumed in large amounts by some groups.
20. The evidence of the Agency's surveillance does not for the most part indicate that imported food is any more likely to pose a public health risk than food produced in the UK. Where surveillance indicates a possible health risk from an imported food appropriate action is taken to alert the European Commission through the Rapid Alert System for Food and Feed (RASFF) and where necessary to remove it from the food chain.
RAPID ALERT SYSTEM FOR FOOD AND FEED AND FOOD HAZARD WARNINGS
21. The EU operates the RASFF system. When a food safety problem is identified, electronic notification enables speedy follow up to remove the product from the human food chain. The Food Standards Agency is involved in routine surveillance of food and contributes to the RASFF notification system as well as alerting enforcement officers where they may be required to take action (by issuing food hazard warning notices). The Agency has a commitment to putting consumers first, and issues information on food issues, particularly where there may be associated health risks. This enables consumers to make informed choices about food.
FOOD SAFETY RISKS FROM IMPORTED FOOD
22. Trade in food with other countries does have the potential to bring into the UK both human and animal diseases and contaminated food that could pose a food safety problem. However, the controls and safeguards in place are aimed at ensuring the risks to public health are minimised
23. The main public health risks associated with products of animal origin are pathogens present in both this country and abroad (where the contamination rate may be different) and exotic pathogens.
23.1 Microbiological risks from imported meat: like any raw meat, there is a risk that raw imported meat may be contaminated with food poisoning micro-organisms. Of particular concern is contamination of raw red meats with E.coli O157 and Salmonella and raw poultry with Salmonella and Campylobacter. It is therefore important to observe normal hygiene precautions when handling and preparing raw meat, to cook meat properly before eating it and take steps to prevent cross contamination of raw meat to ready-to-eat foods. Cooked meats have been associated with listeriosis, but there is currently no evidence to suggest that illegal imports carry a higher risk.
23.2 Tuberculosis, anthrax, brucellosis or parasites risks from imported meat:
All these organisms are sensitive to heat and will be destroyed by cooking.
— Tuberculosis: Human tuberculosis is usually caused by Mycobacterium tuberculosis (usually acquired from another human) and not Mycobacterium bovis which is the cause of bovine tuberculosis. M. bovis infection can be transmitted to man by milk, so the risk from illegal meat imports is likely to be low.
— Anthrax: The highest risk in the UK has been reported in occupations associated with people handling imported hides; imported illegal hides may be a risk for these workers.
— Brucellosis: The presence of Brucella abortus in illegally imported livestock would constitute a risk to public health as the livestock would not be tested as part of the ongoing surveillance programme, however, illegal import of live animals would be very difficult. In 2000, 19 cases of human brucellosis were reported in the UK. All the cases in Northern Ireland were occupational cases (farmers and meat plant workers), and all the cases in England and Wales occurred in people who were infected outside the UK.
— Parasites: Taenia (tapeworm) infections in humans are reported only rarely in the UK. Illegally imported beef and pork may be infected with tapeworm cysts (T.saginata and T.solium respectively). Trichinella spiralis is not believed to be present in the UK. It causes occasional outbreaks of disease in humans, and, as it is known to be present in other countries, the importation of illegal meat, in particular pork, may be a risk.
23.3 Viruses such as Ebola from imported meat: the potential public health risk due to viruses such as Ebola and imports of meat, if one exists, is extremely remote. None of the haemorrhagic fevers, including Ebola, have been shown to be transmissible by ingestion. It is also extremely rare to find Ebola in animals other than primates. There have been extensive searches for the natural reservoir of infection but, apart from a possibility of it being found in bats, the only animals that have been positive for Ebola are primates, all of which are clinically affected by the disease. Although monkey meat could be a possible source, because of the clinical effects, it is very unlikely that meat from an affected monkey would find its way into the food chain, even into illegal imports. Cooking would destroy any viruses present in meat.
24. For raw products of non-animal origin, such as fruit and vegetables, the difference between the UK and other countries is not so much the spectrum of possible contaminating organisms but the possibility of different controls on the use of organic wastes and on the quality of irrigation water.
BENEFITS OF IMPORTED FOOD
25. The benefits of food imports should not be overlooked. The nutritional benefits of consuming at least five portions of fresh fruit and vegetables have been identified. Without food imports the range and quality of fruit and vegetables available to UK consumers would be significantly reduced.
26. From the consumer point of view any significant reduction in the level of food imported into the UK would significantly reduce consumer choice. A significantly reduced range of food would be available with some foods only being available on a seasonal basis. This could cause nutritional problems as some foods relied upon to provide a balanced diet may not be available.
27. A reduction in imports would also disadvantage many consumer groups and ethnic minority groups, whose recipes often require foods, which are not commonly grown or produced in the UK.
28. In terms of trade, the UK imports just over 50 per cent of its overall food requirements, which at 1996 figures amounted to almost £18 billion. Of this, approximately two-thirds come from EU countries and the remainder from third countries. UK food exports, at 1996 prices, amounted to about £10 billion of which just over half goes to other EU countries.
CONCLUSION
29. Whilst the Food Standards Agency recognises that illegal imports carry the potential to introduce food safety risks, as well as animal health risks, most imports are fully compliant with the law and do not pose such a risk. The Agency is playing a full part in cross-Government Action Plan work to improve the controls on imported foods. We fully support the measures in the Government Action Plan, in particular the work that DEFRA is currently doing on risk assessment of disease associated with illegal imports to inform and to enable better targeted and proportionate enforcement action. The Agency is taking forward a ten point action plan to address food safety concerns about imported food and in considering this work will continue to liaise closely with DEFRA to ensure joint working.
Local Authority Enforcement Division
Food Standards Agency
17 May 2002
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