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UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 690-ii House of COMMONS MINUTES OF EVIDENCE TAKEN BEFORE Environment, Food and Rural Affairs Committee (Food Information SUB COMMITTEE)
Tuesday 22 June 2004 DR SUSAN JEBB and DR ADRIAN PENROSE MS LINDA CAMPBELL and MR PAUL WRIGHT MR TIM BENNETT and MR ROBIN TAPPER Evidence heard in Public Questions 155 - 280
USE OF THE TRANSCRIPT
Oral Evidence Taken before the Environment, Food and Rural Affairs Committee, (Food Information Sub-Committee) on Tuesday 22 June 2004 Members present Mr Mark Lazarowicz, in the Chair Mr Michael Jack Mr Austin Mitchell Joan Ruddock Mr Bill Wiggin ________________ Memorandum submitted by Centre for Human Nutrition Research Examination of Witnesses
Witnesses: Dr Susan Jebb, and Dr Adrian Penrose, Medical Research Council's Centre for Human Nutrition Research, examined Q155 Chairman: Good afternoon, Dr Jebb, and Dr Penrose. Welcome to the meeting of the Food Information Sub‑Committee. I look forward to what you have to tell us about today. I understand you want to make a very short statement before we ask you about your work done at the centre. We do have a very heavy timetable this afternoon, so if you want to make that statement as briefly as possible we would appreciate that. If you would like to make that brief statement at this point. Dr Jebb: Firstly, thank you for the opportunity to come and speak with you today. We are here really representing the Medical Council Research Unit for Human Nutritional Research based in Cambridge. Our emphasis is really on strategic and applied aspects of public health nutrition; we are first and foremost a research unit. What makes us slightly different from most other research institutes, and certainly within the MRC, is that we have a specific communications function which is in‑house and headed up by myself as a research scientist. I, in parallel, am responsible for our programme of work on nutrition and long-term health outcomes as well as heading our nutrition communications group, which works both with consumers, the media, and also a wide range of other stakeholders, including industry, health professionals and the Government. I think that puts us at a particularly interesting niche as far as this particular inquiry is concerned with, if you like, a foot in both camps in terms of the evidence base, and, secondly, the translation into policy and practice. I am really going to be trying to speak to you today with that perspective, which is perhaps a little bit different than you may be accustomed to with other MRC scientists. Q156 Chairman: Thank you. That is very helpful indeed. Dr Jebb: I should perhaps introduce my colleague, Adrian Penrose, who is our communications manager and has a background and expertise in communications as opposed to my own expertise in nutritional science first and foremost. Q157 Chairman: I was very struck by the first statement in your written evidence that consumers need enhanced quality not quantity of information on nutrition issues. I think that has been a theme of much of the evidence that we have had. Everyone comes up with a long list of information which should be provided; that, of course, illustrates the problem. I was struck by your point regarding the diversity of messages amongst both the scientific and the public policy communities on these issues. How far is it possible to say there is actually a general body of agreement amongst those scientists and policy makers on some of the key matters relating to food and diet, the key messages that should be given out to the public? Dr Jebb: I think there is very good agreement on the headline issues, the big topics. Those would be, for example, fruit and vegetables; the need to increase fruit and vegetable consumption. We have the five a day programme. There would also be the need to cut salt; we have seen particular emphasis of that in recent years. There is also a recognition of the need to cut saturated fat. That is an interesting message because it is a very clear and widespread agreement between scientists and policy makers. It is also one of the messages which maybe 20 years ago was clearer than it is now. Consumers are increasingly confused about the different types of fat and the issues in relation to saturates, monounsaturates, polyunsaturates: Is the issue obesity? Is it heart disease? Is it cancer? I think that is a classic area where the science is very clear that we should be cutting saturated fat. That is the key message. The policy is actually very clear, but I think for a variety of reasons consumers are increasingly confused. Q158 Chairman: Which types of messengers do you think are the best to deliver that message to the public? We heard evidence last week that the public really did not trust messages coming from not just government but government-related official bodies when it comes to food information. Who do you feel the public trust most and how should these messages best be conveyed? Dr Jebb: There are many ways of answering that question. The surveys show that people trust health professionals, their doctors, very highly. They rate them very highly, but if we think that we are going to improve the nutritional understanding of the entire nation doing this through health professionals, that would be naive. The question is not so much the best, the most trusted, but which is going to be the best strategy? If you take that approach, I think the answer is that there is no one group who are well positioned to take that on in a single‑handed fashion. The reason we have problems at the moment I think is the inconsistency between different groups, not only sometimes in the core messages but certainly in the way they are portrayed. What I think we really need is for there to be consistency of messages across the different people communicating. Different people, different stakeholders are able to communicate well to different groups at different times and in different places. There is no one organisation which is going to be able to address everybody equally and effectively all of the time. Dr Penrose: I think it is important to remember as well that science is very different to policy. Science is there to answer specific questions, but it is ethically neutral. It does not make assessments about risk or benefit. What we are looking for is some kind of system that can mind the gap between scientists, what Government is saying and what consumers are understanding, that is really what we are looking for now. Chairman: Austin, do you want to follow that up? Q159 Mr Mitchell: What should I rely on in terms of the kind of food that we should eat or should not eat? As you say, saturated fats are bad for us; where do I get saturated fats? I am made to eat forcibly, because my wife is a New Zealander, butter in enormous quantities to help the export market in New Zealand. Is she killing me? Should I be eating Flora? What is the impact of your research on a market which is dominated by commercial products? The butter makers attack, wanting you to take butter or the sugar makers, sugar. How do you fit your advice into the commercial market? Dr Jebb: Of course, one of the huge benefits of being a Medical Research Council is that we do have the luxury of that commercial independence. That is not to say that we do not work with the food industry. We do, but we are able to do it from a position in which we are predominantly independently funded and which we are known for the quality and credibility of our research. So we are able to take forward our research agenda I think in a very rigorous and robust way which is free of vested interests. Q160 Mr Mitchell: Do you say: "Do not eat butter"? Dr Jebb: I do say that you will be better off choosing an alternative spread, yes. Q161 Mr Jack: In paragraph 11.2 of your evidence, you say there is a temptation for scientists and journalists to leap to providing action-orientated messages, yet the majority of the population have not yet reached this stage. What evidence do you have for that statement? Dr Jebb: There is quite a body of research, not our own I hasten to add, which has looked at people's readiness to change in a whole variety of different aspects of their life. The one I am most familiar with, of course, is obesity. We, as health professionals assume, say, as clinical dieticians, if somebody comes in through the door who needs to lose weight, there is a tendency to assume that they are ready to do it, they are motivated, they want to lose weight, and so forth. In fact, sometimes they are simply there because their doctor told them to go and see the dietician. They have not made that mind shift that this is an important issue for them, that they need to take some action. So if you are dealing with somebody who is in this stage where it is not even on their agenda why they should change then what you need to be doing is giving them messages which explain to them the health benefits or what they might hope to achieve by the change; rather than telling them they should have Flora rather than butter. Q162 Mr Jack: Not everybody has the benefit of a one-to-one with you? Dr Jebb: Yes. Q163 Mr Jack: What, from your experience, are the things that people believe? I asked this question last week so I shall ask it to you. I have been struck by the unbelievable take-up of the Atkins Diet. From being not on the radar it suddenly becomes the number one thing that people are doing. I was interested to know what actually motivated people to accept lock, stock and barrel a diet which has been the subject of considerable debate but where advocates immediately start to become Evangelists and there was no official input. They just said, "That is for me - I did it". Why has there been such an uptake for that, and yet trying to get through the message that you started your evidence with seems to be so darned hard? Dr Jebb: I think that is a classic example of where anecdote, endorsement, culture has steered public habits, dietary habits in a way that scientific evidence does not always achieve. Of course, there are some examples where scientific evidence has moved it, but in that example, it was a whole range of social and cultural factors which encouraged people to adopt that particular dietary approach. What it shows is that dietary habits are not set just by science or by health priorities. They are set by a whole range of other factors which are going on. We need to understand that and to understand why it is so difficult to change behaviour through the mechanisms which you, as policy makers, or we, as scientists, have at our disposal. Q164 Mr Jack: If I have heard you correctly, we are not communicating the messages properly? Dr Jebb: We are not always communicating them in a way which motivates people to adopt them. Q165 Mr Jack: Safe and sensible does not sound to me like a very good way forward. Anecdote, promise, chat, grapevine: those might be better ways to get our messages across. Dr Jebb: The grapevine is a fantastic way of doing it. We have seen - I think Mr Mitchell mentioned Flora early on - Flora was an example of where marketeers within the food industry brought the word "polyunsaturates" to public attention. They had a very sophisticated advertising campaign. That was founded on scientific evidence that there were real health benefits in switching from saturated to polyunsaturated margarine. That was a time where we had the scientists giving out the scientific message and the marketeers marketing that message in a way which neither Government nor scientists tend to do in a more entertaining way perhaps and also we have the food industry providing a product which met that need. Then we got real change and there was a dramatic shift in eating habits. Q166 Mr Jack: Is there a paradox between the purveyors of a spread which claims to reduce cholesterol in terms of the message: "spread fat: reduce cholesterol"? Dr Jebb: That has been a tricky one. But I think that the manufacturers of plant stanols and plant sterol esters have worked very hard to do it in a very responsible way, not least ensuring that they provide low fat options for each of those products so that one can get the same cholesterol lowering benefits from a plant sterol ester low fat product. I think ideally one would like to see it in a fat-free product, but they have really tried to do that in a very responsible way. Q167 Mr Jack: Let me finally take you up on a point that you make in paragraph 5.1 of your evidence. You say: "Several major companies are now taking active steps to investigate how the communications of nutrient information may be improved such as nutritional benchmarking." That is terribly responsible and very scientific. Does that mean they do not stand a prayer of getting that information through in the light of what you said earlier about people picking up on and acting on things like the Atkins Diet? Dr Jebb: No, I do not think it does. The point I was making earlier is that people make their dietary choices for all sorts of reasons. Different factors motivate people at different times and in different places. Often the people who are the most educated and health conscious, who have made the fundamental decision, they want to change their diet, they know what it is they are trying to do. They are the people who need the nutrition labelling. When they are in the supermarket they can look at the labels and they can make the right choice. For them, improving nutritional labelling, making it more sophisticated will be really helpful to move those people a little bit further on into a healthier diet. Q168 Chairman: You point out in the same paragraph that Michael just referred to that the food industry is estimated to spend £450 million each year advertising in the UK. Is it not predominantly a result of a factor that when a product is advertised every half an hour or so on commercial TV it has a much higher likelihood of persuading people of its content than the occasional food information message from Government? How far, in fact, can the free information in messages compete with the weight of advertising? Dr Jebb: As we have said earlier, there is a whole mix of influences on what people are choosing to do. Advertising is one of them. I can only refer you - I am sure you have seen it already - to the FSA commissioned review from Gerard Hastings which looked at the impact of advertising on food choices in children in great detail. It showed that, yes, it did impact, that it was almost impossible to quantify the magnitude of that impact alongside all the other influences on food choices. Dr Penrose: Food budgeting is very complex because of the kinds of people who are likely to be interested in reading the nutrient labels are probably also making decisions about things like sustainability, where the food is coming from, whether it is organic, whether it is produced locally which makes the actual purchasing decision very complex for that person. Q169 Joan Ruddock: I wanted to ask you to look at the Government's role in transmitting food information messages. You said I think in your evidence that you were involved with the Department of Health, the FSA and the EU, not Defra. Where, in fact, food is split in terms of government departments between Defra and the FSA, which of course reports to health ministers. I just wonder how difficult it is for organisations like your own and lobby groups in general to interface with government, how much confusion you find the government overlap, or whatever. What are your views of how the Government itself is approaching these issues? Dr Jebb: I think there are two parts to that one question. One is how Government is approaching those issues. Secondly, how easy scientists find it. Perhaps I will take them in that order. We certainly perceive, and I do not think we are alone amongst the academic community, in feeling that there is too much fragmentation in government action in relation to food, that there is a lack of joined up initiatives across a whole range of different areas, that there are competing priorities coming from different departments and that makes it difficult for everybody: for scientists, for the food industry, for consumers, for anybody to know quite where they are. I am cautiously optimistic that that message has been heard by Government. Particularly over recent months the obesity issue has highlighted that enormously at the Select Committee inquiry; in other areas too. Now we have things like the Activity Coordination Team, the Food and Health Action Plan, both of which are in principle across government. So I think it seems to me that the message has been heard. Whether it has been fully acted upon is probably too early to judge, but I really truly hope that that is the case because food cuts right across government. We get into DFES with issues in schools. We get into DFID. All over if we are going to make progress, it has to be joined up. As far as scientists are interacting, having a joined-up government would help us enormously. Scientists are not trained in policy issues at all --- I have sort of slipped into this. When faced with policy consultations I notice that we are one of relatively few academic institutions who actually respond to those consultations. They take an enormous amount of time. We sometimes feel like we are drowning. Just recently we have the White Paper, the Food and Health Action Plan, we have the activity plan, the FSA Strategic Plan, this Defra one, the promotion of foods to children. It is absolutely mind boggling. We try to respond to those and that is really our effort to engage with Government. The fact is that I think it would not occur to us really to come directly, in most instances, to ministries to talk about issues. That is not really the way scientists work. We tend to sit there and wait to be summoned. I think it is unfortunate that Government does not make more use of scientists to help them in developing the evidence base, in developing policy. There are clearly one or two important advisory committees, but perhaps they are not even used as much as they might be. Q170 Joan Ruddock: If I may interrupt you, do you have a suggestion to make? You are already overwhelmed you told us, how would you like to do more work? Dr Jebb: I think that certainly at the Medical Research Council we are part of Government. I think that there could be some useful discussions at a very senior level as to how the Medical Research Council should best be using its science to inform policy because it certainly seems to me that it is a rather ad hoc arrangement at the present time. Looking at it from the other angle, I am acutely aware, talking with the nutrition scientists in the Department of Health, that there are fewer of them than ever before. Q171 Joan Ruddock: Really? Dr Jebb: Yet nutrition is on the agenda in such a major way that they are under enormous pressure. I think that we have to find a way of getting in skilled expertise from outside in order to inform policy; consultations are one way of doing it, but I am not sure it is always the most effective. Q172 Joan Ruddock: I think you have just written a Parliamentary question on how many nutrition scientists there are in the Department of Health. Thank you for that. Dr Jebb: Certainly, there are fewer than there were a couple of years ago. Q173 Joan Ruddock: Should that prove to be the case, and I have no doubt you must be right, that is a serious matter I think for us to consider. I would like to just refer also to a point that you yourself made about the Minister for Public Health and the messages about cutting salt. Do you think that was a useful initiative and is it your belief that Government needs to legislate in this area because we know there is a lot of voluntarism in this cut. Clearly, there are messages going to people who are taking very little or no notice of the previous pleas of Government. Dr Jebb: Firstly, it has been absolutely essential, vital and very important that Government has said loud and clearly that salt matters, and called upon the food industry in no uncertain terms to cut salt intakes. That has been critical; the salt debate has been rumbling for years. There has been actually stunningly little progress until the last six months or a year. Some progress: we have seen salt in bread come down over the last few years. I have to say my feeling, and I think it is shared by my colleagues, is that we are seeing real progress on salt within the food industry. Of course, we would all like more and more quickly, and so forth, but we are seeing such substantive progress compared to what we have had two, three, four years ago. My own feeling is that at this stage of the game we should be highlighting those people who have done the most, achieved the most, and applauding that. That might actually be a more constructive strategy. So naming and praising rather than naming and shaming I think would have been my choice. We are moving in the right direction and what we want is to keep that bandwagon going and going at an impressive rate. I think we need to remember that with these nutrition things - if we want the food industry to start producing healthier options and marketing and supporting those - we have to do it with them. If they dig their heels in and refuse to do anything we will all be worse off. I really do believe we have to do this in partnership and a spirit of constructive engagement is what is required. I think they are making progress with salt. We need to keep the pressure on, but we need them to do much more on fat and sugar and a whole load of other things too. We have to stay positively engaged. Q174 Joan Ruddock: Are you saying: "do not regulate, just put more pressure on getting agreement"? Dr Jebb: At this stage, I think we are making significant progress with voluntary action. I think that if we can continue to do that then that is what we should do. Because if we go for regulation what we will end up with is diverting a proportion of the industry into finding a loophole rather than trying to find positive ways of making progress. Having said that, regulation clearly has to be there as the stick, the Government needs to wield a regulatory stick and be prepared to use it if necessary, but I am not sure that we are at that point yet. Q175 Mr Mitchell: Does that mean you are not happy with the European Union's approach? It seems to me to be a matter of imposing labelling definitions on the consumer. If you say your preference is for the voluntary approach when making progress, what is going to happen when this is imposed on us? Dr Jebb: There are two separate issues here. I was talking about voluntary changes in product composition and product innovation and so forth. That is quite different from regulation in relation to labelling. There is already labelling taking place. I think that regulation may be necessary in order to ensure it is done in a consistent way, but again, with labelling, it seems to me that there is actually a lot of agreement that we need good, informative labelling. Consumers want it, Government wants it, scientists want it and I certainly have not heard the food industry objecting to having clear and informative labelling. The question is how can we do that? What we really need to do is to get people together and come up with a better system. I think we have to stop pretending there is a perfect system. I am not sure there is, but we need a better system which people are prepared to sign up to and use consistently. At the moment, labelling is becoming bigger than it ought to be. It is becoming a bit of a diversion. We spend so much time and energy worrying about labelling when it is only one small part of the overall issue of how are we going to improve, help consumers to help themselves to a better diet. We need to ring fence labelling into a discreet working group who get on and come up with some practical, workable solutions and the rest of us should get on in making progress in other areas. Q176 Mr Mitchell: That depends on receptive consumers at the other end. You worried me there earlier by your emphasis on the grapevine. The grapevine is like the internet; is it not? All sorts of rubbish flows through it. You mentioned earlier Flora. From time to time there are articles saying Flora is a waste of money, it is overpriced and is not going to do you any good. You might as well stick to butter. You see all sorts of stuff about drinking a glass of red wine a day. So I inevitably go in for excess and drink three or four, but it helps your heart. You see organic food: that is good for you and good for your children. Yet the Food Standards Agency tells us it is a lot of rubbish. We feed milk to kids at school then tell them not to drink milk when they get older. The fish and chip shops were strung up with posters saying: "fish and chips, the health food". Now we are told fish and chips are bad for you, but then we are told fish is a brain food. What is the consumer to believe in all this? Dr Jebb: I recognise absolutely all of that and I completely understand and share your concerns that consumers are confused. They are confused because there are so many messages. This comes back to the whole issue that nutrition science is not straight forward. This is not smoking where the one message "stop smoking" meets all circumstances, all eventualities. With nutrition science you have endless different nutrients, endless different foods. It is probably at the end of the day the combination of that which really matters. That makes it phenomenally complicated for people to work their way through. Where do they look to for good information? That is hard. I think they do still have some trust in independent scientists. They still like to hear that the scientists have said something. Of course, that has been hit by some of the recent scare stories and worries, not least BSE, but scientists are still there and I think have some trust with the public. I think Government still does have some trust. The Food Standards Agency has done a lot to work with consumers and to bring the evidence in front of consumers. We are not going to solve this overnight, but we all have to be working in the same direction. The other thing we have to recognise is that consumers' level of scientific understanding is actually very low. That makes it difficult not just to teach them about good nutrition but about so many other things as well. It is about risk. Consumer understanding of risk is very confused. It is even about averages. People have real difficulty grasping the basic concepts. So we need to up-skill consumers in their basic understanding alongside more specific nutritional issues. Q177 Mr Mitchell: You are going to tell me I am too old for it. How useful would labelling be in this? Nutrition: it is difficult for consumers to choose what a nutritious diet is. Should provision of nutritional information be part of a label system? Should that be compulsory? Dr Jebb: Of course, we have nutritional labelling and information in the declaration at the moment, but I guess what you are getting at is the idea of a firmer guide as to what is healthier food. This is an issue which the Food Standards Agency is working on actively at the moment as part of their work on the promotion of foods to children. I guess it brings us to the heart of the good food/ bad food, good diet/bad diet story. Q178 Mr Mitchell: It also takes us to the traffic light system. Should you tell them what the nutrients are and should they be signalled by a kind of traffic light system? Dr Jebb: Let us take traffic lights head on. The traffic light system is initially attractive because it sounds so simple and it sounds like it is going to cut through all this and give the consumers a simple red, yellow, green signal. That is its attraction; it is also its flaw. Because it is so simplistic how on earth are you going to compress all this great complexity of nutritional science into a single three point system? To give you some of the issues: are you going to use these traffic lights to indicate to consumers choices within a category or across categories? What I mean by that is, take reduced fat crisps. Reduced fat crisps clearly have less fat in than the original. Does that mean that the original is a red food but the reduced fat is a yellow food because it is a healthier choice relative to --- It is not a healthier choice compared with a banana. So if you are trying to have one traffic light system which works across categories it becomes very difficult. Then if you were doing it across categories probably all of these high fat savoury snacks would all be red. That would instantly discourage food companies from producing healthier versions of those because they were always going to be a red. A traffic light becomes very difficult if you are trying to match up the maximum benefits within a category, with a cross category cutting. The other issue is what nutrient are you going to focus on? Is this just about fat, which I was talking about, or is it about fat and salt or salt and sugar, and what about micro nutrients? Then you got into the whole issue of producing a very complex nutritional score. That becomes mind bogglingly difficult. It may be necessary for foods like cheese because cheese is high in fat, it is high in salt but it is an important source of calcium. Would we really want to label cheese as red because it is high in fat and salt? Maybe not. This is not the time or place to go into the pros and cons of all the systems, but I can assure you this exactly what the FSA working group, which I sit on, is looking at in great detail, not only for a traffic light system but looking at a whole range of options which are being used nationally and internationally. Q179 Mr Mitchell: It sounds impossibly complicated. What you are saying, I take it, is it is difficult to provide additional labelling information to show information to the consumers unless you also educate consumers. The two steps have to go hand in hand. Dr Jebb: Absolutely, yes. You need an educated consumer who knows how to use the label, knows what they are looking for and is also already motivated to want to go to that time and trouble. Q180 Mr Mitchell: Okay. Are you also saying the differences in traffic lights, between different kinds of food, but there is no such thing as good food? There is such a thing as good diet but good food, bad food is not on the same dimension? Dr Jebb: To some extent. Clearly, there are no foods which are so good that if you eat them - nothing else - they override everything else in your diet. Clearly, there are no single foods which are, to put it bluntly, going to kill you tomorrow. It does not work like that. It is about the overall balance. If you just talk about good foods, bad foods, it ignores all of the important issues about how often you consume that food, about the portion and size that you consume. So, of course, one has to say there are good diets and poor diets, but the problem is that this has become a real mantra. The food industry uses it to hide behind. There are no good and bad foods: end of story. They use it as a closing statement to avoid moving any further forward. I think it is quite clear, common sense and rational consumers are quite clear that there are some foods which provide quite a lot of energy and virtually no other nutrients. Sugar-rich soft drinks would be a prime example of that. They know it is perfectly possible to get the same number of calories from a different food which contains a lot of other nutrients and that that other food would be a healthier choice than the food which is just calorie rich which contains no nutrients. I think the Food Standards Agency has done a good job, in a way, of putting the whole issue in the spotlight and saying quite pragmatically: surely it is clear that there are some foods which are healthier than others? Whilst it may sound like a bit of a cop out I think it has actually moved the discussion on a bit to start saying that there are some healthier and some less healthy options. Q181 Mr Jack: How do you communicate the benchmarking messages? Because listening to what you were saying earlier on about micro nutrients, vitamins, salt, sugar, fat, it is quite difficult if you are where you are to then say: how do I benchmark where I ought to be? How do I know how many grammes of this, that and the other thing I ought to be consuming? How do I develop the awareness so that in my everyday workings where I have for some period of time control over what I eat because I prepare it and other times I have subcontracted that to a whole variety of people who have provided me with my meal? How do you get through to people the starting point and also the simple information that enables them, to at least be aware at the back of their minds that, as they go through their week consuming all this variety of foods prepared in all these variety of ways that, they are either above or below where they ought to be to hit the Nirvana of the perfect diet. Dr Jebb: It is difficult and you are absolutely right that this is an important secondary element of the labelling. We have started this by putting the guideline daily amounts on packets which tell you typically that a woman needs 2000 calories and a man needs 2,500, and sets out the goals for fat, for example. Q182 Mr Jack: Like: "A Mars a day helps you work, rest and play"? Dr Jebb: Fortunately they do not use that any more. So we have started to do that, to give people the benchmarks about where they should be. They can, therefore, look and let us use the Mars bar example. They can take a king size Mars bar versus a snack size one. They can see the king size provides about 20 percent of their daily energy needs in a single item, whereas the snack one provides only 10 percent. They can then decide what proportion of their calories they want to spend on this snack. I think that is a start. It is a rather simple thing but rather helpful to people. The complexity comes with how many nutrients do you want to do that for? That is where it becomes much, much harder and also harder at a population level. We can say if we think of macro nutrients, the energy providing nutrients, that in general people are consuming too many calories for their energy needs, which is why most people are getting fatter. In general, they are consuming too much saturated fat and are consuming too much salt. We can set some guidelines for those, but if you start looking at micro nutrients you get much bigger disparities with the population. Q183 Mr Jack: I am going to stop you there. Is there any research to show us of all the things you have just discussed, what the relative levels of awareness are from people? In other words, what messages get through about all these things and upon those messages? What proportion of the population actually reacts to them? You said that: "I think the message was much clearer 20 years ago", about saturated fat. I suppose my sort of question is, as the fat issue has come up the agenda, what has clouded the message? What makes it less clear? Was there some period where people had a much better idea of what they ought to be eating and had worked out strategies to achieve a good diet? But now we effectively are getting a message saying that people have picked up a lot of bad messages, so they have bad diets. Dr Jebb: They have become confused. I think the fat one I would specifically put at Atkins' door where we have had the emphasis that actually eat as much fat as you like, it is absolutely fine. That I think has really undermined what had been a very consistent and coherent message that too much saturated fat was bad for your heart. Q184 Mr Wiggin: Can you accept with the Atkins Diet the reason that people do it is that it actually works, whereas all the other diets we have been told about running up to now: "I have tried it and it works". Mr Jack: What do you mean by "works"? Q185 Mr Wiggin: It works. It does what the book says; it works. None of the others do. Dr Jebb: All diets, if you do what it says in the book, work because they are all low calorie diets. The problem is that people find them difficult to stick to. For some people, by no means everybody, some people have found that the Atkins Diet works for them in the sense that it fits in with their lifestyle. The research evidence shows that if you look at people over the course of a year within the context of a clinical trial people do equally as well, or equally as poorly following, Atkins as they do following a traditional low fat diet. The anecdotal impression at the moment is that it is wildly successful. The research evidence is that it is equally as effective as other diets. Q186 Mr Wiggin: The difficulty is, and I think this is why it is so important, a lot of what you have been saying has been about what is good for you and what is not. The only message - I think Austin said it earlier - was that a glass of wine was actually good for your heart, it was red wine. A lot of the information we have been given about food has been, "if you eat too much salt it will harden your arteries, and that is bad for you". At that point you say, "I will try and eat a bit less", but it is already in the processed food. There is no control that an individual can actually take, in real terms, over their diet until they do something fairly extreme like Atkins. Dr Jebb: I refute that. Salt is an unusual one because around 75 percent of the salt people consume is consumed as part of processed food. So they have less control over their salt intake than they do over other things. Of course, one does choose to what extent you use processed foods versus fresh foods, but that is made for all sorts of reasons. For other areas people have a huge amount of choice: they choose how much fruit and vegetables they consume; they choose whether they cut the fat off their meat or not; they choose what kind of breakfast cereal they have. I think you make an interesting point about the difference between positive and negative messages. We have become much more aware of using positive messages. We have seen five a day for fruit and veg. It is a very positive campaign. We are seeing in the United States things like whole grain, putting the emphasis on choosing good carbohydrates with the low glycaemic industry message being promoted. I think that is a learning curve we have been through and we are now trying to adopt more positive messages. Q187 Joan Ruddock: I just wanted to take you back for a moment to the traffic light system. As you say, it is so simple and so attractive. When we began this inquiry I was hoping very much we might end up saying "Do that", if the one thing we could say would be do that. So I am concerned, but I understand exactly why you said it is a flaw. Can you not envisage any system that is as simple as that in terms of the consumer looking at the product that could be accompanied by a framework? So, for example, if you are eating more than X reds per week you must stop and think. If you are eating this combination your picture looks like a nice sunny yellow, you are probably okay. Is there any way we might be looking to achieve something that has a simplicity? I know when I shop I have no time, and most women that are shoppers are like me, they just do not have the time. Dr Jebb: I do not think you should throw the traffic light system out altogether at this point. What I was trying to do is to illustrate some of the complexities of it. However, it is perfectly possible, but one has an incredibly complex system of definitions and profiling which all goes on behind the scenes, which policy makers have set, which scientists have agreed, which the food industry are very aware of, and that actually the manifestation of that is something very simple on the front of the packet. That is not out of the bounds of possibility but it will require a lot of careful working up to sort that out. I think what you may be asking for is something which is perhaps a little bit different and is perhaps more analogous to some of the flashes we see, logos we see on products already. So things like, for example, the folic acid logo. If you are trying to increase your folic acid there is a logo which some companies use which tells you that this product is particularly high in folic acid. This is also used in a more medical context for people with allergies. They are marked up and used to indicate a vegetarian food and so on. I think there may be opportunities for again coming back to using positive messages to flag up that there are particular attributes of this food which might mean you really might actively want to choose this. In doing so, we have to make the hope that that displaces something else from the diet. If one is going to go down that route clearly you need to do a lot of research to ensure you are achieving what you thought it was you were doing, but there may be some mileage in that which harnesses many of the points you are making about simplicity, about positive messages, and so forth. Dr Penrose: I think underlying this is the need to communicate the whole message. Part of the problem at the moment is that we have food messages, dietary messages and physical activity messages. Whatever system we choose we have to make sure that the nutrients and concepts are linked to specific foods to enable us to be able to turn these abstracts into shopping lists so that people can do something tangible. Q188 Mr Jack: You have sent me a complex message: what is the hypo - whatever it was - index? Dr Jebb: Low glycaemic index. Glycaemic index is a measure of the extent to which a food raises your blood sugar level. Quite clearly for people who suffer from diabetes it is extremely helpful and valuable to choose foods which have a rather low tendency or make a small increase in your blood glucose levels. This message, to my mind, is being portrayed to consumers in advance of the scientific evidence really being marshalled. We do not have any good categoric evidence that for the average person that choosing low glycaemic index foods is going to make you lose weight or reduce your risk to these various diseases. It is probable all the evidence is tending in that direction but it is by no means concrete yet. Mr Jack: I feel better already. Q189 Chairman: Thank you very much indeed for coming along to give us your evidence. It has been very interesting. If there is anything you want to add in writing having given us evidence today, in light of what you said, feel free to send it in to us in due course. Otherwise I thank you very much indeed for your evidence this afternoon. Dr Jebb: Thank you. Witness: Ms Jeannette Longfield, Sustain, examined Q190 Chairman: Good afternoon, Jeanette Longfield. You are the coordinator of Sustain? Ms Longfield: Yes, that is me. Chairman: Welcome to the Committee this afternoon. Thank you for coming along to give oral evidence this afternoon. Bill Wiggin will start the questions. Q191 Mr Wiggin: How helpful is the current food labelling requirements assisting consumers in following a balanced diet? Ms Longfield: Mainly rubbish, really. They are incomplete, incomprehensible, voluntary, confusing, and fairly useless. Q192 Mr Wiggin: In your evidence you refer to loopholes in the current labelling regulation, for example baked goods are exempt from declaring their weight, alcoholic drinks from their list of ingredients. Excepting for a moment the limitations of information required by present legislation, what about the uniform application? What do you feel about that? Ms Longfield: That some goods seem to be exempt? Q193 Mr Wiggin: Sorry? Ms Longfield: What do I feel about some goods apparently being exempt? Q194 Mr Wiggin: The fact that it does not apply uniformly across all goods. Ms Longfield: I rang up a colleague in Laycors this afternoon before I came: that is the Local Authority's Coordinators of Regulatory Services, the Trading Standards Officers who enforce food labelling law. I said: "Why is it that some products do not seem to be weighed, measured?" He said to me: "Ah, well". I will truncate the half an hour into a couple of minutes. It is some relic of old weights and measures legislation, apparently, and cross-referring to food legislation because weights and measures covers more than just food and taking definitions from one bit of law that does not really apply to another bit of law and you just end up with these stupid gaps. He agreed that it was anomalous and ought to be sorted out and it was probably on somebody's list of things to do at some point, but nobody has done it because it is kind of boring. Q195 Mr Wiggin: How would you like to see it develop? Ms Longfield: I just cannot see - there is no reason that I can see that is defensible for having any foods that are exempt. It surely cannot be beyond the wit of the collective expertise of the scientific community, of officials and legislators to come up with a system where everything is covered? How hard can that be? Q196 Mr Wiggin: It is expensive. What about traffic lights; you heard about that I think. What does Sustain feel about the traffic light system? Ms Longfield: Sorry, the reason why I am grinning is because about 20 years ago, I think, a very similar system was suggested, explored exhaustively, and everybody said, "That is too hard, we do not understand it" and, now we are having another look. Again, I think it is not beyond the wit of man, woman and beast to come up with a system that makes it easier. In Australia they have Pick the Tick, and in Sweden they still have the key hole system, in other parts of the world they probably have other ways of doing it. None of them is perfect, but it is surely not impossible to make it easier; even if they do not turn out to be traffic lights it will be something that makes it easier. Q197 Mr Wiggin: What do you do with things like very small amounts or difficult foods: unpackaged meat, vegetables, that kind of stuff? Ms Longfield: With loose foods I am sure if you could solve the problem of simplifying the information you want to give, you have to have labels and tickets somewhere, stuff with a price on. Q198 Mr Wiggin: On the menu when you go into the restaurant, I think? Ms Longfield: With loose foods you can put it on wherever you put the ticket information, what the price is and what have you. With catering, it depends on the catering. If it is in a sandwich shop or a fast food restaurant where basically day in and day out you are selling the same stuff, made to a recipe, do the analysis, get the label: not hard. If you are eating somewhere posh where it is cooked from scratch every day and you are probably not going to eat there very often because it is posh, so it does not matter if you eat there to be honest. Mr Wiggin: It does if you are legislating there unfortunately, but thank you very much. Q199 Joan Ruddock: I want to ask you about action at government level and how well coordinated you think the departments are in terms of food policy and the communication of food messages et cetera. Ms Longfield: They are not. The Department of Health and Food Standards Agency fight. Defra does not really get involved most of the time. DfES is too busy with other stuff. It is just a complete dog's breakfast really. Mr Wiggin: On labels. Q200 Chairman: This is a joined-up Government, do you mind? Ms Longfield: Yes. It is a really good idea. I think that somebody should do it. Q201 Joan Ruddock: When you hear messages coming out, such as came out from the Public Health Minister recently, is that something that you think is useful or do you just say: "what does that count because nobody else is going to follow through?" Ms Longfield: I have a suspicion that is probably the result of some departmental warfare really, not part of an integrated approach to try to get the industry to do the right thing. I think there is probably blood splattered all over someone's carpet over that one. Q202 Joan Ruddock: That is a very cynical view you have here. Ms Longfield: I am sorry. I have been doing it too long, have I not? I should be a dancing teacher, which is what I wanted to do in the first place. Mr Jack: We do special camps. Mr Mitchell does strictly ballroom. Q203 Joan Ruddock: The FSA has set up a consumer committee "to help ensure the views and interests of consumers are represented", and indeed Sustain is on that committee. Tell us something about your experiences on that committee. Ms Longfield: I think we spent a good 12 months trying to work out what the agency wanted us to do. There have been some unfortunate problems with rapid turnover of representatives of the committee and so we have not been able to settle all that kind of stuff. Because the agency is the whole thing set up to be the consumer champion, and I am not sure it has entirely achieved that yet but at least it is trying. It is not entirely obvious what a special consumer committee would do in an organisation that is entirely dedicated, at least on the face of it, to promoting a consumer view. We have discussed some extremely interesting issues. We have looked at food promotion to children, food irradiation, GM food. What else? Food authenticity and also some labelling issues, but I have to say I could not hand on heart say that it has been a wild success and shows the way that we should go. I think it has struggled a bit, to be honest. Q204 Joan Ruddock: So if the Committee has not had the kind of input that we might imagine, people would be saying this is how consumers behave. This is the difficulty consumers have absorbing messages, the time problems with seeing what is on the label. They are too complicated. It has not had that kind of input on that issue of labelling. Ms Longfield: No, it has not. In fact, there is a whole separate bit of FSA machinery dealing with labelling to which we have made bits of contributions as the consumer committee, but I think one of the problems with labelling has been not just the sheer volume of labelling and legislation that comes at it from Brussels dealing with all of that, but also the issue of enforcement of food labelling and legislation which they are not in control of. Because they do not enforce it, it is then enforced at local level. That is a whole new area of difficulty and problems. It is not beyond possibility that the consumer committee could get better and could get a grip of things like food labelling, and that is part of food information. We just have not done it yet. Perhaps a good prod from the committee might help. Q205 Mr Jack: Can I just take you to paragraph 5 of your written evidence? You make an interesting observation. You say: "In the USA the legislation has compelled companies to give more nutrition information than is required in the European Union and restricted the health claims that can be made on labels." Then you go on to say: "Unsurprisingly, this approach has shown to be popular amongst citizens". Can you expand and a bit on that? Ms Longfield: Yes. They did research to see if people could use it and understand it; they could. It is a clear white box with black lettering, quite large type, as large as you can get on the size of the packaging. It is standardised so it looks exactly the same on every single packet. People like it because they can see it easily. They know what it is meant to mean. Clearly, it is not perfect because it has not revolutionised the American duty packets but at least it is not for knowing what is in the packet. Q206 Mr Jack: Given that one is trying to understand what consumers believe and then what they do with that information, does this research actually go the next step and say, "Having seen information which they say is good and it is popular, is that part of an information exercise which the individuals are carrying out saying, I can now work out buying this, buying that adds up to a good diet." I was interested to know what use people made of this information. Ms Longfield: I do not think the research went that far. I think it was looking at recognition and comprehension and working with the formats side. I do not think it went as far as working out what impact it had on their buying habits. I may be wrong. Q207 Mr Jack: The reason I ask that question, and we saw some examples of it last week here, was that the Co-op has gone beyond the requirements of the EU labelling law. The Coop has decided that producing panels, I think we saw it on a packet of jam tarts: very clear, lots of information, but effectively they had broken the law. Is it right that companies do that? What is your view about what the Co-op did? Ms Longfield: I think if you could show, and I think you have shown, that it is helpful when people are looking for information on a label that the way that they have broken the law makes it easier rather than harder, then frankly I am all for it. If they had broken the law and made it even worse than it already is, then obviously I would not be offended, but if you can demonstrate by robust research that it is helping, then why not? Q208 Mr Jack: What does that say in your judgment about EU labelling requirements then? Ms Longfield: EU labelling legislation is just a nightmare. It was never designed when it was established, certainly for nutrition, probably for lots of other issues as well, it was never designed purely to help citizens make good choices. It was the result of, and continues to be the result of, the usual political compromises that have to be made between various lobby groups and industries and different political factions. What you end up with is a dog's breakfast of labelling, which was never designed in the first place to help consumers and so it does not. Q209 Mr Jack: Do you think that the UK Government has a role to give advice about perhaps what those who use labelling to communicate messages should do, if you like, to go beyond the minimum requirements in terms of EU labelling regimes? Ms Longfield: Absolutely. There are clearly two things that a UK Government can do. You can go into Europe to say, "This is rubbish, it needs to be changed. Do what you need to do; circles to get friends to help to do that. That is going to take a long time." Meanwhile, you say, "okay, let us see what can work better and let us encourage people to do it." If that is breaking the law, well, take us to court then. I simply cannot imagine that anybody in the European Commission were to take a country to court for making labelling easy to understand for consumers. Q210 Mr Jack: Finally, one question. Is there any research to show, if you like, it might sound like the idiot question, what use people make of labelling apart from identifying the product is the one that they actually want to buy? Ms Longfield: There is loads of research on what use consumers make of labelling. It depends on what research question you are asking. When you do your research you have to have a very tightly defined question, otherwise it is too big and you cannot get anything sensible out. Depending on what you ask, you can come out with research that consumers never look at labels, they think it is completely pointless, they always buy the same thing, or research at the other end of the spectrum that shows that people always look at labelling and find it extremely important to look for particular ingredients or providence or whatever it is they are looking for. You get completely contradictory results depending on which research question you ask. Sometimes people look and look really carefully because they have particular reasons for doing that. Sometimes they just have a quick glance and sometimes they do not look at all. Q211 Mr Jack: I think what was going through my mind is that you might say that 100 percent of people will quickly look at a label to make certain it is what they thought it was, what they were going to buy. As you go down through all the categories of information that were available on labels there must again, by definition, be a different proportion of consumers at the moment of selection of the item who may then subsequently make use of all the information that is on the label. I suppose the short answer is what is the most read part of the label? What do people react to? Miss Ruddock was asking the question earlier on about traffic lights, in other words, labelling is being offered up by many people as a principal form of communication of a wide variety of pieces of information about a particular manufactured food item in all kinds of context. I am just intrigued to know what use is made of all that information by different categories of people. Ms Longfield: I think probably you are going to be having evidence from other people in the food industry later on in these sessions, are you not? It would be really interesting to know if they bring with them any of their label's designers, the people who make packaging really attractive, so that you reach out and buy it off the shelf. They know what kinds of things catch people's eyes: what colours work, what shapes work, what images work. What makes a piece of packaging, not just the label but the shape, and what makes it attractive? But of course they use that to sell you stuff, not necessarily to tell any of us what we want to know. That is the stuff that is shoved round the back in the small print and tiny box, what have you. So the extent to which people look at and use particular bits of information depends quite a lot, I think, on how the whole thing is designed. You can design it so that it is attractive and easy or you can design it so it is hard. Q212 Chairman: How far do any of the regulations about the information contained in labels counterbalance the type of message that is given over by advertising? On the rare occasions I am unwisely going with one of my children to the supermarket and they immediately go to the highest sugar content breakfast cereal they can find. They point out, "It says here it has five vitamins". How far does that kind of overall packaging counteract the overall message it wants to get over? Ms Longfield: I think one of the things that was really interesting about the remit that this committee took was that you called the whole thing Food Information, and labelling is only one of the things you are looking at. You are looking at advertising and Government communications and world trade, the whole world of information that is available to people when they are choosing food, and you are right: labelling is just a tidgy bit. It is absolutely necessary to get it right and as clear as possible that on its own is completely insufficient. There are all sorts of other things that encourage people to choose what they choose or discourage people from choosing things; advertising is clearly one of them. I am sure that some of the Members of the Committee might know that Sustain is running a children's food bill campaign to try to get legal protection for children from junk food advertising for precisely that reason. Q213 Mr Wiggin: How do you decide what is junk food and what is good for them? Ms Longfield: It comes back to what Susan Jebb was talking about before about developing the criteria, which is this huge lump of iceberg underneath the surface which will come up with what we hope will be a single definition. There is a paper which has been produced by Dr Mike Raynor who is doing some of the work in the Food Standards Agency in the Committee on which Susan Jebb sits. It is doing exactly that kind of working on the definition of the iceberg because it looks at levels of total fat, different kinds of fat, sugar, salt and so on. It is complicated but it can be done and, as I said before, has already been done in several countries so it is not that hard to do. Q214 Mr Mitchell: There are not many ‑ I do not know of any ‑ prosecutions for breaking the labelling law. Why is that? Is that because the manufacturers are so virtuous and fully compliant or is it because they are not bothering to prosecute? Ms Longfield: There is a real problem with food labelling prosecutions. First of all, there are not enough trading standards officers to go round and they have to cover all trading standards not just food so in the list of priorities it is not all that high because, apart from extremely rare examples like nut allergy and anaphylactic shock, people are not going to die from bad food labelling. It is an accumulation of misinformation and misleading information that causes the problem, so it is not high on their list of things to do. Also you need cash to take these cases to court and because it is done at a local level and because there are not very many trading standards officers and they have not got very big budgets, then taking a multi‑national food company to court for a misleading label is quite risky and expensive and understandably, not very many of them want to do it so in the end what happens is companies get away with it. Q215 Mr Mitchell: Has any multi‑national company been taken to court? Ms Longfield: Yes, there is a particularly vigorous and good trading standards officer in Shropshire called David Walker. He has been a senior trading standards officer for a lot of years now and has the backing of his local council. He has taken a lot of companies to court over his career but a recent one was Nestlé because at the time they had some heart packaging and heart disease risk reduction claims all over their shredded wheat and he considered that that was an illegal medicinal claim, took them to court and won, which was an extremely brave thing do. Q216 Mr Mitchell: What was the fine? Ms Longfield: It was derisory, a few thousand pounds I think. It is less than Nestlé's paperclip budget probably and all that effort for that, so it is really difficult for them. Q217 Mr Mitchell: Yes, what is a problem in a sense is that we are a nice government and we want friendly relations with business and capital, we do not want to be sitting in trenches sniping at each other, I am speaking as a Labour MP now and that is our position. If there are going to be prosecutions it is going to develop an antagonistic relationship, is it not? Are we not better seeking co‑operation? Ms Longfield: Should they not just be abiding by the law? I have not got a problem with being antagonistic against companies that are breaking the law. Q218 Mr Wiggin: Like the Co‑op. Ms Longfield: Exactly, if you can show that it is helpful, if you can show that you are doing it for a reason. Q219 Mr Wiggin: Do you not feel that that puts you in a very awkward position because the shredded wheat advertisement saying it is good for your heart was supposed to be encouraging you to look after your heart as well? Ms Longfield: The problem was that the type of fibre in shredded wheat was not at the time that they were making those claims the kind of fibre that is supposed to help you reduce heart disease, so it was not all that helpful, and indeed arguably not true. Q220 Mr Mitchell: So you would advocate a more vigorous checking of claims and an increase in penalties? Ms Longfield: Absolutely because once companies have got the idea that they are not going to be getting away with it then I am sure that they will quite quickly start behaving. In fact, there is an incentive to push the boundaries of the law as far as you possibly can and beyond because you know you can get away with it, by and large, and if you do not do it then your competitor will and you will be at a competitive disadvantage. The mythical level playing field ‑ at least the law should do that. Mr Mitchell: Thank you. Q221 Mr Wiggin: My question is to some extent covered already. What leads you to conclude that global corporations play a large and unwarranted rule in how the Codex rules are set? Ms Longfield: We did some research, admittedly rather elderly research now, looking at the composition of the committees that advise Codex and we found a preponderance of companies from rich, northern companies on those committees and we thought that that was probably not right given it is supposed to be an inter‑governmental agency. Governments around the world were relying rather heavily on expertise from private industry and governments in poorer countries were not getting much of a look in either and consumer organisations and environmental organisations and others, who might be expected to try to counter‑balance the private sector interest, were almost invisible just because they could not afford to get to all of the international meetings, so it is horribly skewed in favour of rich countries and rich companies. Q222 Mr Wiggin: That is one side of it. The other side, of course, is the way things are produced and how much consumers want to know about that and whether that constitutes good information or an actual barrier to trade. How do we deal with that? Ms Longfield: There are lots of conflicting interpretations about what you can and cannot do in this area. Some people say, "Well, of course the World Trade Organisation says you cannot do that." I think it is called PPNs, processing and production methods. Other people have looked at their interpretation of the rules and the law and various test cases and said, "No you can, provided that ..." So, for example, there have been cases to do with dolphin‑friendly tuna and turtle‑friendly shrimps where restrictions have been imposed to try to protect wildlife and the countries whose exports have been affected by this have said, "Excuse me, you can't do that." It appears that provided you do not discriminate between countries and say that one has to protect dolphins and one does not or one has to protect turtles and one does not, and provided that you are not overly prescriptive in how the protection occurs, then you can indeed do these kinds of things, or this is what I am told by people who know more about these things than I do. It is absolutely essential that it is allowed, not only allowed but encouraged because what is the point in having a world full of free trade when the environment is shot to hell? It makes no sense. Q223 Mr Wiggin: Perhaps you would like to say a little bit more about the shrimp‑turtle case because I feel the same way about it as you in terms of dolphin‑friendly tuna and then I get really cross when this select committee looks into the dolphin by-catch and finds that the bass fishermen are slaughtering dolphins with their nets and we are not allowed to say anything about that. Perhaps you can talk about the shrimp‑turtle case. Ms Longfield: My understanding is that it was a ruling by the US that said they would not import shrimps from a range of countries because the way they caught the shrimps had an unacceptably high casualty rate amongst turtles who were getting caught so they said, "We are not going to import them any more." The countries concerned said, "You cannot do that, that is a barrier to trade," complained to the WTO and I think the WTO at first said, "Oh yes, that is quite right, you cannot do that," but then there was an appeal and counter‑appeal. The final ruling, I think, is that the US can indeed impose restrictions on the types of shrimp that are imported and they must indeed protect turtles but they have to apply that to their own fishing fleet. They have to apply it to everybody's fishing fleet not just particular countries, so provided that the rules are implemented fairly and openly, my understanding is that you can do it, but it is too much effort and you should not have to go through all of that to get there. It should be something that is encouraged rather than something that you have to battle for. Q224 Chairman: Turning away from turtles to another subject close to the Committee's heart - alcohol - why do you think that very few retailers or producers give information about the number of units of alcohol contained in a bottle or other container? Ms Longfield: I imagine it is because they do not particularly want to tell people because it is helpful information. It is deeply depressing that the whole alcohol labelling field has languished behind even food, which is bad enough. You cannot get ingredient labelling, you do not get clear unit labelling (apart from the Co‑op) and when we are facing an alcohol problem in this country you would think that more effort would be put into that direction. I do not think it is a technical problem. In fact, it cannot be a technical problem because the Co‑op has done it. It is simply a lack of willingness, as far as I can see. Q225 Chairman: Thank you very much indeed for coming along to give us evidence this afternoon. What you have had to say to us has been very helpful. If after today's session there is any additional written information you think it would be useful for us to have in light of what you have said today then obviously we will be happy to receive that. Once again, thank you for coming along this afternoon. Ms Longfield: Thank you very much for asking me. Memorandum submitted by Product Authentification Inspectorate Examination of Witnesses
Witnesses: Ms Linda Campbell, Chairman, and Mr Paul Wright, Managing Director, Product Authentification Inspectorate, examined. Q226 Chairman: Good afternoon, Ms Campbell and Mr Wright, welcome to the Committee this afternoon. I hope we have not disturbed you by bringing you along a little earlier in the programme than was originally indicated. We are very grateful indeed that you were here a bit ahead of time so that we can use the time usefully. We would like to thank you for the evidence you sent in in writing and look forward to what you have got to tell us today in your oral evidence. Linda, I understand that you are the Chairman of the Product Authentication Inspectorate and, Mr Wright, you are the Managing Director; is that correct? Mr Wright: Yes. Q227 Chairman: I wonder if I could begin by asking you to tell us a bit about what is involved in certifying a farm assurance scheme. Take the National Goats' Milk Scheme as an example; what inspections do you carry out, how regularly, where do you go, what do you look for? Ms Campbell: Paul is the goat man! Mr Wright: We are the verifiers for the National Goats' Milk Scheme which was a scheme that was developed to allow it to attract a red tractor logo marking and the Goats' Milk Scheme is built around the current national dairy farm assurance scheme for cows' milk. Because there are certain differences between goats and cows it was a scheme that was adapted for goats' milk. There are only a very, very small number of goat farms that are actually in this scheme, probably as few as 13 or 14, and in order to get the red tractor logo they were advised to have independent verification and certification of their farms meeting those standards. In order to comply with the standards that have been prepared we visit each of the goat farms once a year with our auditors and confirm and check that they are in compliance with their own standards. If they are in compliance then they continue to be certified and if they are not in compliance then we do what is commonly called "raised non‑conformances", which they have to address before certification can continue. Each audit will take something in the order, depending on the scale and size, of two and a half to three and a half hours on site. Q228 Chairman: What actually happens? How many of your staff or the people you are contracting go out to the particular farms? What do they look for? Mr Wright: Just one member goes out and he has the scheme standard and he has the check list, which might cover a variety of things. I am not totally familiar with every aspect of the Goats' Milk Scheme but it will actually examine production, it will examine welfare, it will examine husbandry, it will examine medical records, it will examine veterinary reports, and it will seek confirmation that they are adequate in compliance with the standards. One person will do that. Those reports are then submitted back to us by the auditor, who is a contracted auditor to us and who has experience in that particular industry, and they are then subject to review by other experienced reviewers and at that point the report is reviewed for accuracy, objectivity, impartiality and completeness. Q229 Chairman: What sanctions do you employ if the recommendations of the review team are not complied with? Mr Wright: In the first instance of the recommendation if they are not in compliance they do not get certified. They are then asked to put forward their corrective actions for any non‑compliances and immediately on confirmation that all their all non‑compliances are what is called closed off they will be certified. For continuing certification at the end of each surveillance visit, if there are seen to be non‑compliances, certification will continue for a period of 30 days during which time they are asked to address those non‑compliances again. Providing they do address those non‑compliances and they satisfy us that they have been addressed, certification will continue. If not, it will be withdrawn. Q230 Chairman: One suggestion is that there are about 30 or so such farm assurance schemes operating in the country, maybe more. Can you give us an estimate of the number of farm assurance schemes currently operating in Britain? Ms Campbell: It will be quite difficult to give you a precise number because there are so many different reasons why there may be a scheme. The 30 probably is conservative but it might be in the right region and I think the thing to recognise about the number of different schemes is that they are covering so many different aspects. There may be schemes there that are covering quality, there may be other things to do with safety or animal welfare, or it could even be to do with regionality of foods. There are just so much different aspects that might require a scheme. Following on from what Paul said about the Goats' Milk Scheme, when you are asking what is involved in a farm assurance scheme I think the key thing to bear in mind is what is involved depends entirely upon what is in the standard and so that is actually the nub of the issue, what is actually in the standard, rather than saying typically a farm assurance scheme is X or Y. A farm assurance scheme will assure you that that farm complies with whatever is in the particular standard against which they are requiring certification. Q231 Chairman: In the guidance from the FSA it states, I understand, that all the food assurance schemes in the UK should be accredited to European Standard EN 45011 by the UK Accreditation Service. What proportion of these schemes actually achieves that accreditation at the moment? Ms Campbell: Again, I would not be able to answer that. I am not even sure UKAS could answer it because it would not necessarily know what schemes have not complied. It is guidance and I think most of the scheme owners would seek to ensure that their schemes are accredited, but I do not think that it is necessary that all the schemes do meet that requirement. Also what tends to happen in terms of accreditation is that some schemes can predate this requirement so there tends to be a practical arrangement to enable schemes to come into compliance with it. Again, a lot will depend on the particular owners of the standards or schemes as to how definitive they are about the need to meet that requirement and/or what terms of time they give in order for schemes to become compliant with it. Q232 Chairman: Take, for example, the schemes which you certify, how many of the ones for which you are responsible in some way meet the European standard? Ms Campbell: I should think probably most of them, do they not, Paul? Mr Wright: Where there is a specific requirement for EN 45011 accreditation, it is always our policy to pursue those accreditations. Accreditation can take a year. It can take 18 months to build a scheme and satisfy UKAS that this scheme is in compliance. Where there are schemes that do not require 45011 ‑ and I am hesitant to think of any at the present time ‑ then we would not necessarily go for EN 45011 because it is an expensive cost burden to the smaller schemes. I will give you an example of that. We certify Whitstable oysters and it is a requirement under EU regulations that the scheme operates to EN 45011 accreditation. Whitstable oysters, however, is one single producer in Whitstable in Kent where to develop a scheme and to accredit that particular scheme would be so burdensome to the organisation concerned that what we do is we simply operate to EN 45011 in that instance. Very rarely is that the case but it is such a small operation that it is agreed with Defra that in that instance we simply operate to EN 45011. It does not make any fundamental difference, it is just less burdensome on the poor old Whitstable oyster catcher. Q233 Mr Jack: In evidence to the Committee from Mr Clive Dibben, an independent consultant, he said that the majority of these schemes in which you are involved certifying simply mirror the basic legal requirements in their respective areas of operation so they give some degree of assurance that people are playing by the rules but they do not, if you like, go beyond the minimum standard. Do you agree with Mr Dibben's assessment? Ms Campbell: I think there will be a number of schemes that are predominantly based on minimum requirements and you could perhaps ask yourself the question why bother with the schemes if they are merely minimum requirements? I think that is because producers have seen the need to be able to demonstrate that they are in fact meeting those minimum requirements and that it is quite important to purchasers, not necessarily the consumer but in the food chain, to know that they are meeting those minimum requirements because obviously there is no policing of every individual producer to be able to demonstrate that, so this is one means of being able to show that. I think there are, though, many, many schemes where they do go beyond the minimum legal requirement when they are responding to what consumer needs are because again it is often consumers who are asking for things that go way beyond what is sensible to legislate for, and therefore there is a need in the voluntary sector to be able to develop schemes in response to that, so again things that we are seeing to do with animal welfare or the provenance of products may be something that will go beyond legislation but they are a particular producer seeing that they are responding to consumer needs, so I do think you have a mixture of both. Q234 Mr Jack: Do you not therefore think the implication is that if people see some kind of message of assurance, some kind of scheme, that they think that the product area is better than the minimum? Do you not think that informing people (because these schemes are designed to send out some kind of message) either about the nature of the end product or the way that it is being produced, that you should be able to differentiate between those who are simply saying, "I am having a rigorous assessment and I am meeting the minimum," as opposed to, in whatever way they do, exceeding the minimum and perhaps adding something on as well? Ms Campbell: Very much so. I think there is a need for consumers to be able to understand what the various schemes deliver. In many respects many of the schemes are not necessarily developed in response to consumer needs. They may be there in response to purchasers' needs further back in the food chain, not the end consumer, and there is a danger that we do as a consumer pick up completely mixed messages. We do not actually know what the various logos mean. It is not easy for us to be able to tell, as a consumer, whether it is a marketing claim or whether it is an independently verified scheme. From the basic level it is quite hard for a consumer to differentiate between those two things, so I think it is quite important that there is an ability to be able to demonstrate that something has been independently verified and that this is not just a marketing claim. Q235 Mr Jack: Have you seen any research to talk about what consumers' perceptions are of the multiplicity of schemes that are around, in other words what they understand? It is quite interesting to see sitting in this Committee the number of people who, for example, have organic schemes, which have a variety of different requirements for products under that scheme's certification process to be counted as organic. There are European legal requirements to set minimum baseline standards but some schemes are far more rigorous in their application than others. It is very difficult for somebody who says, "I would like to try organic for the first time," to know whether they were getting the most rigorous or just the basic. Ms Campbell: I think it is extremely difficult because again government has got the very hard choice of deciding whether it tries to enforce standards that are beyond the legal requirement. We have seen recently this week someone, I cannot precisely remember who it was, who was confirming that there was a feeling in the UK that sometimes we interpreted the EU standards beyond that which our European neighbours did, and certainly in terms of the organic area, I know there was a lot of debate in terms of whether UK organics should be allowed to lower their standards, if you like, to comply with the EU requirements, lower than many of the existing organic schemes that were here in the UK, and it was an extremely difficult area. I think overall there was a feel that as a minimum there has to be a level playing field between the UK and Europe and that we should not penalise UK organic farmers but, equally, there should be the opportunity, if consumers are demanding more than that standard, to be able to promote organic schemes that meet higher standards and to be able to build beyond that minimum legal requirement. Again, like all things, the more choice that you have the more difficult it is to get a message over to the consumer. That does make it much more complex, but I think on balance the preference would be to enable that choice and we have to work harder at trying to simplify the many messages that are there and to hopefully make it a little bit easier for people to quite quickly establish benchmark baselines and then those that are interested, and we have to accept that not all of us are prepared to put that effort into our shopping necessarily to research what each individual schemes means but that those of us who are interested and do wish to know more about what is behind the various schemes we have easier access to that information. Q236 Mr Wiggin: I am very curious about this because a lot of my constituents who are farmers complain that they pay to join various schemes and they do not get much for it. Do you not feel that the boot is really on the wrong foot and it should be us the consumers who are paying for your schemes? I have no difficulty with what you are doing. Essentially you are policing to ensure that we the consumers get what we think we are going to get. Should not the supermarkets be paying for that? Ms Campbell: When you say "our" schemes, we are the independent verifier of other people's schemes. They are not our schemes and our job is purely to be able to come in and be able to verify those claims. That is not to say we are not involved in helping to develop certain schemes because obviously as part of developing any scheme if you are going to have it assessed you need to consider certain elements in it as you develop that scheme otherwise it would be impossible to assess that scheme. At the end of the day the consumer always pays, do they not? Q237 Mr Wiggin: No, definitely they do not pay when it comes to farm assurance, definitely they do not, because there are different schemes, as you rightly identified, and some will be better, some will be different, some will be cheaper, some will be more expensive. Very often, with farm assurance schemes particularly, ultimately the farmer pays and there is no actual premium for selling an accredited product and that is the point, I am trying to get to. Mr Wright: I think you have to go back to the history of farm assurance schemes which were originally membership driven. They were there to respond to the scares of the early 1990s and BSE in the mid‑1990s. If you take the farm assurance schemes as they are now there is a negative to it nowadays because if you are not farm assured you often cannot shift your stock. That is the negative. Q238 Mr Wiggin: That is why I am putting it to you that whilst what you are doing is great, the problem for us with food is this is a very negative type problem we have got now. People are putting in schemes whereby they cannot sell otherwise but that is the wrong way round. Surely it should be the supermarkets saying, "We will only buy from the schemes we run"? You may well be the verifier of that but that is not the way it is happening at the moment. The scheme managers are the ones insisting that farmers cannot sell their crop otherwise. Mr Wright: If you take food safety schemes such as the BRC scheme that is where the manufacturers pay for that assurance, usually at the behest of the retailers one has to say, but it is a common enough problem that you define and it is one that we should have a view on. Q239 Mr Wiggin: You are in the middle but the difficulty for us is that we are trying to talk about food information and it is all the wrong way round. The people who will actually be serving the consumers are the supermarkets/the shops but they are not the ones who are taking a great deal of interest in this. It is the producers who are doing it to promote their product. Mr Wright: You have to identify benefits too and that is probably the trick for scheme owners. If they are having to sell that to their members, bearing in mind that most of the traditional schemes have been NFU driven in the past, quite obviously it is the NFU's members to some extent whom they are trying to represent. If you are looking at it from that viewpoint and the way it was marketed in the past - to actually give benefits and put assurance back into the food chain where there was a degree of cynicism and scepticism with all the claims being made particularly from the farm side (and most of the food scares have emanated from the farm side in latter years) ‑ then there was a genuine desire in the industry to put more confidence back into the food chain by having assurance schemes, so there is some benefit to it. Would we have been so successful in getting beef back on the menu without farm assurance schemes? It is an open question. Q240 Joan Ruddock: I suspect that it may not be about getting a market edge in terms of premium but it may be about market share and people are having these schemes to make sure they can actually sell their produce and that that is part of it. As a person who only buys organic I have to say I have no experience of these schemes whatsoever. As a consumer I do not take any notice of them. What is the evidence that others are taking notice? It sounds from what you have been saying that there is a lot of confusion, that it may not be consumer led, so to what extent are consumers aware of the differences in schemes? Is there research on this? Mr Wright: A lot of this is the confusion of these schemes themselves. Do they represent quality? Do they represent welfare? Do they represent safety? Do they represent something else? If the message is mixed, as I believe it is, and if we are looking at the little red tractor as an example of that, I am not so certain that means an awful lot to people because I am not awfully certain that anybody knows what it does represent ‑ British farm standards or not British farm standards, quality or not quality? A red tractor mark on a scrag end of lamb? Who knows? To enhance the point that Mr Jack made with regard to organics, with organics of course you have a generally discerning purchaser who does know what organic means. When you have got a little red tractor sitting on a logo in a small supermarket that discernment is not there and that is where the education comes into it, which is what we are saying here, and part of the remit of the committee is how far you take the education on it, but I am not certain that any of the major schemes actually have the consumer recognition that they should have. Q241 Joan Ruddock: Clearly that is an example of a less well‑understood scheme. Have you got an example of a particularly well‑run scheme? Mr Wright: I would mention the Soil Association schemes as being particularly well‑known and I think most people who buy a Soil Association-certified product know pretty well what they are getting, but that is down to their discernment. I cannot think of any others that immediately spring to mind. Q242 Joan Ruddock: I was going to suggest that you leave that aside because it is not really comparable because it is a whole category of produce right across the board and there is a different connotation to organics which is a single word and which means something precise. There is no other scheme like the badging schemes that you can point to as being successful? Mr Wright: The one that has got nearest to public acceptance is probably Quality British pork. I think people do recognise that as a valiant attempt at putting quality into the British pig business. Q243 Joan Ruddock: What does it mean? Mr Wright: Quality. Q244 Joan Ruddock: What does quality mean? Mr Wright: Well, it is a mixture of things but they do market it as quality whereas some of the other schemes do not. Q245 Joan Ruddock: I think I have seen it, yes. Mr Wright: They do market it as quality whereas some of the others do not. They are certified to a particular standard. Q246 Joan Ruddock: We had some evidence again from Clive Dibben, who has been referred to previously, saying that "various attempts have already been made to develop an overarching body to explain the merits of assurance schemes to UK consumers ..." Do you think there is any value in that? Ms Campbell: An overarching body? I think there is always a benefit if you can gain co‑operation and consolidation so you can simplify the message. I think that there are already organisations out there that may be able to extend their remit to enable them to fulfil their role. I am not sure whether there is necessarily any great benefit in reinventing the wheel. Potentially you have got the Food Standards Agency whose remit could be extended. You have also got UKAS, which we heard earlier is the UK Accreditation Service, whose job is to ensure that anybody like PAI, who provides independent validation, is competent to do so, and I think the key thing both about the FSA and UKAS that is quite important to anything that you are trying to do in terms of getting over a credible message is that both organisations are seen as being impartial, independent and competent, and I think for anybody to listen to any message that is coming out of anywhere it is essential that they are able to demonstrate that. So for me looking for somewhere to start to help to bring the messages together and to be able to provide something that consumers could trust, I would start by looking at those two organisations and seeing if there was any way in which either their remit or their resources could be extended and, with co‑operation between the two organisations, whether they would be able to help to deliver a solution to it. Q247 Joan Ruddock: Are you conscious of new schemes being on the drawing board? Ms Campbell: I think there are probably new schemes all the time, yes, absolutely. Q248 Joan Ruddock: So we can see an even greater increase of schemes and greater confusion arising if nothing is done? Mr Wright: You might see a greater increase but you also might see a better result because in the past farm assurance schemes particularly have been quite prescriptive in the way they stipulate what you must have and what you must do and what you must not do. That is good and that is sound but the modern way of thinking about farm assurance schemes is that they should be outcome based so you are actually looking at the outcomes and how they get to the outcomes is of interest obviously because if they are doing anything illegal that would not satisfy the outcome. Generally speaking, if you are looking at an outcome that is the way modern farm assurance schemes are going. Ms Campbell: I think there are many, many drivers that are going to say there are going to be more and more schemes, and not least the drivers are the consumers themselves because we are getting more and more discerning consumers who want to know more about where their products come from and associated with that of course we have got the increasing globalisation of food and where we source our ingredients from, and people are getting more and more concerned about traceability of the food chain. We were all very comfortable when we were buying it from our local producer and we all are perhaps much more sceptical now that we are very much based in a supermarket economy in the UK and perhaps we are getting increasingly concerned because we are seeing even more of that sourcing having to go overseas. I think the drivers are there for more schemes not less schemes and therefore I suppose it is beholden upon us to try and find ways in which we can ensure that whilst there may be more schemes because we have many more choices we have got to work harder at trying to enable that information to be digestible to those who are seeking the information. Q249 Chairman: You have hit upon a crucial point because we had written evidence from the National Consumer Council to the effect that having studied consumers' views on voluntary schemes their conclusion was that the schemes were more likely to confuse and mislead consumers rather than inform them. We are getting more and more schemes both domestically and from other countries and most of us will recognise some of the remarks from Germany about recycled material being used in a container by the Soil Association or whatever. If we are going to get more and more of these kinds of schemes it is going to cause both confusion of the consumer and further devalue the schemes which you currently verify. Ms Campbell: I think there are problems. We cannot ignore the internationalisation and we cannot ignore the fact that consumers have strong opinions. They may be many and varied and they may want to be able to meet their particular desires. I think it is important, therefore, that we maintain a focus that the schemes are independently verified because I think that is one way that you can start to increase the confidence levels. That is the first thing ‑ that they cannot just self-declare, if you like, that they meet those criteria ‑ and I think independent verification is very important. I also think that as part of that independent verification should be the ability to access information on what the various schemes mean. If you take the organic one, if you look at that internationally, it is very different and you are not necessarily getting the same things. You may know what the Soil Association label means but there are other organic schemes and they mean something different, so you have, I would think, exactly the same issues in the organic sector as you do in the normal farm assurance sector because you will have certain schemes that are driven by the particular needs of a market‑place and the consumer who wants to set those higher standards, and it is worthwhile developing a scheme because people will respond to it and, equally, as we talked about earlier, you have got the EU requirements on organics which do not require necessarily all the extra safeguards that we may prefer in the UK, so there are many issues in terms of imported foods that can come in with the various different labels as well as the various schemes that we can invent ourselves in the UK, so I think the answer is that we are certainly going to have to work harder at trying to make that information available and, regrettably, the consumer is probably going to have to work harder bothering to find out that information, but we have just got to make it as easy as possible to make it available. Q250 Chairman: A body like yours can only verify independently the claims which you have been asked to verify. You do not control how they are marketed, you do not specify what criteria are to be verified. It is very much we develop a scheme and they decide to be in the scheme. Mr Wright: If we are asked to help develop schemes then we will develop schemes but we do not sit there in adjudication as to what is a good scheme or is not a good scheme. We are asked to develop things. The one thing that you should take into account when you are looking at the development of a scheme is the retailers' involvement in it. Retailers are always going to be competitive, they are always looking for an edge on it. One of the questions you might ask of the retailers is what is driving them? Is it due diligence, is it consumer trust or a variety of other things that is doing it? To actually ask for a reduction in the number of schemes is almost an impossibility because every retailer is looking for an edge on their competitors in that regard usually with a view to gaining trust but very often for due diligence purposes. Ms Campbell: It is also perhaps worthwhile mentioning that the panel talked about the 445011 standard, and that is the standard the independent verifier, the PAI (if we are accredited by UKAS) has to meet and ensure that schemes meet. The one thing that it does do is that whilst we do not set the actual standards if they are to meet 45011 we have to be able to demonstrate that that standard or that scheme did have input from all the key interested parties. I still think that potentially it is quite hard for consumers to input into those schemes but there is a mechanism to say it should not be driven by a particular interest. Quite a lot of effort does go into trying to ensure that appropriate people are around the table in developing those schemes and at times it is probably quite hard to be able to get consumer input because again it is quite time‑consuming and demanding. That is one of the difficulties I know the schemes themselves face ‑ trying to be able to get that input. Q251 Mr Wiggin: Taking a wheat scheme, you go around and you make sure there are no light bulbs so that no glass can fall into the wheat and no birds can get into grain store, but the wheat goes off to the miller, he turns it into bread which goes into a supermarket, and if the wheat is not the right price he will buy his wheat from another country abroad which will not have been verified perhaps by you. So now we have got as consumers the problem of choosing the shop we go to, then buying bread produced by a type of miller which we hope will have used grain from one of your verified schemes, so then we have to make sure we have got the right verifier as well and that it comes from a scheme that we think is a good scheme, and again Mrs Ruddock was talking about her organic interest but that applies in organic just as much as in any other sort. Now we have got an even more complicated system of choosing what is good for us than we had before. Surely by having this legislation we can get rid of the assurances because all food must live up to the standard otherwise the law has been broken, so your role is just as important but you should be policing as opposed to verifying that people are complying with the scheme and that would simplify it surely? Is that one of the things we should be looking at? Mr Wright: Maybe you should be looking at it but it is market pressures. I know increasingly that the millers are sourcing their wheat from assured sources in the UK but in times of shortage commercial considerations come into play and that is a question that you must ask of them. There is a lot coming in and pressures are developing in production so that over a period of time, increasingly so, assured wheat in your example is actually being consumed by us in the bread that we eat. Ms Campbell: I think there would be difficulties because you have got to look at the whole food chain and policing the end product would not necessarily be able to tell you everything. Q252 Mr Wiggin: I meant policing the process because we cannot police the end product. As a consumer we are doing that effectively with our money. We need to be sure that whatever is for sale in our supermarkets is as healthy as it is supposed to be. Ms Campbell: Which is what the validation process tries to do. Depending on the various schemes, the whole chain is traceable going back the way from the ingredients that come in in feed, et cetera. Q253 Mr Wiggin: That is right because now as a consumer I have to not only check the E‑numbers but I also have to check who validated it. That is the problem. Mr Wright: In the submission we talk about (or perhaps we do not and perhaps we talked about it afterwards) the fact that the verification of all claims should be independently verified. That would be our position. We would say that, would we not, but we think that is a sound start point. Q254 Mr Wiggin: I agree with you on that, that every claim should be policed effectively. Mr Wright: That is right and if we go back to something like the animal feed materials, we can do an awful lot of traceability of the raw materials that goes into animal feed and there is no doubt there is more integrity in animal feed than there is in the human food chain at the moment. It is because of the scares in the past that we are deploying a standard that makes sure that anything that is produced for the animal feed industry in the UK has got product integrity associated with it. Having said that, I suppose it is only because we eat the livestock that it can have that impact. It is interesting that what we do in the animal feed chain is not necessarily what we are doing in the human food chain and it is no good, in our view, having a food safety standard that sits above the processing of it and manufacturing of it if you do not know that what you have imported from Brazil or the Eastern Bloc or Far East in terms of spices and all the other things have got integrity themselves. We open a can of worms with that but I am absolutely convinced that it is insufficient to just look at safety in the manufacturing process. What about the integrity of the materials? We have done it in our animal feed; we should be able to do it in human food. Chairman: Thank you very much indeed for coming along this afternoon to give us evidence. It has been very helpful indeed. If there is any additional written evidence you want to submit in the light of your comments today feel free to do so if you so wish. It will be useful to us. Thank you very much indeed. Memorandum submitted by National Farmers' Union Examination of Witnesses
Witnesses: Mr Tim Bennett, President, and Mr Robin Tapper, Head of Food and Farming, National Farmers' Union, examined.
Chairman: Good afternoon, Mr Bennett and Mr Tapper. First of all, my apologies for changing the agenda round so you are a bit later than you otherwise would have been but, as you will appreciate, we wanted to make the best use of the time available as we had moved slightly ahead of our time table. Welcome this afternoon. Could I thank you for the written evidence which you have submitted to us and we look forward to what you have got to give us in oral evidence this afternoon. Could I invite Joan Ruddock to start the questions. Q255 Joan Ruddock: To start with food safety, as so often is the case with these inquiries, we have received written evidence which is quite contradictory. We have the British Retail Consortium saying that food safety is not a significant problem. They say that: "UK legislation is quite clear ‑ all marketed food that is properly processed, stored and prepared is safe for general consumption." We also have evidence from Dr Richard Bain from the Royal Agricultural College in Gloucester suggesting that: "... home-grown produce is largely unregulated in terms of food hygiene." How do you react to those two bits of evidence? Mr Bennett: I am rather surprised by the latter one as someone who is a farmer as well as President of the NFU because over the last few years there has been quite a marked tightening of regulation in terms of food safety, and quite rightly so. As a farmer I am subject to very stringent hygiene through the meat chain and in terms of pesticide usage and in the way that pesticides are authorised there is very tight regulation but what the industry also does is go beyond that and look at the industry doing things like the voluntary initiative in the use of pesticides. We are also a key part of the responsible use of medicines initiative working with others, so I think regulation has tightened up considerably in recent years and if you look at the results in terms of food safety then you see some results from that, and certainly if you go abroad and look at the way hygiene regulation is applied and the way the regulation is there you will find significantly more attempt to do it correctly, with greater cost to our industry I may add, than you get abroad, but I think also we as an industry have always tried to look ahead and see what are the problems that are coming because sometimes, if there is an issue, legislation trails behind problems and that is why we try to be proactive in these areas as well. Q256 Joan Ruddock: Could it be the case that good farmers like yourself are obviously pitching up for the highest possible standards but others in the UK are not and that might have led to this comment? What precise regulations are you required to meet in terms of hygiene? Mr Bennett: It depends what sector of agriculture you are in but if you were like me - and I have just recently given up dairy farming - I would be subject to the milk and hygiene regulations on which there will be a spot inspection not an announced inspection. We are also subject to trading standards inspection in terms of animal records and indeed making sure that the milk is milk and there is no water in it. You have got all that. If you are a beef farmer you have got the animal identification, not only through trading standards but also for the British Cattle Movement Service so if you have not got a passport for an animal and you have not got a history of that animal and where it has been, then effectively it is worthless because you have not got a market. There is lots of regulation. Recently I had an inspection, for example, for checking the welfare of the animals, calves as it happened to be, from a Ministry inspector. While they were there they checked the records to see what medicines I had used and whether I had used them correctly and also what we call the movement book to check that my records are up‑to‑date. A lot of us farmers would say that there are quite a lot of people who can check what we do in terms of food safety. What we would want to do, of course, is we are in a global world and we have to be shown to be better than anyone else because hopefully that will give us an edge with our consumer. I have to say that farmers who do not practise good practice probably will not have a market-place. If they have not got one today they certainly will not have one in the future. Q257 Joan Ruddock: Unless they are selling it down a local market and they are not requiring themselves to go through retailers and supermarkets or whatever. So there is some escape route for some people, is there not? Mr Bennett: If you are selling meat you have to go through an official slaughter house so you are subject to all those sorts of regulations. You still have inspections even if you sell eggs at a farmers' market. You would still be subject to the regulations on farm. There is no doubt at all however in terms of the market-place that if you are selling into the retail sector the market-place itself drives very high standards because the consumer through the customers and the retailers in the food chain set the standards and those standards can vary because every retailer, particularly the ones that go for quality produce in the south of England, would probably add extra conditions for being a customer of theirs. Mr Tapper: I think the household‑type markets or the street‑type markets that you referred to really is the last chance saloon. We are talking about return here and people who are selling into these markets are probably receiving a much lower rate of return for their product than those that are selling into the organised market that Tim refers to. Joan Ruddock: So the Eddy Grundy incident on The Archers is complete fantasy, is it? Q258 Mr Jack: Not as far as Eddy is concerned. Mr Tapper: I am not an Archers' listener but, yes, everything has got a market at a price and I think our job is to ensure that the best product gets the best price in the best market and that we can literally market that, we can inform the customer that those products have had due diligence. Q259 Joan Ruddock: Would you share the British Retail Consortium's view then that British food is safe, that is it? Mr Bennett: British food has got good regulation behind it. I think the industry itself puts a lot of effort into making sure it is safe. To be quite blunt about it, if our consumers do not feel safe then we have not got a business and so it is our job to make sure if there is some perception or even genuine concerns from the people to whom we sell then we have to put that right. Sometimes you try to put things right even if there is not necessarily a health scare. It is not just about getting it right for the consumer, it is also about making sure the consumer is completely happy and you get the nuances from them about their perceptions. Q260 Chairman: I think you heard part of our discussion about the question of food assurance schemes. Could you first of all give us your estimate of the number of such schemes that are in operation in Britain and then tell us whether you are in favour of fewer such schemes or a consolidation of such schemes being brought into effect? Could you perhaps say whether you favour a consolidation or reduction in the number of such schemes and if you would, perhaps most importantly, how would you achieve that? Mr Bennett: I would not know the exact number of schemes out there but I agree that there are probably too many. I think it depends how you determine those schemes. Farm assurance really got going in terms of independent verification of farm standards back in mid‑1995-96, somewhere round the BSE scare, and the schemes developed on a sector‑by‑sector basis. As those schemes developed we in the NFU felt that we had got lots of schemes, lots of inspections and we needed to consolidate them. We have been working to try and get some consolidation in. We have got the Assured Food Standards whose ultimate remit hopefully will then control that. It is an independent body which as part of it will hopefully end up consolidating a lot of the schemes. We have had some success. At least we tend to get single inspections. If you are a cereal and beef farmer or dairy and beef farmer, for example, which is a scheme we are working on now, you now get single inspections so there is some sort of integration. What you cannot avoid is that there will be some retailers who for competitive reasons or their own particular market-place will want to add something to basic farm assurance schemes. Even then there is no reason at all why that cannot be done at the same time. So we are in favour of consolidation but we want something like Assured Food Standards to drive it to make sure that it is being done correctly so that it is not just a trade association doing it. I think it is very important for the independence and integrity of these schemes that it is done properly and not just farmers saying that they want to make this a bit simpler. However, we agree with the consolidation. Q261 Chairman: Is it not a bit odd that in a world where the food retail sector is heavily dominated by a very few major players that no‑one seems to be able to tell us how many schemes are in operation or indeed just simply give us a list of the fields which they cover? I am not blaming you for that but these do purport to be national schemes in most cases, I understand, and yet nobody seems to know what is out there. Does that in itself not say something about the problem? Mr Bennett: We could probably give you a fairly comprehensive list of schemes but I would take the point that I think we need to consolidate those schemes because across all those sectors there tend to be different schemes and indeed in the organic sector there are different inspection schemes so there is an opportunity to do that and we are encouraging people to do that, and I think we are having some success certainly in the sector schemes. Mr Tapper: There is a dichotomy there as well. You have got schemes which are set up such as the red tractor scheme which is effectively a standard, a sort of kite mark if you like, and then you have got other schemes which I think were mentioned by previous witnesses which may refer to provenance or particular elements of a product. It is very difficult to draw a line there. Certainly from the retail point of view and from the customer point of view they would say they are too many schemes and again we are trying to get to one standard which forms the basis upon which other people may want to build extra bits and pieces if they so wish. We need one standard across the chain so the consumer knows that what they are buying is safe and meets certain guidelines. Mr Bennett: The rationale of the red tractor was to try and put a logo that reflected a multitude of schemes that were designed to give consumer reassurance. That is what we are still trying to do. Chairman: That leads neatly to Michael Jack who wants to ask about the red tractor scheme. Q262 Mr Jack: What research has the red tractor scheme done to see what messages the consumers are actually picking up of assurance (because this inquiry is about food information) and to check that the scheme is designed in as simple a way as possible to send out some indication about the way that the food is produced to the consumer? Have you done any research to find out what people actually believe it all means? Mr Tapper: Yes, we have done two pieces of research. First of all, there was some research on recognition and the red tractor has something like 47 per cent recognition amongst customers. That is second only to the lion mark on eggs, so it was a great success from that point of view. The least success is on the understanding of what the red tractor means and there the recognition is low. I think it is low for two reasons. First of all, there is confusion. People see it as a nationality mark sometimes when it is not. We would like to think that people thought of it as British but we certainly cannot promote it as that because of the state aid rules, amongst other things. There is also the issue that we are very conscious of that we have not marketed what exactly it does mean. Of course, unlike eggs where you have got a one‑product industry, the message in agriculture is much more complicated. You might have carrots at one end of the scheme, which is fairly straightforward, but you might have a meat product at the other end which could be very complex, and so trying to get a simple message across the whole of agriculture is quite difficult, but we are trying to develop such a scheme. Q263 Mr Jack: So you have 47 per cent of consumers recognising a label with a meaningless background to it? They have not got a clue what they are recognising. Mr Bennett: I think it is fair to say that it signifies someone has put some assurance in there but they would not know exactly what that is. That would be true of most of these logos. Even the organic labels of the Soil Association people know it is organic but not many would know the detailed scheme standards. Q264 Mr Jack: Do you not think in a way if one were to do an article in some salacious newspaper and it said "owners of red tractor scheme acknowledge that lots of people recognise the label but the whole thing is a meaningless myth" that the whole thing would collapse round its ears, would it not? Mr Bennett: I do not think that is the case. I think the Food Standards Agency came up with that research, they quoted something like 40 per cent a couple of years back, and then also stated that there was a need to increase the understanding behind those logos, which is the same as Tim says. Q265 Mr Jack: What are you doing to address that? Mr Bennett: I think that is important. It goes along the lines in a sense we have tried to integrate the schemes into Assured Farm Standards which the scheme is part of and obviously there are independents on that board and that is an independent body and they will actually market what is behind that red tractor. We will obviously help promote that as the NFU but it is for Assured Food Standards to get the commercial plan about how to explain the standards. We are in discussions with them on that at this particular time. Mr Jack: You may be in discussions but you have allowed this thing to promulgate that so people do, I am afraid, think it is a country of origin marking. You have been quite candid with the Committee in saying that as a piece of communication you cannot market it as such, and you acknowledge the fact that people outside the United Kingdom could come into the scheme, but you have not at this stage said to me, "We are going to do something comprehensive." "We are in discussion," is what I hear and yet people are supposed to derive a glowing sense that if they get a product with the red tractor on, somehow it is good, wholesome, high standard ‑‑‑ Joan Ruddock: Who says so? Q266 Mr Jack: Just a minute, I have not finished the sentence. When I was looking at a publication which the Consumers' Association sent to the Committee they said: "The red tractor scheme also allows birds" ‑ this is in connection with poultry - "to be reared in more cramped conditions than recommended by the Government." Is that a correct statement? Mr Bennett: I could look at the standards of every single scheme and come back with an answer to you on that one. It certainly would not be below the legal standards, I can assure you of that. In fact the lion eggs scheme is not part of the red tractor scheme. Q267 Mr Jack: So the best you can say to us is that this great scheme of assurance simply reassures the public (or if they really understood ‑ the 47 per cent ‑ what was behind it) that farmers have met the basic minimum criteria? Mr Bennett: We are saying a lot more than that. What we are actually saying is that these are the legal requirements (and very often the schemes go beyond that) but on top of that these schemes have been independently verified to make sure that this product has been independently verified, and I think that is an important reassurance for consumers. Q268 Mr Jack: But in terms of the many things that you might want to get across to consumers - for example, animal welfare, which very important, good biosecurity, disease control, the quality of the food that is being produced in terms of meeting specification and so on and so forth, is it right to have a system that dilutes all of that into one label when in actual fact the power of any one of the areas, as just indicated, may be of greater advantage to farmers trying to sell and differentiate product ‑ and I will say British product ‑ from other people because you have diluted it all under one rather meaningless label that people do not understand so that a lot of very good messages are not actually getting out? Mr Bennett: The intention of farm assurance and the red tractor was to make sure that there was good practice taking place on farms that was independently verified to show that legal standards were being met, and that is what the schemes have achieved and that fulfils our place in the market-place. You are quite right that beyond that you can add, in terms of eating quality and things like that, other things. Can I go back on the British thing; because of state aid rules, whether we like them or not, we cannot claim it as a British logo. We did not set the rules on that, they were set by politicians, if I may say so, whether we think them right or not. What we have got at the moment is that it has to be licensed and what we do know is that no product has been licensed to the red tractor other than British product and the customers/the retailers have only brought red tractor produce that is British because they can do it in the market-place as customers to say it is only British with the red tractor, but what we cannot do because of the Single Market is state equivocally that the red tractor is British; that is illegal. Q269 Chairman: Just one point if I may. You did indicate that you thought it would be relatively simple to produce a list of the various farm assurance schemes which as far as you knew were in existence. I am sure that it would indeed be very helpful to the Committee if you were to provide us with that type of arrangement. If you could do that, that would be very helpful. Mr Bennett: We would be delighted to do that, Chairman. Q270 Mr Wiggin: I am a big fan of the red tractor scheme, as you might imagine, because I laid out an example to the previous witnesses about how the farmer can go to the trouble to go through all the assurance scheme and then watch in horror as perhaps his miller will simply buy in cheaper wheat from abroad. One of the questions I wanted to know is once I have got my little red tractor I know that all the way through - if it is on a loaf of broad - that the wheat will be have been properly assured, will it not? How many people are trying to put little red tractors on their production who should not be? I have read about something in Spain where we suddenly saw little red tractors appearing. How much of that goes on? Mr Tapper: Very, very, very little. Certainly in the two instances that I am aware of that happened in the last six months they have been purely production errors and in both cases the product was withdrawn from display, returned and not put back into the food chain, and I believe that is a responsible approach. So we are pretty certain that everything that is assured is assured and is at the moment British. Q271 Mr Wiggin: What about people trying to pretend that they qualify for little red tractors when they do not? Mr Tapper: We are certainly not aware of that. Q272 Joan Ruddock: Just on this little red tractor business, is there any evidence that people are more likely to buy something that is labelled little red tractor than not? Mr Bennett: We have certainly had support from the food chain for this little red tractor so normally if there is support from our ultimate customers for it then they feel that that is something that people value. Q273 Joan Ruddock: It is not the same as saying they choose it because it has got the little read tractor on it when they are doing their own shopping. Mr Bennett: There is a process to this. First of all, we had farm assurance to reassure people at our end of the supply chain. Having done that, we looked at how we could develop a logo that indicated to the consumer we have done that. We have got to that process and recognition is reasonably good. What we have now got to do, which I think is a much more difficult thing to do but we have to do that, as you quite rightly indicated, is make sure that people understand what lies behind it so that people can feel more reassured by this. The end game to this is I want to make sure that consumers buy my product because I have done a little bit more than my competitors and that is what we are trying to do ‑ to reassure and make people feel confident in buying that product. It is not straightforward to inform the consumer and they will know all about it; it is quite a lengthy process. Q274 Joan Ruddock: I think you offered no evidence at all that it makes the slightest difference to the consumer at the point of purchase doing the family shopping. They may be randomly buying red tractor meat or non‑red tractor meat from everything we have heard at this Committee. I can accept the point of sale to the retailer from the farmer of course, but at the other end there is no evidence from what you have said. Mr Tapper: The only thing I would say is that the major retailers, if they are buying British meat, to take your example, would only be selling red tractor British meat so from that point of view ‑‑‑ Q275 Joan Ruddock: The consumer does not have a choice. Mr Tapper: The consumer does not have a choice but is that not the right answer in that the supermarkets are acting responsibly by supporting their own tractor which in itself is a responsible action about food safety, provenance and all the various agricultural ‑‑‑ Q276 Joan Ruddock: I think that is a huge philosophical debate and we have not got time to get into that. Mr Bennett: Can I come back to that. They do have a choice because on that shelf there are products from other countries that have not got a red tractor on them, so they have that choice. If the legislators pass legislation and if we can make sure that that legislation is being enacted and it is being independently verified and marked up as a logo, surely, ultimately, that is for the benefit of the consumer otherwise why pass the legislation? Q277 Joan Ruddock: We are going to vote in two minutes but just to take you on to something which I know is dear to your hearts and that is country of origin; you believe, I understand, that country of original labels can be misleading. Just give us a word on that and what you think should be done? Mr Bennett: I actually think labelling is very important. It is obviously important to us as an industry if we can get the consumer to want to buy our product, and if the labelling is misleading then it is obviously damaging to ourselves, but I do not think anyone has an interest in misleading the consumer. To give you an example of country of origin, we saw one last week and we have probably still got it in our building which we can show you (it happened to be rib eye steak) where it had "product of the EU" stamped all over it but then if you really looked in the small print it said "reared and slaughtered in Brazil". I do not think that is honest and accurate labelling. If I may say so, recently in the United States their labelling, both nutrition wise and on these other things, seems to be slightly better than ours, which rather surprised me. Q278 Joan Ruddock: That is a very good example. If it is reared and slaughtered in Brazil, there is no processing process, is there? A piece of meat reared and slaughtered in Brazil. Mr Bennett: The law allows you to put "product of EU" on it if it is processed. I guess what happened there is that it was reared and slaughtered in Brazil and then was cut up and processed in the UK. Joan Ruddock: Cut up is "processed" by the definition of the EU? We have a few more questions but I think the Chairman would like us to stop. Q279 Chairman: If you want to briefly follow up on the last point, we have one minute left before we finish the meeting. Mr Tapper: What we would like is a very simple label that just says "product of ... packed in ..." If it does not say "packed in" one assumes that the products are packed in the same country. That would be a very simple one to get across. It would certainly fulfil our requirements and I think it would be very easy for the customer. Some companies already do it and I think it should be standard. Q280 Chairman: But for the food that is being processed do you think there is a need to label ingredients by country of origin? Mr Tapper: Yes for the major ingredients so if you are selling chicken tikka you can say "chicken tikka - produced in the UK, made from chicken from wherever" because it is chicken that you are actually selling there, and that is the ingredient that the customers, I would assume, are most concerned about. Chairman: I think that division bell brings us naturally to the end of our questions in any event. I would like to thank you for coming along this afternoon, it has been very helpful. If there is any written evidence you wish to submit further to your comments today we are certainly very happy to receive it and again we await with interest receiving the information on farm assurance schemes which you were kind enough to say you would provide. Thank you very much for coming along. |