Examination of Witnesses (Questions 480-499)
DR RICHARD
BAINES
29 JUNE 2004
Q480 Mr Mitchell: If they are supplying
a British market, then they have got to be regulated?
Dr Baines: No.[12]
Q481 Mr Mitchell: Are you saying the
domestic market is always less well regulated?
Dr Baines: When I say "domestic
market" I should put it in the context of a domestic European
market, because once food is produced and goes on to the next
stage it can move to anywhere in the European Union, the same
as imported food. The point I was making is that before food can
be imported, first of all the manufacturer processor, integrator,
whatever, has to go through European inspection to ensure they
meet the European regulatory standards, and that will be the standards
of the best of our European manufacturers, our large scale abattoirs,
pack houses and food manufacturers, not the average, which will
include small scale that may have derogation. Often, and I have
looked at these schemes in Australia, for example, that will include,
if you are looking at meat supply, the ability of those European
inspectors to judge the farms which are supplying [the slaughter
house]. By that, there is another tier of regulatory inspection
which a significant amount of domestic food would not be subject
to. That is the point I was making there.
Q482 Mr Mitchell: Are you not satisfied
with the legal requirements in respect of food hygiene in this
country and food safety?
Dr Baines: I am comfortable with
the food safety in the European food chain when things are going
okay. I have concerns when things go wrong and we have seen evidence
of that. I am comfortable, with some reservation, over what is
happening beyond the farm gate in terms of the major messages
coming from the drivers of food safety, which I see as being the
major retailers, more so than perhaps Government, and they are
driving this for very good reasons. The systems of identifying
and managing food safety risk are well in place, and we see from
Government and major industry leaders the adoption of HACCP—the
Hazard Analysis, Critical Control Point—but we see politically
an unwillingness to look at this at the farm level even though
there is good evidence of food risks at the farm level and food
safety break-downs which are accounted for at that level as well.
I have experienced schemes where farms are required to do appropriate
risk assessment, and are able to do that in just as good a way
and with the same sort of costs as we would see with our current
farm assurance scheme. So, yes, I would challenge whether we should
be requiring all producers to be more active in their assessment
of food risk. I think the fact we just will not seem to address
this is something which has evolved politically. Often it is argued
it is too difficult for farmers to do, but I have seen farmers
do it. It is said it is expensive; I think we can challenge that.
One of the reasons is that there are some very good firewalls
further up the chain which protect those at the end of the chain
where consumer protection legislation comes in. I am thinking,
for example, of the British Retail Consortium audit which most
food manufacturers are going through. That is a good firewall
and you could maybe argue that safety could be better managed
by being strategically placed at some point in the chain.
Q483 Mr Mitchell: If that was installed
at some earlier point in the chain?
Dr Baines: The counter-argument
is that all of those in the food supply chain have a responsibility.
Q484 Mr Mitchell: Yes.
Dr Baines: I believe we should
all be addressing that at whatever level we operate at. If there
is a food safety break-down, if you are not addressing it, you
have not got a defence. The blame will be passed down to you and
if you have no defence, you have a problem.
Q485 Mr Mitchell: So was Mrs Curry right
or wrong?
Dr Baines: When she told the truth?
Q486 Mr Mitchell: She told the truth?
Dr Baines: Yes. Politically, she
was wrong, in my view.
Q487 Mr Jack: Can I follow Mr Mitchell's
line of questioning? In your evidence, at paragraph 3.2, you draw
the Committee's attention to the line of argument you have just
put forward with reference to HACCP at the farm level. It causes
me to pose the question as to whether in fact that kind of information
undermines the messages that people draw out of the little red
tractor symbol that somehow this is good, wholesome, safe, everything
is okay if I buy this product. The statement you put at 3.2 would
suggest that it rather undermines the assurance message which
is embodied in the little red tractor.
Dr Baines: Yes, I have challenged
those who support the British Farm Standard, both publicly and
in terms of academic writing. As with virtually all the other
farm level schemes I have seen around the world, they are addressing
food safety but they address it in a sector-specific way. It is
a prescription almost; "If you do this, food risk should
be reduced." If you look at that from a food safety risk
management perspective, what we are actually doing is what we
call the pre-requisite programmes; those things which should lower
risk, but it does not actually require a producer to actively
assess whether the risk has been lowered or not. That is the difference
between active risk management on food safety and passive management.
It is not a problem at this stage because the number of risks
which do occur at the farm level are few, but they do occur. Examples
can be where we have seen human-borne pathogens or zoonotic pathogens
from animals which have got into either the water or through food
handling, particularly in fresh produce chains. That is the most
rapidly growing area of food safety concerns for the farm level
at this stage. Most of the others in grains are about storage,
salmonella and aphlatoxins[13]
in grain storage through fungal growth, and then other ones could
be animal pathogens which can largely be addressed at slaughter.
So there are examples where there are concerns at the farm level.
Doing the pre-requisite programmes and lowering the risk on prescriptive
management helps, but I believe we should be going a stage further,
and I do not believe it is cost-prohibitive to do that.
Q488 Mr Jack: So if people are going
to draw lots of positive conclusions from symbols like this, your
judgment is that if that message has been gathered by the consumer
then it may be under a false premise and it is not as thoroughly
underpinned as they might assume?
Dr Baines: I would have to check
this and I am going on recollection, but when we first saw the
website and the promotion of the British Farm Standard, it was
claimed as being British food, safe British food, high quality,
high animal welfare and environmental responsibilities from those
who produce it. In actual fact it is demonstrating for those selected
areas of animal welfare and the environment merely legal compliance,
and that is why there is no premium, but there is a cost. It does
not address quality, there is no audit point within the British
red tractor or anywhere which says, "This is quality or not
quality", and on safety, as I have already mentioned, it
is a sector approach to safety rather than an individual business
approach. As you and I know, as in any food business, individual
farms will have better or worse records in terms of how they manage
safety, and we need to address those who are not so good at the
job.
Q489 Chairman: From what you have been
saying this afternoon, is it fair to say your view is that to
regard farm assurance schemes as some useful form of food information
for the consumer is really just the wrong road to go down?
Dr Baines: If you try and claim
too much on what it stands for, you are going to create a problem.
Let me just balance that up with another comment, and that is
the fact that if we look at British agriculture and if we look
at its overall safety record in terms of volume and the problems
we have, if we look at the environmental performance of agriculture,
if we look at the animal welfare performance of agriculture, generally
it is very good. The fact that we value the landscape we go and
see is a good example of that. So I am not trying to say that
British agriculture has got problems, it has issues to address
as with any other sector of the industry, and it is seeking to
make a margin where a margin is disappearing, and in any leverage
of marketing they are trying to do that. I believe that the British
Farm Standard should be trying to get its message across to those
people whom the farm produce is sold to, who themselves are then
passing a message on to the next part of the chain, who are themselves
passing it on to the consumer.
Q490 Chairman: Can you give us an estimate
of the number of farm assurance schemes currently operating in
Britain?
Dr Baines: I think it is important
that you define what you mean by farm assurance. If we look at
schemes which meet the requirements of the rest of the food chain
in terms of assurance, in other words their independent verification
to a set of agreed standards, we are really looking at primarily
the schemes under the British Farm Standard, Quality Meat Scotland,
Scottish Salmon, the Northern Ireland schemes et cetera, and probably
those 10 or 12 schemes we could put in such a group are accounting
for the majority of the assured produce moving forward. Beyond
that, you will get other assurance claims which are perhaps better
defined as branding or promotional, which may be something to
do with things like localness. We have to separate those as promotional
elements from those which have some form of audit to say what
they are claiming has been assessed. We also have schemes which
operate further up the chain, so they may be led by the manufacturing
level. I guess the first one of these which probably started it
all was Bird's Eye and their frozen peas. Perhaps a good one at
the moment would be Jordan's with their cereals. That is sending
a lot of messages back to farmers about how they farm, but it
is sold to the consumer as this wholesome breakfast cereal, and
this is nothing to do with telling the consumer what is happening
in farming, but the farmers who are participating are contributing
to a system which adds to that aggregate product which is valued
by some consumers.
Q491 Chairman: Is there not a case for
having some overarching body, be it Government or industry, which
has oversight of this area and indeed could regulate a number
of schemes and the verification of them?
Dr Baines: We already have elements
of regulation, first of all, for them to be claimed as assurance
schemes under EM45011, they go through UCAS accreditation. That
is the first level, the system of certification and the mechanisms
are already internationally recognised and regulated. The problem
with that is they are voluntary schemes and they [certification
bodies] are there to inspect or certify whatever the scheme owners
have decided to put into the scheme. Secondly, yes, it is important
to try and get some co-recognition, some understanding, and that
is why I started some five years ago comparing schemes around
the world because I had heard so many times about level playing
fields and about other people not doing what we do. Yes, I have
been doing bench-marking for several years, what has been happening
is that we have the British Farm Standard and Assured Food Standards
seeking to be an umbrella organisation, but Quality Meat Scotland
do not want to be part of it because they believe their brand
is better and they have arguments for that and they see that as
a marketing angle. We also have emerging probably what I think
is the start of this convergence of schemes and co-recognition,
and that is that all of the schemes which are operating above
the farm level—there are relatively few global schemes now
probably only five. These are being bench-marked by the CIES,
which is the global retail forum, which many of the retailers
here are members of, and they are bench-marking their schemes
at least in relation to food safety and how it is delivered. Does
it address it in these key ways? At the moment, the CIS is developing
the mechanism to bench-mark farm level standards. So from the
retail side and the food manufacturing side, we will see a global
benchmarking of schemes. I know the CIES have been in negotiation
with Assured Food Standards, they have been involved in talking
to various scheme owners around the world about this. What it
does not do at the moment is address the other issues of farm
assurance, the animal welfare, the environment, the fair and equitable
trade and so forth; all those other areas in which there is an
interest are not going to be addressed through that mechanism.
But they are suggesting that schemes can co-recognise against
each other where they meet similar standards. In my opinion, what
they are really saying is, they want to see all schemes bench-mark
themselves against the EUREP Scheme which is a European retail
alliance scheme at the farm level. It (EUREP) started off with
fresh produce, we now have livestock, cereals, cut flowers, and
I think they are developing a fish one as well. I guess, and I
would perhaps like to check this, the McDonald's farm assurance
scheme is probably very closely linked to the EUREP Scheme as
they are a member of that group, but I would have to check on
that. Really what they are saying is, "We, European retailers,
have developed a scheme and we want it to dominate", and
that worries me.
Q492 Joan Ruddock: Does the EUREP Scheme
generally just guarantee that minimum standards are being met,
that the legal requirements are being met? It does not actually
take you beyond that? The consumer is not getting something beyond
that?
Dr Baines: There are in the new
animal and cereal schemes three levels. There is a basic level,
which is very much equivalent to the British Farm Standard, it
is about legal compliance in those key areas. Most of them are
around protection of soil, air and water and where there is a
link to human safety in terms of pesticides. Generally what they
are looking for in the second level up is worker welfare, the
correct and legal treatment of workers, which came in initially
for outside-of-European supply, but now we are finding a significant
number of fresh produce growers in the UK are saying, "I
am going to convert from assured produce to EUREP because I have
operations in South Europe and elsewhere where I need it, because
I want to do whole-year round supply to try and keep my share
of the market." The third level, which is an optional level,
is about an encouragement to improve bio-diversity management
at the farm level. But I have not found a scheme anywhere, including
Tesco's Nature's Choice and Sainsbury's Living Landscapes, where
the farmer is rewarded for going further than legal compliance.
Q493 Joan Ruddock: It seems to me even
if people were going to the second or third level, as far as the
consumer being presented with a message is concerned, it could
be the lowest level. Is that correct?
Dr Baines: Yes.
Q494 Joan Ruddock: They would not know
any different. So every consumer, I would have thought, would
expect those minimum requirements and the legal regulations would
be met by all producers. So they gain nothing really from an assurance
scheme?
Dr Baines: No.
Q495 Joan Ruddock: Nothing.
Dr Baines: Correct.
Q496 Joan Ruddock: They are pointless
in many cases.
Dr Baines: I would love to be
able to get a group of producers together and say, "Shall
we stop doing them", and I think I would probably get a fair
degree of support for that. Unfortunately, the market place is
sending us messages which say, "We won't accept that."
The consumers are really getting an assurance that farmers have
been made aware of their legal responsibility and the market place
is checking this out where at the moment Government cannot afford
the level of oversight it would need to have that same level of
confidence. Really we are seeing almost a privatisation of legal
farming to the market place, to the chain captains.
Q497 Joan Ruddock: Yes. If they are going
to go beyond legal requirements, surely the consumer ought to
be made aware of what they have done in addition to what they
are required to do?
Dr Baines: Yes.
Q498 Joan Ruddock: And also, surely,
there ought to be a premium? If there is not a premium being paid,
why are people opting into these assurance schemes which do require
the higher standards? What are they getting out of that?
Dr Baines: They get somewhere
to sell their produce, because the message coming down the chain
is, "If you do not do this, we are not going to deal with
you." I have an example on this one from abroad where a supplier
has been supplying into the UK for some 15 years under a standard
scheme which has been fully accepted by one of our major retailers,
and they have just been informed by their integrator, who acts
on behalf of that retailer, unless they transfer to the EUREP
Scheme they will not have supply. That is the message but it is
not a message from the retailer, it is from the integrator, who
is acting de facto on behalf of the messages coming from
that level. The other problem is, if we could communicate that
message, we would have to have the agreement that that message
is going to go to the consumer in some way. If you add that message
there, you are going to take away from the main message in the
main outlets for food, which is the retailers' own label. It is
quite understandable that retailers will protect that level because
that is their market power, that is their way of competing with
each other.
Q499 Chairman: So who is gaining from
these schemes then? From what you are saying, the consumer is
not gaining, the producers are not gaining, the retailer is not
gaining. Why are they there?
Dr Baines: I would disagree with
you. I think the top end of the chain does benefit from this at
the expense of the lower end of the chain.
12 Not in terms of regulated food hygiene. There are
exceptions eg annual dairy plant inspections. Back
13
Aphlatoxins from aspergillus species plus other myco-toxins from
plant pathogens. Back
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