Memorandum submitted by the Food Standards
Agency (SFS 72)
EXECUTIVE SUMMARY
1. The Select Committee's inquiry is exploring
the challenges faced by the UK in ensuring we have secure food.
Defra's discussion paper "Ensuring the UK's Food Security
in a Changing world" (July 2008) defines food
security as: "consumers having access at all times to
sufficient, safe and nutritious food for an active and healthy
life at affordable prices".
2. The Food Standards Agency's insight on
this issue is principally on how changes in global food production
and consumption will affect the supply and consumption of food
in the UK and therefore present new challenges in ensuring that
food is safe. An essential objective of the Food Standards Agency
(FSA) is to secure continuous improvements in food safety and
also explicitly to retain consumer confidence in food safety.
3. This evidence comments on where the FSA
will focus in order to ensure that food safety systems remain
robust as patterns of food production and consumption change.
4. The evidence also notes the potential
issues which changes in food production may create for ensuring
nutritious food. The evidence also describes how the Food Standards
Agency interacts with Defra and other parts of government to ensure
that food policy is coordinated across government.
THE FOOD
STANDARDS AGENCY
5. The FSA was established in April 2000 as
a non-Ministerial UK Government Department, operating at arms'
length from Ministers, headed by a Chair and Board, who are appointed
to act in the public interest. The FSA is accountable to the Westminster
Parliament, through health ministers, and similarly to the devolved
administrations in Scotland, Wales and Northern Ireland. It has
its own budget, which is negotiated directly with the Treasury.
6. The Food Standards Act 1999 states
"the main objective of the Agency in carrying out its function
is to protect public health from risks which may arise in connection
with the consumption of food (including risks caused by the way
in which it is produced and supplied) and otherwise to protect
the interest of consumers in relation to food". The Agency
is responsible for assessing and managing risk in relation to
food and communicating advice to the public. It is guided by a
set of core principles: putting the consumer first; openness and
independence; science and evidence-based.
FOOD CONSUMPTION
AND PRODUCTION
7. The inquiry is considering potential
demand and supply changes in food over a 40-year period. It may
be instructive to consider the extent of changes that have taken
place in UK food consumption over the past 40 years. For
example the rise of frozen foods in the 1970s, the dramatic increase
in the consumption of ready meals and the steady shift towards
a greater proportion of meals being eaten out-of-home. Given the
breadth of these changes, anticipating the socio-economic and
technological changes that will affect food consumption over the
next 40 years is complex.
8. There are a variety of other drivers
which will determine the nature of any changes in global food
production—for example the effect of production subsidies
and the impact of climate change on the appropriateness of land
and water in different regions for agricultural use. However the
principal determinant is likely to remain the economics of market
demand.
9. Market demand has prompted considerable
innovation and diversification in food production, including the
globalisation of food supply and the development of an increasingly
complex and multilayered supply chain. Measured by unprocessed
value the UK provides around 50% of its own food. Imports are
principally from other EU countries (the Netherlands, Spain, France,
the Irish Republic and Germany are the five largest suppliers).
In total 26 countries account for 90% of the UK's food supply.
These range from traditional trading partners, such as South Africa,
the USA and New Zealand, to Mauritius, Kenya and Chile.
10. The complexity of food supply chains
leads to increased challenges for food businesses in maintaining
standards throughout the supply chain and ensuring that sources
of products can be traced. As patterns of global production change
then new risks for food safety may emerge. As the regulator of
food safety, the FSA has to ensure that it has the regulatory
and policy framework to monitor and respond to these risks.
11. The following sections describe the
food safety risks, considering how those may be affected by changes
in food production, and the FSA's response to those risks.
FOOD SAFETY
RISKS
12. The greatest type of food safety risk
is food borne disease (principally salmonella, campylobacter,
VTEC, listeria and clostridium perfringens). There were an estimated
950,000 cases of food borne disease in 2006. Other sources
of risk include chemical contamination, allergens or intolerance
and radiological contamination.
13. The FSA dealt with 1,300 reported
food safety incidents during 2008. Even where food incidents are
not injurious to health, they undermine consumer confidence in
food safety, are costly to national economies and unless effectively
managed may contribute to an erosion of trust between consumers,
regulators and the food industry.
14. Under UK law responsibility for food
safety rests with the food business operator. The key requirements
are that businesses take responsibility for the safety of the
food that they produce, import, pack, transport, store or sell.
Food incidents may arise in any stage of the supply chain: at
primary production, processing, manufacture or retail, and at
the storage and distribution points between each stage. There
are also risks for consumers in how they store and prepare food.
15. Around a quarter of incidents originate
from outside the EU. In 2008 there was a major incident involving
milk and milk products from China contaminated with melamine,
which highlights the challenges which arise in managing food incidents
from imported goods.
16. Food imports from outside the EU are
subject to controls which are different between animal and non-animal
products. Animal products may only be imported through designated
Border Inspection Points (there are around 20 in the UK).
At the posts the product is subject to documentary and physical
checks. Non—animal products may be imported through around
80 seaports and airports around the UK. Documentary checks
are conducted and a small proportion of products will be subject
to additional checks or sampling.
17. The melamine incident arose when melamine,
an industrial chemical used in the production of plastic, was
added to low grade milk to give the impression of higher protein
content. The Chinese authorities estimated that more than 300,000 children
were affected by the contaminated milk. The problem spread to
the EU through the import of composite products containing milk
or milk powder such as chocolate and biscuits. (There has been
a long-standing ban on the import of milk and other products of
animal origin from China as controls on the food industry in China
do not meet the very strict requirements set in the EU).
18. Following the European Commission's
policy the FSA worked with the food industry and others to proactively
identify possible products which may contain adulterated milk
or milk products which may be on the UK market and then to ensure
that they were withdrawn from sale. Port health authorities were
asked to detain relevant consignments from China pending receipt
of laboratory test results.
THE FSA'S
RESPONSE TO
RISKS
19. Changing patterns of global food production
will present new challenges for the robustness of the regulatory
system. There are a number of measures which the FSA takes to
ensure that the risks to food safety are managed effectively.
20. Key to these is the science and research
which underpins all of the FSA's activity. The FSA is currently
considering its strategic plan for the period 2010-15 and,
as part of this, the associated research needs. This will include
continuing to build our understanding of how food safety risks
arise, for example how campylobacter moves in the food chain.
There is also scope for better sharing of research requirements
across government and with industry so that where appropriate
resources can be shared.
21. An area which the FSA believes merits
particularly close attention is food imports. As food businesses
respond to changing demand, or economic pressures create requirements
for cheaper sourcing, we would expect to see changes in the pattern
of imports.
22. Tackling problems with imported foods
requires a combination of approaches: continued vigilance at border
controls, intelligence-based target surveillance to address illegal
activity, promoting food safety in developing countries and raising
awareness of existing EU food safety legislation. The lesson to
be learned from the melamine incident is not simply one about
food risks relating to a particular country. It also highlights
that risks may occur in food products where there are commercial
benefits to be gained from adulteration of the product to demonstrate
a higher level of a particular nutrient.
23. Underpinning all this activity is co-operation
nationally and internationally to ensure that risks are identified
and managed. The FSA has put in place an incident prevention strategy.
This works with industry, local authorities and consumer representatives
to reduce the number of incidents by preventative action. Key
to this is sharing information and intelligence, based on building
trust and partnerships.
24. The FSA plays an active role in the
work of the European Food Safety Authority and there are active
links and regular exchanges of information with international
food safety authorities. These are particularly strong with English-speaking
countries such as the USA, Canada, Australia and New Zealand.
The FSA is also working with EFSA and the European Commission
to improve links with other countries beyond the EU.
NEW TECHNOLOGIES
25. The FSA continues to monitor emerging
technologies that have developed within the food sector, and the
non-food sector, but which could be transferable into the food
supply. Areas of potential future development include the use
of intelligent packaging to give food safety warnings rather than
relying on use by dates, nanotechnology in food packaging to prevent
decay and more rapid sampling of food products and detection of
food hazards.
26. In all cases it is vital to ensure not
only that such new technologies enhance food safety but that the
technologies are introduced in an open way to ensure that they
have public understanding and support.
27. Future changes in global food production
are likely to raise again the question of the use of GM products
in the UK. The FSA is responsible for the food safety assessment
of Genetically Modified Organisms (GMOs) in the UK. The use of
GMOs in food is determined by European Community Regulation (EC)
1829/2003 on GM food and feed which stipulates that GM foods
may only be authorised for sale if they are judged not to present
a risk to health, not to mislead consumers and not to be of less
nutritional value than the foods they are intended to replace.
28. Authorisation of GMOs for use, or cultivation
within Europe takes place at a European level. The European Food
Safety Authority (EFSA), in consultation with the appropriate
competent authority, is required to provide a risk assessment.
This assessment includes a detailed consideration of the potential
for toxic, nutritional and allergenic effects. The final decision
on authorisation of GMOs is taken by Member States at the Standing
Committee on Animal Health and the Food Chain. Nine GMOs have
been authorized for use in the past two years.
NUTRITION
29. The FSA will also give consideration
to how changes in global food production affect its work on nutrition.
30. The Agency has established an integrated
nutrition policy programme with the overall aim of making it easier
for consumers to choose a healthier diet. The programme seeks
to influence both in home and out of home eating occasions. Its
strategic targets include reducing population salt and saturated
fat intake, contributing to achieving a balance between calorie
intake and energy output and encouraging improved nutrition labelling
both in store and in restaurants to help consumers make healthier
choices. There are three clusters of activity which seek to: influence
people's knowledge and skills; encourage businesses to improve
the nutritional composition of foods; and foster an environment
which promotes healthier choices.
31. To ensure its nutrition policies are
based on the best available evidence the Agency allocates significant
resources to supporting development of independent expert advice,
evaluating the impact of its policies and generating and interpreting
dietary research and survey data. This will allow any changes
in dietary intakes, which may arise from changes in global food
production, to be identified and addressed.
FSA and other Government Departments
32. Food policy has been central to the
Government's agenda in the post war period. The recent spike in
food prices, the impact of food on health outcomes, food crisis
and food scares will continue to ensure that food is a central
priority for this, and future Governments. Food policy in England
is mainly developed with three Government departments: the Food
Standards Agency, Department of Health and Department for Food,
Environment and Rural Affairs.
33. The Food Standards Agency has concordats
with both the DH and Defra that clarify areas of responsibility.
The recently published Department of Health's Healthy Food Code
of Good Practice and Food Matters—Towards a Strategy for
the 21st Century further clarify areas of responsibility between
Departments.
34. The Healthy Food Code of Good Practice,
part of the Government's Obesity Strategy for England, establishes
seven areas where Government expects companies in every food sector
to take action to demonstrate commitment to promoting healthy
eating. The FSA is responsible for front of pack labelling, smaller
portion sizes for energy dense and high in salt foods, reductions
in consumption of the levels of saturated fat and sugar, and nutritional
information on food eaten out of the home.
35. The Cabinet Office's Food Matters—Towards
a Strategy for the 21st Century published in July 2008 recognises
the importance of working with all stakeholders to develop a new
food policy framework. The report states that continuing vigilance
on food safety is one of the four key challenges facing the UK
food system. The report identified a number of actions for government.
The FSA was identified as the lead department for four recommendations:
helping people make healthier choices when eating out; developing
a single web based platform for consumer information and advice
on nutrition, food and sustainability, and food safety; implementing
a whole food chain approach to tackling food-borne illness; analysing
the extent to which changes in the market are putting a strain
on the regulatory system for GM products. The delivery of the
recommendations within the Cabinet Office report is being overseen
by the Cabinet's Office Food Strategy Task Force on which the
FSA is represented.
36. Defra recently established the Council
of Food Policy Advisors to advise Government on food affordability,
security of supply and the environmental impact of food production,
and contribute to drawing up of the policy for food security and
supply expected to be published in 2009. Tim Smith, the FSA Chief
Executive, is a member of the Council of Food Policy Advisors.
37. A new Cabinet sub-committee on food,
Domestic Affairs (Food), has been formed and the Chair of the
FSA, Dame Deirdre Hutton, attends by invitation.
38. Collectively these arrangements allow
government policy on food to be joined up effectively. Within
that structure the Food Standards Agency believes that it plays
an important role, enhanced by its status as a non-ministerial
department.
Food Standards Agency
February 2009
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