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.





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