HC 1048-III Health CommitteeWritten evidence from the Food Standards Agency (PH 25)

Summary

The Food Standards Agency is a non-Ministerial Government Department with UK-wide responsibility for food safety. We have a vital public health protection role through policy development, statutory duties and direct enforcement in certain sectors.

We welcome the proposal to increase the priority given to improving public health and will work closely with the Department of Health during the planning and implementation of proposed changes to ensure the continued protection of public health from food related risks.

Particularly important to maintaining the FSA’s ability to carry out its statutory roles in public health and consumer protection will be ensuring that support currently provided by the Health Protection Agency is continued when its functions are incorporated into Public Health England.

Introduction

1. The Food Standards Agency (FSA) is a non-Ministerial Government Department operating at arm’s length from Ministers, and governed by a Board appointed to act in the public interest. The FSA has UK-wide responsibility for food safety and protecting other consumer interests in relation to food and our remit is set out in the Food Standards Act 1999. Our priority is to deliver safer food for the nation.

2. The FSA was set-up following the food safety crises of the 1980s and 90s – Salmonella in eggs, BSE and the 1996 Scottish E. coli O157 outbreak – with the dual aims of an enhanced focus on controlling public health risks associated with food and re-building public confidence in the safety of food. Our remit includes protecting the public from microbiological, chemical, and radiological risks that could be transmitted via food.

3. The FSA is a science and evidence–based organisation with openness and transparency at its core. Policy development is based on the best independent scientific advice and evidence available and this has been crucial in improving food safety and re-building public trust in the safety of food.

4. Until October 2010, in addition to our responsibility for food safety, the FSA shared responsibility with the Department(s) of Health for nutrition policy across the UK. The FSA had an integrated nutrition policy programme with the overall aim of making it easier for consumers to choose a healthier diet. Strategic targets included reducing population salt and saturated fat intake, contributing to achieving a balance between calorie intake and energy output and encouraging improved nutrition labelling to help consumers make healthier choices.

5. There was considerable synergy between the FSA’s work on food safety and nutrition. For example, work with the food industry by FSA nutrition teams to support and encourage re-formulation of products to reduce salt, sugar and saturated fat levels was supported by FSA food safety experts via an assessment of any food safety risks inherent in undertaking re-formulation. There was also considerable work at a local level to promote both health improvement and health protection activities jointly. This included provision of grants to support local initiatives on food safety and healthy eating and the development of a food competency framework for schools covering both food hygiene and nutrition. The FSA’s national consumer facing campaigns (eg on salt and saturated fat reduction) were amplified at local level through joint work with the health sector, local authorities (LAs) and voluntary and community organisations.

6. Following Machinery of Government changes in 2010 nutrition policy in England and Wales moved to the respective Health Departments, although responsibility for nutrition policy is currently maintained by the FSA in Scotland and Northern Ireland. In England, this change will enable work on public health improvement through improved dietary health to be fully incorporated within the proposed Public Health England (PHE) framework. However, to ensure that FSA responsibilities in this area are fully supported in Scotland and Northern Ireland it is important that the FSA and the Department of Health (DH) work closely together. This will minimise the potential for policy divergence across the UK and ensure that the FSA has continued access to independent scientific advice (eg from the Scientific Advisory Committee on Nutrition) and critically important UK-wide datasets such as that collected through the National Diet and Nutrition Survey.

Current Role of the FSA in Protecting Public Health

7. Food safety is the FSA’s main priority and the reduction of foodborne disease is a key FSA objective. We undertake a wide range of activities to ensure food safety and work closely with public health professionals to deliver this.

8. Foodborne illness is a significant public health problem. Annually there are estimated to be about a million cases of microbiological foodborne disease in the UK, leading to around 20,000 hospitalisations and 500 deaths at a cost of £1.5 billion to the UK economy. Allergens and food intolerances also add significantly to the public health burden with around 3,500 hospitalisations due to allergic responses and around 5,000 due to the most common food intolerance (coeliac disease) in 2008-09. Burden of disease attributable to chemical and radiological risks associated with food is more difficult to define, particularly for chemical contaminants where risk accumulates over a lifetime and is difficult to link to health outcomes. However, more than half the food contamination incidents that the FSA deals with every year are due to chemical contaminants – around 890 incidents in 2010.

The FSA’s role as a regulator

9. The FSA is the Central Competent Authority responsible for Official Controls for food and feed in the UK. The FSA Operations Group has overarching responsibility for the implementation and effective delivery of these Official Controls across the UK through direct enforcement or through other enforcement delivery partners.

10. Official controls are delivered directly by FSA Operations Group staff in slaughterhouses and meat plants throughout England, Wales and Scotland to ensure that meat is produced safely and hygienically. Official Controls are delivered on behalf of the FSA as the Central Competent Authority by over 400 Local Authorities in UK. LAs have regulatory responsibility for the food and feed safety, hygiene and standards official controls of the majority of UK food businesses, and at UK borders (sea ports and airports). The FSA’s role as the central regulator is to monitor the delivery of LA official controls, which it does through the support provided by regionally based staff and by performance monitoring and audit.

Specific FSA programmes to reduce public health risks from food

11. In addition to the regulatory activities we undertake there are a range of specific programmes of work that have been established to help improve public health by reducing the burden of UK foodborne disease - either by tackling it directly or working to improve standards in food businesses, resulting in the production of safer food. In developing and delivering these programmes of work we actively collaborate with partners at the local level and with a range of public health professionals including LAs and the Health Protection Agency (HPA).

12. A key programme is the introduction of the Food Hygiene Rating Scheme in partnership with LAs in England, Wales and Northern Ireland. The scheme provides consumers with easy to use and understand information on hygiene standards in the places they eat out or shop for food and draws on the power of the choices they make to incentivise businesses to improve standards. Since its launch in November 2010, momentum for the scheme has gathered and it is anticipated that all the LAs in Wales, around 70% of LAs in Northern Ireland and 40% of LAs in England will be operating it or preparing to launch it by the end of June 2011. The aim is that it will be operating across England in time for the 2012 Olympics & Paralympics. A similar scheme, the Food Hygiene Information Scheme, is being introduced in Scotland with 60% of LAs having launched it to date.

13. The FSA’s responsibility for ensuring food safety was highlighted in the Public Inquiry of the E.coli outbreak in Wales in 2005. As a result we have developed the Food Hygiene Delivery Programme, which is enabling us to strengthen our work with food businesses and LAs. We have already published comprehensive guidance for food businesses on controlling cross-contamination, provided focused update training for local enforcement officers, introduced sense-checking of LA inspections to ensure they are not an exercise in “box ticking”, carried out a review of legal powers and commissioned research on food safety culture in businesses. This enables us to push for change and will contribute to our overall strategic objective of safer food for the nation.

14. We are also assisting food businesses, particularly small and medium size enterprises, to produce safer food by helping them to comply with food safety management (HACCP) requirements of food hygiene legislation. To do this we have developed and issued practical advice and guidance through systems such as “Safer Food, Better Business”.

Microbiological foodborne disease

15. We are specifically tackling the root causes of microbiological foodborne illness through our Foodborne Disease Strategy. This aims to reduce microbiological foodborne disease by targeting the pathogens that have been identified as causing the greatest burden of disease. FSA food chain analysis has shown that the pathogens whose reduction and control offer the greatest potential for public health gains are: Campylobacter (causes the most cases of food poisoning – estimated to be around 630,000 cases in the UK in 2009); Listeria monocytogenes (responsible for approximately 30% of food poisoning deaths) and viruses (responsible for an increasing number of cases). The strategy is based on a farm-to-fork approach, with the aim of reducing contamination of foods during production and processing and of promoting good food hygiene practice in the kitchen, both commercially and in the home. Crucial to this work is our active partnership with, and support from, the HPA.

Chemical and radiological risks from food

16. The FSA is also responsible for protecting consumers from chemical and radiological risks in food. We provide risk assessment and risk management advice, drawing on in-house expertise in toxicology and exposure assessment as well as advice from relevant independent scientific advisory committees. A key strategic aim is to increase horizon scanning and improve forensic knowledge of, and intelligence on, global food chains to identify and reduce the impact of potential new and re-emerging risks – particularly around chemical contamination. We are also seeking to increase the provision of information about allergens, including in catering establishments.

Incidents

17. The FSA leads the Government response to food contamination incidents (chemical, microbiological and radiological) and is increasingly involved in the cross-departmental Government response to wider food contamination incidents such as radiation, flooding, fires, chemical leaks and oil spills; that call for advice on food safety. The FSA has managed more than 10,000 incidents of varying nature and complexity during its lifetime, including 1,505 incidents in 2010. The Agency works closely with the HPA (in England), enforcement authorities, food business operators, and other key stakeholders in order to manage incidents appropriately and proportionately.

Public Health England

18. Outlined in the white paper “Healthy Lives, Healthy People: Our Strategy for Public Health in England” is the intention to create Public Health England (PHE), incorporated within DH and accountable to the Secretary of State for Health. The intention is that PHE should lead health protection in England, set the overall outcomes framework for public health and work across Government, with the NHS Commissioning Board and national partners to support local public health action, including through funding, the provision of evidence and data, and professional leadership.

19. However, responsibility for leading health protection activities relating to food safety remains with the FSA, as part of our statutory duties, outlined in the Food Standards Act 1999. PHE and the FSA will therefore need to work closely together to ensure appropriate alignment and prioritisation of food safety-related health protection outcomes delivered through PHE, FSA and local government activities.

HPA support for the FSA

20. The HPA provides a range of specialist services and scientific support and advice vital to enable the FSA to discharge its public health responsibilities.

21. The HPA currently collects, analyses and publishes data for England on a number of notifiable diseases including gastrointestinal infections caused by foodborne pathogens. The high quality monitoring and surveillance data on these infections currently provided by the HPA (including those caused by Salmonella, Campylobacter, E. coli O157, Listeria and Norovirus) is vital to the FSA and underpins the FSA Foodborne Disease Strategy. The FSA’s work on the investigation and management of outbreaks of foodborne disease is made possible by the results of microbiological testing, allied to sophisticated typing work carried out by the HPA, which enables the epidemiology of the spread of disease to be determined and controlled. Although many outbreaks can, and are, managed locally, where they have an impact that extends beyond local boundaries and resources, HPA resources and its established links with equivalent bodies in the devolved nations (eg Health Protection Scotland) are vital in ensuring that we are able to deal with national or international incidents. An example where the importance of this support is fully demonstrated is the current large and very serious E. coli outbreak centred in northern Germany.

22. Regional HPA Food, Water and Environmental microbiology laboratories are equipped to carry out a range of specialist microbiological tests on food, water and environmental samples. Specialist testing (ca 180,000 tests/year) is conducted to determine the microbiological quality of food and water samples and to check on a regular basis that they are safe for human consumption, for LAs and other stakeholders.

23. The UK Food Surveillance System (UKFSS) is a real time system which collates data on chemical and microbiological analysis of official control samples taken by Food Authorities. The system can be used to monitor trends, track foodborne illness outbreak sampling, identify food hazards as they arise and help LAs verify food businesses’ food safety controls. The FSA are currently rolling out UKFSS to LAs across the UK. In England linking the system to Public Health Laboratories for microbiological samples is being done in partnership with the HPA, for all laboratories in time for the 2012 Olympics, to increase public health protection by improving recording of sample data and streamlining of LA resources.

24. HPA scientists also undertake substantial amounts of research for the FSA, particularly supporting our work on microbiological foodborne disease. This includes undertaking large projects to explore the epidemiology of Campylobacter infection and being a major participant in the recent large second study of infectious intestinal disease (IID) in the UK – designed to allow a greater understanding of the burden of IID in the UK population, including foodborne disease.

25. The HPA are an advisory body to Government on radiological protection issues and provide important support for the FSA’s duties in this area (including in Scotland). The HPA assess proposed changes to radiological protection standards and methods and provide advice on interpretation of international standards and methods to ensure consistency of approach across Government.

26. Since the Chernobyl accident in 1986, the HPA have aided the FSA’s preparations for emergency response and supported them during nuclear exercises and during the recent Fukushima incident. They are an important source of advice during policy development on setting of acceptable levels of radiological contamination in food. HPA radiological laboratories offer an analytical service for mixed diet samples collected under a European requirement as part of the UK’s show of compliance for Articles 35 and 36 of the European Atomic Treaty.

Impact of the abolition of the HPA and formation of PHE on the FSA

27. The abolition of the HPA and the integration of its function into a Ministerial Government Department has some important implications for the work of the FSA. As outlined above (paras 20-26) the HPA provides substantial support for our work. This will need to be continued, supported and appropriately prioritised when these functions become integrated into PHE.

28. In particular, there is a substantial body of scientists with international standing within the HPA in the field of foodborne pathogens, epidemiology of foodborne disease and radiological protection, which will be integrated into PHE. The FSA is keen to ensure that we can continue to rely upon them for independent scientific advice and can continue to commission high quality independent scientific research from them to support our policy priorities. Given the remit of the FSA and our ability to publish the advice we give to Ministers it is crucial that scientific advice and data we base our policies or advice upon is seen to be independent.

29. In addition to supporting FSA activities in England certain HPA functions (including advisory and monitoring services for chemicals and radiation as well as particular specialist laboratory services) are also accessed to support health protection activities in Scotland and it is important to ensure continuation of this support.

The Future Role of Local Government in Public Health

30. LAs are key to the delivery of official controls in the food chain. They operate through regulatory teams (environmental health and food standards), often with a wide range of allied responsibilities and statutory duties which they perform for the FSA and other authorities. Their work underpins public health in the widest sense, and ensuring high standards of food safety and food standards is an integral part of their wider work to support community health and well-being. The FSA actively supports LAs in the work they deliver on food safety through provision of advice, guidance and training. The FSA and PHE will need to be clear about roles and responsibilities, align work and identify synergies to make effective use of local authority resources, for example to reduce levels of foodborne disease in vulnerable groups.

Conclusion

31. The FSA is a UK statutory body with responsibility for leading health protection activities relating to food safety. We welcome the proposal to increase the priority given to improving public health and emphasise the importance of DH working closely with the FSA to ensure that the proposed changes do not adversely impact on our ability to deliver safer food for the nation.

June 2011