Select Committee on Science and Technology Written Evidence

Memorandum by the Food Standards Agency


  1.  The Food Standards Agency (FSA) was set up in April 2000 to protect public health and restore public confidence in the way that food safety decisions are made. The 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. It is a UK body, accountable to the Westminster Parliament and to the devolved administrations through the relevant Health Ministers. Our UK headquarters is in London and we also have offices in Scotland, Wales and Northern Ireland and each of these countries has its own advisory committee chaired by a Board member.

  2.  The Agency's core values are to:

    —  put the consumer first;

    —  be open and accessible; and

    —  act as an independent voice.

  3.  Our sphere of interest ranges across the entire food chain, from pesticides and veterinary medicines, to food safety and hygiene standards in shops, restaurants and takeaways and the home kitchen. We aim to provide clear guidance to the public on safe and healthy eating. To be able to give sound advice, the FSA needs access to the best possible information including surveillance data and evidence-based research. We consult widely, commission independent research and, wherever possible, seeks consumers' and other interested parties' views before reaching conclusions.


  4.  Since the Agency was established in order to restore public confidence in the national arrangements for food safety, public attitudes, risk perception and risk communication are at the heart of the Agency's activities.


  5.  Foodborne disease makes a major contribution to morbidity and mortality from human infectious disease in the United Kingdom. A large study of infectious intestinal disease (IID) in England in the mid 90s estimated that there were a total of 9.4 million cases of IID each year, with costs of £750 million to the NHS, employers and the cases themselves. On the basis of the pathogens isolated, we have estimated that between 17-50 per cent of these cases were foodborne. Work to refine and update this estimate has been carried out by the PHLS Communicable Disease Surveillance Centre (currently in press). This confirms a current estimate of over 1 million cases a year of UK-acquired foodborne disease, with just under 500 deaths. A recent Regulatory Impact Assessment prepared for the Agency suggested that annual costs are currently in the order of £1.4 billion.

  6.  On the 28 July 2000, the Food Standards Agency announced a target to reduce foodborne disease in the UK by 20 per cent by 2006. In July 2001 it published its "farm to fork" strategy to reduce foodborne illness in the UK on its website[56]. A paper summarising the current trends in foodborne disease was published in August 2001[57].

  7.  The major foodborne pathogens, in terms of incidence, are Campylobacter and Salmonella. In 2001, there were just under 63,000 laboratory-confirmed cases of Campylobacter and over 18,000 laboratory-confirmed cases of Salmonella. On the basis of the IID Study, this probably represents over half a million cases in the community due to these two pathogens alone. Whilst there has been a major decrease in Salmonella in recent years, the number of reports of Campylobacter has continued to increase and this pathogen is likely to continue to represent the greatest threat in the foreseeable future.

  8.  Whilst verotoxigenic E. coli accounts for fewer cases (generally 1,100-1,400 laboratory confirmed cases a year), it continues to pose a significant threat because of its severity. It also illustrates the way in which new pathogens emerge, in ways which can only in part be predicted, and exploit aspects of the increasingly complex food chain to give rise to new foodborne diseases.

  9.  Robust surveillance data is fundamental to the Agency's ability to monitor the success of its foodborne disease strategy and a comprehensive, expert-led system is crucial in detecting and investigating the emergence of new threats.


  10.  The term infectious intestinal disease (IID) is used to describe gastrointestinal symptoms (diarrhoea, vomiting, abdominal pain) due to microorganisms or their toxins. Only a proportion of these cases is foodborne. While it is relatively easy to obtain robust data on IID, the proportion of cases that are foodborne can only be estimated, however promptly or completely those cases are investigated. Information on pathogens isolated from cases of IID helps refine such estimates. Whilst no single system provides a complete picture, data from a number of different sources helps to build up the picture.

  11.  The main sources of data on human foodborne disease and other infectious intestinal disease are:

    —  The statutory notification system.

    —  Reports of Intestinal Infectious Disease made to the Royal College of General Practitioners' Weekly Returns Service.

    —  Laboratory reporting of the major foodborne pathogens.

    —  Reports of outbreaks to the national surveillance centres.

  12.  The statutory notification system is recognised as being a poor way of ascertaining the true incidence of food poisoning. It is based on clinical suspicion only and requires no laboratory confirmation of the diagnosis. It also relies upon a subjective judgement by the doctor regarding the cause of the symptoms. There is, moreover, evidence of a general under-reporting of notifiable diseases. On the other hand, it is a difficult figure to ignore because it comes with the label "food poisoning".

  13.  The GP sentinel surveillance system provides a reliable figure for the number of cases of IID seen by GPs in the sentinel practices. In common with the statutory notification system, no microbiological confirmation of the diagnosis is sought. Like all sentinel systems, it suffers from the potential problem of being unrepresentative of the general population, and it is confined to England and Wales. However, it does provide a good indication of the underlying trend in IID against which trends in laboratory-confirmed cases can be judged, provided there is no major change in the frequency with which patients consult doctors about symptoms of IID. The advent of NHS Direct could affect these data and it is therefore important for surveillance to capture data from this service.

  14.  The laboratory reporting system provides microbiological confirmation of the clinical diagnosis of IID and data on trends in individual organisms. The IID Study showed that laboratory reporting identified a significant proportion of all cases of Salmonella (one in three) and Campylobacter (one in eight) that occurred in the community.

  15.  However, since the system is voluntary, not all laboratories take part. Evidence suggests that, to date, the level of participation has been high and it is by no means certain that a statutory requirement for laboratories to notify their positive results would yield a significant amount of additional information. However, changes in the Health Service ("Shifting the Balance") and in arrangements for microbiology services ("Getting Ahead of the Curve") have the potential to change the level of laboratory investigation and reporting.

  16.  National surveillance centres also have systems for recording outbreaks. It is generally only outbreak cases for which the route of transmission can be established and thus outbreak reports provide key information on trends in foodborne disease. However, outbreak cases probably account for fewer than 5 per cent of all cases of foodborne disease. Moreover, outbreak reporting is known to be patchy and smaller outbreaks in particular, may tend to be under-reported.

  17.  Current systems cannot provide information on cases that do not seek medical advice or that are not reported to local Environmental Health Officers. This can only be ascertained by community-based studies such as the IID study, which identified cases prospectively and linked symptoms to a questionnaire and microbiological investigations.

  18.  For all the shortcomings of the existing sources of data on IID and foodborne illness it is possible to obtain a reasonable representation of trends in foodborne disease when data from a number of the sources described above are combined. Such data currently provides a firm basis from which to manage food safety. However, the Food Standards Agency supports the promotion and strengthening of surveillance of foodborne disease. The PHLS has played a crucial role in the surveillance of foodborne disease, in laboratory testing, in provision of specialist reference facilities and as collector and interpreter of surveillance data. Current proposals following on from Getting Ahead of the Curve should maintain the role as collector and interpreter of surveillance data. In the light of proposals that have emerged about the future of microbiology services, there is an opportunity to improve surveillance data because all microbiology laboratories will be required to acknowledge and meet public health responsibilities, including obligations to contribute to surveillance systems. The public health microbiologists and Regional Public Health Microbiology Co-ordinators will have an important role in making sure that this opportunity is seized and to prevent any danger of the public health responsibilities of microbiology laboratories being sacrificed to their clinical role. There are concerns that these two key positions will not be occupied on a full-time basis.

  19.  The monitoring of pathogens in food animals and in foods also plays an important part in surveillance of foodborne disease. Zoonotic infections in man can occur by a variety of routes, which include foodborne, waterborne, direct contact and through insect vectors. In the United Kingdom, the foodborne source is thought to be the most common. However, some zoonoses do not cause disease in animals so samples will not be submitted to the laboratory for examination unless a programme of routine monitoring has been implemented to detect them, or samples are taken as a result of an investigation into an outbreak of disease in humans.

  20.  Good links have been forged between PHLS and the VLA to bring animal and human surveillance systems in line with one another. This enables data from the monitoring of food animals to be used more effectively to monitor prevention strategies in the primary production sector and to flag emerging problems. It also facilitates understanding of human epidemiology by tracing pathogens back to their probable source. Such an understanding is fundamental to the prioritisation of measures to reduce foodborne disease. Getting Ahead of the Curve recognises the importance of integrating veterinary and human data although the mechanisms whereby this will be improved remain to be determined.

  21.  Provision of food, water and environmental (FWE) microbiology services is important not only to support enforcement activities but in surveillance of foodborne disease. Getting Ahead of the Curve did not make specific mention of these services but subsequent discussion has resulted in an agreement that such services will continue to be provided by the Health Protection Agency through a centrally-managed network of FWE laboratories and that existing FWE laboratories will continue to operate on a "business as usual" basis in the lead up to the establishment of the HPA and immediately thereafter.


  22.  Some collaboration already exists which aims to improve and harmonise surveillance systems, outbreak investigation, reporting systems and diagnostic methods across Europe and we believe that the systems in the UK benefit from these collaborations. One such collaboration, which is funded by the EU and is led by the PHLS, is Enter-net. Enter-net is an international surveillance network for human gastrointestinal infections, which involves the 15 countries of the European Union, plus Switzerland and Norway (and co-operates with international colleagues including the US, Canada, Japan and Australia). The network aims to conduct international surveillance of human salmonellosis, including antimicrobial resistance in isolates from humans, and of human infections by verocytotoxin producing Escherichia coli O157.

  23.  The UK also currently contributes data to two other surveillance networks. One is a surveillance network on Foodborne Viral infections and the other is a new network on Listeria. In contributing to these networks the UK supports their aims to develop standardised methods for investigation of outbreaks and transfer technology to established and starting laboratories to enable comparative analysis of the epidemiology of foodborne disease and early detection of multi-national outbreaks.

  24.  Contributing to these surveillance networks and sharing diagnostic methods, in addition to the routine reporting of UK data under the Zoonosis Directive and to the WHO Programme on Foodborne Intoxications, can facilitate the timely exchange of international information which can lead to public health action in Europe and beyond.


  25.  In the area of foodborne disease the UK has been at the forefront of detection and typing research for many years. It is important that strong reference laboratory services are maintained and that adoption of new methodologies for routine use constitutes an important ongoing objective.

  26.  The most beneficial advance in diagnostic methods that the Agency would like to see would be a molecular approach to Norwalk-Like Virus (NLV) detection. At present laboratory methods only detect a very small proportion of all NLV infections. This is because few samples are examined by electron microscopy (EM) and, when they are, the chances of making a positive diagnosis are small because after the first couple of days of illness, viruses are no longer detectable on EM. We would hope that the development of a molecular method for routine use would facilitate routine examination for NLVs and enable detection of the virus weeks after infection rather than just days.


  27.  Although most cases of food poisoning are self-limiting and resolve quickly without treatment, the use of antibiotic treatment may be necessary in cases of severe illness and infection in vulnerable individuals. Therefore an understanding of the emergence and spread of antibiotic resistance in foodborne pathogens in humans is important. The spread of resistances in zoonotic microorganisms in food animals and the potential route of transmission of these organisms to humans through food is also of concern.

  28.  Prevention is the key theme of the foodborne disease strategy. The strategy includes three main strands of activity:

    —  reducing microbial contamination of foods;

    —  promoting better food safety management and practice; and

    —  promoting hygienic preparation of food commercially and in the home.

  29.  The Agency has put in place a wide-ranging programme of action, which it believes will have maximum impact on preventing foodborne disease, both outbreaks and sporadic cases. Current activity is summarised in Annex 1. Surveillance data is required to monitor the impact of this programme and will be used to highlight any area requiring further policy interventions.

  30.  While vaccines for prevention of foodborne illness in humans are generally not appropriate because of the multiplicity of pathogens and short-lived nature of the illness, there is a role for vaccines in the control of zoonotic agents in animals. An example of this is the vaccination of the UK egg laying flocks against Salmonella. In its second report on Salmonella in Eggs[58], the Advisory Committee on the Microbiological Safety of Food (ACMSF) concluded that vaccination had a significant effect on the prevalence of egg contamination and human infections. This was based on consideration of evidence including trends in vaccination of the UK laying flocks and in Salmonella infections in humans. However it can sometimes be difficult to predict the cost benefit of developing vaccines to control animal carriage of zoonotic agents at the time the initial investment is needed.

Annex 1


  1.  An outline of the main activities being undertaken at part of the Foodborne Disease Strategy is given below.

Reducing Microbial Contamination in Foods

    —  Developing and implementing a strategy to reduce Campylobacter in chickens.

    —  Implementing further measures to reduce salmonella levels in chickens.

    —  Improving enforcement of hygiene requirements in meat products, minced meat and meat preparation establishments through enhanced guidance and training for enforcement officers.

    —  Continuing to operate food safety management awareness initiatives for on-farm pasteuriseurs and on farm milk product producers.

    —  Reviewing the guidance available on enforcement of dairy products hygiene legislation to ensure own checks are applied effectively.

    —  Production of a discussion paper on the enforcement of on-farm pasteurisation of milk.

    —  Reviewing the function of the Dairy hygiene Inspectorate in relation to the need to reduce faecal contamination of milk during milking.

Promoting HACCP and Food Safety Management

    —  Implementing a strategy to promote HACCP in food businesses and in particular catering and retail establishments.

    —  Introduction of HACCP guidance to help meat processors and food plants carry out their operations in accordance with HACCP principles (ie introduction of HACCP manual for meat plants and food safety management awareness initiative for specialist cheesemakers).

    —  Developing sampling protocols and microbiological criteria for testing carcasses at meat plants in support of HACCP.

Developing and Promoting Best Practice

    —  Developing guidelines for growers to minimise the risks of microbiological contamination of ready to eat crops when using manures.

    —  Reviewing the current classification system for shellfish harvesting waters in England.

    —  Commissioning research to develop best practice guidelines for teat cleaning prior to milking.

    —  Developing best practise and guidance to ensure animals presented for slaughter are clean (ie clean livestock policy).

    —  Investigating ways to minimise the risk of poultry becoming colonised with pathogens during growing, transport and slaughtering (eg potential control measures for Campylobacter, crate washing and physical decontamination methods during slaughter).

    —  Working with industry, DEFRA and the British Pig Executive (BPEX) to reduce Salmonella in pigs through the implementation of the ZAP Salmonella monitoring scheme.

Food Hygiene Promotion and Education

    —  Launching a five year multi-media Food Hygiene Campaign on 11 February 2002 to:

    —  Raise awareness of food poisoning as an issue.

    —  Establish the link between poor food hygiene and food poisoning.

    —  Increase understanding of the key hygiene messages.

    —  Change food hygiene attitudes, knowledge and behaviour.

    —  Involvement in EU sponsored education campaigns since 1998,[59][60].

    —  Partner in the Food and Drink Federation's Foodlink activities including the Food Safety Week initiative, which has been running for ten years to promote the communication of food hygiene messages to children and young adults[61].

  For a more detailed account of the work being undertaken to implement the foodborne disease strategy see Board paper NOTE 01/07/01 and NOTE 02/05/04 which can be downloaded from the Agency's website:

October 2002

56 Back

57 Back

58   Advisory Committee on the Microbiological Safety of Food. Second Report on Salmonella in eggs. 2001. London. The Stationery Office. ISBN 0-11-322466-4 Back

59   Two food hygiene teaching resources: "Aliens in Our Food"-aimed at children at secondary schools, and "Safe T and the H Squad"-aimed at children in junior schools. These resources are accessible from the "Food Hygiene Mission Control" navigation button on the Agency website home page ( Back

60   A web based education package aimed at UK teenagers and young adults (14-24 year age group). The site was launched on 15 April 02, can be viewed at: Back

61   Material produced for Food Safety week can be downloaded from Back

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