What Do We Want from the FSA's Board?
Action, Reaction, Education with Urgency. -
We answer invitations to comment on the FSA's functions, gained from impressions at recent open meetings of its Board. The plough-to-plate and farm-to-fork integration is being neglected. Food must be interesting, pleasurable and health-friendly all the way through the chain, not just sterilized and safe gut-fill. Feedback Questionnaire. FSA. Open Board Meeting 09/02/05 London
1. We were disappointed at evidence of hesitation and neglect in despatch and attention to topics that should engage the FSA and inform its purpose and future. 2. Such are: 2.1 Emphasis in the politicking before the imminent General Election on reducing the Civil Service and associated ministerial and agency enterprise; Tory reforms, we understand, propose curtailment of the activities of the “ Food Safety Agency” (already undermining the mission of a Food Standard Agency that had been won as a result of campaigns in earlier elections and superior to the food safety agency that was all the Euro-parliament could achieve) These threats are serious for a scientifically-based independent charity-an NGO-with a plough-to-plate farm-to-fork concept of standards of food production in which the environment (the factory-floor and “waste” receptacle) and the comprehensive welfare of animals, humans, non-human, domesticated, farmed and wild-counts as the essence of the quality of life.
2.2 The fate of many topics on which we have been involved with ministries and government agencies-as well as with producers, manufacturers, and retailers-seems unsettled while the FSA is in a defensive mode of weakness when it could be coordinating and linking options that express initiatives presented, with much common interest, by organisations such as ours who are offering objective and scientific campaigning in furtherance of the FSA’s mission. Two Bills, at least, to be rushed through before the General Election will have connotations requiring assessments and collaborations from the FSA and its responsibilities for both safety and standards: They relate to animal welfare and litter.
2.3 These challenges arise while a protracted process of finding a successor to the FSA’s present chairman, who is retiring, is being sought. Two other retiring members of the Board are also being replaced.
2.4 It is appropriate at this time to make general comment on the choices and members of the Board and the details published of their relevant experience and competence, which are useful for the public to ascertain their financial involvements and needs to declare specific interests in meetings, open and closed. However, we should be given more information on their personal decisions in the purchase of food and consumption, especially in the light of evidence, advice and example from the FSA on matters such as benefit-risk appraisals, with apparent scientific authority, on fish consumption and risks from contaminants, as well as on consumption of sheep-and goat-meat that might be coming under suspicion as a carrier of BSE masquerading as scrapie. It is as relevant to us as critics to know where candidates shop for food as for stocks and shares, what time they devote to reading labels and what time they give to preparation of food and to the choice of dishes when eating out and how often they resort to restaurants and takeaways (as well as what they choose at FSA functions). Some of the candidates may profess interesting and relevant aversions, e.g. to eating organic, kosher, Halal or at McDonald’s, or because they are (or at risk) of diabetes, milk allergy, lactose-intolerance, or celiac disease. We have read over 100 individually volunteered descriptions of members of the board not one of whom confesses to being a vegetarian, yet 5 % of the general population describe themselves to marketeers as vegetarian. It is noteworthy that no such declaration has been represented by membership of the FSA’s Board.
2.5 The foregoing requirements are no more impertinent than those we were able from the start to see implemented at the Phillips BSE Inquiry, at which every witness was required at the end of their testimony to answer whether knowledge of the situation had had at any time caused a change in their dietary practices (or modified advice they had proffered to their nearest and dearest, or charges, e.g. as school governors). The final report included very much testimony and collation but omitted the replies to the dietary question. By our own research we obtained privately from members of the tribunal that they had not changed their dietary custom during the decade before the Inquiry, although the wife of one member, whom I met by chance, averred that her household had “gone organic” for meat early in the BSE epidemic. I asked Professor Krebs soon after his appointment to the FSA about his reaction to the unfolding BSE epidemic. He had no reservation in telling me that he had abstained from beef for a while and he endorsed the corresponding precaution to remove beef from school meals. We would like to retrieve the missing information from the BSE inquiry- possibly by resort to the procedures of the Freedom of Information Act- but we contend that the precedent justifies statements by members of the FSA Board declaring any dietary changes they had adopted or privately advised over the last decade as a consequence of the findings and recommendations of the expert committees on matters covered by MAFF, DEFRA, DoH, FSA. Children on whom so much advice is being lavished by the FSA might be benefited by answers from their elders to the question “And what did you do in the BSE Campaign, then?”
2.6 Our research in the public interest also requires investigation of the fare and presentation in catering at Aviation House, Members of the Board and many of the FSA’s staff must have had opportunities, such as we have had, to sample ( and pay for) facilities available to attendees at the many meetings and conferences held at Aviation House; and they have occasion to make comparison with local commercial enterprises and interpretation of the FSA’s contractors (on a card supplied on the counter). We found shortcomings in information and presentation between the servery and the till of a tray of confectionery that included Mars bars, Kitkats, Twix etc. As an example we looked for information on the Mars bar label: the list of ingredients was difficult to read and there was no indication of nutrient content-not even of kcals per bar (or per 100g). Nearer the till the customer would find a tray of redeeming snacks, including little tubs of mixed nuts bearing only the FSA logo and the description “mixed nuts”. In fact, the customer was paying for no mixture of nuts, but peanuts (unsalted) with raisins. The intention was good and exemplary, but could have been improved by a more enterprising mixture of nuts and apter labelling. We found the catering average by local standards but surely and after labelling the Board could set higher standards to practice on site what it preaches to the food trade and citizens at large.
2.7 Organisations such as ours seize every opportunity to communicate with authorities and other bodies at open meetings. Some allow payment at reduced rates for charities and academics, but even then the cost based on events organised by industry or marketing concerns exceed resources that we can command. “Expenses paid” also means compensation for staff or representatives’ time and travel. Volunteers with the appropriate competence are few and far between, and fund-raising has become fiercely competitive. It seems to distract some NGOs from the purposes they should be serving as the priority. Notwithstanding our commitments in food and health we depend for survival by living off the dead. Factors such as increased longevity of potential donors and milder winters tell against survival in the colder climes of independent charity; therefore we find the FSA’s open Board meetings useful, and economical, but they could be improved by a more relaxed period for networking and lobbying with the Board’s members after, say, a buffet or sandwich-all eyed critically-subsequent to the open meeting and formal questions and discussion.
2.8 We are dismayed by the FSA’s undue attention to the evil, heavily-subsidized live/dead stock industry when the heavy expenditure on the BSE Inquiry and other official reports on the foot-and-mouth disaster, zoonotic diseases, and environmental and animal welfare and ensuing and persistent crimes in the folly of cheap food policies damn it utterly. It is an abomination of intensification for which customers-accomplices in the malpractices-are urged to reduce their demand and greed. The Board is deluded if they think that the MHS can elevate an industry of inept and untrained farmers, hauliers, market workers, slaughterers, knackers, gutmen, renderers, fellmongers, pullers-back, and bummarees-all included once in the official roster of aptly described “offensive trades”. The Lanarkshire outbreak of food-borne disease was traced to shortcomings at the premises of the Butcher of the Year, with displays to advertise the destinction. In our observations of the livestock marts, slaughterhouses, and knackers’ yards we appreciate the difficulties besetting the MSH meat inspectors and the vets, many of whom have to accept intimidation as part of the job. The notorious Roddy Crowther was eventually prosecuted for an attack on an MHS vet, who is Spanish, in the course of her duties. We understand that he was fined more for errors in the paperwork than for assault. Some slaughterers, such as Toby Baker and John Chadwicke, are influential critics in the meat-trade and its entire works. John Chadwicke is at the moment in dispute with an MHS vet over his HAS rating and his impatience with the paperwork. These are facts that should be told to board members invited to advise the public on the workings of the OTMS and the possibilities of BSE manifesting in sheep and goats.
2.9 Excuses presented at the Board meeting for problems over traceability and control elicited some concern and a wish for a prosecution or two-reminiscent of Mrs Ramsbotton’s demand for a summons after the lion Wallace had eaten her son Albert at the zoo. The MHS was in a foreseeable predicament owing to its implication in the shortcomings: the butchers were paying the MHS levy as a form of indemnity and devolution of responsibility. Labelling tobacco products with health warnings provides similar precedents as another way of lessening customers’ opportunities for recourse to litigation and objection to claims and advertising. Sales of symbols and leasing of logos are likewise approbations bestowed with risks of accessory blame if the products incur litigation between buyer and seller, and it should entail appropriate resources of policing and indemnification. The RSPCA’s Freedom Foods scheme represents monitoring rather than approval- in fact it sponsors research exposing and publishing shortcomings in its own system (for dairy-products). The RSPCA has been implicated with Tesco and Moy Park in errors, due to faulty bookwork, in monitoring of poultry-products. Such supervision is especially tricky when a farmer is simultaneously producing for “approved” and ordinary markets (as we were able to discover in the Mc Libel case). We have recently been in consultations over the EU’s border posts and their facilities and the possibilities in change-of-use and multiple brokerage as traceability falters in investigating components of our food supply and of supplements and nutraceuticals. The EU’s REACH initiative will become an increasing and controversial factor in this debate. The latest episode of withdrawals, litigation, and indemnification over Sudan Red will furnish a tragic contrast to support and responsibility the FSA provides the live/dead stock industry.
2.10 We were surprised that the council were not informed about the report just before the FSA open meeting from the VLA and VHA on an Extended-spectrum beta-lactamase (ESBL) detected in Ecoli recovered from calves in Wales. It described an outbreak of scour (diarrhoea) in calves reared on a dairy farm in the last quarter of the year 2004. Of 103 born 25 died of scour (a comparable mortality rate for human babies would be less than 1 %).The enzyme isolated is “an ESBL which confers resistance to a wide range of beta-lactam (penicillin and cephalosphorin) compounds”. The reporters conclude that “spread of this form of resistance in bacteria affecting the animal health, rendering many therapeutic options redundant. Spread is also undesirable from the public health perspective, in that the livestock population might provide a reservoir of resistant strains and genes that could be transferred to the human population”. We think this a serious omission from the attention of the Board meeting a few days later. It is certainly a farm-to-fork matter and brims with allusions to debased standards of husbandry, emphasizing again the teaching of the BSE inquiry. We cite the following factors from the report.
2.11 “Cryptosporidia, rotavirus, and sub-optimal colostrum status have all been identified as major contributory factors to the diarrhoea problem, with coronavirus also detected on the farm”. Powerful and useful antibacterial compounds are of no avail against viruses; their application in this instance indicated excessive misuse of antibiotic and undue stress on the calves and their dams, and it revives memories that the BSE epidemic originated and was maintained in the relentless (“milk of human unkindness”) dairy/beef/veal job, which is further beset by production diseases, quotas, and changes in CAP policies from which it may have difficulty in resiling. The report describes immediate measures it intends as a result of the Welsh outbreak. Does the FSA rate them apt?
2.12 Recent material on our website anticipates some of the further problems affecting dairy-farms and we shall be reporting on the counter-Herriot worship in the veterinary profession now disfavouring practice in farming (large animals), there being better prospects and glamour with pets (companion animals) and equines (many horses being used by the hunts) We heard recently of the closure of a large-animal practice serving much of central Wales.
2.13 Current changes instigated by the EU spell the relaxation of restraints on the prescription of veterinary medicines possible, which are already blatantly advertised to farmers and available on-line. Control by qualified vets and the consequent general supervision will be loosened and overuse and misuse will become likelier. There are already signs in Europe of increasing purchases; some of these drugs are applied as growth-boosters (also called performance or digestive enhancers in the procedures of metaphylaxis). One way or another, consumers perceive antibiotic resistance and residues as risks of greater consequence than the jump of BSE into sheep and goats. Has the FSA no advice to proffer on these developments?
2.14 Our warnings at the open meeting in London before Christmas on the vigilance needed over imports, especially of poultry, from the orient and the Pacific Rim and the controls at the border inspection points (BIPs), which have been under renewed consultation, seemed timely and new to the Board. These tidings referred to the spread, resistance and persistence of avian flu. We hope a useful purpose and our mission will be served by sounding another timely warning. These events draw attention to lapses in the FSA’s intelligence services and mobility of pathogens in the unquarantined arrivals and departures in international travel. The threat of terrorism lurks in this intercourse. In oriental countries trading in animal products, a massacre of about 100 million poultry in an abominable cull due to avian flu has been perpetrated. Is the FSA content that the UK’s animal population (human and non-human) is adequately protected by resources of vaccines and drugs-or by bans on imports and international movements-to counter and overcome the threats of further spread?
2.15 I had intended at the last Board meeting to concentrate on enquiries about the water industry. A recent conference in London organised by the Chartered Institute of Water and Environmental Management heard that “the pollution control system is a shambles and that nothing is likely to improve without a major injection of political well and matching funding…..” Leachate from agricultural runoff and heavy use of fertilizers are aggravating problems of pollution and environmental damage. Water is a commercial product with useful mineral content in some areas (e.g. calcium, magnesium and fluoride), as well as accessory and essential functions in good diet and nutrition. Is the FSA involved in remedying problems in the water industry?
2.16 Water is now included as a major ingredient mentioned on the labels of many foods and beverages, without indication of the content of minerals, chlorinating or oxidizing agents or organic matter; nor is the word “filtered” explained-from what and what with (which might extend to finings use to clarify beverages). The F-word for fluorination is bound to crop up as controversies in local authorities need illumination from experts such as the FSA. (We note that “natural” bottled waters provided at FSA events declare a content of fluoride. Uncertainties over fluoride contents invalidate regional comparisons of teeth and bones. Hard drinking water contributes significant amounts of calcium and magnesium to the diet).
2.17 We have contributed to many consultations on the labelling of foods (and feeds and pet foods). Single-issue zeal can neglect corollaries that need attention. For instance, the impression of many people that British salt contains essential sources of iodine, especially for populations of dairy-frees, can confuse consumers and manufacturers when the FSA is doing all it can to reduce sodium intake in the British diet (or to improve the sodium/potassium ratio). The UK is almost unique in being a major nation in which the salt is not iodised; and even in these countries subclinical hypoiodism is quite common. The NDNS survey has confirmed evidence of this deficiency in young girls- a significant observation because recommended iodine intakes should be raised in pregnancy and are essential for brain development and cognition in the offspring. A recent scan by ultrasonography of nearly 10,000 German workers found evidence of subclinical hypothyroidism in nearly 1 in 3, and 14 cases of unsuspected thyroid cancer were discovered. This procedure bids fair for application to British populations. It nicely complements urinary assays.
2.18 Veggie might has not prevailed however its Assault operations begun in our campaign for real bread and in skirmishes with Marmite soldiers over salt contents. We have been unable to persuade Marmite and own-brand manufactures and retailers of yeast-extracts to sell low-salt versions; however, the health-food trade has come to the rescue with required products and we can commend these to the FSA’s attention. Development of a taste or craving for salt probably needs as much effort as countering the satisfaction of an over-active sweet tooth.
2.19 The FSA should heed and explain the contradictory factors in intakes of sugary sweeteners. We have tried to illuminate-as Oxfam, for instance, is now doing more effectively-the reluctance of European farmers to abandon their subsidized cultivations of sugar-beet to meet the restrictions required by nutritionists in an economic world of over production and tariffs, with disastrous consequences for developing countries relying on sugar cane as a cash crop. We think the FSA should accompany its admonitions on the wider and strictures on sugar consumption with education and advice on the wider issues for conscientious consumers whose principles extend from safety to comprehensive standards.
2.20 Discussion at the Board meeting of the successor to the NDNS seemed premature because the lessons from the original project had not been assessed: Volume 5 has only just appeared and there can be few of the Board and audience who can have seen it, let alone read it. We have had an interest in epidemiological studies and dietary and nutritional surveys on general and specific populations. It has entailed establishments of collaboration, coordination, and links, as well as the value of the results on the national scale and to the individuals interested in the relevance and interpretation of their own results. Issues of confidence and ethics may clash with the NHS’s efforts at deploying all methods of IT to furnish doctors with essential information of use in the advice and treatments they can offer patients. Well-person studies carried out in some areas, with mobile facilities-as for blood donations and chest X-rays-fulfil some of these purposes. We have also considered the worth of the (expensive) BUPA offers and the prevention of national hypochondria.
2.21 We think that the Board needs longer to ponder. The following issues need consideration.
2.21.1 What action has been taken as a result of the NDNS and has it been of benefit; or has it been anticipated by steps prompted by other investigations?
2.21.2 Did the NDNS detect populations of special concern (and thus of special importance) while a national average might be reassuring (e.g. on alcohol consumption).
2.21.3 Reliance in any survey may be undermined by well-recognised under-reporting, e.g. of food consumption. Further, investigations suffer from uncertainties and omissions in the composition of food tables.
2.21.4 Genetic and cultural traits must be allowed for, The report to the Board referred to long-running surveys embracing these factors but the highly relevant Lipgene project was not included, for instance.
2.21.5 Advances in diagnostics and biomarkers (and the trio of proteomics, metabonomics, and genomics-not to mention economics) and other borrowings from the pharmaceutical industry must determine the array of data generated for interpretation in a convenient and up-to-date way.
2.21.6 The foregoing considerations and advances by manufacturers in producing gismos with potential in obtaining results from on-site non-invasive tests. Alternatives such ultrasonography can advantageously replace methods using x-rays.
2.21.7 In this context information gained from blood and urine may be usefully augmented by tests on other bodily materials, e.g. saliva, breath and feces. Such tests are already of use in forensics, SNPs can be obtained from such sources.
2.21.8 Unless numbers of participants are very large, results may be affected by significant variation of some factors during the day or seasonally. In smaller studies these changes may yield extra information, e.g. on fluctuations and abrupt changes and long-term trends.
3. Innovation and Development. 3.1 In urging the FSA to tackle the salutary opportunities in the promising links between food production and well-informed dietary trends we recognise that it has to break out of the thrall of fire brigade tasks of safety that the rottenness of the livestock industry imposes on it-and the consequent complicity in heavy disbursements of grants and subsidies that could be much better spent. The time is ripe for longer term, consideration and action, built on CAP reforms and Green Planning. This change of emphasis would engage support from a variety of well-informed interests, acting in concert, and from beneficial enterprise in food production and the quality of life (which cheap food policies and meretricious High Standards of Living betray).
3.2 Our experience reaches back to WW2 when the Radio Doctor dealt with these topics. More recently and in conditions similar to the present the popular Jimmy Young program broadcast regular contributions, usually by the editor of Grocer magazine, with comments on the food market and related topics. We moot something like a gut slot on BBC R4 with the God Slot as a Grace, perhaps. Different and provocative speakers could ginger the subject up; opportunities arise for members of the FSA’s Board, at least as an interesting expression of the purports, competence, and openness the FSA professes to offer. There must be many academics, farmers, nutritionists, campaigners, doctors, and vets with tales to tell (and need of a fee) Both Oxbridge universities have well-reviewed encyclopaedias on food to their names; surely they could provide correspondingly well-delivered opinion and illumination. The enterprise should generate a varied diet of discussion and debate-and especially interest.
3.3 Much more interest and enjoyment should be engendered, elevating the FSA to the status of a reliable partner in the enterprise rather than a monitor of sterilized gut-fill awarding arrays of dubious and highly coloured values on labelling that is uninformative or not read. We treat this as a subject requiring more than leads from celebrities hired from public relations agencies, but rather discourse from interesting exponents of the many aspects of bromatology (to use the appropriate term). These would complement (or replace) the endless stream of cookery articles and programs, as well as bland, uncritical, and un-objective coverage in the media. Most importantly, they would amplify courses in schools on citizenship and raise the unalloyed enjoyment of food.
We have set out a full response because our requests for individual interviews with FSA representatives with “common interests” have been rebuffed and our offers for an exemplary shopping expedition have been refused. With our long experience in matters of farming, food and “well fare” it is hardly surprising that the limited opportunities at the open meetings are inadequate for a full expression of our views.