Standards, Decision, and Determination -
Is the Food Standards Agency well advised? Do its stakeholders and consultees perform useful functions, especially to the consumer, in the standards for Salutory Food from Salubrious Farming? As vigorous participants ourselves in these functions we provide observations in the interests of animals of all species (including humans), wildlife, and the environment. VEGA comments on the Food Standards Agency’s (FSA) consultation 'FSA's Approach to Regulatory Decision Making'.
Our status and interest in these matters follow from the content of our website www.vegaresearch.org and from correspondence and consultations, with repetitions and reiterations, with the FSA, DEFRA and other departments and agencies.
1. Our opportunities for written consultations with the FSA are governed by the effect – as an NGO and registered charity – that our resources, based on research and a data base we are compiling for the use of other organizations, journalists etc., allow us to hold our own in these contexts. We therefore need access to the literature and libraries equivalent to the facilities of an academic institution. Our researchers are graduates and deserve more help in acquiring academic status. Such facilities are available off-site for accredited members of some institutions. The FSA could improve the value of consultations and the work of research-dominated NGOs by offering help in these matters; it may also be able to extend the range of facilities for its own staff. The librarians at Aviation House are very helpful, but their services are of less use for researchers living far from London or the site of similar libraries. Learned and professional societies, as well as universities have appropriate on-site facilities and the British Library is useful.
2. Our pedigree from the post-war Vegetarian Nutrition Research Centre, and various activities in charitable organizations with common interests in farming, food, health, and the land (and thus in animal welfare – of all species – and the environment), led to our involvement in the inception of the Food Standards Agency with the James report and the subsequent procedures to achieve enactment of the Bill and instigation of activities. We emphasize our pleasure that the comprehensive view of standards, rather than restriction to safety, demonstrated the purpose of a holistic plow-to-plate, farm-to-form concern that we are wont to express as Salutary Food from Salubrious Farming, informed by a rigorous scientific analysis and driven by research, information and campaigning. We are independent of commercial involvements or funding. We volunteered much advice and testimony for the defence in the McLibel trial, which resulted in success in that part of the judgement in the defendants’ favor. We have consistently warned the FSA to appraise the strengths and weaknesses of the consumers’ testimony to it, which can be superficial and swayed by questionable information in the media, and from organisations compromised by commercial complicity in ventures such as sales of symbols and leases on logos. The FSA must also deal with manufacturers and retailers, who are much better organized, financed, and informed, and enjoy support in one way or another from government grants and favor – than consumer groups. The S for Safety and fire-brigade considerations tend to dominate spatchcocked Standards in these circumstances. The FSA’s response to the last foot-and-mouth disaster and the lulling of some concerns from consumers have not been matched by accounts of overhaul in an industry riddled with wheeling and dealing, stress to livestock, and heightened risk of infection that could recur with familiar or new challenges. Warnings have been ignored.
3. Stringalongs suit NGOs with limited or very recent existence but without the means for research or full appreciation of current issues and debate. Stringalongs (umbrella) groups are dominated by the lead players in the ensemble enlisting general support for the causes that exercise them most and for which an accretion of support would usefully increase their apparent influence. Members of the stringalong may have little voice in deliberations in the main policies nor will it sound out in the opportunities the leaders of the orchestrated group manage to secure in specialized sessions with the FSA. Parallel situations arise in workplace politics. For the lesser players their tacit fate may be taken as support or compliance for the main themes smaller in commitment than the tally of complaints appears to suggest. Participants are expected to sign on to petitions they have no time to peruse, let alone debate. This is akin to 1st-past-the-post democracy but alien to the FSA’s purports for entertainment of individual issues that may be submerged in debates in which polarizations intensify and in which the enormous farming and food industries can put on a full orchestra that even an ensemble of minor players can hardly match, let alone a soloist bursting to play or sing a good tune in a key and setting that suits his instrument best.
4. The more dedicated players can take their chances at open meetings (where they may be in competition with prominent representatives of the stringalongs, who have already had their turns with individual meetings with FSA officials, exercising their various influences) or by taking on the more onerous tasks of consultees and stakeholders, for which NGOs have to employ staff (unless they can enlist competent volunteers) and maintain a database (ours is open for use by other organizations, researchers, authors, the press etc.). The cost in time and expense for such services intended to contribute to the FSA’s purposes, as well as to the general good, almost beggars a small and independent charity such as ours with variable and always inadequate funds. (Some of the stringalongs appear to enjoy financial support from national and local authorities, as well as academic facilities and contacts with the press. Some other NGOs and charities bask in the benison of commercial sponsorship of some sort.
5. We have made various suggestions to the FSA on educational and media efforts at engaging an objective view of bromatology – the science and tradition of food production and consumption and introducing new concepts, e.g. nutrigenomics. On the BBC’s programs a Gut Slot in the form of the God Slot would call for varied contributions, without a celebrity as interviewer, somewhat after the style of the objective market reports run on the Jimmy Young program. The FSA would submit suggestions for speakers, particularly from relevant academic departments covering the history and development in the whole range of the FSA’s recycling plow-to-plate purview. It would nicely complement the Farming Today program and balance the superficiality behind many series in media devoted to the final few stages of this enormous subject. The style would resemble more the Economist’s standards than the tabloids’.
6. We have also commented on the range of consumer issues that occupy members of the FSA’s Council and what engages their purchasing and catering for special needs and indicate their proficiency and probity on the Stock Exchange other than their familiarity with the goings on at Livestock Marts and developments in the markets for fruit, vegetables, and fish. Surely some must have had some dealings with diabetics, celiacs, vegetarians, organics, and anti-GM campaigns that have significantly affected their perspectives and should be declared in their CVs and official statements and declarations; compare the information required of witnesses testifying to the BSE Inquiry. Prof. Krebs had no hesitation in answering our enquiry to him in this vein and he volunteered information on his wife’s attitude, acting as a school governor, on bans on beef in school meals at the height of the epidemic. These are communications of commitment and self-discipline when experts are bereft of the revered scientific evidence and consumers are left for their judgements to the example of scientists respected for making reliable subjective assessments and proffering guidance to politicians.
7. We have been disappointed at the rebuffs we have had in requesting representatives if the FSA to join in study on-site in a retailers’ interests for shoppers in matters of labelling and background to the goods they may choose to buy, exercising principles that we expound in many representations and consultations to the FSA, DEFRA, FAWC etc.
8. The FSA must overhaul its commitments to attract more representation on all level from the HACCP-immune factory floor of farming to the corollaries in animal health and welfare (human and non-human), wildlife, and the environment. At the moment it is setting fuzzy targets, benighted in the blite of evils perpetrated by the live/deadstock industry and the ineptness and partiality of MAFF. The FSA in ite present assessments would do well to measure the degree of commitment it has received in responses to its consultations and attendance at meetings. In our experience many otherwise vociferous organizations are content to remain mute and lethargic in these contexts and on relevant issues. We know that some agencies such as the FAWC have direct assess to the FSA’s senior staff, but NGOs and charitable organizations are poorly represented at open meetings of the Council (which are webcast) that call for their input. These occasions cost a lot. The FSA must now berate the indifference of organizations professing the wider interests; otherwise the food industry will continue to excuse the true cost of falsely cheap, subsidized food on the supposed reluctance of customers to count the environment, animal welfare and world trade and imbalances as standards worth paying for.