VEGA's reponse to the FSA consultation
1. Assessment of all the combinations and permutations of compounds and their residues used in farming and food production (as well as exposures to these substances of workers – and their families and partner – handling chemicals used on crops grown for manufacturing and biofuels, in the UK and imported) is an enormous enterprise yielding questionable results at heavy cost. The penalty would be borne by the consumer; the toll exacted on animals, fish and birds in experimentation and testing must be costed as well. The cocktail effects of the various combinations and permutations would redouble the need for testing the tests for the effects of interference and interactions.
2. Extended testing would have to comprehend the effects of metabolites at the various plow-to-plate and stable-to-table stages of production, as well as the methods of storage and preparation of the food (and feed), substances such as mycotoxins, nutrients and other components of plants and meat, milk, fish and eggs that may add complications, induction of physiological processes and by synergetic action. Appreciation of differences between breeds, species and increasing knowledge of genetics is needed.
3. More stringent pharmaceutical testing (some of the present work is not available to the public) must amplify the volume of data to inform practice of the precautionary principle and to extend the design and interpretation of protocols and the results of epidemiological studies such as the EPIC survey and proposals for the Bio Bank (and similar enterprises in other countries. Present controversy between Europe and the USA (and some other major sources of food and industrial crops) over the use and alleged misuse of veterinary drugs and production illustrates the size of the toxicity problems that can arise even at a restricted level of apparently well-informed scientific monitoring.
4. We have been urging the FSA, in collaboration with the DoH and others, to ‘mine’ every last scrap of evidence from epidemiological and pathological studies and we’ve made suggestions from our own experience for the desirable protocols and collation storage of pathological samples, and revival of post mortem examinations in health services and availability of stored specimens for retrospective surveys.
5. Selected populations for certain purposes have been studied. For instance, the MAFF’s shopping basket survey concentrated on nitrates in vegetarian diets; groups with varied dietary aversions have yielded useful information, eg Seventh Day Adventists, Jews and some ethnic groups and sufferers from food intolerance or allergies. Muslims have been selected for studies on BSE, scrapie and VCJD because they consume above-average amounts of mutton (ie from cast sheep and goats) than the normal population. These studies offer biological materials, obtained without violation of the Islamic principles, of wider significance.
6. Many of the suspect chemicals distribute in fat rather than water (ie they are lipophilic or hydrophobic) and residues accumulate in fatty foods and at the top of predatory levels of consumption; therefore the fat in breast-milk is an easily available source of material of biological significance for many reasons for monitoring.
7. Education preparing children and adults in the realities of good citizenship and the cost of consumer choice is needed urgently. Cheap ‘safe’ food doesn’t come cheap.
Dr Alan Long