Comments to the Codex Alimentarius Committee on Food Labelling, and on the performance of the FSA
1. We are using this opportunity to object formally to the FSA’s competence to understand or represent views and research in our function as an NGO required to fulfil the purposes of our Trustees and of the Charity Commissioners. We regret that we must complain because we have been involved from the beginning - with the James Report - in the development of the FSA, and we have taken every opportunity, through responses to consultations and attendance at open meetings, to assert the FSA’s authority and confidence for the general good, as well as for particular reasons.
2. The ‘S’ in FSA requires Standards, not just perceived Safety at the end of the food chain; it must therefore comprehend plough-to-plate factors behind aversions probably different and some possibly congruent with those based on consumers’ genomes, food allergies, or religion. At a recent public conference we attended in London we managed, in competition with many other interests, to plead our arguments- that are highly relevant to labelling- without much recognition, it seemed, from the remarks of the chairperson, Rosemary Hignett, but with a glimmer of appreciation in the concluding remarks of Baroness Hayman, a Board member attending the all-day meeting. In some other countries the ‘S’ is restricted to stand just for Safety.
3. We have repeatedly requested special meetings with the FSA to inform the Agency of issues such as that arise in interpretations of vegetarianism in the UK as well as in international trade and custom, which the Codex aims at comprehending. We have cited a special meeting the FSA granted to Muslim groups, some of whom we have assisted and alerted. We were seeking similar courtesies of the FSA at which we would have the opportunity in full plough-to-plate fashion to remind the Agency of the government appointed Farm Animal Welfare Council’s repeated demands for bans on the production and sale in the UK of Muslim-style meat and poultry (halal) and Jewish (kosher); or, at least, full declaration on labels or at point of sale of the method and place of slaughter (EU trends are suggesting, rightly in our views, that this practice should be followed, in the pursuit of traceability, on all products from killed animals).
4. Current emphasis on advertising to children must include attitudes in schools and institutional catering where the pressure on prevailing majority practices intimidates or overwhelm exposed and shy children at meal times. From our experience the vegetarian child, imbued with ethical views that are easy to deride or disrespect, suffer forms of rejection or harassment with nutritional consequences, some going as far as inducing anorexia. Teachers must be alerted to translate the wetter of dietary advice with regard to those of their charges whose conduct and emotions deserve sympathy just as understanding as is devoted to children governed by religious doctrine or by the effects of food allergies or intolerances. Vegetarian tendencies, sometimes with parental support, overtake many children up to the age of adolescence. Compensatory consumption for loneliness may on the one hand render them more susceptible to the lures of advertisers or feelings of rejection may conduce ultimately, and with other factors, anorexia. This issue could well be raised at the Codex meeting as it affects other countries and cultures.
5. Some other issues requiring special attention relate to the definitions and confusion over labelling, approvals, logos, and symbols for customers, manufacturers, and retailers attempting to serve a well-informed vegetarian constituency. Our website protests the importance of this.
6. At the meeting chaired by Rosemary Hignett she declared an intention to discuss vegetarian and related issues, indicating an opportunity that afternoon. Two of the audience in the morning read out statements but did not stay until the afternoon. A speaker from Sustain to which we are affiliated arrived to deliver scornful (and applauded) rating of the FSA and its general performance; then she left. The afternoon’s opportunity was not sharply focused. A representative from an Indian vegetarian society propounded definitions that indicated ignorance of European dairy-farming and egg production and of all the evidence compiled by us and others (e.g. by the scientists at Reading University) of the relentless ill treatment they entail. The RSPCA has published independent veterinary assessments that it has sponsored condemning the husbandry behind products bearing its Freedom Foods logo: standards for (pasteurised) safety don’t always match those for welfare. We are correspondingly suspicious of any messages on these topics that the FSA utters here or elsewhere. We have little confidence in its authority on definitions, claims, and labelling.
7. We have already informed the FSA of difficulties experienced by independent organizations such as ours in gaining access to library material and full versions of refereed literature attainable on the net. This is a problem besetting many researchers working outside the academic institutions and pass-worded networks, and it is attracting national and international attention. Lack of support from the FSA is hindering the assistance NGO’s like ours can render the Agency and the consumer bodies influencing it, many with no research base but unduly vociferous and persuasive. We are putting a lot of effort into a database easily accessible to all enquirers into our broad purview. We know our difficulties are shared by similar research organizations in other countries, where efforts at solutions are in hand. We look forward to news from the codex meetings over discussions on these matters.
8. The confusions, misunderstandings, and strife over GM foods and organic commodities swamp objective assessments of Standards where so little can be made of Safety and hazards of these foods on the plate. The FSA must educate consumers on the facts of production and provide labelling that well-informed customers can take the time to read and appreciate. We urge the FSA to appraise the competence of the Advertising Standards Authority, because we rate it inept in verdicts it reaches and the powers it exerts. We would like to hear of discussions at the Codex meeting comparing bodies controlling and monitoring in other countries.
9. We have been disappointed recently in FSA explanations on authenticity and reliance on logos and symbols awarded without sufficient control and policing and for undisclosed fees. These must be examined closely and steps must be taken to avoid undue confidence in them and assurance by the public; the RSPCA Freedom Foods scheme, for instance, does not connote organic standards and accepts standards of animal rearing that many welfarists could not abide. An FSA lecture on authenticity was strong on the DNA of potatoes, but told us little about the significance of a slide from the MLC of cattle of various colours and conformations but without explanation of the different purposes the customer would demand of them. It seemed odd to bring geneticists to bear on the potato when the customer purchases potatoes mainly for their qualities for mashing, baking, frying or for salads. For better or worse, CAMRA does not demand varietal information on the barley or hops in the labelling- which is inadequate in other ways- on cans or bottles of beers or lagers. Customers don’t ask for the names of the wheat hulled for their bread, and probably don’t pay much regard to the grapes used to make wines; some, however, need special information on processing agents such as finings. Results of surveys of customers’ wants and inclination to read labelling have to be judged on the manner in which the question is put and the answer recorded: prompted (or primed) questions with yes/no or scored answers are unreliable, although quickly collected and collated.
10. We find the FSA guilty of single-issue fanaticism. A recent public meeting of the Board linked sugar only with its campaign on obesity and foods and advertising directed at children. The dangers of sugars to children’s teeth remain but were ignored and the place of fluoridation, a nutritional topic now devolved on to lay councillors claiming no competence on this matter, was ignored. Standards of food supplies should engage the attitudes and attentions of economists, politicians, and taxpayers on the whole issue of the production of sweetening agents and farming subsidies; environmentalists should be enlisted into condemnations of sugary abominations for the packaging and litter their sale entails; and animal welfarists should be alerted to the additives to impart cosmetics effects (such as colour and texture) that have been tested by avoidable experimentation on animals. Children should be persuaded by education and example by adults, rather than by overdue zealotry. For major parts of the food and advertising industries the FSA’s mission must seek every concerted means to set the sales curve downwards.
11. The recent public meeting of the Board in London attracted a large audience, which was augmented by facilities for interactions from people engaged in the discussions through the Net. However, the chairperson of the public debate prematurely halted the proceedings 20 minutes short of the advertised time. Participation was lively up to then, but no apology was offered. Opportunities for buttonholing individual members, e.g. during the breaks or at the end were few, and some of the members, continuing discussions among themselves, inhibited introductions to the public who had bothered to attend. We hope all requests for focused meetings and for more opportunities for debate after Board events will be more sympathetically received.
12. From our observations at public meetings the FSA has not yet developed a competence in the assessment of standards that we would rate adequate by international criteria. At an open Board meeting in London on 13 March last year the members were presented with a poorly researched report from the secretariat on the use of nitrofuran drugs in food-animal production (in which several Board members have connexions at various stages in the food chain). Queries over the usage of these drugs arose, could not be answered and aborted. There must have been several in the audience with experience of these issues who could have instructed the Secretariat then and there how to gain the required information before the Board had ended that item on their agenda. Again, we think the FSA is denying itself expert knowledge and advice from independent research bodies among the NGO’s; and the Board of a big company in the industry would demand better service and intelligence. Judgement of the quality of consumer views needs much more attention. We noted signs of this objectivity at the last open Board meeting in London; we hope this aspect will be reviewed at the forthcoming Codex meeting.
13. Space on labels is increasingly under contention and territorial stake holding is not necessarily managed in the fairest way for consumers, whose concern may range from necessity through mild curiosity to no interest nor time for most of it. Heavy legislation requires data that is almost illegible at the point of sale and may be obscured by stick on labels concerning price adjustments etc. Traffic through supermarkets, for instance, is seldom hindered by customers scrutinising labels and most could not interpret the objective details, anyway. These observations apply to sales of pharmaceuticals and household goods, as well as to foodstuffs. Labelling on clothing offers useful comparison and appraisal for its practicality. Vegetarians are a population for which information on labels is more-than-average interest: manufacturers’ and sponsored assurances of suitability and even approval are in many instances denied in the small print describing ingredients; and on many goods manufacturers’ protective disclaimers (for their own good) overegg warnings and restriction of choice for customers with perceived dietary aversions and intolerances. Global validity may prove too forbidding in local contexts.
14. We have recognised these challenges since well before the launch of the FSA and have promoted an example set by the Body Shop for sales of their cosmetics: customers with more than a passing interest in what’s on the label can refer in the shop to a dossier of detailed evidence that accommodates almost all enquiries, many of which go beyond the knowledge of the staff at the counter.
15. Advances in IT and in requirements set by authorities emphasise the practicability of such systems, which would also circumvent obstruction on disclosure of manufacturing practice and procedures and traceability. Bar-coding and in-store modems and facilities for printing out would facilitate release of specifically required information in full. It is surely a system that the FSA should further in the interests of the consumer and it would stimulate and educate an informed demand on retailers.
16. To illustrate some of these points we have offered FSA officials a visit to a big food-outlet to see what use vegetarians make of labelling information and what is lacking. Such suggestions are also implicit in consultation replies we offer DEFRA and the FSA, and FAWC as well as in representations to the industry. We hold such an offer open for realization before the codex meeting in May.