The Royal Society of Edinburgh is pleased to respond to the Scottish Office's request for comments on the White Paper "The Food Standards Agency - A Force for Change". The RSE is Scotland's premier learned society, comprising Fellows elected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. This response of the RSE is based on comments received from a small number of our Fellows with research expertise in food science and nutrition.

The decision to create a Food Standards Agency is to be welcomed as a positive step towards the integration of research and surveillance on food. There is no doubt that recent events, relating particularly to BSE and E. coli (0157), have greatly undermined public confidence in the safety of our food. The existing mechanisms and the role of MAFF have not proved to be adequate, and MAFF's dual role has led to the perception that it is unable fully to represent the interests of consumers and the wider public. The sheer scale of the proposed Food Agency, however, carries with it considerable risks similar to those encountered by MAFF. The agency will need to be careful not to find itself compromised in the way in which MAFF was perceived to be in the past.

Most recent concern has focused on immediate issues of food safety and it is important that this is seen as a critical part of the agency's role. If it is to fulfil its role properly, the Food Standards Agency must be seen as entirely independent and that is clearly the Government’s intent.


As a learned society whose Charter aim is "the advancement of learning and useful knowledge", one of the RSE’s major concerns is the remit of the agency to commission research. Over the past 10 years there has been increasing confusion over the remit of MAFF, BBSRC Food Directorate, the Department of Health and the MRC in the commissioning of research related to food. The MRC has declined as a major organiser of research on nutrition and on food-borne pathogens. It is essential for the future that there is a clear strategy in these agencies to commission research and the funds to enable it to do so. In general, the BBSRC and MRC are the best equipped to further the fundamental studies on food-borne micro-organisms, pathogenicity and the relationship of diet to health. These two agencies have done a remarkable job under difficult circumstances but have been undermined to a significant extent by the commissioning of "applied research" by MAFF and the DoH, who in turn went through a period of de-commissioning "near market" research. The problem with "applied research" is that to get the best quality, one needs to engage the interest of the top scientists in the country. This same group is often reluctant to engage in "applied research" because the funders place rigid restrictions on how it should be developed. In addition, the concentration on "research quality" (through devices such as the RAE in Universities and the Visiting Groups for Research Institutes), has meant that staff consider too much "applied research" will jeopardise their career prospects. It might be better to commission short-term surveillance and "fire-fighting" research from the independent Food Research Associations. This is a fundamental issue facing the Food Standards Agency since one needs a good scientific opinion in support of any change in policy. This means that we must encourage the best scientists to have a real interest in the problems posed by food.


A particular issue to be given priority is that of provision of information and education to the public on food matters. The increasing usage of convenience food provision has far outpaced the ability of the public to perceive the changes in their own responsibilities. In the past, conventional foods required conventional cooking, which had built-in considerable safety margins in the killing of food-borne micro-organisms. Convenience foods are designed to have a relatively short shelf-life and frequently require minimal preparation and cooking. This change may be one of the most frequent causes of domestic food poisoning. A clear understanding of the significance of sell-by dates, use-by dates and storage conditions (shop and home) will be essential to the future reduction in instances of food poisoning. For example, the extensive use of microwaves for cooking post-dates the completion of any traditional education of good hygiene for the majority of the population.


The proposal to include nutrition within the remit of the agency has been somewhat controversial but the arguments for inclusion are strong. Ultimately, nutritional quality should be a central goal - indeed the key driver - of the food chain and it is therefore important that nutrition is integrated into the work of the agency. Nevertheless, issues relating to nutritional quality are often controversial, or open to serious debate. It is therefore important that the agency takes a prudent view in relation to nutrition based on proven science, if it is to obtain consumer confidence in this area, and indeed the confidence of the various components of the food industry. The recent changes of advice about "safe levels" of meat consumption provide an object lesson in how not to inspire confidence in so-called "food experts".


The proposal to fund the agency in part through a licensing system appears somewhat awkward andbureaucratic. Whilst we understand Government's reluctance to increase expenditure through direct taxation, the costs as proposed are likely to be largely passed on to consumers. We would take the view that funding from industry, albeit through a licensing system, is not the best way of ensuring that the public view the agency as completely independent of commercial interests. It also means that the costs thus passed on to the consumer will bear more heavily on many people less able to afford them.


Lead responsibility
The concept of the Health Minister taking the lead role and being the main line of accountability is entirely appropriate for an area which is fundamentally that of human health.

Industry representation
In order to ensure public confidence it is important that industry representatives - broadly defined - should be in a minority of the membership of the Commission. Members must have appropriate professional expertise and not simply be representative of various pressure groups. People should ideally be appointed on the basis of their personal qualifications and experience rather than as representatives of a particular sector of the market.

Technical support
Section 3.24 of the white paper described the requirement for the agency to have its own technical support. Given the large number of Food Research Associations, research institutes and governmentlaboratories already in existence it may be in the best interest of the UK that more use is made of independent food research agencies and institutions for provision of such technical support.

The proposal for the FSA to be located in London is clearly necessary in order to ensure close liaison with the appropriate departments. Nonetheless, Executives in Scotland, Wales and Northern Ireland are clearly also essential, particularly given the current moves towards devolution.
March 1998

Further information is available from the Research Officer, Dr Marc Rands


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