Response to the FSA Draft Science Strategy 2005-2010 Public Consultation

Submitted on behalf of IFR by
Prof David White & Dr Nick Walton

August 2005

The Institute of Food Research (IFR) is an independent research organisation, with charitable status, sponsored by the Biotechnology and Biological Sciences Research Council (BBSRC). IFR’s mission is to undertake international quality scientific research relevant to food and human health, and to work in partnership with others to provide underpinning science for consumers, policy makers, the food industry and academia. IFR’s research programme reflects an appropriate emphasis on food safety (particularly microbiological safety) and on nutrition, diet and health, and including the determinants and effects of consumer behaviour. It also includes research to assess and develop novel foods and processes, together with fundamental science and analytical technologies underpinning the assessment of food safety (notably issues associated with potential applications of GM technology), food origin and food authenticity. Much of IFR’s research programme is therefore strongly relevant to the research requirements of FSA in the areas of food safety, nutrition and food choice and IFR is a major contractor to FSA; the annual value of contracts is approximately £1.2M. IFR welcomes the opportunity to respond to FSA’s Strategy Consultation.

In our Response, we have followed the layout of seven questions outlined in the consultation details publicised on the FSA website.

1. “Drivers”

i. Food safety: food-borne illness

We concur with the drivers that are identified in the consultation document. Three additional drivers that we consider to be important are: i) the global sourcing of perishable foods, particularly poultry, meat and fish, but also of other foods that can potentially pose an appreciable microbiological risk including, for example, organically grown and/or pre-prepared vegetables; ii) the implications of animal-husbandry and animal-welfare practices (including stress management) for the level of microbiological contamination of poultry and meat; and iii) the ever-present potential for the emergence of newly-adapted and/or more virulent food-borne pathogens.

ii. Food safety: TSEs

No additional comment.

iii. Food safety: chemical and radiological risks

See comments in 2.iii) below

iv. Eating for health

It is difficult to overstate the importance of the future national health and economic burdens of obesity, cardiovascular disease, diabetes and diet-related cancers that will occur if present trends persist.

There are broader, closely-associated drivers: the need to raise public awareness of the requirements to plan ahead (not least, financially) for later life; and the need to promote the general health of an ageing workforce (particularly important given the financial pressures on pension provision and the consequent upward trend in retirement age).

v. Choice

This is (and needs to be) associated with “Eating for health” above. A principal driver is therefore the promotion of informed dietary choices to promote (or at least not undermine) health; this includes choices to avoid foods that can cause an allergic or intolerance response in an at-risk individual. Furthermore, accurate labelling of origin and content is vital both to ensure that consumers can make appropriate choices, particularly according to ethical or religious requirements, and as part of measures to prevent misrepresentation and fraud.

vi. Underpinning delivery

We agree with the drivers identified and with the general need to ensure a level of monitoring and scrutiny that is commensurate with the risks and costs involved.

2. Existing and emerging issues

i. Food safety: food-borne illness

Please see comments on “drivers” in 1.i) above and on “evidence requirements” in 3.i) below. We would also note the risks of bioterrorism mediated via microbiological contamination of the food supply (cf. iii) below).

ii. Food safety: TSEs

No comment.

iii. Food safety: chemical and radiological risks

There is a continuing need to ensure that appropriate quality and authenticity standards are maintained for all materials that come into contact with foods; besides straightforward adulteration, the acknowledged global problem of counterfeit drugs and manufacturing in the pharmaceutical sector potentially has implications for substances used in food production or packaging. As indicated in the consultation document, more widespread recycling practices could also create additional risks.

We note (para. 32) the risks of deliberate chemical or radiochemical contamination of the food chain (cf. 2.i) above).

iv. Eating for health

Individual and social attitudes to diet-related or self-induced ill-health or disease are an emerging issue and will be an aspect of any strategy to deal with the problem. A related issue is the reversibility of diet-related ill-health and disease: what are the mechanisms – biochemical, physiological and psychological – that may tend to maintain the status quo (habituation) in an affected individual and how can these mechanisms be subverted or overridden? How do these mechanisms vary between socio-economic and ethnic groupings? To what extent is a diet-related health problem definable or soluble as one of diet alone and to what extent is it associated with other cultural or socio-economic factors?

v. Choice

We agree with the issues identified; however, there are distinct mechanistic questions associated with food allergy and intolerance that should arguably be addressed cross-theme (i.e. in partnership with “Eating for health”).

vi. Underpinning delivery

We agree with both the issues identified, particularly with the implications of the internationalisation of the food supply. The highly-competitive global market has serious implications for the competitiveness of UK-produced food, for the maintenance and improvement of standards in UK production and for the importation of foods that may not conform to UK standards. (For example, controlling the incidence of Campylobacter in UK-produced poultry will not fully address the issue of campylobacteriosis if there is an increase in contaminated imports.)

3. Evidence requirements

i. Food safety: food-borne illness

We would emphasise the vital role of mathematical modelling approaches in understanding and predicting the incidence and spread of food-borne pathogens and the effectiveness of measures to eliminate or control them. These approaches should also take fully into account inter-strain variation and genetic instability, notably in Campylobacter.

It is of course vital to ensure that high-quality data are collected, using robust sampling procedures and skilled expertise. Maintenance of the resourcing and skill-base of the HPA and NHS laboratories is particularly relevant in this regard.

ii. Food safety: TSEs

No comment

iii. Food safety: chemical and radiological risks

We would agree with the evidence requirements outlined, but clearly there is a need to ensure that the level of expenditure is justified by the estimated level of risk. Whilst chemical and radiological contamination requires constant surveillance, particularly with regard to serious toxins (e.g. aflatoxins), vulnerable groups in the population and the possibility of a sudden outbreak or “food scare”, negative effects on health and well-being are thought to be quantitatively minor, especially in relation to food-borne or diet-related disease. However, the potential toxicity of new materials, used for example in packaging, or of new processes, must be realistically and stringently assessed.

iv. Eating for health

Understanding the mechanisms behind the alarming rise in diet-related disease must continue to be a principal science priority, to be addressed by complementary approaches focusing particularly upon: i) the aetiology of diet-related disease, its prevention and reversal (encompassing also epidemiological and nutrigenomics methodologies); and upon ii) the behavioural and socio-economic determinants of dietary and lifestyle choices. Understanding mechanisms (including molecular mechanisms) of habituation and how they might be overcome lies at the interface of these two areas.

There is an urgent need to develop improved biomarkers of intake and status in order to determine the health implications of the low micronutrient status/intakes that are observed in some population subgroups (para. 48).

Whilst providing information on nutritional content is important in allowing consumers to make informed or rationalised choices, dietary choices are certainly not based on nutritional information alone. We believe it would be undesirable if survey work in this area were to be funded at the expense of research to establish mechanisms.

v. Choice

We agree with the evidence requirements that are outlined under this section (noting again the close relationship with “Eating for health”), in particular the need to understand the mechanisms of food allergy and allergenicity in order to develop new intervention strategies.

vi. Underpinning delivery

Para. 68 implies that it is the work of enforcement laboratories that will provide evidence on mictobiological (and chemical) risks, particularly from imported foods. It is important to recognise that the detection of microbiological contamination is governed by the proportion of samples that can be tested and that in practice such testing may only detect batches with a high proportion of contamination. Furthermore, there is a need to recognise that evidence concerning microbiological risks, and the introduction of systems to prevent these risks, depend upon observation of the conditions and practices used throughout production of the food.

4. Strategic aims

We agree with these aims, though we would question whether these are “strategic” in the sense usually understood. Para. 80 states: “The Agency has research management procedures to support the 5 aims of our science strategy.” In effect, though, Aims 1-3 are also statements of research management procedures, whilst Aims 4-5 are statements of management procedures for the dissemination of research outcomes. The Strategy document therefore appears quite strongly weighted towards generic Agency procedures and mechanism and rather less strongly towards the Agency’s six Themes (discussed under 1.-3. above), which represent the true outcomes of the Agency’s work.

In our view, the Agency has been very innovative in its engagement with stakeholders and with the wider public, for example in its practice of holding open Board Meetings, and has built up a strong reputation for the quality of its procurement and management practices. The Agency has played a very valuable and conspicuous role in promoting high standards of awareness of the importance of quality control, notably in sampling procedures and in data handling. To a large extent, therefore, we would regard the Aims outlined here as part of the practice that we have come to expect from the Agency.

5. Future initiatives

We broadly agree with the initiatives outlined, though we would also reiterate the comments in 4) above. In addition, we wish to make some specific comments.

We welcome the initiatives for closer working with BBSRC, with NERC, with DEFRA and with DoH, and with EFSA and European national agencies (paras. 84, 91-93). However, it is essential that a coordinated strategy is agreed between FSA, DoH and DEFRA, such that each agency takes responsibility for appropriate food-related areas, that between them they cover all the important public health issues, and that progress towards agreed targets is monitored. An appropriate cross-agency Board could take on this responsibility. Collaborative ventures with research councils and the EU are a welcome expansion of the remit but should be considered as a separate activity that would fall under the umbrella of the overarching cross-agency agreement. Consideration must be given to the added burden of dual reporting and differing financial and other contractual agreements.

We also greatly welcome the initiative to review and improve the procedures for the identification of priorities and the allocation of resources (para. 85). There is at present a lack of transparency with regard to identifying priorities for scientific evidence required. The involvement of contractors/potential contractors (usually national experts) inevitably gives rise to potential conflicts of interest. The Agency obtains advice and reviews, or input to priority-setting, from a community of contractors/potential contractors who are in competition with each other and are actively seeking funding from the Agency. This is promoting a growing disquiet in academic circles and is leading to a loss of credibility. Whilst the two arms of FSA (funding and policy) continue to be managed as a combined entity, this unsatisfactory situation cannot be resolved. One solution would be to separate the funding activity and adopt a system similar to that used by the Research Councils. Furthermore, (re also para. 124) it is important that Intellectual Property Agreements are introduced at the proposal submission stage (as practised by BBSRC Committees). At present there is nothing to stop programme advisors/managers from identifying desirable components from more than one proposal and suggesting changes to the preferred contractor such that they are incorporated into the final proposal. The emphasis on “value for money” is another driver for such a practice.

6. Indicators of success

FSA is successful if it is contributing authoritatively and effectively to the safety and quality of the UK food supply, to the promotion of health through diet and to a reduction in the incidence of diet-related disease; and if it responds rapidly, effectively and proportionately in the event of a “food incident”, ensuring that the response is not out of proportion to the risk.

It is important that the Agency has in place good communication practices and acquires evidence that these are effective (for example, in the communication of food-related risks, a field in which good experimental evidence and evaluation is still largely lacking [this relates to para. 154; also to para. 114, relating to consumers’ representation on scientific committees]). On the other hand, excessive regard for indicators of success per se, particular if these are essentially process- and mechanism-related, could lead to a culture of surrogate values where success against the real objectives outlined under the “drivers” becomes insufficiently recognised within the Agency.

7. Balance of the science strategy

It is difficult to comment on the balance of the strategy as outlined in the consultation document because (apart from para. 90) there is little indication of relative priorities. Furthermore, and surprisingly, there is no indication of projected spend in relation to each of the “drivers”. In our view, this is a significant omission that will detract from the value of the consultation exercise.

Finally, we would point to the continued and vital importance of research in support of the Agency’s mission. The Agency rightly makes use of a number of evidence streams in support of its strategic objectives. However, in our view, a defensive impression is conveyed (para. 89: “We can obtain most of the scientific evidence we need from the peer-reviewed scientific literature. In cases where the evidence we need has not been published, we may choose to fund research or surveys to address that need.”). Is research a tool of last resort, or an integral part of the Agency’s vision to improve the safety and quality of food and to increase and promote standards of dietary health?