Response from the
Welsh Agri-food Partnership
Organic Strategy Group
Prepared by Organic Centre
(
to the Food Standards Agency consultation on
Food Standards Agency=
draft Science Strateg=
y
2005 - 2010
http://w=
ww.food.gov.uk/news/newsarchive/2005/jun/scistrat
1. In the Forward Look section of the doc=
ument,
we have set out the main drivers behind the research and survey work=
we
propose to carry out in each strategic theme. Do you agree with these drive=
rs
and what others, if any, would you wish to see included in the strategy?
Food safety: food=
borne
illness
A reduction in food b=
orne
disease is clearly important, but we would like to see some proportionality=
in
risk assessment carried out on procedures required – for example
procedures needed in abattoirs slaughtering hund=
reds
of beasts from different sources in one day will be very different from a s=
mall
slaughter house processing a few each day because the likelihood of disease
will be very different but more particularly any breakdown in procedures wi=
ll
have a vastly different scale of impact.&n=
bsp;
See also comments on paragraph 65.&=
nbsp;
Chemical and radiological risks
27. We strongly conte=
st
the assertion evidence exists to suggest that ‘risks to health are
low’ – these impacts may be of a long-term nature but may be ve=
ry
severe – we do not know at this stage.
28. This paragraph re=
lies
on assumptions on what are ‘harmful’ exposures to chemical
contaminants in foods, and knowledge of ‘unsafe’ levels of
chemicals. We argue that the =
health
impacts of mixtures of residues of agrochemicals are unknown and should be
presumed to be unsafe until proven otherwise, and the driver should focus on
avoidance of residues.
Eating for health
We are strongly in fa=
vour
of work in this area and would like to see a greater focus on food for
promoting good health.
We would particularly like to see greater emphasis on research to investigate the health-promoting properties of the greater consumption of raw and unprocessed foods. We also wish to see work on the different impacts of production methods on any health-promoting qualities.<= o:p>
Choice
51. We are strongly in
favour of urgent exploration of the nature of factors governing differences=
in
susceptibility of individuals to food allergens.
Underpinning delivery
65. We strongly agree
with the need for more quantified cost/benefit analysis to inform a
proportionate response to both the quantity and severity of risks.
2. In
the Forward Look we have also identified, in each strategic theme, exist=
ing
and emerging issues that we believe are likely to be particularly impor=
tant
over the next five years. What other existing or emerging issues do you thi=
nk
are important?
Food safety: food=
borne
illness
We consider that ther=
e is
a major factor relating to the risk of food borne illness that is overlooke=
d by
the current strategy, which relates to tolerance and immunity. We would like to see less emphasis=
on
sterility as an aim, and more investigation into the building of resistance
through low level challenges. Additionally, the issue of foodstuffs
contaminated with antibiotic resistant bacteria is one that has recently be=
come
high profile and needs research and leadership from the FSA.
Chemical
and radiological risks
30. We are
particularly interested in the effects on consumers of exposures to mixture=
s of
chemicals in food, and would like to see a major research effort into this
subject.
Eating for health
47. Education is not
mentioned here, but is the most important issue relating to eating for heal=
th
and is particularly important for economically and socially disadvantaged
people.
Access to fresh foods
– proximity to shops, including transport issues, is also hugely
important to enable people to make health food purchases.
Choice
56. We are particular=
ly
keen to see more work on this area of food allergy and food intolerance,
although our emphasis would be on prevention of susceptibility rather than
treatment. We consider food
processing methods and their impact on food intolerance to be an area of ma=
jor
importance.
Access to fresh foods
– proximity to shops, including transport issues, is also hugely
important to enable people to make health food purchases.
Underpinning delivery
67. We are very conce=
rned
about the costs of increasing regulation of food supply, and the impact that
may have on entrepreneurs and producers.&n=
bsp;
We believe there should be more work on the cost and benefit of risk
factors prior to increased regulation.&nbs=
p;
We are particularly concerned at the impacts that unequal imposition=
of
regulation on imported foodstuffs may have in prejudicing
3. We have summarised some of=
the
scientific evidence we will need to address issues that we believe are like=
ly
to be important over the next five years. Bearing in mind that the science
strategy is a high-level document and does not go into fine details, what o=
ther
scientific evidence might we require to address<=
/span>
the issues outlined in the strategy or any additional issues you have
identified in answer to question 2?
Food safety: food=
borne
illness
20. Work is needed to
investigate the impacts on health (seen here as an ability to resist infect=
ion
and health challenges) of sterile surroundings for babies and toddlers, and
reduced exposure to low-level health challenges in childhood.
Chemical and radiological risks
36. We are keen to see
more work on the effects of packaging on food nutritional quality, as well =
as
chemical migration and contamination issues. We urge that environmental impacts=
of
packaging be considered as part of this research effort.
Eating for health
48.
Although a presentation issue rather than scientific, we will draw attentio=
n to
our concern that an emphasis on highlighting the salt, fat and sugar conten=
ts
of foods will lead to a focus on processed and packaged goods and may lead =
to
an assumption that these goods may be more ‘healthy’ than fresh=
or
raw produce that will not be labelled.&nbs=
p;
We reiterate our view that more evidence is needed on health-giving
properties of fresh and unprocessed food, rather than the negative impacts =
of
individual processed items, which if consumed rarely will have low or no he=
alth
impacts.
We agree that work on factors influencing
people’s food choices is very important.
Choice
59. We do not concur that a k=
ey
aim should be harnessing emerging technologies to resolve difficult food
authenticity issues. Our focus
would be on greater transparency in the food chain and labelling claim
enforcement.
We
would, however, be keen on emerging technologies having a role in detecting
variances in production, storage, processing and packaging methodologies on
food nutritional quality.
Underpinning
delivery
We agree on the
importance of work on costs and benefits associated with different areas of=
FSA
activity.
4. The last section on achiev=
ing
the aims of the Agency’s science strategy also sets out five main
strategic aims. Do you agree with these aims and what others, if any, would=
you
wish to see included?
The aims are reasonable, however we would like to highlight the risks
associated with decisions based on information from academic experts and
research contracts which we consider are increasingly the product of
funding-lead research, therefore producing an inherent technology-focussed
bias.
Th=
is
issue impacts on the Strategic aim 2: Obtaining scientific evidence, and the
emphasis on evidence from peer-reviewed scientific literature. The literature is clearly valuable=
, but
does reflect research spend. =
We are
concerned that absence of evidence is sometimes interpreted by the Agency as
evidence of absence.
5. The last section of the
science strategy also sets out initiatives that we intend to take over the =
next
five years. These will supplement our current initiatives and aid us in
achieving the strategy’s five main strategic aims. Do you have any
comments on these initiatives and are there any other initiatives that you
think we should be taking?
These initiatives have our support.
6. The strategy lists indicat=
ors
that might be used in five years' time to establish if we have successfully
achieved the strategic aims. Do you have any comments on these indicators of
success and what others, if any, might we include in the strategy?
No comment.
7. We have tried to produce a
balanced science strategy that will support and inform both our Strategic P=
lan
2005-2010 and our wider corporate plan. Are there any parts of the strategy
where we have put too much or too little emphasis, or omitted anything
important?
We would like =
to
see greater emphasis on the health-promoting value of foods, particularly
investigation into the different values of fresh and unprocessed compared w=
ith
various degrees of processed foods.
Pre=
pared
by Sue Fowler, Policy Officer, Organic Centre