In our Response to the draft London Food Strategy in July 2018, we devoted a section on the threats to the safety, assurance and integrity of our food supplies — to which we owe the Association of Public Analysts our grateful thanks for their contribution to it.
I’ve replicated what we said below. As you read it, note that the state of the to assure UK food supples have been further under-resourced over the last three years. Covid-19, too, has had impact in two significant ways. First, as we said in this Submission to the EFRA Commons Subcommittee (see section 3.4), the relaxation of food sector regulations (with no date for review) coupled with now-virtual auditing, is perceived by the unscrupulous or criminal, to be de facto suspended. It’s inevitable that the safety of seasonal workers, and of food itself, is threatened. Secondly, food inspection and sampling is carried out by Environmental Health officers, many of whose workload is now devoted to Covid-related work.
Notice, too, the footnote (#4 in this blogpost) refers to ‘most Brexits’. The Brexit we have, and the trade deals so far, look set to seriously threaten both both food hygiene and standards.
And finally, when you listen to Professor Chris Elliott in the video which starts the section in our Response (see below), you might well be reminded of the ravages Covid has wrought on the world which possibly, probably originated in the food supply system, as did the the last flu pandemic:
His opening words are: Our food supply system is under threat. Food that is diluted, mislabelled, tampered, counterfeit, adulterated or contaminated costs the world economy over $40 billion a year. The human cost is catastrophic. 200 diseases are spread through food, already affecting the health of 600M a year. Anti-microbial resistance is rising; we’re losing the battle against food-borne illnesses. 420,000 people die every year.
The human cost here in the UK
In 2014, the Food Standards Agency reported one million cases of food poisoning in the previous year, of which half were caused by identified pathogens. Of these, 20,000 people were hospitalised and 500 died. In addition, there were also ten million cases of infectious intestinal diseases. (1)
Safety, assurance and integrity can only be achieved through regulation and its effective enforcement through inspections of food premises and, in theory, local, laboratory testing of samples. (2) (3) Local authorities have a statutory responsibility to carry out these duties.
The breakdown in our regulatory system
Pressures on local authority budgets have resulted in a chronic decline in the number of of enforcement professionals. This means fewer inspections and falling numbers of samples to test compliance with both food hygiene and food standard requirements. Due to reductions in food standards sampling, there are now no public analysts based in London. (4)
The consequences of this breakdown
The UK food system is currently one of the safest in the world. This looks likely to change. In areas that still carry out enforcement of food standards, numerous breaches are found ranging from substitution of meat and fish species, through the presence of undeclared allergens and illegal use of additives to non-approved health claims. These problems exist nationwide, but where intelligence gathering, inspection, sampling and analysis are all but absent, they are not detected. The increase in artisan food production with many small businesses unable to access suitable guidance from their local authorities also increases risks to food safety. (5)
The UK is thus becoming increasingly vulnerable to attack, whether through local authorities not directing adequate resources to discharge their responsibilities, unscrupulous food businesses or organised criminals making a fast buck while using our lives as collateral damage or, in the case of the terrorist, disrupting our social order.
(1) In the 2018 footnote, we stated we couldn’t find the relevant document for these figures from the Food Standard Agency (FSA)’s new website; we obtained them from the LeighDay website here.
note: The FSA used to publish annual figures, but haven’t done so for several years. The latest information on [incomplete] figures on the FSA website appears to be this, dated February 2020.
(2) In the context of food law enforcement, Food Hygiene relates to the microbiological safety and quality of food, and food standards relates to the composition (including additives, contaminants, nutrition, allergens and authenticity), food fraud and all aspects of labelling. Food Standards enforcement in most of the UK falls under the remit of Trading Standards. In London, however, it is the responsibility of Environmental Health Departments. Each Borough, as other local authorities (LAs), must appoint a Public Analyst, and a re required to submit any samples.
The Local Authority Enforcement Monitoring System (LEAMS) data for the period April 2016-March 2017 indicated that two London Boroughs took no food standard samples, and a further six Boroughs took fewer than ten. LAs have clear targets for business hygiene which in general are prioritised over other areas such as Food Standards and associated sampling. With the reduction in LA funding, they’re using their limited responses on inspections rather than sampling, resulting in a continuing decline in the number of laboratories and their capabilities.
(3) A note on the statutory food work of Public Analysts: In England and Wales, it is essentially chemical analysis to establish chemical safety (e.g. mycotoxins, heavy metals, dyes, pesticides, veterinary residues, acrylamide etc), compositional, nutritional and value claims (e.g. meat content of sausages; fibre, vitamin, supplement claims etc) and authenticity (e.g. Bismati rice, wild salmon , cheese or or ham on pizza, balsamic vinegar, meat and fish species, spices, herbs, other flavourings such as vanilla, etc).
The Government Chemist has a statutory function as a referee analyst.
The non-chemical food safety side is undertaken by Public Health England (PHE) in England and Wales as the analysis is at zero-cost to the local authority (PHE is centrally funded to do this work, unlike that of Public Analysts). In Scotland, the Public Analyst undertakes the microbiological work too.
(4) In addition to all this, most Brexits would inevitably put new pressures on the FSA’s ability to regulate.
(5) It is a requirement for all Food Authorities to produce an annual service plan, many of which (but not all) are published.