Criterion 2: What are their recommendations about ensuring food safety, assurance and integrity?

None.

It would appear that Henry Dimbleby and his team made the remarkable decision that the National Food Strategy would not examine food safety, assurance and integrity issues and make related recommendations. Nor have they provided a rationale for their decision.

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In this post in answer to our second question about the National Food Strategy, we give the detail of this decision.

The ‘industry, government and non-governmental organisations’ represented on the Advisory Panel to the National Food Strategy do not include those with specific professional experience and expertise in food safety, assurance and integrity, such as the Association of Public Analysts, the Chartered Institute of Environmental Health (CIEH), the Chartered Trading Standards Institute, the Food Standards Agency (FSA) and the National Food Crime Unit, or the Government Chemist.

It makes no reference to the Local Authority Enforcement Monitoring System (LEAMS) data, the role of Public Analysts and Environmental Health Officers (EHOs), the Food Hygiene Rating Scheme (FHRS), the Hazard Analysis Critical Control Point (HACCP) or the Codex Alimentarius.

Nor does it mention that cases of of food-borne illnesses  in the last seven years have risen by 140%, i.e. significantly more than doubled. (1) (2) (3) 

It’s surprising, too, that Professor Chris Elliott, who led the Elliott Review into the Integrity and Assurance of Food Supply Networks, is not part of this Advisory Panel, nor listed as one of the ‘many other experts’ on page 262.

Emily Miles and Professor Guy Poppy, respectively the Chief Executive and immediate past Chief Scientific Advisor of the Food Standards Agency are listed as two of the ‘many experts’.

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The National Food Strategy doesn’t mention the following at all:

  • adulteration, analyst, assurance, chemist, disease, food borne, fraud, integrity, local authority (with regard to food safety, assurance or integrity) or primary authority, pathogen/s,* poisoning, sample/sampling, testing, toxin/s.
    *or mention of, for example, campylobacter, e-coli, salmonella or norovirus

The word ‘toxicity’ occurs in the title of one of three papers cited in footnote 43 to their first recommendation as support for this statement: the use of potassium chloride — which is less harmful to health than conventional salt about which, regrettably, it is at best equivocal. (4)

There are six uses of the word ‘hygiene’ (plus three to the London School of Hygiene and Tropical Medicine), none specific. One use of the word is in this sentence on page 206: Formal training for school catering staff is not consistent and there is an emphasis on food hygiene and safety, and not on cooking skills which we trust was not meant to under-estimate the importance of food safety and hygiene.

There are six uses of the word ‘enforcement’, four of which are related to food, but only in general terms, none indicating the authors have any knowledge about how the legislation governing food safety and standards is enforced.

There are 165 mentions of the word ‘standards’, all used generically or in reference to the FSA or other Standards bodies. None related to food standards.

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Strategic action is needed urgently to ensure the safety, assurance and integrity of UK food supplies. Here are five (among many!) reasons why:

  • In September 2014, the Secretary of State for Environment, Food and Rural Affairs, Elizabeth Truss, welcomed the Elliott Review into the integrity and assurance of food supply networks, and accepted all its recommendations. Whilst we have seen the National Food Crime Unit set up and attract additional Treasury funding, there has been no progress on developing a strategic approach to maintain a resilient network of food analytical laboratories providing services for local authorities and businesses. When the Elliott Review was published there were six local authority Public Analyst laboratories in England, today there are three. (5) (6)
  • This situation is compounded by the Brexit this Government negotiated with the European Union; e.g. it is not possible to test perishable fresh produce quickly enough within the UK given our limited laboratory capacity and, since the ending of the transition period, non-tariff barriers mean samples requiring certain tests cannot be sent to EU27 labs. (7)
  • There has been decline since the Elliott Review in inspection sampling and enforcement as well as testing. For example, in December 2014, Birmingham had 15 FTE EHOs covering food standards, inspections, hygiene and food crime. (8)
    The 2019-20 LEAMS data indicate the city had only three FTE EHOs working on food-related matters in 2019-20 (i.e. pre-pandemic). Worryingly, the highest number reported in any authority was 8, the median being only 1.5 FTE EHOs. (9)
  • The pandemic, too, has gravely affected laboratory capacity for food testing around the world, as well as in the UK and the EU27. The work of UK EHOs on pandemic matters, too, will have led to a significant drop in inspections, sampling, testing and enforcement.
  • As we pointed out in our submissions to the Commons EFRA Select Committee on Covid and food supply in May 2020 and January 2021, the relaxation of regulations at the beginning of the pandemic needed to be subject to review and time-limited. For example, the inclusion of virtual or self-reported inspections inevitably provides opportunities for the unscrupulous and the criminal or, as a senior supermarket executive said to us, an ‘invitation’ to them.

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The omission of any consideration of food safety, assurance and integrity issues within the National Food Strategy is, in our view, a matter of grave concern.

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(1) The 2020 FSA study estimate there are currently about 2.4 million cases a year compared to approximately one million in 2013.

(2) The 2013 figures state that, of the one million cases, 20K people were hospitalised and 500 died, stating also there were 10 million cases of infectious intestinal diseases. When we researched the 2013 figures (published in 2014) for our Response to the draft London Food Strategy in 2018, the data was no longer on the FSA website, though it was on the Leigh Day site, and still is here.

(3) The hospitalisation data for 2018 (upon which the FSA based their 2020 study) estimate between 16,439 and 26,116 cases of hospitalisations, substantially lower than would be anticipated from the 2013 figures. They do not provide any mortality figures. They refer to the 2013 figures for infectious intestinal diseases without comment.

(4) The reference is to this SACN-COT statement on potassium based sodium replacers: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/660249/SACN_-_Potassium-based_sodium_replacers.pdf

(5) The three in England are Hampshire, Kent and Lancashire. There are four public laboratories Scotland (Aberdeen, Dundee, Edinburgh and Glasgow), one on the Isle of Man, one on Guernsey, none in Northern Ireland, three in Ireland (Cork, Dublin and Galway).

(6) Two commercial companies run laboratories in the UK: Eurofins, global company with its HQ in Luxembourg, and Minton Treharne & Davies, a privately-owned group of companies with its HQ in Cardiff. See: http://www.publicanalyst.com/about_us/the_laboratories/

(7) The range of Brexit-related food issues, including safety, assurance and integrity can be gleaned from inter alia these The Grocer articles, and the number of food issues listed in this #BrexitReality twitter thread from @DanielKelemen.
note: The National Food Strategy has only two mentions of Brexit: On page 148 Recommendation 3 and in relation to qualifications in the light of post-Brexit skills shortages in hospitality, and on page 281 in the Glossary: Following Brexit, the UK will no longer participate in the EU’s Common Agricultural Policy (CAP).

(8) See the synopsis of the presentation by the the City Council’s EHO Nick Lowe, on pp 6-9 our Update on food crime since the Elliott Review (2015) for this figure, and examples of cases. Note, also, this 2019 report by the CIEH: Birmingham council ‘unable to fulfil food safety function without external help’.

(9) LEAMS data sets for 2019-20 (i.e. before the pandemic): https://data.food.gov.uk/catalog/datasets/069c7353-4fdd-4b4f-9c13-ec525753fb.

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