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| Priorities
for government-funded research priorities in the area of food |
CFG
01/05 rev. 1
Comments by Foodaware
on priorities for government-funded research priorities in the area
of food
IIntroduction
Antimicrobials
Zoonoses
Allergens
Pesticides
Nutrition
Nutritional quality of food
GM food
Materials and articles in contact with food
Conclusion
1. Introduction
1.1 It is important that government consults
consumers on priorities, including from very beginning of research
design. Different questions may occur to the layperson. One example
is that consumers have always demanded that non-scientific concerns
are taken into account in the process of risk assessment, evaluation,
and management. The issue of need applies, especially in new products.
Consumers raise the question, why take a risk at all? The issue of
need applies, an analysis of the benefit to consumers should be made
explicit especially in new products. Public perception also needs
to be taken account - a process that failed in the introduction of
gm food.
1.2 Priorities
Foodaware agrees with the FSA overall priorities of food safety, eating
for health and choice, but would add sustainability. As far as scientific
research is concerned, our overall priority would be on the food safety
side. Therefore, Foodaware would point to zoonoses, allergies and
antibiotic resistance, including biological and other alternatives
to pesticides and antibiotics as priorities.
Poor nutrition causes more death and disease than food safety problems,
and there is a need for urgent action in the area of nutrition too
as well as for research, particularly on the behavioural aspects.
2. Antimicrobials
2.1 Monitoring
The monitoring of antimicrobial resistance in humans and animals must
be extended to all pathogens. It is important to know how many pathogens
are expressing resistance.
Monitoring of antimicrobial consumption should not be limited to human
medicine, but extended to animal medicine and agricultural use. Figures
on total usage broken down into categories (humans, animals, agriculture)
should be collected and made available. This would also allow for
assessment of whether usage is decreasing over time.
2.2 Resistance
Research on microbiological resistance must be developed. Foodaware
acknowledges current initiatives and actions developed in the framework
of the Fourth Programme for Research and Technological Development.
In the light of the importance of the problem of antibiotic resistance,
its impact and cost on public health, research in this area must be
a priority. In particular, there is a need to promote research on
the irreversibility of resistance among bacteria. Publication of usage
in hospitals, GPs, dentists and also in farming would help consumers
and farmers understand how demand could be lowered.
Research is also urgently needed to widen the range of antibiotics
available for use in medicine, so as to circumvent resistance as far
as possible. Now that the complete genome sequence of the soil bacterium
Stretomyces coelicolor has been published 1
for example, a valuable opportunity for obtaining new antibiotics
has opened up. This bacterium manufactures many antibiotics for its
own protection, and a number of them have already been adopted as
medicines. Now this source is wide open for innovative development.
3. Zoonoses
3.1 Many human diseases are zoonotic in
origin. Foodaware’s starting point is that food should be safe,
so research should focus on eliminating zoonoses as far as possible.
3.2 Monitoring
The EU directive includes provisions to monitor a wide range of zoonoses
and zoonotic agents, as well as to co-ordinate the monitoring and
publication of data with the involvement of the European Food Safety
Authority. It is important that this is vigorously carried out and
that data is compatible. We also welcome the proposal to monitor antibiotic
resistance in zoonotic organisms. Research needs to cover pathogens
in general, and to look at causation, prevalence, testing (as for
BSE) vaccines (as for TB in cattle) and resistant animals (as in scrapie).
3.3 Exotic diseases
Since the 11th September attacks, the need is to take account of the
possibility of malign development and dissemination of zoonoses. New
zoonoses may also appear as a result of transfer of animal parts and
increased travel. In the fossil record, periods of rapid extinction
have been associated with rapid evolution. It is a reasonable hypothesis
that this has included rapid evolution among disease organisms. Global
warming is therefore likely to encourage new disease.
Both the corona virus of SARS and the bird flu virus are problems
derived from animals eaten as food. Each is an RNA virus. These viruses
mutate much more rapidly than do DNA viruses and, possibly related
to this, they have very small genomes. So they change unpredictably,
but between a limited range of genetic and serological variants.
3.4 BSE
Although the number of BSE cases is declining, this is not happening
in line with government predictions and there is inadequate explanation
as to why cases are continuing to be found in cattle born after the
1996 feed ban reinforcement. Equally, many uncertainties remain about
Transmissible Spongiform Encephalopathies (TSEs). National Consumer
Council and FSA research shows that consumer risk perceptions about
BSE remain salient and any change to a more lenient regime therefore
risks being viewed in a negative light. Research into consumer responses
to any change to the current system of controls is needed and feeding
methods must be monitored to ensure that ruminants remain vegetarian.
The thirty month rule should not be replaced unless and until it can
be demonstrated that a testing regime is certain to work as effectively.
We believe any such testing regime would require, in addition, regular
monitoring, further research on improved testing and continued exchange
of information with other Member States on their results.
Foodaware would highlight the continuing importance of research into
the possibility of BSE in sheep and/or goats.
3.5 Campylobacter
We agree that the FSA should seek to assess the effectiveness of its
strategy in this area, but it will need more specific targets and
clearer goals within the strategy in order to do so. The rolling retail
survey will be valuable in providing data on the contamination rates
at different times of the year and may help in identifying particular
sources. It is nevertheless important that the retail survey should
include smaller outlets as well as the major retailers and that some
means should be found for monitoring food processors and catering
establishments which supply raw chicken. We understand that a significant
proportion of UK produced poultry is sold as whole birds and that
imports are used for the value-added cuts sold at retail and to processors.
A more broadly based survey would be important both to ensure effective
coverage of the market and to monitor the standards of processors.
There is concern about the role of factory farming in fostering disease;
also about slaughter methods. The Consultative Group on Campylobacter
and Salmonella in Chickens identified a need for research to improve
sampling and testing techniques for detecting Campylobacter in poultry
on the farm and to control it in extensive production systems. Given
the time such research is likely to take, and the cost of food poisoning
outbreaks for public health, the FSA should encourage funding agencies
to support this work as a matter of urgency.
The EU should also promote research, in particular on prevalence so
that best practice countries can be identified and copied.
4. Allergens
4.1 Causation and avoidance
According to studies, the increased prevalence of allergies and food
intolerances could be explained by some modifications of social behaviour:
the early exposure of newborn babies to a greater range of allergens
(no or short period of breastfeeding, early diversification of food)
and the possible sensitisation of the foetus during pregnancy. Another
hypothesis is the changes in the allergenicity of foods during industrial
transformation. These modifications could partly explain the increased
prevalence of allergies and food intolerances. Consumers are concerned
about the role of food additives and farm chemicals.
4.2 Status of food
Foodaware would like to see more research into causation as well as
to determine the allergenicity status of food, to allow reliable labelling
and information to consumers. This has very practical implications
since the new EU labelling directive does not require absolutely full
ingredient listing except where identified allergens are concerned.
Therefore new and emerging allergens need to be noticed urgently to
ensure labelling.
5. Pesticides
5.1 Cocktail effect
The “cocktail effect” is the biggest challenge for pesticides
research. Regulatory systems for pesticides and veterinary medicines
consider the potential health effects of each substance as an individual
compound. However there are possibilities for groups of compounds
to have a greater toxic effect when in operation together.
The “cocktail effect” studies to date indicate that the
probability of any health hazard due to an exposure to a mix of pesticides
and/or a mixture of pesticides and veterinary inputs is likely to
be small - at least on the evidence available to date. However the
body of evidence is limited and it is possible that some interactions
are not readily predictable. Further research is clearly needed because
of remaining question marks as indicated in the UK Committee on Toxicity
Report "Risk Assessment of Mixtures of Pesticides and Similar
Substances", 2002.
In addition, a scientific and systematic framework should be established
to carry out combined risk assessments of exposures to more than one
pesticide and/or veterinary medicine. We support the view that the
approval of pesticides should include more formal analysis, and possibly
experimental investigation, of the potential for combined toxic action
or interaction due to the addition of other substances to the formulations
employed.
5.2 Alternatives
Foodaware welcomes the Commission’s strong support for substitution.
However the difficulty of commercial application of the alternatives
to pesticides - particularly higher risk pesticides needs to be tackled
alongside. Some bio-rational naturally derived products are not always
approved for use by national regulatory systems. The EU Commission
needs to address the lack of encouragement from national and EU legislation
and regulatory frameworks for such alternatives.
Foodaware would also support increased research and development in
the field of potential safer substitutes for the most dangerous pesticides
and of non-chemical alternatives.
5.3 Aquaculture
Foodaware has considered chemical use in fish farming also has its
downside. High fish densities inevitably mean vulnerability to infectious
diseases and parasites, which leads to increased use of pesticides,
antibiotics and other chemicals. As the production of farmed fish
has more than doubled in Europe over the last 20 years, so the problems
of chemical contamination have multiplied. The chemicals contaminate
the fish, the farms, and are found later in the food chain and in
surrounding waters and rivers.
Biological solutions are to be encouraged such as multi-species culture
methods, particularly where one species east the parasites of another.
6. Nutrition
This is a hugely important area where much action needs to be taken
regarding advertising, catering, schools etc. We welcome the progress
made by the recent White Paper on Health and urge rapid implementation.
Foodaware urges that more research be undertaken into the differences
in food preferences and intakes between geographical and population
sub-groups and the health impact these differences may have, for example,
the susceptibility of different parts of the population to salt. One
area of particular concern is that of obesity in young people and
why it is becoming such a problem. Research on the effects of ‘grazing’
rather than eating regular meals would also be of great interest as
would research into exactly what and how much people are consuming
in this way.
Another area of concern is the effect of diet during pregnancy, and
immediately prior to pregnancy, on the lifelong prospects for the
health of the baby. Action is needed now to improve the situation,
but there is also a need for further research to refine the crucial
dietary influences.
It is important that member states collaborate and share information
including on best practice. The EU R&D programme should include
the dissemination of research on nutrition and research into the barriers
to healthy eating. The collection of comparable information would
enable concerted EU action programmes.
It would be very helpful if the Commission could ensure consistency
of data in the nutrition area between member states, indeed more generally,
as we have found with zoonoses. We would then be able to draw more
sophisticated conclusions about the impact of different diets and
the barriers to healthy eating.
A pan-European study of food production and consumption measures,
extended from those already monitored by the Food and Agriculture
Organisation (FAO), and pan-European sample surveys of actual dietary
patterns (possibly an extension of the EU Scientific Co-operation
[SCOOP] project) could allow monitoring of the progress towards nutrition-related
targets.
7. Nutritional quality
of food
Given the paucity of data in this area, EU support for research into
the links between soil fertility and nutritional quality would be
very welcome. Different cultivation methods (and not just organic)
should be researched.
Research to improve the nutritional quality of the foods available
to consumers should be given higher priority. The policy initiatives
of the FSA have taken increasing account of encouraging the consumption
of good, not merely chemically and bacteriologically safe, food. For
instance to eat more fruit and vegetables is now a familiar message.
However more research could have as its aim bringing better food to
the market place. The qualities of visual appearance, but also taste,
texture and flavour, influence consumers’ choices. Nutritional
qualities are hard or impossible for consumers to judge when they
buy food. Food manufacturers, aware of this, are marketing products
with claims for enhanced nutrition, but these tend to be at the more
expensive end of the market.
FSA research shows that cruciferous vegetables may protect against
carcinogens produced when cooking meat. Furthermore, cultivated varieties
of each species are likely to vary genetically for vitamin and mineral
content. Brassicas have been investigated, but other crops could be
studied to find which varieties would be most valuable to grow from
the nutritional point of view.
Access to nutritional food
The consumer position in key economic policies determining access
to food - the Common Agricultural Policy and the Common Fisheries
policy, is underrepresented and could usefully be backed up with more
research.
For example, the failure of policy-makers to accept scientific advice
on fish stocks puts supplies to consumers at risk.
8. GM food
There is still huge public concern about gm food and members consider
that the jury is still out on the potential for environmental damage
from gm production. Foodaware supports measures to reduce the use
of pesticides, herbicides and agri-chemicals in food production but
the evidence that the use of gm seed can reduce the use of pesticides
and other chemicals is inconclusive.
There is also insufficient knowledge of the potential long-term health
consequences to judge this question and we are unaware of any research
currently being undertaken in the UK or elsewhere into this vitally
important aspect of potential long term health risks. We applaud current
research into potential long-term health benefits, but we find it
astonishing that the UK Government does not appear to have commissioned
further studies into potential health risks either directly or through
the EU or other international bodies. See comments under section 6.
Health considerations are important for the population as a whole
and for particular subgroups, such as ethnic and religious minorities,
children and the elderly, with particular needs. There is no satisfactory
means of monitoring the population as a whole for potential long term
effects. Foodaware is keen that arrangements for post-marketing surveillance
should be introduced to enable unexpected outcomes to be identified.
Increased prevalence of allergies would be a particular risk for which
monitoring should be established. Competent authorities should always
be able to review a decision, withdraw or limit marketing authorisations,
and introduce additional labelling requirements.
While knowledge of potential medical benefits is also limited, we
believe that research in this area would be valuable and should continue.
9. Materials and articles
in contact with food
Innovations such as ‘intelligent’ packaging should be
an area for research. These may carry disadvantages - for example,
fruit and vegetables or other unprocessed foods might have their shelf
life prolonged and lose vitamins. The food may appear just as good
to the consumer but its nutritional status may have declined. A cost
benefit assessment is clearly needed to determine that some forms
of intelligent/active packaging do not carry similar disadvantages
to irradiated food.
10. Conclusion
Foodaware’s overall priorities for scientific research are antimicrobial
resistance (how severe and what alternatives); progress towards the
elimination of zoonoses by studying their prevalence and behaviour,
testing methods, vaccines, and, to a lesser extent, resistant stock
and allergies. The apparent growth in allergies, causation and the
allergenicity status of foods also needs to be researched.
In the important area of nutrition, we would highlight the behavioural
issues for particular attention.
Ann Davison
February 2005
1 (Nature 417, 9 May 2002, 141-147)
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