CFG
13/04 rev.
Foodaware response
to the consultation on ‘Putting Consumers First: the Food Standards
Agency draft strategic plan 2005-2010’
General comments
Foodaware recognises the need for the Food Standards Agency (FSA)
to plan strategically for the years ahead and welcomes the emphasis
on ‘putting consumers first’. However, overall we are
disappointed with the draft strategic plan that appears high on gloss
but low on content. Rather than a tough and positive approach to facilitating
change for the better, it appears to chronicle the poor state of the
nation’s health where little improvement has taken place over
that last 20 years. While the FSA cannot be blamed for this sorry
state of affairs, we feel its approach in this document is complacent
and should be much tougher. We would like to see greater emphasis
on the role of regulation in bringing about much needed improvements
and more ambitious targets.
In sum, we are anxious that this does not turn into yet another glossy
document highlighting the need for improvements to the nation’s
health but without the content and real commitment to making that
change happen.
Responses to specific questions
Q1. We think that our priority areas for the next 5 years should
be Food Safety (foodborne illness and chemical contamination), Eating
for Health and Choice. Do you agree?
We agree with the overall priorities of food safety, eating for health
and choice but believe that a reference to sustainability would be
appropriate in a strategic plan such as this. Consumers are increasingly
concerned about the manner in which food is produced and want to see
sustainability recognised and incorporated into food production and
distribution systems. ‘Local food for local people’ is
something many consumers would support if it were available and the
choice was there.
Q2. How appropriate and how achievable do you think that the proposed
targets are? It would help if you could make it clear which specific
target(s) your comments relate to and explain briefly your reasoning.
In general we are disappointed that the targets are not tough enough.
Why, for example, are so many for 2010 and not sooner? We believe
that, in many cases, targets could and should be set for 2006-2007.
Examples include:
p. 16 (Chapter 3 ‘Food safety’) - why so long to achieve
a 50% reduction in the incidence of pigs which test positive for Salmonella
at slaughter? Can this not be achieved before 2010?
p. 18 (Chapter 3 ‘Food safety’) - why so long to reduce
the number of high and medium risk cases of chemical contamination
by 25%? Can this not be achieved before 2010?
p. 19-22 (Chapter 4 ‘Eating for health’) - the statistics
concerning obesity are of great concern and urgent action is needed.
We welcome the targets in this section set for 2005 or 2006; this
kind of timescale is needed. However, we believe the targets concerning
reductions to the average salt and saturated fat intakes should also
be achievable in the next few years (see comment below concerning
Finland). There have been targets in these areas, particularly saturated
fats, and wide-ranging concern about salt levels for many years. Now
it is time for concerted effort for change – not for setting
long ranging targets again. We are disappointed that the last target
in this chapter, on working with industry to achieve changes in the
way food is promoted to children, is left so vague.
p. 24 (Chapter 5 ‘Choice’) - while we support most of
the targets in this section, why so long to publish the compendium
of information about assurance schemes so that consumers can compare
the standards they review?
The FSA should consider the greater use of regulation to bring about
change and make these targets achievable.
Q3. Some of the targets that we have set are aspirational and
we need to do a lot of work to map out how to achieve them. Do you
agree with the principle of setting aspirational targets even though
this increases the risk that we may not achieve all of them?
As we have said above, we believe that the FSA should be taking a
more committed and positive approach to its role in facilitating improvements
in public health alongside better consumer information and choice.
Of course change can only take place if other parties (in particular
other government departments together with the producers and distributors
of food) show the same level of commitment. However, the FSA must
take a lead role in putting sufficient levels of pressure on these
to play their part. In the case of industry, the wider use of regulation,
together with well-resourced enforcement, is likely to be necessary.
We recommend that the FSA look more closely at the example of Finland,
where significant improvements to public health were achieved in just
five years or so. What lessons can be learnt from their example?
Q4.The draft strategic plan contains an interim position on sustainability.
The Board will be considering this area in more detail later in 2004.
The present consultation is one route through which we are inviting
stakeholder comments ahead of the Board’s discussions. What
issues should the Agency be tackling in this area bearing in mind
that the means by which food is produced is not within the Agency’s
remit unless it affects safety or public health?
Embedding sustainability into FSA policies is both highly desirable
and welcome as an approach. The outline framework covers the FSA’s
current approach. This could be supplemented by directly identifying
those targets in the strategic plan which impact on sustainability
such as reducing chemical and microbiological contamination and the
associated risks; minimising pesticide residue levels and working
with other departments to secure reductions in inappropriate use.
The FSA should also continue to promote the availability of fresh,
locally produced food, and to reduce the number of food deserts. Regrettably
there is no reference to these initiatives in Chapters 4 or 5.
Q5. We recognise that we will need to work with a wide range of
interests to deliver the proposed targets. Have we overlooked any
groups or individuals who will have a key role to play?
Foodaware supports the principles set out in Chapter 6 (‘How
we will deliver’) listed on page 25.
We also agree that the FSA needs to work with a wide range of interests
to deliver the proposed targets. However, in many cases, they will
need to find ways of putting greater pressure on these than has been
the case in the past. We agree that these should include: the relevant
Departments of Health, Agriculture and Education across the UK; local
authorities and other regional bodies working at the local level;
consumer bodies, the food industry, research funders, and also EU
partners and the European Food Safety Authority.
As a consumer organisation, we would like to see more detail on how
FSA plans to seek ‘more active consumer involvement in policy
development’. We would positively welcome more feedback on how
our views have been taken into account. We would also like to draw
attention to the vital importance of consumer education, which should
be a lifelong process starting in childhood, and should be integrated
into plans to achieve these targets.
Working with food industry on selective and specific campaigns could
prove useful, for example a ‘fat audit’ of products leading
to efforts to reduce fat levels. Alongside this we would like the
FSA to commit to legislating in certain areas - a strategy that might
encourage industry to make voluntary changes in the meantime. Restrictions
on the promotion of food to children is an obvious example but there
are many more.
The media also has an important role to play and the FSA could make
greater use of it to promote positive campaigns taking place.
June 2004
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