CFG
29/05
Letter dated 4 November
2005 from Foodaware to Ms Julia Unwin, Deputy Chairman, Food Standards
Agency:
Dear Julia
FSA’s Consumer Engagement Strategy
When you addressed Foodaware members in July, you invited us to send
you any further thoughts on the FSA’s proposed Consumer Engagement
Strategy. Here are just a few key thoughts which we hope you will
take into account in developing the Agency’s approach.
One of the FSA’s core values is ‘to put consumers first’.
We believe FSA can only do that effectively if there are staff within
the Agency in every area of work, who understand the consumer perspective,
are informed about the needs and interests of consumers and can ensure
that issues of relevance to consumers are addressed in developing
policy and practice. In their roles they should identify gaps in knowledge
of consumer behaviour, what consumers expect from the FSA in particular
areas of policy, and how that could be delivered given the constraints
of current UK or EU policy, and market practice. The presence of such
individuals (as with the inclusion of independent, consumer members
on specialist advisory committees) should bring about a change in
the way topics are approached, truly considering consumers first.
FSA staff are regularly exposed to scientific and industry views,
but because of lack of resource in the consumer movement do not have
sufficient access to consumer knowledge and opinion.
The FSA’s consumer unit is a valuable focal point for consumer
issues and contacts with external organisations and the consumer panel
and is necessary to inspire out-reach work and help the FSA access
hard to reach groups. But however well resourced a free-standing consumer
unit is within a regulatory structure, it is unlikely to be as effective
as an integrated approach working alongside the policy, scientific
and technical staff.
The paper which the Board considered in July stated that the purpose
of engagement is to seek advice about policy, bring views into the
Agency and build strong relationships with organisations (especially
those in contact with hard to reach groups).
We would respectfully suggest that the purpose should be ‘to
ensure that the Agency’s policies are underpinned by a sound
understanding of consumer views as evidenced by research, consultation,
and specialist advice from their representative organisations. The
FSA also has a responsibility to educate and inform consumers which
we believe has been effectively delivered to date, and must continue.
The FSA has undertaken a wide range of activity under the umbrella
of ‘consumer engagement’. It will continue to require
a range of different approaches to meet its policy objectives including:
- Technical input from consumer specialists on regulatory issues,
scientific developments, risk assessment and management.
- Market research to canvass public opinion on proposed policies
and action.
- Consumer research to inform decisions.
- A consistent method of monitoring how consumer views change
following FSA advice to allow assessment of the FSA's effectiveness.
- Novel approaches to encourage debate and consumer input (eg
citizen's juries).
- Partnership working particularly at local level to involve new
stakeholders and develop projects.
- Mechanisms for consultation including a properly resourced specialist
Consumer Committee, more effective consultation methods, and stakeholder
meetings which provide briefing but focus particularly on consumer
issues.
- Issue-based meetings involving a range of relevant government
departments and agencies to address consumer questions e.g. BSE,
Avian flu, nutrition.
The FSA should not seek to reinvent the wheel, but build on what is
known to be effective in other regulatory environments. It should
also look at how the web could be used to encourage e.g. the development
of regional consumer panels, or interested stakeholder groups supported
by periodic meetings or events perhaps linked in to Board activities.
The Board must retain ‘Engagement with Consumers’ as a
key element in its Strategic Plan but should ensure that its internal
structures enable a consumer perspective to be brought to all its
work. Only then will its strategy be sustainable.
If you or your colleagues would like to discuss any of these points,
or other aspects of the Consumer Engagement Strategy with us, we would
be more than happy to do so.
Yours sincerely
Barbara Saunders
pp Susan Knox
Chairman
cc Deirdre Hutton,
John Bell,
Jaswinder Bangar
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