Submission to the Consultation on the “Putting Consumers First” Strategic Plan

16th June 2004

Mr Ike Damon
Room 240
Aviation House
125 Kingsway
London. WC2B 6NH

Dear Mr Damon,

Thank you for inviting me to comment on this consultation but I really do not think it is true that the Food Standards Agency has made a convincing start or ”established a reputation for openness and honesty”.
I have seen many reports where the FSA has been accused of supporting industry and endangering the health of the public, not least in respect to the much-publicised “jury” debate on GM crops and in the continuing scandals over pesticides.

A pattern appears to be developing in that the appearance is of an agency which flags up suspected dangers, such as the ”BSE in sheep” theory, but suppresses any report that could endanger the profits of the pharmaceutical and chemical companies.
Natural dangers are exaggerated while man-made problems are understated.
I was genuinely concerned when the Food Standards Agency was formed by staff taken from the Department of Health and MAFF, because both agencies of Government have been involved in the cover-ups of major health scandals.
It is of interest that the web site address for this “Independent” agency is given as - part of the series of Government web sites.
It seems to me, and others, that we are simply getting more of the same and that the results are clear – a steady increase in cancers, allergies, asthma, and other illnesses.

My answers to the questions posed are therefore as follows.

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?

I must admit that I thought that this was the reason why the FSA was formed, with the intention of rebuilding public confidence in food and science.
I believe that the FSA has failed so far and will fail in the future unless it insists on the highest standards of honesty from its scientific advisers.
We are not getting honesty at present. Internationally the evidence is mounting against glyphosate and other organophosphorus compounds and yet the FSA retains an eerie silence on the subject. This cannot be justified since these chemicals are daily contaminants in our food and they have been linked to adverse health effects at very low levels.
Copies of correspondence over many years demonstrate how adverse effects on health are being deliberately ignored in order to protect the chemical industry and those civil servants whose task it was to protect the public.
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.

I am sorry but I do not think either priority target is achievable unless there is a change in attitude at the FSA.
Currently it seems that farms are targeted as the source for many foodborne and chemical toxins and yet the processing part of the food chain is more often than not the true source of foodborne illness and the manufacturers of chemicals are responsible for the dangerous chemicals used in food production.
There seems to be a fixation currently at the FSA on the possibility of BSE in sheep, which I find remarkable when we compare that with the lack of concern with regard to the proven toxins in the dips that the sheep are immersed in.
Here we are in the UK, one of the most advanced scientific nations in the world, and we are trying to deny that deadly poisons can poison people whilst at the same time suggesting that half the nation’s sheep flock should be destroyed on the whim of some scientists chasing after research grants. Are the sheep farmers to be sacrificed to unsound science just as the beef and dairy sectors were?
There are serious doubts as to whether or not the real cause of BSE has ever been admitted and there are very serious questions to be asked in regard to the use of contaminated injected drugs such as vaccines and hormones.
Fish farming chemicals are also of questionable safety but they continue in use.
Some meat recovery and ”enhancing” practices are extremely dubious but their use is still permitted so that consumers can be duped into buying substandard food.
Why the conspiracy of silence on these matters? Perhaps the idea is to make consumers fear natural foods so much that they turn to those such as Quorn and Soya Milk as ”safe” alternatives and thereby increase the profits for the chemical industry.

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 targets even though this increases the risk that we may not achieve all of them?

Targets are surely targets? It is difficult to hit targets every time but it is not as difficult to achieve standards. Currently the standards expected of public bodies are not being adhered to. Independence is the first priority and that does not mean ignoring the concerns of the people in order to promote the unwanted GM crop programme, which is simply a means employed by a handful of companies to gain total control of the world’s food supply and force farmers under contract to use their own pre-determined range of pesticides and fertilisers.
Honesty means admitting known dangers from certain chemicals and not trying to pretend that the information is not known.
Openness means supplying information to consumers freely when asked and admitting to the public when things have gone wrong.
It is not “aspirational” to set standards and if those standards are adhered to then any targets which are not achieved would not undermine confidence, always providing that in not achieving them the consumers are not harmed.
Setting “Targets” in safety is an interesting concept. Vigilance, training, and scientific integrity should reduce the frequency of harmful occurrences without the need for setting theoretical “targets”.

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.

“Sustainability” requires consideration of the supply and use of all resources but modern food production methods are by no means “sustainable” because they depend on chemicals and a steady supply of hydrocarbon fuels and oils. Even the fertility of the soil is now almost entirely reliant on chemical inputs and there is increasing concern that chemical fertilisers are being used as a means to dispose of dangerous toxic waste – a practice which could have serious consequences in the long term.
In addition the food chain is becoming ever longer between producer and plate and once again this is resulting in higher energy requirements for transport and storage and increased danger in terms of reliability, security, and safety of supply. Even the use of antibiotics in food premises for the control of bacteria is not “sustainable” because resistant strains will inevitably be created.
The Strategic Plan claims that the FSA upholds “The precautionary principle… we adopt a precautionary approach through action to protect and inform consumers” and yet the increasing evidence demonstrating the dangers of such chemicals as glyphosate are systematically ignored.
If the FSA really does uphold this principle why has the agency never insisted that the grain store insecticides such as pirimiphos methyl and chlorpyrifos methyl are declared as additives on food labels? Consumers eat whole grains such as oats and wheat and it is a fact that grain store chemicals are used as food additives and they are not simply “residues” that remain after spraying the growing crop.
In truth they are additives which are not declared on labels and they are dangerous chemicals which it would be wise for vulnerable people to avoid where possible.
Failing even to warn consumers of their inclusion is not adhering to the FSA’s quoted “No.1 core value” which is claimed to be “to put consumers first”.
It is interesting to contrast this with the FSA’s attitude in respect to salt. For centuries man has used salt to preserve food. Even the phrase “Salt of the Earth” refers to the importance of salt to the survival of man. I have no doubt that high salt levels can be dangerous to babies but equally I recall being told by my father that desert troops died if they were not supplied with salt to replace that lost through sweat.
Then again there different forms of salt and perhaps the body reacts to modern salts in a different way. In addition we have chemical “enhancement” of our foods using molecules that fool the senses in respect to flavour, smell and appearance.
Similarly the FSA raises concerns about sugar but carefully avoids mention of the real and increasing concerns surrounding the sugar substitutes such as aspartame, which is becoming extremely difficult to avoid, even in medicines. I was recently prescribed a medicine containing aspartame and the chemist admitted that there had been problems with aspartame and a new prescription was provided for a drug free of the chemical.
Fat was part of everyone’s diet, even in wartime, and there was little obesity. The obesity problem has increased proportionally with the use of man-made fat substitutes and lipophilic pesticides that corrupt the metabolism.
Why has the FSA’s supposed reliance on science not recognised these dangers?

Most of us do not know what we are eating unless we grow the food ourselves and even then, with the advent of GM control over the seed suppliers, unless we save our own seeds in sterile conditions we will soon have absolutely no idea of the potential for harm in our food.
Where are the FSA warnings about the dangers of such contamination?
Recently there was a scandal over the adulteration of chicken meat with that from other animals via a meat recovery and water infusion process. The manufacturer boasted that he would soon be able to denature the “meat” so that no test could determine the DNA or, therefore, identify the species of meat animal from which it was taken. Could an unscrupulous manufacturer use human flesh in this way?
As a former farm manager producing high quality milk and beef for human consumption I could never understand why the authorities allowed water to be added to perfectly good meat in order to fool the consumer into thinking they were buying larger joints. I recall being burnt when removing a turkey from the oven at Christmas time because the water hidden in the bird had been released into the baking tray.
The consumer is being duped, the farmers are being cheated, and the FSA remains silent. Is this putting the interests of the consumer first?

The “Strategic Plan” claims that the FSA is “Taking a long term perspective” and that it is ”forward looking; the strategic plan aims to anticipate future challenges to food safety and health”
Why then does the FSA not call for the immediate withdrawal of all cumulative poisons used in the food chain? In the USA as long ago as 1997 there were calls for the immediate ban of all Organophosphorus pesticides in food production because of the high cumulative levels in children’s food.
Nothing was done save for the EU ruling withdrawing a few forms of the chemical, from the market. It is an utter disgrace.
The FSA claims that “we take an impartial view based on the best available scientific evidence and advice” but the evidence suggests that this statement is also misleading. As is the case with many regulatory bodies in the UK the FSA seems to ignore any science which does not fit well with their preferred policy.
Thus the science against glyphosate is ignored as the FSA promotes GM crops.
The science regarding the transmission of vCJD via contaminated pharmaceuticals is ignored while the FSA tries to find BSE in sheep.
The science demonstrating immune, heart, respiratory, and gut disorders, induced by organophosphates is ignored while the FSA raises concerns about bacteria in milk.
The poor standard of imported food is ignored while the FSA calls for ever-increasing restrictions in both UK agriculture and the UK retail sector.
Is the FSA really “ensuring that the regulation of food supplements and health claims is based on evidence and is proportionate” when they made no protest against the pharmaceutical industries’ move to ban consumer choice in regard to vitamin and other supplements, many of which have proven to assist those with medical conditions induced by chemicals manufactured by those same companies?
What sort of a game is this that the FSA are playing with the consumer?
Where is the “Transparency,[of] information?” Does the FSA really ”listen and develop our participation and access to food policies openly and transparently”?
Is the FSA really being “honest with consumers”?
With so much misinformation used against consumers by “scientists” does the FSA really think that there is “access to justice”? Government has restricted access to the courts and therefore denies justice to the consumer.
Is the FSA really “Combating poverty and social exclusion” as it endangers the organic food supply by promoting GM crops and claiming falsely that there is no advantage or taste difference in organic foods? It is at this time of the year that we notice the tremendous difference in taste between purchased vegetables and our home grown organic supplies.
Those who claim there is no difference must have lost their taste buds or are being dishonest.
Does the FSA really “give priority to initiatives which help disadvantaged and vulnerable consumers” when only the rich can protect themselves by their ability to afford uncontaminated, quality food, or when food labels do not declare pesticide content and so risk the health of those who are vulnerable to residues?
Wasn’t it interesting that MPs banned GM foods from their own restaurants whilst promoting them in the country? Is that a perfect example of ignorance and hypocrisy?
The FSA states that it “will develop by 2006 guidance on use of label statements to warn allergic consumers of the risk of contamination with nuts or sesame seeds” but would it not also be wise to warn of pesticide content and the MRLs permitted so that consumers can avoid the chemicals which might trigger the allergies in the first place?
It should not be a case of assessing “the consumer demand for specific rules on labelling of pesticides use on crops after they have been harvested” since most consumers and a large percentage of farmers have no idea what chemicals are added to food after harvest. The FSA however does know and it could take immediate action if the protection of consumers was truly their first priority.
To wait for the consumer to find out, whilst at the same time controlling all efforts to report the dangers to the consumer in the media, is not protecting consumers.
How will the FSA ensure that imported foods, both legal and illegal, meet the same standards as expected of food producers here in the UK, especially when an ever increasing quantity of our food is being produced and processed outside our area of control in order to escape those restrictions?
I sincerely hope that the FSA does “improve the way food law is enforced“ because someone needs to. Locally we have had reports of illegal pesticide use and illegal antibiotic use, all reported to the authorities with no action taken. How many people would have received food contaminated with those products? In one case the Health & Safety Executive actively worked against those who had reported serious problems involving illegal pesticide use. In fact they claimed to have thoroughly investigated the matter and found nothing wrong.
Obviously no one did residue tests in the food supplied to supermarkets and the adverse health effects were deliberately hidden.
Only when the supermarkets supplied by the farmer were notified of the illegal practices did the HSE take the reports seriously and only then did they succeed in taking the farmer to court. He was found guilty of no less than 11 breaches of pesticide regulation but was not prosecuted for a further breach involving cyanide burial near a bottled water plant which could have had disastrous results had the workers not reported the matter. The authorities, despite the power of the Control of Substances Hazardous to Health Regulations, ignored all adverse health effects.
Similarly farmers can be fined for storing pesticides near food but supermarkets have them in the same building, and often the same aisle, and shoppers happily place leaking packages in with their food shopping. What action will the FSA take to protect consumers from such irresponsible marketing practices?

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?

I notice that the FSA states that it will “form an independent view taking into account the arguments and evidence from all our stakeholders” but it is fairly obvious that the majority of the stakeholders are members of the public whose voice is not represented as the majority in the FSA’s list of stakeholders. Most of those submitting views to the FSA will be from industry and they will benefit from actions taken by the FSA that may not be in the best interests of the public.
The decision making process is therefore heavily biased before any work is done and any decision made. A similar situation was found recently with the “stakeholder” involvement in the consultations over pesticide notification and buffer zones for which the majority of stakeholders whose views were sought would benefit from lack of regulation. The general public had very little representation and those that did manage to take part had their views ignored despite the backing of scientific evidence.
It is very difficult for the public to make decisions or recommendations unless they are correctly informed.
Currently here in the UK much of the information relied upon by the public comes from those with vested interests. What is hard to understand is that those of us who have direct experience of all sides of the arguments are completely ignored in the decision making process. As mentioned before I was a farm manager but I have spent a lifetime on farms involved with cattle, grass and arable crops in the main, but also with pigs, chicken and sheep. In that time I have seen things that impress me, and actions that have horrified me, but all the time every effort was made to improve standards.
In my close family we have at least four fully trained chefs, two of which are still actively involved in the food retail industry, but all work with the public.
Many of my friends are active in agriculture and share my concerns.
This is not a bid on my part for my own involvement as one of those “with a role to play”, as I am in poor health, but it is simply background to this question to the FSA;
Why will the authorities not listen to those of us who have direct experience of the harm caused when things go wrong, and scientific understanding of why they happen?

In Conclusion.

It is stated that the FSA is “an independent voice within government” but there is no such animal. The FSA is either part of Government or it is not. Members may at times flex what little muscle they have by making statements not cleared by government officials but in reality they are restricted by policy and funding from, and all members are appointed by, government.
I was deeply involved, with others, in the BSE Inquiry and I recall the concerns over scientists, who were hiding and distorting evidence, and Government Ministers, who were badly advised on matters of both policy and science.
We were all pleased to see the Food Standards Agency created and hoped for good things but nothing has changed. We still get more of the same, and those advising ministers are still trying to protect industry from the consumers by hiding embarrassing, or even damning, truths.
I hope for improvements.

Yours sincerely,

Dated 16/05/2004    Updated 20/02/2016

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