Setting the standards 
- An interview with Philip James

Public confidence in food safety has been at an all time low, following the outbreak of BSE. The government's response has been to propose a new Food Standards Agency (FSA) as set out in a White Paper published in January 1998(1). It is designed to improve food safety by overhauling the system, from plough to plate. Before the 1997 general election Tony Blair, then leader of the opposition, commissioned Professor Philip James, Director of the Rowett Research Institute, to set out a blueprint for a Food Standards Agency(2). In an interview with David Buffin, Philip James discusses how far he thinks his ideas are likely to become reality.

Many of Philip James' proposals have been adopted by the government. The FSA has been universally welcomed, and has generated a large response from most sections of society. "Generally, it is quite remarkable that over 90% of my own report is in the White Paper. As I recommended, the new Agency would have a remit that encompasses the whole food chain. It would be a non-departmental body with executive powers reporting to the Secretary of State for Health."
    There have been accusations in the media that the FSA will be too closely linked to the Ministry of Agriculture, Fisheries and Food (MAFF). Philip James maintains it will separate food and farming interests by taking over MAFF's responsibility relating to food safety, food standards, nutrition and public health. "The whole set of my proposals was based on the premise that the FSA would have complete independence."
    MAFF officials were stunned by the deep-seated anti-MAFF feelings, noted Philip James. "This attitude came across from every sector of society that I looked at when preparing my report." He emphasised: "I cannot describe to you the abuse that I got when any suggestion was ever made that MAFF should be involved with the FSA." Ironically Philip James says he presented the most pro-MAFF proposals he could have produced. "It was far more important to concentrate on what should happen in the future, rather than dwell on the past too much. Therefore to everyone's astonishment I changed the whole tenor, and that is, I think, why my report received such an extraordinary response."
    From his discussion with government Ministers, Philip James says they are desperate for the FSA to be correctly established, and are actively encouraging constructive criticism. "They are worried that, after all the praise that came with my proposals and the White Paper, people will say, thank god we have a wonderful proposal, let's implement it. Whilst preparing my reports, I had to make decisions on about 1,000 questions at break-neck speed, quite often without being able to see the dynamics involved in the wider processes. So I think that we are dealing with a complex system that has to evolve over time. We should not assume all the problems have been solved," he concluded.

Pesticide evaluation concern 
Pesticide safety is one of the few areas where Philip James' proposals differ from the government's White Paper (see PN39 p17). His report recommended that the FSA should take over the safety evaluation of pesticides from MAFF's executive agencies the Pesticides Safety Directorate (PSD) and the Veterinary Medicines Directorate (VMD) [that licenses sheep dips].
    He is not alone in his desire to see this differentiation established. Many environmental/consumer groups do not want the PSD and VMD to remain within MAFF's remit. Neither does the House of Commons Agriculture Committee. Its recent report on food safety said: " We consider that public confidence in the safety of food in respect of pesticides and veterinary medicines would be enhanced if the surveillance programmes were carried out by the FSA wholly independently of the authorities responsible for product approvals."(3)
    In their evidence to the Committee the British Agrochemicals Association pointed out that the current registration system run by PSD is 'highly effective'. However they did agree that public perception of the regulatory system is poor, and if the proposal to move PSD out of MAFF gave the public greater confidence then "it should be considered".
    Philip James does not think this issue is closed. "I am not necessarily making that assumption yet. I think that some very strong recommendations need to go in. The evidence that I have accumulated suggests that there is an important need for the safety surveillance scrutiny system to be done in the Food Standards Agency context."

Establishing independence
He is also convinced that committees such as PSD and VMD which advise ministers should be opened up. "I believe that it is very important people have no vested interest in the analysis of pesticides. They are not there for the welfare of the pesticide industry. The concern should not be the welfare of the civil servants who need to keep their jobs. The concern should be public health."
    But where will these independent committee members come from? Philip James believes Britain has many toxicologists and other academic experts who are independent. He says we should also develop a second group of lay representatives, who have no previous direct involvement with pesticides evaluation.
    Even at the risk of generating scorn from the 'experts' Philip James would be much happier with a broader base of people to help the committees with their difficult deliberations. "For example, as we speak, I am involved in a US think tank on Bovine Spongiform Encephalopathy (BSE) and we have had a whole series of new proposals and new analyses that come from people who would never believe themselves to be experts on BSE."
    Similarly with pesticides, Philip James believes there are consumers who can provide pertinent lay input. He said: "Over say a three year period, they could acquire professional analytical skills. This would allow them to challenge the expert view." He is concerned that the experts see the risks in a constrained technical mode in the traditional academic view. "And that is quite inappropriate for a public body that has a responsibility for taking the dimensions of public concern."
    Many of the civil servants who will run the FSA are due to come from MAFF. Philip James is aware that their transfer could be seen as 'business as usual' resulting in no ultimate improvement in the public's confidence in food safety. "I believe that one has to change the culture of those who are going to work for the FSA. This will be achieved by making new appointments from outside MAFF for chief posts. You can change people's attitudes quite dramatically by challenging them, especially if you have strong bosses," he believes.

Impact on agriculture
Patrick Holden, Director of the Soil Association, is critical of the proposed FSA because it does not make the connection between food quality and the method of production (see PN37 p10-11). In essence the problems all result from intensive agriculture, which needs reform, he says. In answering this concern, Philip James maintains that: "The FSA will have operational influence into the farm, but there is a battle at present with MAFF on this issue. The FSA will have demands on sustainable agriculture that must be met. I believe MAFF is currently being reformed, there is a revolution going on."

Funding
Philip James says the proposed levy which might average say £100 per food outlet should raise £60 million to fund the FSA.
    In its report the Agriculture Committee says "it is not in favour of the Government's proposed licensing fee (levy) as a mechanism for raising money. It would be a regressive tax as food is proportionately a larger item in the budgets of low-income house, and the costs would be passed on to consumers by industry. We believe that licensing should not be the subject of charges and should be selective, not universal."
    According to Philip James, the £60 million represents just 0.3% of the £20 billion that is spent on food in Britain each year. "So the cost to the consumer should not in fact be very big," he says.
    Philip James disagrees with the Committee's position. "If the funding comes from general taxation, the FSA will be at the beck and call of the Chancellor. The FSA will get modest priority given the huge numbers of issues he has to address."
    The proposed levy that will fund the FSA has caused concern among consumers groups because they fear it may compromise the FSA's independence.       

Concluding thoughts
Philip James concluded the interview by explaining what he wanted the FSA to achieve: "I would like to see a FSA that is truly recognised to be independent. It has to have a long term view of the problems in terms of risk assessment, and how to handle them. The FSA should  not end up responding to every whim of a minister, or whatever the national newspapers demand. It must get to grips with a proper analysis of hazards that confront us. We must begin to develop a legitimate and coherent approach to tackling these issues."

1. Food Standards Agency: A Force for Change, MAFF/DoH, 14 January 1998.
2. Food Standards Agency: An Interim Proposal, Philip James, 30 April 1997.
3. Food Safety, Vol.1 Report on Proceedings of the Committee, House of Commons Agriculture Committee, 22 April 1998.

Professor Philip James is Director of the Rowett Research Institute, Greenburn Road, Bucksburn, Aberdeen,  AB2 9SB, UK.

[This article first appeared in Pesticides News No. 40, June 1998, page 14]