Consultation on the European Commission's proposal to introduce legislation controlling radioactivity in foodstuffs

1. This consultation seeks your views on the nature and structure of the proposed legislation in order to inform the Food Standards Agency on the line which the UK should adopt in the forthcoming negotiations. Please send your reply to the address given in paragraph 16 no later than 1 October 2001 and earlier if possible.

Background

2. The European Commission proposes to introduce new legislation to replace Council Regulation (EEC) 737/90, which came into force in March 1990. This lays down Maximum Permitted Levels (MPL) of radiocaesium contamination of Chernobyl origin in agricultural products originating from countries outside the Community that may be imported into the Community.

3. The new legislation would set MPLs on all products (foodstuffs) offered for sale in the Community, wherever they are produced. Current legislation adopted in 1987 sets out MPLs (given in Annex 1) for foods produced within the Community but only for use in the event of a future nuclear accident. We understand that these MPLs will be superseded by the new legislation and apply at all times.

Why replace Regulation 737/90?

4. The European Commission has come to the view that Regulation 737/90 should be replaced for the following reasons:-

i. Countries from outside the Community have complained to both the Commission and the World Trade Organisation that Regulation 737/90 is discriminatory in that there is no comparable Community legislation setting MPLs for products originating within the Community. They further complained that the pre-defined MPLs adopted by the Community for use within the Community in case of a future nuclear accident are higher than the MPLs imposed on them by Regulation 737/90. Such dual standards, they argue, are discriminatory and a distortion of international trade contrary to the agreements that established the World Trade Organisation.

ii. Some of the countries which suffered significant radioactive contamination as a result of the Chernobyl accident are due to join the Community in the first wave of the enlargement process. The lack of any comparable intra-Community legislation means that no controls would exist on the levels of radioactive contamination in foodstuffs allowed to circulate within the single market once these countries join the Community.

What are the options for replacement?

5. The Commission has considered three options for the replacement of Regulation 737/90, these are:-

i. Amending Regulation 737/90 so that the MPLs for Chernobyl origin radiocaesium apply to 'products placed on the single market' as opposed to just imports from third countries;

ii. Enacting a new Regulation laying down MPLs for the radioactive contamination of foodstuffs;

iii. Retaining Regulation 737/90 unaltered for imports and enacting complementary legislation for 'products placed on the single market'.

6. The Commission has indicated that option (iii) is their preferred choice as it is the simplest to implement and would be introduced under the provisions of the EURATOM Treaty.

Can you give some examples of the sort of changes that could be made and an idea of their impact on the UK?

7. There are a number of possible approaches to aligning the different MPLs of 737/90 and 3954/87 and two examples are given below.

8. The first option the European Commission might chose could simply be to merge the MPLs from both regulations. The effect of this is shown in the table of MPLs given in Annex 2.

9. If the European Commission chose to merge the MPLs as shown in Annex 2, this would have several effects on the UK. Certain species of shellfish collected from the west Cumbrian coast may exceed the proposed limits as a result of technetium-99 and plutonium-241 arising from permitted discharges from Sellafield, even though the food safety risk associated with these discharges is extremely low. For lobsters in particular, in which contamination levels of technetium are higher, the limits might be exceeded over a wider area, possibly from Lancashire to South West Scotland. Other foodstuffs such as fruit and vegetables are very unlikely to be affected as levels of radioactive contamination are significantly below MPLs, and often below analytical limits of detection. Any new and lower caesium limit would require the Food Standards Agency to demonstrate that existing controls on sheep grazing certain upland areas of the UK contaminated by Chernobyl fallout were still adequate.

10. The second option the European Community might chose is similar to that described in paragraph 8, except that the numerical values assigned to 'all other nuclides' would be reduced by the amount which was re-assigned to the 'isotopes of caesium' category. In this case, the total sum of radioactivity allowed for each type of foodstuff is the same as Annex 1. The effect of this is shown in the table of MPLs given in Annex 3.

11. The impact of this change on UK foods would be similar to the situation described in paragraph 9, but levels of radiation in shellfish from a slightly larger area might exceed the proposed limits. Again, there would be no significant impact on other foodstuffs such as fruit and vegetables and existing controls on sheep would have to be confirmed as adequate.

How do these changes compare with the international dose limit?

12. The international dose limit for members of the public in the European Union is 1 mSv/year. To put the proposed changes into perspective, the Food Standards Agency has calculated the annual radiation dose from radiocaesium in the diet, because this radionuclide is most affected by the proposed regulations. The calculations below are for an adult consuming 1 kg per day of solid foods, 10% of which contained radiocaesium at the MPLs, for the options described in the Annexes to this letter. The value of 10% of the foods eaten being contaminated reflects the fact that our food comes from all over the world and it is extremely unlikely that all of it would be contaminated.

Annex 1 levels 0.6 mSv

Annex 2 levels 0.3 mSv

Annex 3 levels 0.3 mSv

What if more extensive changes are proposed?

13. If a more wholesale revision of MPLs is undertaken, it is difficult to assess how these would affect the UK due to the large number of combinations of radionuclide grouping and MPLs that are possible, particularly if the MPLs set are based solely on arbitrarily chosen numerical values with no reference to actual radiation risk. In general terms the lower the MPL, the larger the area in which food might exceed the limit. This is also true if radionuclides with very low values of radiation dose per unit of radioactivity ingested, such as tritium and carbon-14 that are commonly discharged from non-nuclear establishments (hospitals, university research laboratories etc) were included in a 'all other nuclides' category.

14. In the final analysis, however, the UK would have to decide whether the desirability of a transparent, radiation dose based but possibly complex system is outweighed by the benefits of arbitrary one that is simply but opaquely derived.

Issues on which your views are sought

15. Given that the Commission has indicated its preferred option, the Food Standards Agency seeks your views on the following.

i. Should the UK support the introduction of European legislation to standardise MPLs for radioactive contaminants in foods thoughout the Community?

ii. Should such legislation apply to all radionuclides regardless of source?

Comment: For example, the pre-defined MPLs of 3954/87 apply to artificial or man-made radionuclides only and not natural radionuclides. It can be argued that radioactivity has the same adverse effect regardless of where it comes from.

iii. How should radionuclides be grouped together for setting MPLs?

Comment: For example, the pre-defined MPLs of 3954/87 are grouped by a combination of type of radioactive emission, and half life. This system has the result that radionuclides with low toxicity (eg technetium-99) could cause the MPLs to be exceeded and intervention measures taken out of proportion to the risk posed by the radioactivity. An alternative form of grouping could be by radiation dose per unit of radioactivity ingested and be directly traceable to the internationally recommended radiation dose to members of the public of 1 mSv/yr.

iv. What numerical values should be ascribed to MPLs for the various radionuclide groupings for different types of foodstuffs?

Comment: The current grouping for pre-defined MPLs of 3954/87 is reproduced in Annex 1 to this paper. There are many other possible combinations.

v. How would the new proposed legislation take into account the dose limits and requirements in the Basic Safety Standards?

Comment: Council Directive of 13 May 1996 laying down basic safety standards for the health protection of the general public and workers against the dangers of ionizing radiation (the Basic Safety Standards) states in Article 3 (2f) that no reporting need be required for practices involving " material contaminated with radioactive substances resulting from authorized releases which competent authorities have declared not to be subject to further controls."

Where should I send my views?

16. Replies should be sent as soon as possible and to arrive no later than 1 October 2001 to:

Mrs Chester Wood
Radiological Safety Branch
Food Standards Agency
6th Floor, St Magnus House
25 Guild Street
Aberdeen
Direct Line 01224 285162
Fax 01224 285168
E-mail chester.wood@foodstandards.gsi.gov.uk

Will the responses be published?

17. It is the Food Standards Agency's normal practice that all responses to its consultations are made publicly available. We will put a summary of the responses on our website and a copy will be sent to all respondents.

Radiological Safety Branch, Food Standards Agency, Scotland

ANNEX 1: Current pre-defined MPLs for Foodstuffs and Feedingstuffs as laid down in Council Regulation (EURATOM) N0 3954/87

	Foodstuffs Bq/kg or Bq/l (1)
	Baby foods (3)	Dairy Produce (4)	Other foodstuffs except minor foodstuffs (5)	Liquid foodstuffs (6)	Feedingstuffs (2)
Isotopes of strontium, notably Sr-90	75	125	750	125
Isotopes of iodine, notably I-131	150	500	2,000	500
Alpha-emitting isotopes of plutonium and transplutonium elements, notably Pu-239, Am-241	1	20	80	20
All other nuclides of half-life greater than 10 days, notably Cs-134, Cs-137 (7)	400	1,000	1,250	1,000
The level applicable to concentrated or dried products is calculated on the basis of the reconstituted product as ready for consumption. Member states may make recommendations concerning the diluting conditions in order to ensure that the maximum permitted levels laid down in this Regulation are observed. Maximum permitted levels for feedingstuffs will be defined in accordance with Article 7, since such levels are intended to contribute to the observance of the maximum levels for foodstuffs, do not alone guarantee such observance in all circumstances and do not lessen the requirement for monitoring levels in animal products destined for for human consumption. Baby foods are defined as those foodstuffs intended for the feeding of infants during the first four to six months of life, which meet, in themselves, the nutritional requirements of this category of person and are put up for retail sale in packages which are clearly identified and labelled "food preparation for infants". Dairy produce is defined as those products falling within the following CN codes including, where appropriate, any adjustments which may be made to them later: 0401, 0402 (except 0402 29 11). Minor foodstuffs and the corresponding levels to be applied to them will be defined in accordance with Article 7. Liquid foodstuffs as defined in the heading 2009 and in chapter 22 of the combined nomenclature. Values are calculated taking into account consumption of tap-water and the same values should be applied to drinking water supplies at the discretion of competent authorities in Member States. Carbon-14, tritium and potassium-40 are not included in this group.

ANNEX 2: Option 1 for merging MPLs of Regulation 737/90 and Regulation 3954/87

	Foodstuffs Bq/kg or Bq/l (1)
	Baby foods (3)	Dairy Produce (4)	Other foodstuffs except minor foodstuffs (5)	Liquid foodstuffs (6)	Feedingstuffs (2)
Isotopes of strontium, notably Sr-90	75	125	750	125
Isotopes of iodine, notably I-131	150	500	2,000	500
Isotopes of caesium, notably Cs-134, Cs-137	370	370	600	600
Alpha-emitting isotopes of plutonium and transplutonium elements, notably Pu-239, Am-241	1	20	80	20
All other nuclides of half-life greater than 10 days (7)	400	1,000	1,250	1,000
The level applicable to concentrated or dried products is calculated on the basis of the reconstituted product as ready for consumption. Member states may make recommendations concerning the diluting conditions in order to ensure that the maximum permitted levels laid down in this Regulation are observed. Maximum permitted levels for feedingstuffs will be defined in accordance with Article 7, since such levels are intended to contribute to the observance of the maximum levels for foodstuffs, do not alone guarantee such observance in all circumstances and do not lessen the requirement for monitoring levels in animal products destined for for human consumption. Baby foods are defined as those foodstuffs intended for the feeding of infants during the first four to six months of life, which meet, in themselves, the nutritional requirements of this category of person and are put up for retail sale in packages which are clearly identified and labelled "food preparation for infants". Dairy produce is defined as those products falling within the following CN codes including, where appropriate, any adjustments which may be made to them later: 0401, 0402 (except 0402 29 11). Minor foodstuffs and the corresponding levels to be applied to them will be defined in accordance with Article 7. Liquid foodstuffs as defined in the heading 2009 and in chapter 22 of the combined nomenclature. Values are calculated taking into account consumption of tap-water and the same values should be applied to drinking water supplies at the discretion of competent authorities in Member States. Carbon-14, tritium and potassium-40 are not included in this group.

ANNEX 3: Option 1 for merging MPLs of Regulation 737/90 and Regulation 3954/87

	Foodstuffs Bq/kg or Bq/l (1)
	Baby foods (3)	Dairy Produce (4)	Other foodstuffs except minor foodstuffs (5)	Liquid foodstuffs (6)	Feedingstuffs (2)
Isotopes of strontium, notably Sr-90	75	125	750	125
Isotopes of iodine, notably I-131	150	500	2,000	500
Isotopes of caesium, notably Cs-134, Cs-137	370	370	600	600
Alpha-emitting isotopes of plutonium and transplutonium elements, notably Pu-239, Am-241	1	20	80	20
All other nuclides of half-life greater than 10 days (7)	30	630	650	400
The level applicable to concentrated or dried products is calculated on the basis of the reconstituted product as ready for consumption. Member states may make recommendations concerning the diluting conditions in order to ensure that the maximum permitted levels laid down in this Regulation are observed. Maximum permitted levels for feedingstuffs will be defined in accordance with Article 7, since such levels are intended to contribute to the observance of the maximum levels for foodstuffs, do not alone guarantee such observance in all circumstances and do not lessen the requirement for monitoring levels in animal products destined for for human consumption. Baby foods are defined as those foodstuffs intended for the feeding of infants during the first four to six months of life, which meet, in themselves, the nutritional requirements of this category of person and are put up for retail sale in packages which are clearly identified and labelled "food preparation for infants". Dairy produce is defined as those products falling within the following CN codes including, where appropriate, any adjustments which may be made to them later: 0401, 0402 (except 0402 29 11). Minor foodstuffs and the corresponding levels to be applied to them will be defined in accordance with Article 7. Liquid foodstuffs as defined in the heading 2009 and in chapter 22 of the combined nomenclature. Values are calculated taking into account consumption of tap-water and the same values should be applied to drinking water supplies at the discretion of competent authorities in Member States. Carbon-14, tritium and potassium-40 are not included in this group.

Glossary

Artificial radionuclides Also called man-made radionuclides. Radionuclides with half-lives less than about a million years which do not occur naturally. See natural radionuclides.

Becquerel A unit of radioactivity describing the rate at which a radionuclide decays. 1 becquerel = 1 decay or emission per second.

Council Regulation (EURATOM) Number 3954/87 laying down maximum permitted levels of radioactive contamination of foodstuffs and of feedingstuffs following a nuclear accident or any other case of radiological emergency. Official Journal of the European Community No L371 of 30 December 1987, p.11.

Council Regulation (EURATOM) Number 2218/89 amending Regulation (Euratom) No 3954/87 laying down maximum permitted levels of radioactive contamination of foodstuffs and of feedingstuffs following a nuclear accident or any other case of radiological emergency. Official Journal of the European Community No L211 of 22 July 1989, p.1.

Council Regulation (EEC) Number 737/90 on the conditions governing imports of agricultural products originating in third countries following the accident at the Chernobyl nuclear power station. Official Journal of the European Community No L82 of 29 March 1990, p.1.

Council Regulation (EC) Number 616/2000 amending Regulation (EEC) No 737/90 on the conditions governing imports of agricultural products originating in third countries following the accident at the Chernobyl nuclear power station. Official Journal of the European Community No L75 of 24 March 2000, p.1.

Commission Regulation (EC) Number 1661/1999 laying down detailed rules for the application of Council Regulation (EEC) No 737/90 on the conditions governing imports of agricultural products originating in third countries following the accident at the Chernobyl nuclear power station. Official Journal of the European Community No L197 of 29 July 1999, p.17.

Commission Regulation (EC) Number 1609/2000 establishing a list of products excluded from the application of Council Regulation (EEC) No 737/90 on the conditions governing imports of agricultural products originating in third countries following the accident at the Chernobyl nuclear power station. Official Journal of the European Community No L185 of 25 July 2000, p. 27.

Decay, radioactive The process of spontaneous transformation of a radionuclide.

Emission, radioactive General term given to the particle and/or ray given off by a radionuclide during decay.

EURATOM Treaty One of the three treaties establishing the European Community (formally the European Atomic Energy Community). Its purpose is to promote the safe development of nuclear energy for industry and advancement of the cause of peace, and to encourage international co-operation in the field.

Half-life The time taken for the activity of a radionuclide to lose half its value by decay.

Man-made radionuclides See artificial radionuclides.

Natural Radionuclides Radionuclides formed when the earth was made. They are either those with half-lives around a billion years or those with shorter half-lives that arise from the decay of the former.
Radiation dose per unit of radioactivity ingested A value calculated by the International Commission on Radiological Protection for each radionuclide expressed in units of Sievert per Becquerel.
Sievert The international unit of measurement for radiation dose. A milliSievert is one thousandth of a Sievert.

FURTHER BACKGROUND INFORMATION

What is Council Regulation 737/90?

Regulation 737/90 was adopted on 22 March 1990 and replaced earlier Regulations on the same subject. The MPL for radiocaesium, which applies to imported foods, was set at 370 becquerels per kilogramme (Bq/kg) for baby foods, milk and milk products and at 600 Bq/kg for products listed in annex 1 to the Regulation. All other products are excluded from its scope. Small amendments to the text of 737/90 were made by Council Regulation (EC) 616/2000 which also extended the life of Regulation 737/90 until 31 March 2010. Annex 1 of 737/90 has been recently superceded by the annex to Commission Regulation (EC) 1609/2000. Detailed rules for the application of 737/90, including the special conditions relating to the import of non-cultivated mushrooms, are contained in Commission Regulation (EC) 1661/1999.

What are the pre-defined MPLs?

Council Regulation (EURATOM) 3954/87 (as amended by Council Regulation (EURATOM) 2218/89) sets MPLs, reproduced in Annex 1 to this letter, of radioactive contamination for foodstuffs and feedingstuffs offered for sale in the Community which would only apply in the immediate aftermath of a future nuclear accident or any other case of radiological emergency. They are not applicable to Chernobyl origin radioactivity and are intended as a precautionary measure to prevent excessively contaminated food being offered for sale. They would remain in force for no more than three months or until superseded by new legislation coming into force. The 3954/87 MPL for radiocaesium is higher than that of 737/90 and this has given rise to the impression that the Community is operating a system of dual standards for radioactivity in food.

List of Consultees in Scotland

Steve Cannon Aberdeen University
Brian S Pack ANM Group
Mr James Grant Association of Public Analysts of Scotland
Association of Scottish Community Council
Mr Doug McLeod Association of Scottish Shellfish Growers
Brewers Fayre
Mr J MacGregor British Institute of Agricultural Consultants
Mr John Terry British Medical Association
Craig Campbell CBI Scotland
Dr Wendy Wrieden Centre for Public Health Nutrition Research
Tom Young Convention of Local Authorities
Prof John Cummings Department of Molecular and Cellular Pathology
The Chairman Farming and Wildlife Advisory Group
Mr J Downie Federation of Small Businesses
Mr D MacInnes Federation of Highlands and Islands Fisherman
Mr Nick Bailey Fisheries Research Services
Sandra Taylor Food Certification (Scotland) Ltd
Donald Muir Food Quality Group
Dr Susan Morgan-Jones Food Training and Consulting
Friends of the Earth Scotland
Mr J Daly Glasgow Caledonian University
Mr Fred Buchan Glasgow College of Food Technology
E Campbell Glenrothes College
Mr Fred Duncan Grampian Country Food Group Ltd
Scott Erwin Greencity
John Spencer HMP Scotland
Emma Lock Iceland Frozen Foods
Mrs M P Woods Institute of Food Science and Technology
Michael Halls International Federation of Environmental Health
Mr David Cook International Fish Canners Ltd
Mr Les Oman Live Shellfish Traders' Association
Prof T Jeff Maxwell Macaulay Land Use Research Institute
Mrs Mary Berget Moray Seafoods
Dr W Donachie Moredun Research Institute
Mrs J E Castell Mothers' Union
Ms Sarah Bradburn National Farmers Union of Scotland
Mr Trevor A Croft National Trust for Scotland
Mr Hugh Raven Organic Scotland
Mr A Hardie Paterson Arran Ltd
Mr A Donaldson Quality Meat Scotland
The Secretary Roslin Research Institute
Terry Atkinson Rowett Research Institute
Dr Andrew Chesson Rowett Research Institute
Dr Harry J Flint Rowett Research Institute
Mr John Frather Royal Environmental Health Institute
Dr Marc Rands Royal Society of Edinburgh
Mr John Hermse Scallop Association
Mrs M Longmuir Scotch Whisky Association
Dr D Lewis Scottish Agricultural College
Mr A F Murray Scottish Agricultural Contractors
Mr E Rainy Brown Scottish Agricultural Organisation Society Ltd
Dr Jonathan Davey Scottish Agricultural Science Agency
Mr I Hay Scottish Association of Master Bakers
Mr J H A Stevenson Scottish Association of Meat Wholesalers
Mr Les Webster Scottish Bee Keepers Association
Dr Ian Jones Scottish Centre for Infection and Environmental Health
Mr Bill Stitt Scottish Chamber of Commerce
Scottish Conservative and Unionist Party
Ms Donna Heaney Scottish Consumer Council
Scottish Corn Trade Association Ltd
Mr Rory Dutton Scottish Crofters Union
Professor J R Hillman Scottish Crop Research Institute
Mr Kirk Hunter Scottish Dairy Association
Ms J Nelson Scottish Enterprise
Ms Jen Anderson Scottish Environment Link
Ms Julie Tooley Scottish Environment Protection Agency
Mr David Dickson Scottish Executive Environment and Rural Affairs Department
Mr Derek Feeley Scottish Executive Environment and Rural Affairs Department
Ms Jan Polley Scottish Executive Environment and Rural Affairs Department
Mr Jim Halley Scottish Executive Environment and Rural Affairs Department
Dr Arthur M Johnston Scottish Executive Health Department
General Manager Scottish Federation of Meat Traders
Mrs C Cowie Scottish Fish Merchants Federation
Mr Ian Duncan Scottish Fishermen's Federation
Mr J B Tudor Scottish Flour Miller's Association
Ms Flora Mclean Scottish Food and Drink Federation
Dr C McDonald Scottish Food Co-ordinating Committee
Ms Margaret Harvey Scottish Food Quality Certification
Ms Claire Whitelaw Scottish Food Safety Officers
Mrs M McTear Scottish Food Trade Association
Dr Nina Baker Scottish Green Party
Mr Scott Landsburgh Scottish Grocers Federation
All Scottish Health Boards
Ms Sheena Dunlop Scottish Health Food Retailers
Mr C H Gillespie Scottish Hotel School
Scottish Labour Party
Mr J R Hall Scottish Landowners Federation
Scottish Liberal Democrats
Mr E W Ridehalgh Scottish Licensed Trade Association
All Scottish Local Authorities
Scottish National Party
Scottish Natural Heritage
Mr Chris Atkinson Scottish Organic Producers Association
Mr Brian Simpson Scottish Quality Salmon
Mr Patrick Browne Scottish Retail Consortium
Mrs S E Watson Scottish Seed and Nursery Trade Association
Mr Tommy Sheridan Scottish Socialist Party
Scottish Soft Fruit Growers Association
Scottish Trade Union Congress
Dr David Sanderson Scottish Universities Environmental Research Centre
Housewives Committee Scottish Womens Rural Institutes
Mr Scott P Brady Scott P Brady Food Consultant
Mr David Cleghorn Sea Fish Industry Authority
Ms Julie Allison Solway Shrimps
Mr Charles Young UKASTA
Mr Gibson UK Association of Fish Producers Organisations
Miss E Taylor Uni-Lever Best Foods
Professor G A Codd University of Dundee
Professor Jackson University of Strathclyde
Mr Hugh Edmonds VTSC Growers Association
Miss M H Walker Walkers Shortbread Ltd
West of Scotland Fish Processors Association
Mrs K Salmon Wholesale Grocers Association of Scotland

List of Consultees in Northern Ireland

Prof Jack Pearce Department of Agricultural and Rural Development
Mr S Miskelly General Consumer Council for Northern Ireland

List of Consultees in England and Wales

The Company Secretary AEA TechnologyPlc
Ms Julie Williams Amersham Plc
Ms R Pascal Argyll Stores
The Secretary Association of Consumer Research
Mr Trevor Dixon Association of Convenience Stores
Mr P Rotherham Association of Port Health Authorities
The Company Secretary AWE Plc
The Company Secretary BAE Marine Systems Ltd
Dr K Pearce BNFL Magnox
Ms Louisa Platt British Egg Industry Council
Mr Robert M Armour British Energy Generation (UK) Limited
Ms Katherine Anderson British Fruits and Vegetable Canners
Mr Steve Hillier British Meat Manufacturers Association
Mr Roger Coates British Nuclear Fuels Plc
Mr Alan Kite British Nuclear Fuels Plc
Ms K White British Nuclear Industry Forum
Mr John Morris British Retail Consortium
Mr Alain Zenetti Campbells Grocery Products Ltd
Mr C Crews Central Science Laboratory
Mr P Brereton Central Science Laboratory
Dr D Swift Centre for Environment, Fisheries and Aquaculture Science
Mr Graham Jukes Chartered Institute of Environmental Health
Dr Roy Hamlet Committee on Medical Aspects of Radiation in the Environment
The Secretary Consultant in Food Law and Legal Metrology
Ms Sue Davies Consumers' Association
Mr S Crampton Consumers in Europe Group
Mr M Forwood CORE
Dr E S Komorowski Dairy Industry Federation
Mr Philip Edmunds Department of Environment, Food and Rural Affairs, Horticultural Division -A
Miss Angela Pawlyn Department of Environment, Food and Rural Affairs, Horticultural Division-A
Mr Chris Wilson Department of Environment, Food and Rural Affairs, Radioactive Substances Division
Mr G Hooker Department of Health
Dr Hilary Walker Department of Health
Mr Robert Gunn Department of Trade and Industry
The Company Secretary Devonport Royal Dockyard Ltd
Mr J Titley Environment Agency
Dr Joe McHugh Environment Agency
Mr Kevan Williams Eurofins Science
The Secretary Farmers Union of Wales
Mr Bob Parry Farmers Union of Wales
Ms Lindsey Stanberry Federation of Agricultural Co-operatives
Mr Steven Norton Federation of British Wholesale Fish Merchants Association
The Secretary Food & Environment
Mr D Bellamy Food and Drink Federation
Mr J T Winkler Food and Health Research
Mr Tim Lobstein Food Commission
Dr S J Fallows Food Policy Update
Mr J Taylor Food Technologists
Mr R Parker Fresh Fruit and Vegetables
Mr D Henderson Fresh Produce Consortium
Dr P Green Friends of the Earth
Dr H Wallace Greenpeace
Mr C Brock Griffiths Laboratories
Mr L Williams Health and Safety Executive
Mr Miles Harriman Hydro Agri UK Ltd
Prof A Goddard Imperial College Reactor Centre
Dr B J Howard Institute of Terrestrial Ecology
Mr J Gordon-Smith J Gordon-Smith
Mr Brian Pitcher J Sainsbury Plc
Mr L Bailey LACOTS
Mr M Ainscough Lancashire County Laboratory
Ms Eva Hurt Leatherhead Food Research Association
Mr R Mitchell Marks & Spencer Plc
Mr Peter Wight Marks & Spencer Plc
Mr M Tunnicliffe MRC Ltd
Dr H Prosser National Assembly for Wales
Ms Sue Dibb National Consumer Council
The Secretary National Council for Women
Mr David Brown National Farmers Union
Ms Stella Walsh National Federation of Consumer Groups
Mr Barry Deas National Federation of Fishermens Organisations
The Home Economics Advisor National Federation of Women's Institutes
Mr G Cannon National Food Alliance
The Secretary National Housewives Association
Mr Malcolm Thomas National Farmers Union, Wales
Miss F Fry National Radiological Protection Board
Dr B Wilkins National Radiological Protection Board
Ms Pam Vassie Nuclear Awareness Group
Dr D Davies Nycomed Amersham Plc
Mr Scott Denyer Nycomed Amersham Plc
Mr Tim Green Organic Farmers and Growers Plc
J Wade Organic Food Federation
Mr Robert Jackson Radioactive Waste Management Advisory Committee
Mr D Amor Reading Scientific Services
The Company Secretary Reading Scientific Services
The Company Secretary Rolls Royce Marine Power Operations Ltd
The Company Secretary Rosyth Royal Dockyard Ltd
Dr A Robertson Safeway Plc
Mr Alistair Fairburn Sea Fish Industry Authority
The President Society for Radiological Protection
Mr G Hudd Somerset County Council
Mr Stuart Challenor Tesco Plc
The Company Secretary The Provisions Trade Federation
Mr Jamie Woolley Legal Advisor, Nuclear Free Local Authorities
Mrs Jenny Richards UKAEA
Mr Geoffrey Molloy UK Association of Frozen Food Producers
Ms C White Unilever
Mr A Dell Veterinary Laboratories Agency
Mr Alan Wilson Waitrose Ltd
Mr Andrew Jones Welsh Collaboration for Health and the Environment
Mr Llewellyn Welsh Consumer Council
Mr J Desmond Welsh Food Alliance
Mr Colin Jones Welsh Local Government Association
Dr D Jackson Westlakes Research (Trading) Ltd
The Chairperson Women's Farming Union
Mr W Anzer
Dr Barrie Lambert

This consultation has been prepared in accordance with the HM Government Code of Practice on Consultation, which states that a consultation must follow better regulation best practice, including carrying out an Impact Assessment (Regulatory Impact Assessment in Scotland). The assessment is included in the consultation documents.

We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process. If you would like to assist us to improve the quality of future consultations, please feel free to share your thoughts with us by using the consultation feedback questionnaire.

Consultation feedback questionnaire (Word)

Consultation feedback questionnaire (pdf)

In accordance with the FSA principle of openness our Information Centre at Aviation House will hold a copy of the completed consultation. Responses will be open to public access upon request. The FSA will also publish a summary of responses, which may include personal data, such as your full name and contact address details. If you do not want this information to be released, please complete and return the Publication of Personal Data Form. Return of this form does not mean that we will treat your response to the consultation as confidential, just your personal data.

Data protection form (Word)

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Within three months of a consultation ending we aim to publish a summary of responses received and provide a link to it from this page.

If, after three months, the summary is still not showing, please contact the person who was responsible for the original consultation. Alternatively, you can contact Judith Taylor, the FSA Consultation Co-ordinator, on 020 7276 8633.
Email: judith.taylor@foodstandards.gsi.gov.uk