Protecting consumers in the future world market

All of us in the hall are experts on food in one way or another, but so are the other 59 million people in this country. Everyone has a view about food, which makes it at the same time a remarkable and a tendentious topic.

I was struck last weekend by the glorious display of new cookery books in my local bookstore in Oxford, each one encouraging us to cook, eat and enjoy. Right next to them was an equally large and impressive array of diet books exhorting us to eat as little as possible!

I hope tonight, to make a good salad because, if I may paraphrase Oscar Wilde, 'to do so is to be a skilled diplomat, as it means knowing exactly how much oil one must put with one's vinegar.'

I am going to talk about consumer confidence. I will touch upon issues that are close to many of you: dealing with risk in a continually changing global food market, the challenges that will arise from European enlargement, and the task that we all face in maintaining and improving consumer confidence.

Just a couple of weeks ago, the Sunday papers were full of their end of year reviews.

As I glanced through my half hectare of forest turned into newsprint I was struck by the recurrence of three words that seemed to capture the year-end mood:

uncertainty, risk and trust. Whilst these are not new issues, they seem to have renewed emphasis.

Uncertainty: life seems less certain than before, whether we think of our jobs, the threat of war, climate change, or whether or not the train will arrive!

Risk: we seem to be faced with so many risks - pensions, street crime, terrorism, or vaccinating our children with MMR.

Trust: whom do we trust nowadays? Not necessarily private companies after Enron, Worldcom and Equitable Life; not public institutions, including those of Government, of which we are suspicious.

How does this climate affect consumer confidence in the food we eat?

The Food Standards Agency is, in a real sense, a child of the BSE crisis. It was set up, nearly three years ago, to restore public confidence in the way in which Government handles food safety issues.

Setting out to restore public trust is, if you think about it, a slightly unusual mission. And, given the recent history of food safety in the UK, a somewhat tall order. The Government was, in my view, very bold in setting up the Agency and giving us powers of independence that make us rather different from other Government departments.

We do not have a minister at the helm, and we have unique powers to publish our advice without seeking ministerial permission. And we have a Board that discusses and decides policy in public.

So we have a degree of independence, transparency and accountability that safeguards our role in putting the consumer first and ensures that we take balanced judgements.

I should make it absolutely clear that I, and the FSA Board, firmly resist any attempt, from whatever quarter, that seeks to compromise our independence.

Our starting point in protecting consumer interests is that food, like everything else in life, cannot be guaranteed to be totally risk free. What is more, quite often the risks are not precisely known – there is uncertainty. This means that in managing risks we have to come to a judgement, informed by the best available scientific advice, on what is an acceptable risk. In reaching this judgement we try to involve as many points of view as possible and to do so in an honest and transparent way.

Generally speaking, standards of food safety in the UK are high, arguably higher than ever before, and people have confidence in the food they eat. But there is a legacy of public mistrust and suspicion of government in this area that is deep and pervasive.

Trust is, perhaps, the most valuable of commodities. It is something you can't buy. The more you ask for it, the less likely you are to get it. It is a fragile commodity: once you have it its all too easy to lose. Opinion polls suggest that doctors, teachers, clergymen and campaigning organisations tend to have it, whilst Government and industry has less of it.

And it goes without saying that trust is earned as a consequence of doing things: both what you do and how you do it.

By many accounts the FSA has made some headway at the start of our long journey to earning public trust and confidence.

We measure ourselves in a variety of ways, including a large-scale annual survey of public attitudes and opinion. In our three years, public awareness of the FSA has risen steadily from 58% (in 2000) to 76% (in 2002).

Half the population considers the FSA an organisation they can trust and nearly 90% of people who have received information from the Agency think we are a reliable source. Confidence in the role of the Agency in protecting health with regard to food safety has increased from 50% in 2000 to 60% in 2002.

At the same time, most people have become less concerned about food safety than they were three years ago.

Research by the National Consumer Council suggests that people have more confidence in Government handling of food safety risk than other areas, and Mintel's most recent report on the food industry concludes that the FSA is helping to restore public trust in the food chain.

So how has the FSA contributed to some of these changes over the past three years?

Some might say that we've been lucky, with no major food crises to torpedo us.

But actually there have been big potential crises during the past three years. You'll no doubt have your own top ten, but mine would include the following.

The risk of BSE in imported beef, following the discovery that the UK was not alone in Europe in having the disease.

Chemical contaminants such as the surprise discovery of acrylamide in many kinds of food, and the emission of dioxins from Foot and Mouth funeral pyres.

The possible risk of BSE in sheep

But, in part, the way we have dealt with these risks, working closely with industry, consumers and other stakeholders, has meant that they have not become crises in consumer confidence.

What we have been exploring in the past three years is a different way of doing things; one that is at the same time more honest and more transparent.

Contrast this approach with that of the 80s and 90s. Each new revelation dragged out of Government and industry compounded the perception that there was something deeply rotten in the system.

For instance, when we first started to talk about the possible risk of BSE and sheep we were not saying anything that was fundamentally new, but the way we said it was new. We did not disguise the uncertainties and we provided clear advice to consumers. And we said it very publicly.

We said: 'Scientists cannot rule out the possibility of BSE in sheep. None has been found to date but it could be there at a low level and it could pose a food risk. We don't advise you to stop eating lamb, but you the consumer can make up your own mind. We will keep in touch as we find out more.'

It turned out that many people, and importantly the media, were ready for this more honest, straightforward yet more sophisticated message. It is one that gives people options and responsibility, and I think it also leads to two way trust: 'We trust you to make your own choices and you trust us to tell it straight.'

We put a lot of effort into analysing how our messages are conveyed in the media and interpreted by the public, or to be more accurate publics, since there are many different kinds of people out there.

For BSE and sheep, our research showed a surprisingly high level of public awareness of the message and understanding of its key elements.

Whatever difficulties there may be in being honest about uncertainty, they are far preferable to the alternative, which Lord Phillips in his Inquiry into BSE called the 'culture of sedation' and which he said led to a sense of betrayal by the public when the facts finally emerged.

BSE has been recognised as a food risk for about 10 years. But acrylamide was discovered more or less by accident in many kinds of cooked food only a few months ago. Although the knowledge is new, the risk itself has probably been there since our stone-age ancestors started cooking. We probably will not know for some time how big a risk it is as a cancer-causing chemical.

We should not be surprised if other such potential risks emerge, not least because analytical techniques are getting more powerful in detecting them. Dioxins can now be measured to ten parts per quadrillion. Before you start counting the noughts, think of it as detecting a single post-it note on the surface of the United Kingdom!

Each new discovery will raise questions about how the risk should be managed and communicated. Transparency and honesty, acknowledging that food is not risk free, and that there are uncertainties, are for me important parts of maintaining public confidence.

Our new style of communication is not always comfortable for you in the industry, especially when it comes to naming individual brands.

I hope, however, that you share with me the recognition that it is a far more effective way for Government to deal with risk and uncertainty about food, and that there are benefits for everyone, not least those of you who produce and sell food.

Of course, all of this takes place within a framework where European institutions are beginning to play a greater and, in some cases, dominant role.

Increasingly assessment and communication of risk and uncertainty will be done at a European level; most of our food legislation comes from Brussels; and, with the free flow of goods within the single market, for food imports the border controls of other member states are our border controls.

In thinking about what this means for the future, we should remind ourselves of the obvious: cultural differences are still important. And this will be accentuated in 2004, when Europe expands to include 25 member states and around 450 million citizens.

The science of risk assessment is the same in Newcastle and Naples, but consumer acceptability of risk may differ between countries, and that will influence risk management decisions.

Therefore we cannot blithely assume that what works well for us in the UK will work equally well elsewhere in Europe.

However, I suggest that there are common principles. First, the assessment of risk should be based on the bedrock of the best available scientific evidence and opinion. Second, the basis of any scientific advice, including the uncertainties, should be fully exposed. Third, the translation of this advice into policy should be carried out in a transparent way that includes a dialogue with all stakeholders.

We will strongly support the new European Food Safety Authority in its role in bringing this approach to the European stage. The fact that Geoffrey Podger, who has been outstanding in establishing the Food Standards Agency in the UK, is to be the first Executive Director of EFSA, augurs well for the future.

We certainly hope that EFSA will rapidly come to command the authority to prevent a recurrence of the bogus food safety arguments that were used to prevent exports of British beef. It cannot be acceptable for food safety to be used as a political football in Europe.

European enlargement, now firmly on the horizon, will bring consumer benefits, but also possibly new risks.

For one thing, there are food-processing plants in the new member states that do not meet EU standards, and they will have to be upgraded or closed. But upgrading will take time and meanwhile compliant and non-compliant products will have to be segregated.

I hardly need to say that this will create opportunities for accidental mixing or fraud, which in turn could erode consumer confidence if and when it is uncovered. Within the European framework, regulators will play their part, but industry will also have to be vigilant in checking its sources to ensure safety and standards are upheld.

Equally, the new borders of the expanded Europe will present a challenge for the integrity of our food supply. Eighty-seven new inspection points at the new external borders will have to be created to check legal imports and to stop illegal imports slipping through from countries outside. As I have said, the borders of other member states are our borders, so simply enhancing our UK import controls will not help.

Public authorities will check as much as they can, but given the scale and complexity of what will be taking place, UK importers will have a major responsibility for ensuring the security of their supply chains.

Closer to home, here in the UK we are fortunate indeed in the choice, quality and affordability of food on offer. Technological innovation in production and manufacture, together with improved storage and transport mean that we all enjoy food choices, standards and prices that are beyond our grand-parents' dreams.

So far, so good. But let's not forget that the 20% poorest households in Britain already spend 30% of their net income on food - for them, affordability will always be a key issue.

Changing lifestyles have also dramatically affected our consumption of food.

Almost half of us eat convenience foods on a regular basis. And we eat out more than ever before.

In effect, much of what we eat nowadays is not made by us, from raw ingredients, in our own homes, but by the hands of others – the food industry.

At the same time, there is increasing press coverage of, and public interest in, diet and health, a trend reflected in the huge range of healthy eating options on offer.

And here, I suggest, the industry can have a significant impact on both public confidence and public health.

Take one simple ingredient, salt. We all need to consume salt: it is a vital nutrient at all stages of life. But as with everything else, you can have too much of a good thing. And the scientists say that in the case of salt we are all having too much. In fact about one and half times as much as would be good for us.

The FSA’s independent scientific advisory committee on nutrition has concluded that the evidence for a direct association between salt intake and blood pressure is stronger than ever. And high blood pressure means a higher risk of heart disease and stroke.

All of us must, of course, do what we can to look after our own health. But since as much as 75% of the salt we eat is in ready-prepared foods, I believe that the food industry can and should help.

Therefore I very much welcome the steps already taken by the bakers to reduce the salt content in bread.

And I am delighted that we are working with the food industry across the board to find ways of reducing the salt content of prepared food. This will bring real public health benefits as well as public confidence.

I have no doubt that the industry has the ingenuity to reformulate many products to retain their taste attractiveness whilst reducing their salt content and I look forward to seeing how this will be achieved.

There is an argument that healthy eating is simply down to consumer education and choice. The industry offers the choice, which may include a range of foods that are patently high in, for example, sugar, salt or saturated fats, and consumers have the right (as well as the responsibility) to choose; and anything else is nannying.

But how tenable is this given the rise of obesity in the population and the higher profile of other diet-related issues? These particularly affect consumers on low incomes who are least able to exercise choice.

Certainly, if consumers are expected to exercise prudent choice, the industry must be honest and transparent about what is on offer if it wishes to retain consumer confidence.

The Agency has worked closely with industry and consumer organisations to bring in new guidance to tackle some of the most, shall we say, exotic, claims that are sometimes made. These include terms like 'natural', “traditional”, “pure” and “country fresh”. We will be undertaking a survey this year to see whether or not these claims are still being made in ways that could mislead.

However, a quick shopping trip will also show shelves that are bursting with foods that claim to be low fat, low sugar, high fibre, vitamin enriched, or virtually fat free. In some cases these health claims are fine, but in others they are potentially misleading.

For example, our research shows that one-third of consumers do not know that a food labelled “80% fat free” contains 20% fat.

And 20% fat is pretty high!

Reverse the claim: “20% fat”. No grounds for consumer confusion there!

We need to ensure that when people want to eat healthily, they can make the right choices just by reading the label.

The shelves of our food stores are also becoming increasingly laden with foods that go further, claiming to give a particular health benefit, for example cholesterol-lowering spreads, heart-protecting cereals, calcium-enriched juices, and bio yoghurts. What exactly does bio yoghurt do for your health? I confess I am not sure.

At the moment there are no specific Community or National rules on health claims, despite the increasing number of food products which carry them.

To put an end to consumer confusion, we have argued that such claims should be scientifically based and go through an approval process.

In June 2002 the Commission produced a draft proposal for harmonising rules on health, nutrition and functional food claims, and it is likely to adopt a formal proposal in 2003.

But it will be some years before these controls are fully in place, and in the meantime we look to the food industry to participate in the voluntary Joint Health Claims Initiative, to ensure that health claims are properly substantiated.

It is just not acceptable for bogus health claims to be made in relation to food and it contributes to consumer cynicism. That is why the Agency, in supporting the Joint Health Claims Initiative, will this year be undertaking a wide-ranging audit of the claims for food currently on sale. We will, of course, in line with our usual practice, publish our results.

Another area of confusion relates to how our food is produced, and the claims that are made in relation to particular styles of production. In recent months, partly as a result of Don Curry’s report on the future of food and farming, there has been renewed interest in food assurance schemes.

Our view on these schemes is straightforward. In principle, they are a force for good. Not only can they help to ensure that legal requirements of production have been met, but they can also foster innovation - taking production standards beyond minimum requirements and hence providing further choice for consumers.

The schemes can help improve standards for safety, as well as animal welfare, environmental stewardship and so on, although this may come at a price premium.

The problem at the moment is that, as our research shows, consumers have little understanding of what “assurance” means. And the ways in which claims are justified and checked is not transparent enough. People may be being hoodwinked.

If assurance schemes are to play a significant role in raising standards and building consumer confidence, they must be committed to the principles of honesty, transparency and independence.

I am pleased to see that producers are aware of these needs and are attempting to meet them.

But what about assurance of imported food? The same principles should apply for any assurance claims, wherever the food originates.

And of course we as a nation will continue to rely on imported food in the future as we have done in past centuries.

Locally produced food is an important part of the mix, but by no means the whole story. Nor is this new: Daniel Defoe remarked in 1725 that 'England consumes ...more goods of foreign growth ...than any other nation in the world.'

We live on a small island, stuck in a windy corner of the Northern Hemisphere, with a big population, and agricultural conditions that limit what we can produce, even though productivity has steadily increased in the last 50 years.

Does the complexity and length of the global food chain bring increased risks?

The devastation of the foot and mouth epidemic is still fresh in our minds. Although not a food safety risk, there could be no more compelling demonstration that the movement of people and commodities around the world can carry risks to animal health.

We do not know, and probably never will know, how the deadly virus made its way into Britain, but one suggestion that has been made is that it came in on illegally imported meat.

However, for me the appropriate response to these risks, whether to animal or human health, is not to try to create “fortress Britain”, with the barriers manned to keep out imports. Rather, it is to be better equipped, as other countries in Europe affected by the epidemic seemed to be, to stamp out problems when they arise and to more effectively manage any risks that may be present.

Last year, the European Commission suspended imports of products of animal origin from China because an illegal drug was discovered in Chinese honey. Honey quickly disappeared from many supermarket shelves, as much of it came from China.

But an unexpected consequence was that frozen white fish from the Bering and Barents Sea was also caught up in the ban as the fish was being transported thousands of miles to China for processing - before being exported to the UK. This illustrates how the increasing complexity of the global food market throws up new challenges for risk management.

Of course protection of public health was paramount. But there was considerable inconvenience for many in the industry and, for a while, consumer choice was restricted.

My question is this. Should it have been left to the European Commission to discover the problem and impose a blanket ban, or should the industry itself have taken more steps to check imported products?

Which has a bigger impact on consumer confidence: pre-emptive vigilance by the industry, or the removal of foods from the shelves after the consumer has eaten them?

I think there may be room for food manufacturers and retailers to be more pro-active in ensuring that the materials they use meet the required standards. In this way unacceptable levels of contaminants can be kept out of the food supply without the need for the recalls and withdrawals that cause you so much concern and cost. This applies as much to home produced foods as it does to imported foods.

But perhaps confidence can also be built by going further than the minimum requirements for protecting health. For example, some, perhaps many, consumers say they prefer not to eat pesticide residues on their fruit and vegetables.

The Board of the Food Standards Agency agrees that residues of pesticides should be minimised. Some producers achieve low enough levels that are not detectable with current analytical techniques. Why can't these elements of best practice be adopted by all, not because there are health risks, but because they meet consumer concerns and build confidence?

I hope you agree from what I have said that the FSA has made headway in starting to rebuild consumer confidence in the way that Government handles food issues. This has been achieved through partnership both with the industry and with other stakeholders.

But we still have a long way to go.

We will continue to play our part and we look to the food industry to continue to work with us in our honest and open approach, whether it's to do with safety, nutrition or choice. The food industry has an extraordinary record of innovation and I am sure that you will continue to deploy this to deliver consumer benefits and confidence as you have done in the past.

It may be that we will look back on the food scares of the 80s and 90s as an historical aberration; an unfortunate co-incidence of events, that may never be repeated. But BSE will cast a long shadow and it may be many years before it fades.

No one would want to see such a situation again. We can never predict such events and we can never be complacent.

What we promise is that we, at the Agency, will not return to the false reassurances of the past. We will be honest about uncertainty, and we will continue to work in the public interest. These are our stepping stones for building consumer confidence in an increasingly complex and changing world.