Why the World Health Organization laughs at Britain's Food Standards Agency

"The World Health Organization laughs at it. Consumer organisations rail at it. Environmentalists despair over it. MPs ridicule it. Even the Women's Institute is unhappy."

Probably the best (and certainly the longest!) article ever written on Sir John Krebs and the Food Standards agency which he heads
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Gluttons for punishment
By Richard Girling
The Sunday Times Magazine
March 28, 2004
http://www.timesonline.co.uk/article/0,,2099-1044017,00.html

Its findings smell fishy, its dietary advice is confusing and doesn't amount to a hill of beans. It's had to eat humble pie and runs around like a headless chicken. Is Britain's food watchdog dressed mutton as lamb?

The World Health Organization laughs at it. Consumer organisations rail at it. Environmentalists despair over it. MPs ridicule it. Even the Women's Institute is unhappy.

In the eyes of many who ought to be its allies, the Food Standards Agency (FSA) has been worse than a disappointment. To people who care about what they eat, and who believe that the UK's official food monitor should have a wider duty than to certify the harmlessness of chemical additives, it has been the kind of friend that makes enemies unnecessary. It loves GM. Hates organics. Exalts science to the position once occupied by gods. Pays no more account to public opinion than it might to the clucking of a hen.

It was not supposed to be like this. When the FSA was set up four years ago, its aim was "to be trusted as the most reliable source of advice and information about food". To the pressure groups that had been campaigning for it, April 2000 looked like the end of an anti-consumer Dark Age. Until then, food had been the responsibility of the Ministry of Agriculture, Fisheries and Food (Maff) - the very same outfit that was responsible for the protection of farmers. Was Maff ever going to uphold the interests of consumers against the industry? You've only got to look at the degradation of the farmed landscape to see the answer to that, never mind cast your mind back to salmonella, foot and mouth, and BSE. Its scientists were forever telling us that everything was hunky-dory when we all could see that it wasn't.

The FSA, then, strode into the breach like a toqued crusader. Here was our champion! It had a meaty annual budget (last year it rose to GBP95m for England alone), with more than 600 staff at its London headquarters and another 107 at its outstations in Cardiff, Aberdeen and Belfast. Agribusiness and food manufacturers had better watch out. Chemically inflated yields, water-injected meat, fraudulent food labelling, filthy restaurants and pesticide-riddled greengrocery were yesterday's story. Tomorrow's was all about the consumer.

The toqued crusader, alas, had feet of pastry. Following a far from laudatory report by the National Audit Office last year, the agency was savaged by a plainly exasperated House of Commons public accounts committee (PAC). Crudely summarised, the PAC's conclusions were that the FSA had failed to give a public lead on food safety issues; was an incompetent communicator with a next-to-zero public profile; was unclear about its own responsibilities, powerless to make local authorities meet their inspection targets for restaurants and other food outlets, and a political minnow when set against food-manufacturing giants, the EU and other government departments with different agendas.

Nothing better illustrates the muddle it has got itself into than the issue of farmed salmon. It first got snarled up with this in January 2001, when BBC television screened a controversial documentary suggesting that farmed fish were being contaminated through the food chain with carcinogenic dioxins and PCBs. Trouble arose when the presenter, Julian Pettifer, asked an FSA scientist whether he was happy for children to eat more than a single portion of farmed salmon a week. Viewers then saw the scientist, Dr Nigel Harrison, flounder and fail to answer, and an FSA press officer step in to halt the interview.

The agency compounded this public-relations disaster by complaining to the Broadcasting Standards Commission. Dr Harrison, it claimed, had been subjected to an unnecessarily aggressive interview; the programme had portrayed the FSA as "secretive, heavy-handed and censorial"; it had unfairly implied that the press officer had ended the interview prematurely, and that, by filming her intervention, the programme makers had infringed her privacy. It even complained about criticism of its website. The BSC, having watched the film, rejected the complaint in its entirety.

Most organisations would have found such humiliation salutary. Lessons would have been learnt; the website cleaned up; straightforward answers given to straightforward questions. How, then, did the FSA respond in January this year when the American peer-reviewed journal Science dropped another toxic bombshell? Researchers from the University of Albany in New York state had tested seven tonnes of farmed and wild salmon collected from around the world. As everyone now knows, the results were devastating. Concentrations of carcinogenic chemicals in Scottish farmed fish were so high, the scientists said, that consumers should eat no more than one portion of it every four months.

As always, the FSA invoked the highest authority: "The World Health Organization," it said, "set safety levels for dioxins and PCBs in 2001 based exclusively on public health protection. These form the basis of safety levels set for consumers who eat fish sold in shops."

To check the truth of this, I call the WHO headquarters in Geneva. A scientist in the chemical-safety department agrees to check the FSA website, and a few hours later calls back with the verdict. The FSA's assertions, he says, are not justified by the science it has published. The presentation of evidence is misleading. The WHO disapproves of the way the FSA has presented its assessment of risk.

The agency is right about one thing. The WHO does set recommended safe limits for PCBs, but it does so on the basis of total diet, not on individual foods. There is no specific recommendation for "fish sold in shops" (or any commodity, for that matter). Yet the FSA's reassurance had gone further: "The known benefits of eating oily fish," it said, "outweigh any possible risks". For it to be a problem you would need to eat more than our recommendations every week throughout your lifetime."

This makes the man in Geneva laugh out loud. "You can't justify or deny it," he says. "They haven't presented data on the website to defend it. We don't like to see risk assessments presented like this. Consuming above the recommended level may not cause problems, but it might. There are a lot of uncertainties involved in picking that level." This is not a new concern for the WHO. In 2001 it became so worried by what was being said in its name that it issued a corrective statement: "WHO's recommendation concerns maximum daily intake of dioxins, not salmon [our italics]."

This time round, the FSA beefed up its response with two scientific papers of its own, linked from the website in early January. The first of these uses data collected in 1996, measured against even older WHO recommendations that have long been superseded. Interesting the paper may be, but it's about as relevant as last year's weather forecast. WHO scientist's verdict:

"I don't know why it's there." The second paper is about "dioxins and dioxin-like PCBs in the UK diet". Again it concerns the overall diet, not specific foods. The survey did include fish, but they were of various kinds, collected from 24 different places in the UK and "composited into a single sample for analysis".

Asked how this might help a consumer decide how much salmon is safe to eat, the WHO expert is unequivocal: "It doesn't." There is nothing wrong with the science as such; the problem lies with the way it has been used. "It is presented very poorly because it's the first thing you're directed to. It was certainly very confusing to me."

His confusion is widely shared. Sue Davies, the principal policy adviser of the Consumers' Association, is one of many who return to the question that won't go away. "The FSA," she says, "should be clearer about whether consumers should avoid eating more than a single portion of salmon a week."

The problem is that the FSA literally has no answer. It knows that an "average" balanced diet, containing one portion of oily fish a week, should do more good than harm. Beyond that, as the WHO expert testifies, it really has no idea. But the WHO is not the only authority on toxicology. The US Environmental Protection Agency (EPA) also publishes guidelines for dioxins and PCBs and, unlike the WHO's, these do relate specifically to fish. It was for this reason that the Albany group decided to measure their results against the EPA's guidelines rather than the WHO's.

Dr Paul Johnston, principal scientist in the Greenpeace research laboratory at the University of Exeter, has no doubt about which ones to trust. "All WHO says is that you should eat a balanced diet. Assertions that salmon, or anything else, conforms to WHO guidelines, are untrue. Averages are very dangerous because they don't take account of individual behaviour. Some people may eat salmon three times a week, and no advice is given about that."

He does not believe the FSA under its present leadership is capable of reform, particularly as so many of its staff were hired from the ranks of Maff and still carry the echo of that weary old drone's anti-consumerist dogma. "What's needed," says Johnston, "is root-and-branch reform of the FSA. Given its various pronouncements on GM and organics, the man at the top ought to consider his position very, very carefully."

The man at the top is the agency's chairman, Sir John Krebs, a distinguished zoologist with a specialism in bird behaviour. He is above all a man of science, whose opinion of GM protesters, organic-food producers and their customers is like that of a medieval pope for the Muslim hordes. Contempt by comparison would be an expression of high regard. Criticism of GM food, he said, was "shrill, often ill-informed and dogma-driven". Organic food was an "image-led fad".

In appearing to align the FSA with the biotechnology industry, and in opposing European legislation on the labelling of GM foods, the FSA under Krebs's leadership bizarrely set itself up in opposition to its own core supporters. In an otherwise generous appraisal of the agency's work in its first three years, the Consumers' Association awarded it one mark out of 10 for its performance on GM. In March last year, together with the National Consumer Council and Sustain, it wrote to Sir John Krebs in terms that left little room for misunderstanding. The FSA's stance on GM, it said, "while claiming to be impartial, is anti-consumer and biased in favour of GM technology".

"Our main criticism is of the FSA's website, entitled 'GM public debate'. The content is biased, failing to address issues currently facing UK consumers and selective with the information chosen to be included. In many cases, what are set out as 'basic facts' give a one-sided view. The FSA's decision to take a prejudicial view towards GM will affect its credibility and undo the good work it has done in other areas. The information appears to have little to do with the desire to have a meaningful debate; rather, it is a defence of the government's approach".

Nor was this the only stinger in Sir John's postbag. Only a week earlier, another group of signatories, including the National Federation of Women's Institutes, the Food Commission, Soil Association, Friends of the Earth, Greenpeace and the health union, Unison, had blazed away in very similar terms. "There is a strong consensus amongst consumer and environment organisations that the published views and statements of the FSA and its Chair are indistinguishable from those of the pro-GM lobby and do not properly represent public health and consumer interests." Most bruising of all for a man of science, the WI group attacked not just the perceived prejudice of the website but the validity of its research. It deplored the agency's "willingness to rely on unpublished or confidential corporate data that is neither independent, nor peer-reviewed nor available to the public".

They might as well have saved their ink. Over a long weekend the very next month, an FSA "citizens' jury" heard witnesses from interested parties - environment and consumer groups, scientists, GM companies, food manufacturers and supermarkets - and delivered its verdict. GM crops, it said, should not be grown in Britain. The following day, the FSA issued a press release: "FSA citizens' jury says GM foods should be available to buy in the UK." This was true: a nine-strong majority of the 15 "jurors" had decided British shoppers should be able to buy imported GM foods if they wanted them; but all 15 were unanimous that the crops should not be grown here. Not only was this not thought worthy of a headline, it was not even mentioned in the text.

It left Sue Dibb, senior policy officer of the National Consumer Council and herself a member of the FSA consumer committee, bemused at the FSA's continuing inability to grasp what was being said to it. "I think it regrettable that UK government policy did not reflect what consumers were very clearly saying they wanted. Safety is not the only issue that concerns many people about GM."

The FSA was out of step not only with British public opinion but also with the rest of the EU. Alone among European nations, the UK argued against the European commission's proposal for compulsory labelling of GM "derivatives" - ie, ingredients such as soya oil, whose provenance is not detectable in manufactured products. Alone, too, it wanted the entire thrust of labelling policy reversed - for GM products to count as the norm, and for the rest to be labelled "GM free". It lost the argument, but only after it had spent vast amounts of time and energy justifying its position (it insisted that the law would be unenforceable). It is this that frustrates people who support the FSA's ultimate aims and objectives, but who find themselves forced into opposition. "Time spent arguing that extended labelling can't work," says Sue Dibb, "could have been spent making it work."

In the end, the agency just looked out of touch. UK food manufacturers and retailers, being more sensitive to the public mood, are careful to keep GM ingredients off the shelves; and the labelling of GM derivatives will be a legal requirement from April 18. The UK government, meanwhile, doggedly trundles forward in its determination to impose GM crops, come environmental hell or the high water of public hostility.

If anything exceeds Krebs's enthusiasm for GM, it is his loathing of organics - another area in which the scientific high ground is claimed by "conventional" (ie, chemically dependent) agriculture. Krebs is very fond of the scientific high ground, and scathing of the media bias he descries on the lower slopes. In the autumn of 2000, he was one of a number of scientists invited by the Royal Institution and the Social Issues Research Centre (SIRC) to draw up new guidelines for journalists reporting on science and health. "As chair of the Food Standards Agency," he said at the time, "I feel that people in our society should have access to accurate and balanced information about food safety and nutrition in order to make sensible decisions about what they eat. I very much hope that with these guidelines we will reduce the distortions and sensationalism which so often are associated with stories about what we should or should not eat."

The guidelines themselves were largely unexceptionable, though the irony of that "balanced information" was not lost on aficionados of the FSA website. The odd eyebrow was raised, too, at the involvement of the SIRC, whose website appears even more violently anti-organic than the FSA's own.

"It was inevitable," it says, "that when Sir John Krebs first punctured the myths surrounding organic food, he would become a target for both personal abuse and zealous attempts to prove him wrong." Oddly, this is the first sentence of a piece which itself is larded with personal abuse, and which zealously attempts to prove wrong the author of a Soil Association report on the nutritional value of organics. "No journalist," it complains, "seems to have explored the credentials of [the author] Shane Heaton. If they had bothered to do so they might have been more concerned about his so-called 'results'." And the damning evidence from Heaton's background? That he trained with the Institute for Optimum Nutrition, whose "founding patron was Linus Pauling - the man responsible for the now discredited idea that massive doses of vitamin C are effective in preventing colds and other ailments, and even cancer".

What it neglects to add is that Pauling was a double Nobel laureate (Chemistry, 1954; Peace, 1962) and an unlikely vehicle for a "guilt by association" smear. This leaves the SIRC and, by association, Sir John Krebs, ducking the ricochets. Is this the standard of scientific objectivity it wants to impress upon the media? If even a Nobel laureate can be wrong, then how can scientists continue so arrogantly to proclaim their own infallibility? And if people are to be judged by the company they keep, what about the SIRC's own food-industry funding, and its association with a commercial market-research company? What about the FSA's warm embrace of officials who thought it good practice for animal protein to be fed to cattle? If this is scientific objectivity, then you might as well hand editorial control of Nature to the editor of the Daily Mail.

Half-truths abound. Krebs says people who buy organic food are "not getting value for money". Well, they are and they aren't. Unlike customers for "conventional" foods, they are indeed paying the real price for what they eat, without much in the way of subsidy. The true cost of supermarket food can be seen in the degradation of the farmed landscape, from which every kind of agricultural pollutant floods into groundwater and streams, with devastating effects on wildlife. The Department for Environment, Food and Rural Affairs (Defra) calculates that the total annual cost to the water industry of scrubbing agricultural pollutants from the public supply is £225m. Find this on the FSA website if you can. You will look in vain, too, for any acknowledgment that the health of inland waterways is as much an issue for consumers as the price of carrots. Krebs himself insists that, far from having a coherent argument on its side, the organic industry "relies on image", and that there is no advantage to be had from eating food free from pesticide residues. Indeed, he told the Guild of Food Writers in October 2001 that pesticides had passed the scrutiny of an expert committee and were therefore preferable to the many natural toxins in fruit and vegetables that did not have the benefit of official approval.

The irony here is that Defra itself has published an action plan encouraging organic food. In an enthusiastic foreword, the secretary of state, Margaret Beckett, commends organics for offering "real benefits for the environment". Peter Melchett, policy director of the Soil Association and a former Labour environment minister, is both encouraged and dismayed. "There is a huge shift in government thinking on sustainable food policy," he says. "New science is coming out all the time to show environmental, food quality and health benefits - and it's in the latter area that the FSA is still resistant.

"It's a real pain for us because it affects what the organic sector can say to its customers. For example, organic food contains less of the hormone-disrupting chemicals that may be implicated in the reduction of men's sperm counts. This is serious science, but the Advertising Standards Authority, which follows the FSA's lead, won't allow us to mention it. Neither can we mention that pesticides are particularly dangerous for the very old and the very young, and especially to the unborn foetus. The reason given is that it would cause undue alarm, but scientifically it's not controversial." It's the same with meat. "Beef from cattle fed on grass has lower levels of saturated fat and higher levels of unsaturated fat, which is healthier. Again this is not controversial as science, but you'll be in trouble with the ASA if you want to say that organic meat is better for you."

There have been other examples of what he calls "crass behaviour" by the FSA. One of these was its attempt to design simple tests to check the authenticity of claims on food labels. "Because they didn't understand that organics was a process - involving the way you look after your soil and the way you treat your animals, all laid down in a very precise and demanding set of standards - they treated it as if it were just another claim on a label, like 'free range' or 'no added sugar'. In any other market sector they would have talked to the industry, but they never said a word to us about what they were doing. They spent hundreds of thousands of pounds trying to devise tests to show whether artificial nitrogen had been applied to crops or not; but it's useless. It means that if you were a conventional farmer and didn't apply nitrogen, you could sell your crop as organic."

Even so, he still doesn't see this as anti-organic mendacity. "It's not a conspiracy. It's a cockup." The same explanation might fit some of the other shortcomings catalogued by the public accounts committee. Its principal complaint - that after four years the agency "has not yet demonstrated convincingly that it is able to lead on issues of food safety and standards, and is an authoritative and trusted voice where there is public doubt" - is devastating. Astonishingly, only 3% of the public said they would turn to it for advice. There remains confusion, too, about division of responsibilities between the FSA and other arms of government (Defra on meat imports, for example, and the Department of Health on nutrition).

Successes? There have been a few. The agency recently saved us from donkey-meat salami. It fingered wholesalers and retailers who mis-sold "varietal" potatoes (35% of King Edwards in its survey were wrongly labelled). And it honoured a promise, given by its chief executive, Jon Bell, to the public accounts committee, that it would do more to "name and shame" the guilty. It has tested sausages for salt, fat and nutritional content; and tested bread and a range of ready meals for salt, which it is keen for us all to eat less of. Pizzas, canned spaghetti, baked beans and soups are next. It is also taking a close interest in Coca-Cola's use of the word "pure" in its marketing of the processed Sidcup tap water, Dasani.

Meanwhile the giants of the food industry still get away with the kind of labelling that allows products with a 16% fat content to be sold as "Lite", and those with 10% fat as "90% fat free". Local authorities continue to fail in their statutory duty to inspect restaurants, butchers' shops and other food outlets, and the public stomach continues to heave. In 2001, 5.5m people said they'd suffered food poisoning in the previous year, and 4.2m of these blamed restaurants or other caterers. The FSA does have power to move in on negligent local authorities but - although many are failing abysmally - it has yet to do so. Instead, it is relying on education. If it is to realise its ambition of a 20% reduction in food poisoning within four years, the learning curve will need to be steep. The PAC heard that half of all catering staff do not wash their hands before preparing food, and that a third don't wash after using the lavatory.

Response to criticism is not the FSA's strong point. As ever, salmon is the classic example.

Question: "Could you answer the criticism that you wrongly imply that the WHO has set specific safe limits for dioxins and PCBs in 'fish sold in shops'?"

Answer: "We did not say that WHO had set safe limits."

Truth: Remember the website? "The levels of dioxins found in farmed salmon are below the safety levels set by the World Health Organization. The WHO set safety levels for dioxins and PCBs in 2001 based exclusively on public health protection. These form the basis of safety levels set for consumers who eat fish sold in shops."

It may be possible, by close textual analysis, to reconcile these apparently conflicting statements, but there is no doubting the inference that most ordinary readers may be expected to draw: the WHO does set specific limits for farmed fish, and Scottish salmon falls within the margin of safety. As we now know, this is simply not true. At every turn, the route to clarity is blocked by theoretical concepts of "average" or "balanced" diets. Already three years have passed since doubts about the safety of salmon first emerged in public - three years that the FSA has spent in issuing denials and reassurances. Only now, three years since it pulled the plug on the BBC, has the agency appointed a panel of experts to advise on the "risks and benefits" of eating more than one portion of salmon a week. You'll get the answers in the autumn.

On other issues it is no less evasive. Asked to justify its attack on the scientific competence of the EPA, it merely reiterates its faith in the WHO, and other official bodies in the UK and US, whose findings it prefers. There is no engagement with the issue. On questions of organics it remains simply bewildering. "The agency has always made it clear," it declares, "that it would not be appropriate for it to make statements supporting any particular food production scheme." Yet at the same time it has "consulted on a proposal" to compare the nutrient content and pesticide residues in organic and conventionally grown fruit and vegetables. By implication, if such a study goes ahead and demonstrates a clear advantage of one side over the other, then it must debar itself from making any recommendation based upon the result.

This February it found itself in deep trouble with another group of MPs, the House of Commons select committee on environment, food and rural affairs. This time the whipping was for its costly mishandling of the shellfish industry, after flawed toxin monitoring had caused prolonged closure of cockle beds in England and Wales. The FSA, it said, "had not lived up to its core value of being open and accessible". Its standards of communication and co-operation had been so poor that they had led to "an atmosphere of distrust and, at times, hostility".

The science had been a shambles, and the FSA had been slow to accept the possibility that its methodology could be at fault. "It is both astonishing and unacceptable," said the committee, "that the three laboratories conducting statutory toxin monitoring used different methods, and more importantly, did not appear to have a common standard for determining whether a result was positive or negative."

But there is no sign that anything is about to change. An FSA spokesman immediately popped up in a BBC studio to declare that the agency had done nothing wrong. His excuse, which cannot have been better designed to cause mirth in anybody who had followed the salmon saga, was this: for the sake of public safety, it had been essential to adopt a "precautionary approach in the face of scientific uncertainty".

One portion a week, anyone?

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