The lie of the land
Wisdom used to be thought to increase with time so society would progressively benefit from the synergistic accumulation of the sum of its parts. However, recent issues and "initiatives" appear to challenge this philosophy.
Despite repeated assertions that food legislation is based on science, political spin and responses to "consumer concerns" seem to be creeping into the arena.
One example is the UK Food Standards Agency's (FSA) call to ban the colours used in the Southampton hyperactivity study, despite scientific opinions highlighting deficiencies in the research protocol and, most significantly, limitations on conclusions that may be drawn.
Like the reality behind many food headlines, the study shows a weak relationship between the generic parameters studied, without proving specific causality. Such proof would require complex and time-consuming studies, eliminating the many other confounding factors known to affect child behaviour in order to ensure an objective assessment of behaviour patterns related to the colours.
The FSA admitted that its initial response was based primarily on "consumer concerns" rather than scientific assessment of risk - hardly the stance of an evidence-based body! Some readers may recall that the FSA was established to ensure that politics remained separate from the science on which risk management decisions were made. Let us hope that we are not witnessing its silent transformation from an "independent" body making science-based decisions into a thinly veiled consumerist champion.
It is also puzzling why "advisory" labelling has not featured in this debate. Paraphrasing the cartoon at Brussels airport: "Strange, isn't it, that when lobby groups want to highlight things they don't accept but against which they cannot adduce any scientific evidence, they demand 'informative' labelling to facilitate choice; but as soon as any 'supporting' evidence for their cause appears, no matter how strong or weak, there must be a total ban in order to impose their demands on the silent majority - even when the 'offending' items are already subject to clear, mandatory labelling?"
Use of these colours to make fun foods bright and exciting has stringent quantitative restrictions. Labelling rules also enable buyers to avoid products containing them without removing the pleasure given to the vast majority of children for whom they are of no concern.
Many suppliers have already substituted these colours. Is there adequate proof that alternatives are safer, considering the increased range of products in which they are used and the quantities consumed? The legality of using "natural extracts" for their colouring ability may even be challenged.
Political interference with sound science-based legislation resulted in recent proposals to "cut red tape" by exempting firms with fewer than 10 employees from legal requirements to base food safety controls on hazard analysis critical control point principles. More bizarre was the European Parliament's extension of this to firms with up to 250 employees. Both proposals ignore the flexibility already in the legislation and the irrelevance of linking size to ability to produce safe foods. Thankfully, it is unlikely that either proposal will progress.
Further bureaucratic nonsense has emerged. Notwithstanding that businesses must ensure that products are safe before being put on the market, Parliament and DG Enterprise have proposed a "consumer safety mark" to facilitate free movement and guarantee a high level of protection for consumers; how any logo can enhance food safety has yet to be explained.
Political spin accompanied the launch of the proposed EU Regulation on Consumer Information. PR material claimed the proposal introduced "clarifies and modernises labelling legislation". While paying lip service to the fact that current food legislation is outdated, and consumers are flooded with information, the proposal fails to remove one existing requirement whilst imposing others such as the fatuous and totally unrealistic proposal for a 3mm minimum font size. Clearly, when it comes to launching new food legislation, there are lies, damned lies and PR spin!
Neville Craddock is a food law and safety consultant with extensive experience in the development and application of food law. arivyyrpenqqbpx@ghaubhfr28.sfarg.pb.hx
