Review of agency's advice on fish consumption

The key areas highlighted in this consultation are:

• The evidence regarding the health benefits and safety of eating fish is established and has not been re-examined.
• The discussion of environmental concerns regarding the Agency’s dietary advice on fish consumption.
• The proposal that the Agency should develop an ‘information hub’ within its dietary advice. This would offer links to other sources of information and advice to enable choices that take into account other aspects of sustainability. The emphasis would be on facilitating access to information rather than interpreting or duplicating it on the Agency's website.

It is not the Agency’s role to regulate the UK fishing industry or advise on its practices (other than in terms of the EU Food Hygiene Regulations), or offer a new definition of sustainability in relation to fish stocks.

Other Government departments, international bodies and stakeholders are already active in this area. The Agency wants to support and draw on their work, and not duplicate it.

The Agency’s current advice to consumers is to eat at least two portions of fish a week, one of which should be oily fish. (A list of common types of white and oily fish is available on the Agency’s 'eatwell' website - see link below). The advice also covers maximum intakes of oily fish. A ‘portion’ is defined as 140g, the average fish portion size consumed by adults recorded in the National Diet and Nutrition Survey of adults, 2000/01¹. In light of the Agency’s commitment to sustainable development and in response to comments from stakeholders (including recommendations from the Royal Commission on Environmental Pollution² and the Sustainable Consumption Roundtable³) the Agency is reviewing this advice to include sustainability in its policy making. The aim is to produce integrated dietary advice that takes into account environmental, economic and social (including nutrition and food safety) aspects of sustainability.

The purpose of this consultation is to seek your views on an approach to including these aspects in the Agency’s current advice. This review has not reopened the scientific evidence on nutrition and safety as these have already been thoroughly examined by the Scientific Advisory Committee on Nutrition (SACN) and the Committee on Toxicity (COT). Their conclusions are published in the joint report ‘Advice of Fish Consumption: Benefits and Risks’ (2004), and are summarised in the enclosed draft Impact Assessment. This advice applies only to the consumption of fish and does not include shellfish.

Two possible approaches appear most practical:

• leave the Agency’s advice on fish consumption unchanged
• maintain the Agency’s consumption advice, but supplement it with encouragement to make sustainable choices and advice (or direction toward sources of advice) on how to do this.

These are considered in more depth in the consultation letter and draft impact assessment.

The consultation seeks views in several areas, in particular:

• Consumer perceptions and understanding of ‘sustainability’ issues, the issues in this consultation that are most important to consumers and the type of information and guidance (other than certification and labelling) that would be most useful to consumers would be welcomed.
• The Agency’s role in helping consumers find information on fish sustainability as part of its existing advice on fish consumption, in particular on the information that would be of most practical use to consumers and criteria the Agency should apply in selecting sources for this.
• Whether sufficient good quality evidence is available to support a review of advice on the consumption of shellfish on nutrition and environmental sustainability grounds. (No decision on the practicality of such a review has been taken yet – this is not a call for submission of evidence, but rather for comment on its availability.)
• The Agency already provides guidance on assurance schemes⁴, which aims to encourage transparency, involvement of public interest groups, monitoring, and clarity for consumers. Comments on further criteria specific to fish consumption that could usefully supplement the Agency’s guidance would be welcomed.
• Demands on stocks of the most popular fish (e.g. cod, haddock, plaice) could be transferred by encouraging consumers to use a wider range of sustainable fish, although care would be needed in doing this to avoid unintended consequences of increasing pressure on other stocks. We would welcome views on practical steps the Agency might take in this regard.
• Many retailers, manufacturers and caterers are taking steps to ensure sustainability of the fish they sell. We would welcome comments from all sectors of the food industry on ways in which the Agency could help consumers to access clear, helpful information about these practices.
• Fisheries Departments in all four countries of the UK are encouraging sustainable fishing and aquaculture⁵. We would welcome comments from these Departments on how the Agency might help consumers to access information on this work. This links to work the Agency is carrying out to provide consumers with integrated Government advice on food as part of the agenda set out in Food Matters⁶.
• An early draft impact assessment has been included. Your views on the economic, social and environmental impacts, as well as the description of costs and benefits, would be welcome.

The outcome of this consultation will inform the development of clear, integrated advice to consumers on eating fish. This will update the information already available on the Agency’s websites and that used in future work on healthier eating.

¹Henderson et al, The National Diet and Nutrition Survey: adults aged 19-64 years, Vols 1-5, TSO 2002-04. See link below.
²Twenty-fifth report of the Royal Commission on Environmental Pollution "Turning the Tide" 2004
³"I will if you will – Towards sustainable consumption" May 2006
⁴Food assurance schemes Guidance Notes (See link below)
⁵See for example Defra’s Fisheries 2027: a long term vision for sustainable fisheries'
⁶Cabinet Office, July 2008.

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)

Data protection form (pdf)

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 the FSA Consultation Co-ordinator by email: consultationcoordinator@foodstandards.gsi.gov.uk