Welsh Food Advisory Committee Chair's Report 15 July 2021

WFAC 21/07/01    
FOR DISCUSSION

WELSH FOOD ADVISORY COMMITTEE (WFAC) CHAIR'S REPORT 

Executive Summary

1.    The attached report provides a brief summary of matters discussed at the Board policy meeting on 16 June, lists other Board-level meetings attended and reports on aspects of work relating to the FSA remit within Wales. 

2.    Members of the Committee are invited to:

o    note the Board discussions; 
o    ask the Chair to expand on any issues for further discussion.

Contact: Lucy Boruk
Lucy.Boruk@food.gov.uk 

 
WFAC 21/07/021    
FOR DISCUSSION
WFAC CHAIR'S REPORT – July 2021
1.     Board Meetings
1.1    The last Board policy meeting was held on 16 June.  The Welsh Food Advisory Committee (WFAC) met on 10 June to agree its advice on the seven papers being considered.  In the Board’s discussion on each paper, where relevant, I drew attention to the different context in Wales and reflected WFAC’s advice.  The policy papers, which were approved after discussion, were:

•    Annual Science update from the FSA’s Chief Scientific Adviser (CSA) (Paper FSA 21/06/04)
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-04…

1.2    This paper provided an overview of the role of science within the FSA, highlighting the major science milestones and engagement with wider Government. 

1.3        Endorsing the work of the CSA, I raised the following:

•    that WFAC was reassured to hear that there are continued strong links with CSAs in other government departments including with Professor Peter Halligan the Chief Scientific Adviser for Wales;
•    the suggestion from WFAC that, in addition to Peter Halligan, Dr Rob Orford (Chief Scientific Adviser for Health within Welsh Government) would be a useful contact;
•    that WFAC welcomed the creation of ‘user-friendly’ science communication pieces such as ‘FSA Explains’ leaflets and videos and their availability in the Welsh language;     
•    that WFAC was disappointed that are there no Welsh universities or higher educational establishments involved in any FSA research projects (which received a positive response);
•    the suggestion that a more user-friendly digital platform would increase the visibility of research calls, which the CSA accepted and thought could be addressed by more direct engagement; 
•    that food manufacturing in Wales is a large sector, with many SMEs; and 
•    that issues around food affordability are a frequent area of concern for WFAC and I asked how consumer tracking information might be used to address these issues – the CSA responding that he was keen to ensure publication of FSA data, so that it could be useful.

•    Strategic Priorities for FSA Policy and Regulation (Paper FSA 21/06/05)
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-05…

1.4        This paper provided an overview of the developing policy landscape. 

 1.5         In welcoming the key strategic priorities, my comments were based on: 

•    the approach of grounding future policy development in the three- and four-country context was welcomed;
•    that the FSA’s continued commitment to delivering collaborative working both across the three nations and with Food Standards Scotland (FSS) was positive and essential;
•    that the Concordat of working arrangements between the FSA and Welsh Government was currently under review; 
•    that WFAC welcomed references in the paper to Wales-specific legislation and action plans – the Food and Drink Action Plan for Wales, the Agriculture (Wales) Bill and the Well-being of Future Generations (Wales) Act 2015 ;
•    that it was important that the cost of illness model would take account of the differences across the four countries (prescriptions free in Wales for example); 
•    the central co-ordination of labelling matters reflecting the different remits across the FSA was welcomed; 
•    when engaging with industry, it was important that, in Wales, there are a large number of SMEs and so the Committee welcomed the innovative approaches being used to engage with this sector; and
•    using the phrase ‘food standards and food safety’ risked creating the impression that ‘food standards’ did not include safety, whereas its scope included anything which could be harmful or adverse for consumers. Moreover, the term ‘food standards’ would help bridge the gap between FDSA’s current remit regarding nutrition and potential changes which could see FSA taking a greater role in that area.

•    Annual Report on Horizon Scanning (Paper FSA 21/06/06)
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-06…

1.6       The paper explored the horizon scanning capability at the FSA, and the ability to identify, emerging threats, risks and opportunities.  

1.7       Whilst welcoming the work, the points which I drew upon included:

•    the need to validate the assessments and ranking provided against other evidence; 
•    the consumer information emanating from the tracker showed no significant differences between England, Wales and NI; 
•    the need for regular scanning for new areas and the work of the Bio Composite Centre at Bangor University in relation to innovation in biomaterials may be of interest to the FSA – a suggestion positively received.   

•    Annual Report on Risk Assessment (Paper FSA 21/06/07) 
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-07…

1.8        This paper provides details of the FSA’s risk assessment work and progress to date, highlighting challenges and plans. The paper also provides an update on the risk assessment proposals for nutrition related labelling, composition, and standards (NLCS) supporting delivery of the FSA’s responsibilities in NI, and also requests for risk assessments to support the policy remit of other Government departments. 

1.9      Supporting the work of the risk assessment unit, the points which I raised included: 

•    the need for systematic reviews to be continuously updated; 
•    the need for experts to regulate, minimise and eliminate risks through an understanding of innovative technologies.

•    Food Hypersensitivity Update (Paper FSA 21/06/08)
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-08…

1.9      The paper sets out the progress made since December 2020 for key areas in food hypersensitivity. Those areas of work include changes in the legislation around pre-packaged direct sales and supporting consumers & businesses.

1.10     In supporting the progression of the mechanism to report on allergies, I raised the following points:

•    concern that possible proposals to amend the FHRS to incorporate a food allergy safety scheme would be complex given the statutory schemes in Wales and NI and might be confusing to the consumer;
•    the need to progress allergen management control and labelling within the manufacturing sector, specifically use of precautionary allergen labelling (PAL) might avoid proper consideration of the actual risks  – in response I was assured that FSA would be consulting both food businesses and consumers on the appropriate use of PAL:
•    the need for continued work with small business and, given the large number of SMEs in Wales, to ensure that regulation is gauged to include small caterers and that they are aware of the allergen labelling changes for pre-packed for direct sale (PPDS) goods – which led to an assurance that support for such businesses already included those in Wales; 
•    concern that possible proposals to amend the FHRS to incorporate a food allergy safety scheme would be complex given the statutory schemes in Wales and NI and might be confusing to the consumer; 
and
•    there was some overlap with the Food Hygiene Rating Scheme (FHRS), so consumers needed to understand what was included within each of the two schemes – to avoid an impression that a high FHRS score meant effective allergen management – to which I was told that this was one key area on which efforts were concentrated in developing the Food Allergy Awareness Scheme, taking account of the complexity around food hypersensitivity.

•    Final Report from Science Council Working Group on Food Hypersensitivity and FSA Response (Paper FSA 21/06/09)
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-09…

1.11    This paper presented the final report and recommendations from the Science Council’s Working Group on Food Hypersensitivity, set out the FSA’s analysis of the Group’s recommendations and proposed responses.  I raised the relevance of engaging with academia in Wales to understand the work they are undertaking.

•    Annual Report on Food Standards (Paper FSA 21/06/10)
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-10…

1.12    This paper provided an update on plans for a joint FSA and FSS annual report.  FSA officials have since been working alongside FSS colleagues on plans to develop the report. 

1.13     In supporting the proposal for a joint annual report, my comments were based on the following points:

•    that the report should be focused on consumer interest and whether food standards have been maintained or improved;
•    that the three- and four-country approach in the report was welcomed; and 
•    that WFAC welcomed the more holistic approach to “food standards” being adopted,  including nutrition and food labelling as well as environmental and animal welfare standards.   

1.14     A link to the video of the full proceedings of the 16 June meeting is below: https://www.food.gov.uk/about-us/fsa-board-meeting-june-2021. The minutes of the meeting, when available, will be posted on: https://www.food.gov.uk/about-us/our-board#meetings.

1.15      An Audit and Risk Assessment Committee (ARAC) meeting, which I attended, took place on 9 June and formally approved the annual report and accounts, which had previously been discussed at length when in draft.  

2               Mollusc Harvesting in the Menai

2.1          In the Chief Executive’s Report to the Business Committee, harvesting in the Menai was amongst the topics  discussed:  
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-13…

2.2           Page 3 has the particular extract especially relevant to Wales:

2.3       Following on from my update to the May Board on shellfish and classification of harvesting areas, I want to report that the FSA has completed its initial analysis of changes to the classification process for Live Bivalve Mollusc harvesting areas.

You will recall that the end of the Transition Period heralded a change in the way the EU viewed the import of shellfish, and so the UK shellfish industry was no longer able to export shellfish to the EU from Class B waters. The FSA has therefore been working to refine our approach to distinguishing between Class A and B waters to ensure we are classifying waters as accurately as possible. Previously the distinction between A and B waters had not been material to whether shellfish were exported to the EU. 

Our focus in the short term has been on proposals that are workable within the existing legal framework, evidence-based and that could impact on A/B classified harvesting areas within a reasonably short time-frame. These are technical changes in detailed protocols, which would not normally be reported to the FSA Business Committee, but I wanted to put this on the public record given this matter has been raised in Parliament and in the media. 

As a first step, our protocols will be updated to include two additional criteria for consideration of anomalous results from Class A harvesting areas. These will allow us to exclude uncharacteristically high results (those 3 standard deviations above the mean contamination levels) and take a proportionate response to occasional results slightly above the threshold for Class A harvesting areas where monitoring data otherwise shows that the area is on track to remain within the Class A criteria. This approach is in keeping with Retained EU Law which allows anomalous results from Class A harvesting areas to be disregarded on the basis of a risk assessment based on an investigation. We believe that there is no additional public health risk from the revisions since anomalous results can already be disregarded, and the changes are evidence-based. 

These changes will be implemented in respect of England, Wales and Northern Ireland with effect from this year’s annual review of classifications applicable from September 2021. This timing will allow the additional criteria to be applied to historical anomalous results in the 3-year dataset to be taken into account. We are working at pace to consider how these will impact individual harvesting areas and ensure that the protocols are updated to provide the appropriate framework to apply the changes. In Northern Ireland, the changes will be implemented at the time of the annual review of shellfish classifications in January 2022 

2.4           The annex contains a more detailed analysis: 
https://www.food.gov.uk/sites/default/files/media/document/fsa-21-06-13…

2.5          The Director of the FSA in Wales will provide an update providing the latest information on this matter.  

3        Other Matters

3.1     As the Chair of the WFAC, I attended the  introductory meeting with Lynne Neagle MS, the newly appointed Deputy Minister for Mental Health and Wellbeing, on 23 June.  I also attended, as an observer, the meeting of the Safe Sustainable Authentic Food Wales (SSAFW) partnership later the same day.  SSAFW’s next meeting is on 22 September. 

Peter Price
Board Member for Wales and Chair of the Welsh Food Advisory Committee
12 July 2021