39th Annual Campden Lecture
at Campden BRI Day 2017
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Heather Hancock, Chairman of the Food Standards Agency, delivers a candid consideration of the FSA's relationship with consumers and industry - and in particular on science, sustainability and character – in 'A coming of age of the Food Standards Agency'.
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Thank you for that kind introduction and for inviting me to speak here today.
I must start by letting you know that there's a general election tomorrow.
That means we are in the purdah period. I cannot anticipate the future direction of Friday's government and I cannot talk about the UK's exit from the EU. I hope you'll understand.
I'm the third FSA Chairman to be invited to give this lecture. It's ten years since you last heard from the Agency on this platform. A lot has changed since then. But with only 25 minutes at my disposal, I am going to resist giving you chapter and verse on the FSA since 2007.
Instead, I want to reflect on the FSA as it comes of age. We're now in our 18th year. The UK will have left the European Union before the department hits 21. Today's world is already fundamentally different from when the FSA was created. What does this mean for good food regulation today and in the future? What does it mean for us as a regulator? What are the implications for you?
Many of you have observed us from our infancy, under the guiding hand of John Krebs. In our 18 years, we've experienced some formative events. We've undergone a little surgery as we lost part of our remit to other agencies, and we acquired a new sibling in FSS. There have been unexpected shocks – most dramatically, the horsemeat scandal in 2013, and back in 2005, the Sudan 1 mass recall. Some in the industry say that at times we've been a rather truculent teenager, calling out the approach the FSA took to break the impasse in tackling unacceptable levels of campylobacter in chicken. However, with the most recent statistics showing 100,000 fewer cases reported, there's a valid alternative view that, without pushing industry as hard as the FSA did, we wouldn't have got so far so quickly. In any case, I hope that we won't have to play ‘blink' again on such an important public health issue, and that on campylobacter, we can all agree that progress has been satisfying, industry hugely raised its game, but there remains more to do to sustain the reduction in infection rates, to tackle the places where contamination levels remain stubbornly high, and as important as both those, to keep the science progressing because there is still too much we don't know about this very clever pathogen.
Like any adolescent, we've tested our boundaries in the last few years – exploring wider issues about the future of food, getting the campaigning t-shirt, embracing the language of advocacy. We've pioneered the use of new digital technologies to improve real life for consumers and businesses, and our use of social media to improve consumer messaging and alerts on issues like allergens and recalls has made a material difference to people – like me – who absolutely need to know what's in their food.
What has all that experience taught the FSA? How do we see our role and responsibilities today? Today, I'd like to talk about three important components: science, sustainability and character.
All three must be approached through the lens of trust.
I have a favourite proverb, which comes from Holland. It's this:
Trust arrives on foot. It leaves on horseback.
In the context of food safety, leaving on horseback feels particularly painful. But the point is this. Years spent building reputation and trust are undermined in the blink of an eye by someone, somewhere, in the food system getting it wrong. And we are all back at square one.
My most startling FSA statistic sums up how the public feel about food businesses. Only 47% of people responding to our latest consumer survey said that they trusted the people who produce or sell their food.
The uncomfortable truth is that your average person has very little knowledge of the journey their food has taken, before it got to their kitchen or their plate. That lack of comprehension breeds unease and distrust.
The public worries that food production could become so complex that it's impossible to choose food that is good for them without a price premium. Authenticity, provenance and honesty are concerns for them. Rightly or wrongly, consumers fear they are being hoodwinked – that the food they buy is not authentic, it ‘is not what it says on the label'. They worry that food businesses only operate through the prism of maximising profit.
The public do feel more confident about food safety specifically – 2 in 3 consumers believe that someone has got their back, 66% of them trust the FSA. Not that we should be complacent about that. Trust arrives on foot, and leaves on horseback. But my point is that distrust in other aspects of food can be a powerful contaminant when it comes to safety and authenticity.
The fact is that the vast majority of food businesses do the right thing by their customers. Food and drink from the UK is regarded as some of the safest in the world. We have globally respected food standards, and UK food businesses are at the forefront of innovation, investing to keep driving up quality and choice. Well over one billion food items are sold every week in UK supermarkets alone. Just 175 recalls were issued in 2016. That's a miniscule % of food products that require recall or trigger a foodborne or food-related illness.
But, perception is reality – I'd suggest we have a shared goal to drive up public trust in food and food businesses. We'll be facing into the wind. Between 2012 and 2017, Edelman's global trust barometer registered a 19pt fall in trust across government, business, media and even NGOs. Nearly half of all people in Edelman's last survey said that facts mattered less to them. But they do still attach relatively high credibility to technical and academic experts – giving us a possible hook on which to build.
EM Forster wrote of trust being a luxury in which only the wealthy can indulge, the poor cannot afford it. This can't be allowed to be true of food. People should have food they can trust.
To trust their food they have to trust you.
They have to trust me and the FSA.
And, industry and regulator, we have to improve our trust in each other.
What are we going to do to tackle this?
I'll talk about science first.
Science should always be first at the FSA. The FSA is a science and evidence based body. When I took over as Chairman, I heard some concerns that science was less visible in the FSA. In the last 12 months, we have taken steps to reinvigorate science in the department. We have begun to modernise surveillance. We are using inputs beyond sampling – including data from OGDs and industry. We are critically assessing how we achieve the necessary statistical power. We are reviewing our surveillance priorities annually. Our first application of the new approach is to investigate antimicrobial resistance in commensal and pathogenic bacteria in food, part of our wider contribution to addressing AMR.
One of the risks in any institution is that past priorities linger beyond their use-by date. This year, we have acted on that risk in relation to our science spend. We have clarified three categories of science in which the FSA invests: core business, investment and strategic. Core science is where we have been spending most – it keeps the wheels turning on current statutory processes, our contractual commitments, today's regulations. We intend the proportion we spend on core science to reduce over time, not least through better use of data. Investment science will benefit, science exploring how we improve controls, respond to new risks and evolve the regulatory regime. A good example is our recent decision to explore the increase in adult onset food-related allergies. Spend on strategic science will also benefit. This provides for future resilience and potential breakthrough moments. For example, our research fellow at the Quadram Institute aims to exploit cutting edge technology and data sources to investigate the gut microbiome, particularly relationships between normal gut bacteria and pathogens, pathogen virulence and molecular epidemiology.
Our new high-powered Science Council will advise and challenge the Board and our CSA. It meets for the first time later this month. We've made two initial asks. First, for advice on the science capacity and capability we need to draw on. Second, for best practice in determining and communicating risk and certainty. Input on both will help us be better at explaining, in plain English, two things:
- our core science, the expert, independent risk assessment.
- and how we on the basis of that we reach risk management decisions which find a balance between public health and consumer choice.
The FSA can help build public trust by sharing scientific and technical information more effectively. Consumers don't know where to go or who to trust to find out about food. I believe that source of independent, non-partisan, advice and insight should be the FSA. We ought to be the go-to for the truth about food. Providing information. Identifying the unknowns. Explaining risk concepts as well as specifics. Talking about certainty and uncertainty. Treating the consumer as a grown-up, giving them confidence to make their own ethical or value judgments.
In 2001, giving this lecture, John Krebs talked of the FSA's early strategic ambition to be trusted as the UK's most reliable source of advice and information about food. We must recommit to this, and redouble our efforts to achieve it.
Alongside, I want our new Science Council, and more intelligence from industry, to help us improve our foresight, our readiness for future risks and challenges. I hope this re-commitment to science will increase our influence on research council priorities, and lead to greater collaboration here and abroad to advance our microbiological and wider scientific knowledge. The UK has long been regarded as a global leader in these fields, and the FSA has a part to play in sustaining that position.
If our ambition is to be an excellent modern regulator, we need a regulatory regime that makes it real. A regime that is agile, responsive, and sustainable. Business innovation – and just plain old purchasing and consumption habits – have outstripped the way regulation has always been done. We are running a one-size fits all model. It's not proportionate to the risk. The current approach is unsustainable. There is a pressing need to build a new food regulation system for Northern Ireland, England and Wales.
16 months ago, the FSA launched our ambition to create and implement a 21st century blueprint for sustainable food and drink regulation. We have been piloting, trialing and refining ideas with local authorities, the profession, businesses large and small, and with consumers. Later this summer, we will publish more detail about our overall ambition, how the new model will work, and the steps to introduce it.
We want to use proven accreditation schemes, regulated third party assurance, and business's own data, to give us greater confidence that food safety and authenticity are top of a food business's mind every day – not just on inspection day.
Our new approach will segment businesses according to the risk they present. There's much more information in and about food businesses that we could be using to build a more accurate picture of business behaviour. Technology is making this easier and more effective all the time. I'm talking about data that industry collects about itself from its own audits and checks, and about information we can get from other sources, including other regulators. Earned recognition schemes have an important role to play, where we are confident about their standards and quality. On that note, I am delighted that the BHA is taking the lead in developing a recognition scheme for the hospitality and catering sector, filling a void in that part of the food system.
With more understanding of how a business manages food safety and authenticity, we can set a more proportionate regulatory regime. Lower risk, and consistent performance, will result in a lower regulatory burden.
That will allow the FSA to focus our efforts on filling the gaps rather than replicating the work of others. We'd like to see more choice in how businesses get external assurance, hence our ideas to create a new, certified, regulatory auditor role. We know local authorities can innovate in how they deliver essential services. We've identified opportunities to strengthen and update the value of EHPs – for example, with deeper technical specialisms so they add more value in a primary authority relationship, or at the other end of the scale, using cheap, easy to use technology to provide real-time digital compliance data from small food businesses rather than rafts of paperwork, filled in at the end of the week.
Our new regime has to take a proportionate and consistent approach to near misses or occasional problems. Harnessed intelligently, these can drive a learning and improvement culture across the vast majority of food businesses that aim to do the right thing when it comes to food safety and authenticity.
This isn't light touch regulation. It's right touch regulation. It's businesses doing more to evidence their compliance. It should give us a better line of sight into the industry overall, changing risk patterns and upcoming issues. We'll be freed up to focus on the higher risk, the vulnerable, and those who seem determined, deliberately or wilfully, to put the public at risk, undermine trust and therefore harm people and the industry.
I'd like you to think about the Great Wall of China. A vast construction. 5,500 miles long. Visible from moon. built to keep out the barbarians. So high no one could scale it. So deep you couldn't punch a hole through it.
So how come, in the first 100 years after the wall was completed, the barbarians invaded China three times?
Because they bribed the gatekeepers.
The integrity of the defence fell down at the human level.
Business integrity, personal integrity, these are what lie at the heart of a successful food safety system. The pathogens we are bothered about don't even need to make a cash bribe to exploit failures of integrity.
We can do a lot better if we bolster our system of process controls with better evidence about the people question. Management and culture is at the heart of public protection. 100 people knowing and doing the right thing on the factory floor are the best defence against 1 person in their midst doing the wrong thing. Would you feed that to your kids? Is this person putting your livelihood at risk? Are you going to call it out?
My ambition is that our future regulatory regime can use better evidence and more certainty about the management and culture of food businesses. Remember, fewer that half of people said they trusted the PEOPLE who produced or sold their food. And what about us, the FSA. What characteristics will enable us to succeed with our ambitions for reform, our ambitions for greater public trust in food.
I think our foundations are strong. We are independent, from political and special interest influence or direction. We are open and transparent, we do not operate behind closed doors. We are honest about what we know, what we don't know, and what we can do about it. We put consumers first.
I've described to you an ambitious change programme for food regulation. It's easy to think of the change being for everyone else to make, and for the FSA to carry on as normal. But we too must change. -get match fit to take advantage of opportunities that lie ahead, and to be on the front foot against unexpected risks. The FSA must become more agile – not a word frequently associated with government departments, but there has to be a first!
We need to find a different voice – in recent years, we adopted an advocacy style, a campaigning mission. We've concluded this isn't the right approach – it's not for government departments to become campaigning bodies. That's for the charity and NGO sector. We'll be focussing our communications on building recognition and confidence in the FSA as the go-to source of truth about food, food safety and food authenticity. We're working up plans for FSA Explains - a way of giving the public non-partisan and balanced information – and realising the goal of being better recognised as the independent, trusted voice on food.
We are ramping up our international contribution, with a warm welcome from our peers across the globe at Codex, GFSI and other congresses – not just being there, but taking the chair on key issues such as AMR and third party accreditation. I have been struck by how keen our sister bodies are to learn from what the FSA is planning on modernising regulation.
I think that leadership role should be more evidence from us at home. We have heard loud and clear that industry wants more clarity and ownership from the FSA in setting and defining standards. That's what we'll do.
I know what I'd like people to say about the FSA. We want to be regarded – here in the UK and abroad – as an excellent, modern, accountable regulator. We want to be trusted. And we want to be part of a UK food system that is trusted.
We'll make most progress towards those goals if we can change our relationship with the food industry. To move away from parent-child, into grown-up relationships based on mutual understanding and trust.
There are three motivations behind the effort I'm making to build better relationships with industry.
First, we always need half an eye on the next food crisis. Cold calling in the heat of the moment isn't ideal for getting on top of a crisis. I'd rather we'd got to know each other in peace time.
Second, better relationships give us a better understanding of your business motivations, risks and opportunities - meaning we can deliver better targeted regulation.
Third: good relationships lead to us sharing our insights and intelligence, working together to identify threats and risks on the horizon and agreeing how to address them.
I have been challenged on whether the FSA can temper its regulatory zeal when, through our reforms, we'll know more, more often, about what is happening in food businesses. It is a fair challenge. We ourselves have to be measured & proportionate in response - and you need to see that.
In my first year at the FSA, I've learned that this sector has very long memories when it comes to relationships with its regulator. I have got the message that there's a trust hurdle to overcome.
Time and again, I hear that the FSA's commitment to openness and transparency is the big obstacle to sharing more business or industry data with us. Whether that's sharing intelligence about food crime with the NFCU, or sharing compliance data. I appreciate that you are anxious that anything we hold will automatically end up in the public domain. I understand that media headlines about food scares cause waves with customers and shareholders. I can see that's why you don't yet fully trust us with your data. But with mutual understanding, I feel sure we can find pragmatic ways to address this without compromising on our core principles.
I also occasionally hear that cross-industry cooperation on food safety would fall foul of the CMA. I refuse to accept that excuse, we need to put it behind us, including working with the CMA if needs be to deal with it.
I really don't dismiss your concerns. If I worked in a food business, they'd probably be my concerns too. But I genuinely believe we want the same goals – safe food, authentic food, for the public to have trust and confidence in the protection they are getting. If I'm right, then surely we can work through these obstacles and find a solution to the trust-transparency conundrum.
Because, either way, the public will demand new levels of transparency about the systems and processes that produce and guarantee our food. They'll demand it easily understood, easily encountered. That's just the way the world is going. I would much prefer for us to work together to build public trust in food by being more open. More information, in the open, means better public understanding, including of the context.
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