Memorandum by the Food Standards Agency |
1. The Food Standards Agency (FSA) was set
up in April 2000 to protect public health and restore public confidence
in the way that food safety decisions are made. The FSA is a non-ministerial
government department, operating at arm's length from Ministers,
and governed by a Board appointed to act in the public interest.
It is a UK body, accountable to the Westminster Parliament and
to the devolved administrations through the relevant Health Ministers.
Our UK headquarters is in London and we also have offices in Scotland,
Wales and Northern Ireland and each of these countries has its
own advisory committee chaired by a Board member.
2. The Agency's core values are to:
put the consumer first;
be open and accessible; and
act as an independent voice.
3. Our sphere of interest ranges across
the entire food chain, from pesticides and veterinary medicines,
to food safety and hygiene standards in shops, restaurants and
takeaways and the home kitchen. We aim to provide clear guidance
to the public on safe and healthy eating. To be able to give sound
advice, the FSA needs access to the best possible information
including surveillance data and evidence-based research. We consult
widely, commission independent research and, wherever possible,
seeks consumers' and other interested parties' views before reaching
4. Since the Agency was established in order
to restore public confidence in the national arrangements for
food safety, public attitudes, risk perception and risk communication
are at the heart of the Agency's activities.
FSA TARGETS TO
5. Foodborne disease makes a major contribution
to morbidity and mortality from human infectious disease in the
United Kingdom. A large study of infectious intestinal disease
(IID) in England in the mid 90s estimated that there were a total
of 9.4 million cases of IID each year, with costs of £750
million to the NHS, employers and the cases themselves. On the
basis of the pathogens isolated, we have estimated that between
17-50 per cent of these cases were foodborne. Work to refine and
update this estimate has been carried out by the PHLS Communicable
Disease Surveillance Centre (currently in press). This confirms
a current estimate of over 1 million cases a year of UK-acquired
foodborne disease, with just under 500 deaths. A recent Regulatory
Impact Assessment prepared for the Agency suggested that annual
costs are currently in the order of £1.4 billion.
6. On the 28 July 2000, the Food Standards
Agency announced a target to reduce foodborne disease in the UK
by 20 per cent by 2006. In July 2001 it published its "farm
to fork" strategy to reduce foodborne illness in the UK on
A paper summarising the current trends in foodborne disease was
published in August 2001.
7. The major foodborne pathogens, in terms
of incidence, are Campylobacter and Salmonella. In 2001, there
were just under 63,000 laboratory-confirmed cases of Campylobacter
and over 18,000 laboratory-confirmed cases of Salmonella. On the
basis of the IID Study, this probably represents over half a million
cases in the community due to these two pathogens alone. Whilst
there has been a major decrease in Salmonella in recent years,
the number of reports of Campylobacter has continued to increase
and this pathogen is likely to continue to represent the greatest
threat in the foreseeable future.
8. Whilst verotoxigenic E. coli accounts
for fewer cases (generally 1,100-1,400 laboratory confirmed cases
a year), it continues to pose a significant threat because of
its severity. It also illustrates the way in which new pathogens
emerge, in ways which can only in part be predicted, and exploit
aspects of the increasingly complex food chain to give rise to
new foodborne diseases.
9. Robust surveillance data is fundamental
to the Agency's ability to monitor the success of its foodborne
disease strategy and a comprehensive, expert-led system is crucial
in detecting and investigating the emergence of new threats.
10. The term infectious intestinal disease
(IID) is used to describe gastrointestinal symptoms (diarrhoea,
vomiting, abdominal pain) due to microorganisms or their toxins.
Only a proportion of these cases is foodborne. While it is relatively
easy to obtain robust data on IID, the proportion of cases that
are foodborne can only be estimated, however promptly or completely
those cases are investigated. Information on pathogens isolated
from cases of IID helps refine such estimates. Whilst no single
system provides a complete picture, data from a number of different
sources helps to build up the picture.
11. The main sources of data on human foodborne
disease and other infectious intestinal disease are:
The statutory notification system.
Reports of Intestinal Infectious
Disease made to the Royal College of General Practitioners' Weekly
Laboratory reporting of the major
Reports of outbreaks to the national
12. The statutory notification system is
recognised as being a poor way of ascertaining the true incidence
of food poisoning. It is based on clinical suspicion only and
requires no laboratory confirmation of the diagnosis. It also
relies upon a subjective judgement by the doctor regarding the
cause of the symptoms. There is, moreover, evidence of a general
under-reporting of notifiable diseases. On the other hand, it
is a difficult figure to ignore because it comes with the label
13. The GP sentinel surveillance system
provides a reliable figure for the number of cases of IID seen
by GPs in the sentinel practices. In common with the statutory
notification system, no microbiological confirmation of the diagnosis
is sought. Like all sentinel systems, it suffers from the potential
problem of being unrepresentative of the general population, and
it is confined to England and Wales. However, it does provide
a good indication of the underlying trend in IID against which
trends in laboratory-confirmed cases can be judged, provided there
is no major change in the frequency with which patients consult
doctors about symptoms of IID. The advent of NHS Direct could
affect these data and it is therefore important for surveillance
to capture data from this service.
14. The laboratory reporting system provides
microbiological confirmation of the clinical diagnosis of IID
and data on trends in individual organisms. The IID Study showed
that laboratory reporting identified a significant proportion
of all cases of Salmonella (one in three) and Campylobacter (one
in eight) that occurred in the community.
15. However, since the system is voluntary,
not all laboratories take part. Evidence suggests that, to date,
the level of participation has been high and it is by no means
certain that a statutory requirement for laboratories to notify
their positive results would yield a significant amount of additional
information. However, changes in the Health Service ("Shifting
the Balance") and in arrangements for microbiology services
("Getting Ahead of the Curve") have the potential
to change the level of laboratory investigation and reporting.
16. National surveillance centres also have
systems for recording outbreaks. It is generally only outbreak
cases for which the route of transmission can be established and
thus outbreak reports provide key information on trends in foodborne
disease. However, outbreak cases probably account for fewer than
5 per cent of all cases of foodborne disease. Moreover, outbreak
reporting is known to be patchy and smaller outbreaks in particular,
may tend to be under-reported.
17. Current systems cannot provide information
on cases that do not seek medical advice or that are not reported
to local Environmental Health Officers. This can only be ascertained
by community-based studies such as the IID study, which identified
cases prospectively and linked symptoms to a questionnaire and
18. For all the shortcomings of the existing
sources of data on IID and foodborne illness it is possible to
obtain a reasonable representation of trends in foodborne disease
when data from a number of the sources described above are combined.
Such data currently provides a firm basis from which to manage
food safety. However, the Food Standards Agency supports the promotion
and strengthening of surveillance of foodborne disease. The PHLS
has played a crucial role in the surveillance of foodborne disease,
in laboratory testing, in provision of specialist reference facilities
and as collector and interpreter of surveillance data. Current
proposals following on from Getting Ahead of the Curve should
maintain the role as collector and interpreter of surveillance
data. In the light of proposals that have emerged about the future
of microbiology services, there is an opportunity to improve surveillance
data because all microbiology laboratories will be required to
acknowledge and meet public health responsibilities, including
obligations to contribute to surveillance systems. The public
health microbiologists and Regional Public Health Microbiology
Co-ordinators will have an important role in making sure that
this opportunity is seized and to prevent any danger of the public
health responsibilities of microbiology laboratories being sacrificed
to their clinical role. There are concerns that these two key
positions will not be occupied on a full-time basis.
19. The monitoring of pathogens in food
animals and in foods also plays an important part in surveillance
of foodborne disease. Zoonotic infections in man can occur by
a variety of routes, which include foodborne, waterborne, direct
contact and through insect vectors. In the United Kingdom, the
foodborne source is thought to be the most common. However, some
zoonoses do not cause disease in animals so samples will not be
submitted to the laboratory for examination unless a programme
of routine monitoring has been implemented to detect them, or
samples are taken as a result of an investigation into an outbreak
of disease in humans.
20. Good links have been forged between
PHLS and the VLA to bring animal and human surveillance systems
in line with one another. This enables data from the monitoring
of food animals to be used more effectively to monitor prevention
strategies in the primary production sector and to flag emerging
problems. It also facilitates understanding of human epidemiology
by tracing pathogens back to their probable source. Such an understanding
is fundamental to the prioritisation of measures to reduce foodborne
disease. Getting Ahead of the Curve recognises the importance
of integrating veterinary and human data although the mechanisms
whereby this will be improved remain to be determined.
21. Provision of food, water and environmental
(FWE) microbiology services is important not only to support enforcement
activities but in surveillance of foodborne disease. Getting Ahead
of the Curve did not make specific mention of these services but
subsequent discussion has resulted in an agreement that such services
will continue to be provided by the Health Protection Agency through
a centrally-managed network of FWE laboratories and that existing
FWE laboratories will continue to operate on a "business
as usual" basis in the lead up to the establishment of the
HPA and immediately thereafter.
22. Some collaboration already exists which
aims to improve and harmonise surveillance systems, outbreak investigation,
reporting systems and diagnostic methods across Europe and we
believe that the systems in the UK benefit from these collaborations.
One such collaboration, which is funded by the EU and is led by
the PHLS, is Enter-net. Enter-net is an international surveillance
network for human gastrointestinal infections, which involves
the 15 countries of the European Union, plus Switzerland and Norway
(and co-operates with international colleagues including the US,
Canada, Japan and Australia). The network aims to conduct international
surveillance of human salmonellosis, including antimicrobial resistance
in isolates from humans, and of human infections by verocytotoxin
producing Escherichia coli O157.
23. The UK also currently contributes data
to two other surveillance networks. One is a surveillance network
on Foodborne Viral infections and the other is a new network on
Listeria. In contributing to these networks the UK supports
their aims to develop standardised methods for investigation of
outbreaks and transfer technology to established and starting
laboratories to enable comparative analysis of the epidemiology
of foodborne disease and early detection of multi-national outbreaks.
24. Contributing to these surveillance networks
and sharing diagnostic methods, in addition to the routine reporting
of UK data under the Zoonosis Directive and to the WHO Programme
on Foodborne Intoxications, can facilitate the timely exchange
of international information which can lead to public health action
in Europe and beyond.
25. In the area of foodborne disease the
UK has been at the forefront of detection and typing research
for many years. It is important that strong reference laboratory
services are maintained and that adoption of new methodologies
for routine use constitutes an important ongoing objective.
26. The most beneficial advance in diagnostic
methods that the Agency would like to see would be a molecular
approach to Norwalk-Like Virus (NLV) detection. At present laboratory
methods only detect a very small proportion of all NLV infections.
This is because few samples are examined by electron microscopy
(EM) and, when they are, the chances of making a positive diagnosis
are small because after the first couple of days of illness, viruses
are no longer detectable on EM. We would hope that the development
of a molecular method for routine use would facilitate routine
examination for NLVs and enable detection of the virus weeks after
infection rather than just days.
27. Although most cases of food poisoning
are self-limiting and resolve quickly without treatment, the use
of antibiotic treatment may be necessary in cases of severe illness
and infection in vulnerable individuals. Therefore an understanding
of the emergence and spread of antibiotic resistance in foodborne
pathogens in humans is important. The spread of resistances in
zoonotic microorganisms in food animals and the potential route
of transmission of these organisms to humans through food is also
28. Prevention is the key theme of the foodborne
disease strategy. The strategy includes three main strands of
reducing microbial contamination
promoting better food safety management
and practice; and
promoting hygienic preparation of
food commercially and in the home.
29. The Agency has put in place a wide-ranging
programme of action, which it believes will have maximum impact
on preventing foodborne disease, both outbreaks and sporadic cases.
Current activity is summarised in Annex 1. Surveillance data is
required to monitor the impact of this programme and will be used
to highlight any area requiring further policy interventions.
30. While vaccines for prevention of foodborne
illness in humans are generally not appropriate because of the
multiplicity of pathogens and short-lived nature of the illness,
there is a role for vaccines in the control of zoonotic agents
in animals. An example of this is the vaccination of the UK egg
laying flocks against Salmonella. In its second report on Salmonella
the Advisory Committee on the Microbiological Safety of Food (ACMSF)
concluded that vaccination had a significant effect on the prevalence
of egg contamination and human infections. This was based on consideration
of evidence including trends in vaccination of the UK laying flocks
and in Salmonella infections in humans. However it can sometimes
be difficult to predict the cost benefit of developing vaccines
to control animal carriage of zoonotic agents at the time the
initial investment is needed.
1. An outline of the main activities being
undertaken at part of the Foodborne Disease Strategy is given
Reducing Microbial Contamination in Foods
Developing and implementing a strategy
to reduce Campylobacter in chickens.
Implementing further measures to
reduce salmonella levels in chickens.
Improving enforcement of hygiene
requirements in meat products, minced meat and meat preparation
establishments through enhanced guidance and training for enforcement
Continuing to operate food safety
management awareness initiatives for on-farm pasteuriseurs and
on farm milk product producers.
Reviewing the guidance available
on enforcement of dairy products hygiene legislation to ensure
own checks are applied effectively.
Production of a discussion paper
on the enforcement of on-farm pasteurisation of milk.
Reviewing the function of the Dairy
hygiene Inspectorate in relation to the need to reduce faecal
contamination of milk during milking.
Promoting HACCP and Food Safety Management
Implementing a strategy to promote
HACCP in food businesses and in particular catering and retail
Introduction of HACCP guidance to
help meat processors and food plants carry out their operations
in accordance with HACCP principles (ie introduction of HACCP
manual for meat plants and food safety management awareness initiative
for specialist cheesemakers).
Developing sampling protocols and
microbiological criteria for testing carcasses at meat plants
in support of HACCP.
Developing and Promoting Best Practice
Developing guidelines for growers
to minimise the risks of microbiological contamination of ready
to eat crops when using manures.
Reviewing the current classification
system for shellfish harvesting waters in England.
Commissioning research to develop
best practice guidelines for teat cleaning prior to milking.
Developing best practise and guidance
to ensure animals presented for slaughter are clean (ie clean
Investigating ways to minimise the
risk of poultry becoming colonised with pathogens during growing,
transport and slaughtering (eg potential control measures for
Campylobacter, crate washing and physical decontamination methods
Working with industry, DEFRA and
the British Pig Executive (BPEX) to reduce Salmonella in pigs
through the implementation of the ZAP Salmonella monitoring scheme.
Food Hygiene Promotion and Education
Launching a five year multi-media
Food Hygiene Campaign on 11 February 2002 to:
Raise awareness of food poisoning
as an issue.
Establish the link between poor food
hygiene and food poisoning.
Increase understanding of the key
Change food hygiene attitudes, knowledge
Involvement in EU sponsored education
campaigns since 1998,.
Partner in the Food and Drink Federation's
Foodlink activities including the Food Safety Week initiative,
which has been running for ten years to promote the communication
of food hygiene messages to children and young adults.
For a more detailed account of the work being
undertaken to implement the foodborne disease strategy see Board
paper NOTE 01/07/01 and NOTE 02/05/04 which can be downloaded
from the Agency's website: www.food.gov.uk
56 http://www.food.gov.uk/multimedia/pdfs/fdscg-strategy-revised.pdf Back
Advisory Committee on the Microbiological Safety of Food. Second
Report on Salmonella in eggs. 2001. London. The Stationery Office.
ISBN 0-11-322466-4 Back
Two food hygiene teaching resources: "Aliens in Our Food"-aimed
at children at secondary schools, and "Safe T and the H Squad"-aimed
at children in junior schools. These resources are accessible
from the "Food Hygiene Mission Control" navigation button
on the Agency website home page (www.food.gov.uk). Back
A web based education package aimed at UK teenagers and young
adults (14-24 year age group). The site was launched on 15 April
02, can be viewed at: www.good2eat.info. Back
Material produced for Food Safety week can be downloaded from