The Food Standards Agency. Six Months On 

Geoffrey Podger 

Thank you everybody and could I also say to start that I was actually very grateful not to say surprised to be invited back again. I'm not quite sure why you've done it, possibly to see whether what I claimed to you the Food Standards Agency would be, has actually what's come to pass. But I did very much want to make the point this afternoon that we are a young agency, we're six months into our life. What I hope I'm going to be able to explain this afternoon, and very much hope you're going to comment on, is what we're trying to do, how we think things have gone so far, but very much also to invite you to comment and to tell me what you think we could do more of and frankly what we you think we could do ourselves, or stop doing at all. That would actually be very useful. I think it is very important when you are setting up a new organisation to actually be very open and very receptive to criticism and let me say, with a few exceptions, we are very receptive to criticism so please do come forward with it when you feel like it and I'll try and say one or two provocative things just to stimulate some. I think the first point I should do is just a very brief revision as to what the Food Standards Agency actually is and what we're here for, because there are very strange views of what the Food Standards Agency is here for. There are people who think it's purely a safety organisation, there are people who think it's purely in charge of labelling, there are certain people who think it's purely in charge of nutrition, and I'm afraid there are a few people who think the world would be a better place if it stopped interfering in all these things. Well in fact we actually have a very wide remit. I think probably as a result of the BSE crisis frankly we got given a rather greater chunk of food policy than most other organisations comparable in other countries have been given. And I regard us as a very good thing. It's very challenging, but actually all these things feed into one another, and I think it's important to make the point that we are, primarily of course, interested in protecting peoples health, that has to be the first priority for us, as it is for you. But going beyond that we actually do have to try and see how we can meet consumers’ other aspirations in relation to food, and on that I think you will agree is quite a challenging agenda. And to make the point there is a whole series of interlocking things we do, and the first point again is protecting public health.

 Protecting public health is a very key area for us, and is not just, a matter of looking after enforcement, it's also much further back, in that at the end of the day we are the authoritative body in this country on the crude question of "is this additive, is this food safe?". And that, as recent history has shown, is quite a responsibility to have and not without its difficulties. But we do employ, I think somewhere near 200 food scientists simply in our headquarters staff. We have the ability to call on a whole series of expert advisory committees who we've inherited, and are delighted to have inherited, and let me say I have also, on occasion, we have the opportunity to call on all of you in your companies when we actually need a bit of technical advice that may you have. We are very keen indeed that we should properly be seen as, and actually act as, a science based organisation on public health. But, as we all know, it's not just a question of asking the question is it safe, it is also a question of enforcement. And we have, and I shall come back to the issue of enforcement more generally, but it is worth making the point that the Food Standards Agency does have an executive agency that meet hygiene service with direct responsibility for looking after meat hygiene in abattoir slaughter houses and meat cutting plants. And it's worth reflecting I think why we've taken this role on, because when we set up the agency everyone said to me don't take on the meat hygiene service whatever you do, there'll be trouble. And of course they were quite right. But the fact is, that actually meat hygiene enforcement is terribly difficult and terribly necessary, and I took strongly the view, and I still take the view not withstanding all our difficulties, that we made the right decision to take on the meat hygiene service for the simple reason that actually it means that the agency can't just be an ivory tower organisation.

 It literally has to get its hands dirty, it in fact has to get blood on its hands day after day through 1600 meat hygiene inspectors, and actually it means that we begin to have an understanding, not just of what the world is like in our ivory tower, but what people on the ground have to do in relation to enforcement. 

I should say also, and I'll come back to this, that we are not the major enforcement body, that of course is the local authorities, and our relationship with them is a developing one, which I think would be of interest to you, and which I'll talk about again. One of the things I think you have to be quite clear about, if you're an organisation with as many functions as we are, is what it is in principle you're actually trying to do. And these are our core values. Hopefully  self-explanatory, they cause the odd headache and I think they cause other people even more so. The first point to make is we are actually there to put the consumer first. I think it is important to stress that in doing that we are not getting at anybody else, any other party or interest, not least getting at the food industry or any part of it. What we are actually trying to do is to work the classic divorce between the protecting the interest of the consumer and actually sponsoring the industry. We don't sponsor the food industry, that's a matter for the agriculture department. If you like, what we do is look after the consumer's interest. That doesn't mean to say we're in any way anti- industry; I'm going to come back and talk a bit about our relationship with industry, how it might be, but also again very much relying on you for your views as to how it should be and if you think we fall short of what we claim we do.

 If I think there's one correct complaint that's come out of the BSE saga it's that government wasn't open, wasn't accessible, that people who had different and critical view points to put never managed to get a word in edgeways. Government just rolled ahead doing what it wanted to do. The disaster occurred and then for the first time people began to think. And I think there's some truth in this, perhaps we ought to go about a different way of food policy arrangement, and for us that means actually involving people from the beginning in consideration of difficult questions. Being entirely open, publishing data, publishing information, and letting people dialogue with us, not in a sort of token formalistic way, but actually in a meaningful way where we really are listening and are really prepared to change our views. And finally to be an independent voice. 

One of the things which has greatly amused me in recent months is that everybody used to be in favour of the Food Standards Agency being an independent voice until it started being one. And I personally take some pleasure in this though I don't think I'm actually supposed to. But I think it is worth making the point that what we set out to be is to be an objective source of advice for the public. We don't claim to be always 100% right. None of us in this room can claim to be 100% right. What we do claim to do is to give the best advice we can get and to give the most objective advice we can get, and not, frankly to be in hock to any particular part of the food industry or any particular group who favour a particular means of food production. And if you haven't quite got the reference yet, you will because I'm coming to them specifically. What is our aim? I think it's worth making the point that it's quite specifically a long term aim.

 Nothing I think could be more foolish than to think that you set up a food standards agency beginning of April, by the middle of April everyone says yes they're absolutely wonderful people, they're looking after our interest, we now feel entirely happy. That would frankly not be in any way a sensible public reaction. I have to say, whilst there are strongly held convictions I have, having been looking after food safety and other guise's for about the last four or five years, is that actually the public are a great deal more sensible than many people give them credit for. I think actually the public are not to be fooled in this area, and I think they will inherently be suspicious and cautious about us, and will only become convinced that actually we really have something worthwhile, that they can actually judge what we've done and what we've said from what the outcome is. So that becomes for us very much a test of what we can do. 

Again I'm very open to others arguing quite differently, but actually the way food policy is arranged in this country has quite materially changed since the beginning of August. The Board actually meets in public, often to quite large audiences of over 100 people. That's something which has never been tried before and I think we should be quite clear in saying that actually I think it's very brave of the Food Standards Agency Board to agree to this. These were a group of people who came often, new to the subject, having to deal with quite fiendishly difficult and sensitive subjects and having to do it all in front of an audience there to note there every word, and on occasions television cameras filming their every word and actions. But we were quite clear that this was actually what was needed. We had to make a break from the past, we actually had to move to a different way of doing things. Is it worth it? Well, I think there are two points. The first is that I think if we've actually asked, as we always do, the members of the audience what they think of the experience, I have to say it's rather a frightening experience when you actually come to look at the returns, I don't think my own personal morale has ever entirely recovered from the comment that I saw in the audience's response to the first open meeting, where they said it was extremely easy to understand what people were saying except the Chief Executive, who seemed to be wilfully obscure. You might have some sympathy with that point of view. I have to say it's always been my view that comment was an inside job and I'm still looking for the culprit. 

Secondly, we've actually been engaged in consulting with a lot of people who weren't traditionally consulted at all. And I think we should be quite frank about this. Government has not been good at consulting in this area and it's not surprising therefore that it's actually succeeded in falling out with quite a few people it shouldn't have fallen out with. There are two actual items, which illustrate this. The first is we've been engaged in very extensive talks with local authorities. The reason for this is under the act we actually assume the responsibility for auditing local 23 authorities in relation to food safety performance and for setting general standards. We've been very keen that actually doing this should not be seen by local authorities as simply getting another central government initiative aimed at them, but should actually be something that was genuinely supportive to them in what they do locally, and also, let me say, led to a greater degree of consistency of enforcement across the patch. And I suspect there are some people in this room who might agree with that sentiment. And that, you will appreciate, is not something which can be achieved just by people like me writing letters saying do this, do that. It is something, which is only achieved if in fact you actually manage to win the hearts and minds of people by drawing them into the organisation and giving them the right to put their views and their perspectives. So we've said to local authority colleagues, who have, let me say, I think very nobly gone along with this. Okay, fine, we do actually require some further legal rights in relation to you, but there is a side for you. There is an upside for you, which is that we accept that in the past enforcement, in particular, has not been a good area in that government has been very prone to write rules and regulations which people on the ground found very difficult to enforce, that we have not sufficiently consulted with people on the ground over enforcement issues, and from here on in we are genuinely trying to make it different, and we will involve you earlier. 

So that's the nature of the new relationship we're trying to have with local authorities, and we've engaged, I think, in what is one of the classic banishment tactics in these situations, which is that we have gone out there and recruited a new Director of Enforcement and Standards from the previous traditional enemy. David Stathom, who used to be the Assistant Director of Leicester City Council, and who now has constantly put up with jokes from me at his expense by pointing out that now he's joined us there's no longer anybody in the local authority world who disagrees with this policy. But you know what I mean. We actually have to be clear that we want to have a different and new relationship with local authorities where they, quite rightly, perceive us as supportive of them. Thirdly, we've been involved in some direct debates. BSE controls long regarded by Ministers as one of the most sensitive subjects on earth ever to be discussed with anybody, is actually openly and publicly debated at any meeting of the Food Standards Agency's BSE Controls Review. And anyone in this audience can come along, if you haven't got time you can look at our web site, and you'll find all the papers there, all the information there, and I have a horrible feeling in due time you'll actually see television clips of the meetings, because at least one of them was filmed throughout. But what that does, it creates a completely different environment, and it's been very interesting as an experience because everyone with an interest in the Controls has been there, the farmers have seen there, the industry have been there; you might say well they would be there, they're always there at these discussions, but there have been other people there as well. The consumers have been there, the public health people have been there and the relatives of the victims have been there. And that has produced a very different dynamic in which to discuss these questions. It has frankly meant that people with very extreme views have found it very difficult to get a hearing at all. It has meant, however, that there has been a very constructive and genuine dialogue between people who are genuinely trying to pursue the public interest. And I think we shouldn't underestimate what's been achieved through that, and indeed we'll come back to it. 

If we look at one of the things we've been talking about in these meetings is the theoretical risk that BSE might naturally occur in sheep. And this, I'm afraid, is just an example of one of these ghastly scientific unknowns, but it is theoretically possibly. It's been looked for, it's not yet been found, but thankfully the extent to which we've looked means that we can't be confident that it wont be found. And in this situation I think the traditional government reaction would have been to hide it all or keep it all in journals that nobody reads. We're being quite open with people about this. It's been quite widely publicised in the press and we've been quite open about the measures that are being taken to try and deal with the problem, particularly the problem of ascertainment. The result has been a lot of press coverage. 

There has not, in any way, been an example where there has been mad consumer panic, as people who object to openness would predict. Quite the reverse. There has been a very responsible debate. 

Challenging assumptions. Organic foods is a very interesting case study I think. People are much interested in organic foods quite obviously from their purchasing pattern. The Agency comes forward and says, well okay fine, there are various questions people ask about organic foods. Firstly, some people say organic foods are actually microbiologically less safe than conventional foods, the Agency's gone through the literature and actually we don't think there's any persuasive study that finds this. Second thing, well people say I buy organic because I think it's better for my health. We say fine, the Agency has gone through the studies and actually there wasn't any evidence of that either. The first point concerning the safety isn't picked up by anybody, absolutely ignored. The second point, which let me say is frankly incontrovertible on the basis of the present evidence, and it's on that basis that it's been put forward, the subject caused enormous ructions from a whole variety of 24 people, who I think very much take the view that being an independent voice is fine, but you can't be independent when it comes to us, because we're virtuous. And I think one of the great challenges to the Agency is not to fall into that trap, to be quite objective and fair with everybody, and that's not easy to do. Not in any way to be anti this or anti that, but to actually put the same kind of microscope on everybody for the public good. And it's worth mentioning an another example, which is at the other range of this, which is the issue of GMO foods, where in fact, the board of the Food Standards Agency have actually written letters, or had letters written on their behalf, to all the companies saying could you please explain to us what the advantages to the consumer are from your products. And this is very interesting. Nobody in government has ever done this before. Nobody apparently ever thought there was any need to ask this question, and yet fairly obviously it's the question the public, want an answer to. Very interesting level of responses, which of course being open we shall publish in due course. I think the most interesting one was from a company that said if we reply can we be sure that you wont publish our answer? Some people don't learn. 

What have the board being doing? The Board has been very busy. The local authority enforcement agreement is entirely new, entirely different. GMO foods. The board's been much preoccupied with GM foods.

 Keen to make sure that we continue to put proper safety assessments, not biased one way or the other to the public domain, and that we've done, really re-asserting the safety of those foods has gone through the regulatory process. 

They are very keen, as with the food-labelling debate, to be absolutely certain that at the end of the day people who want to choose can choose. And I think freedom of choice is a very important point for the board of Food Standards Agency. Obviously freedom of choice isn't absolute. Those of you who like myself have somewhat strange physical dimensions will be well aware of the fact that if you actually try and buy off the peg clothes, you discover from time to time that you can't find one in your exact measurement. It doesn't follow from that that this is some terrible infringement of one's consumer's choice. It simply follows there isn't a market. That's a very different matter I think from saying, here we are, we've got the new technology, it's highly controversial and what we're going to do is put as normal a staple food as you eat even though you may not want it, and isn't that reasonable? The answer is it's not reasonable. It's the consumer choice which actually has to be protected and not in this instance to be ignored. And the board I think has been very much guided by that kind of principle and looking at food labelling. Just briefly on the other points.

 Food poisoning. Where we, like other first world countries have astonishingly high figures, quite unnecessarily. We have it in mind to hold a major campaign with a variety of stakeholders, and we'll be launching that. Nutrition is a very key area where we are in fashion with various other government departments and agencies, because I think you would agree what's needed on nutrition is an across the board approach by government, not simply picking off individual items. Pesticide residues are a very good area to illustrate the board's approach. We have to accept that people are very worried about pesticide residues, I don't think there's any doubt about that. I think we also have to accept that the scientific evidence is that actually residues are much less in conventional food than people imagine, and such residues as there are almost invariably are not actually matters of concern. We've been very keen to put that message across, recognising that it's an important message, but also recognising that there is still further work to be done in this area. But what we can't afford as an agency is to be complacent. And one of the issues which campaigners on this issue have often put forward is the issue of cocktails of the pesticide residues that you have. It's all very well to say there is nothing wrong with what you get in your carrots, but when you start looking at the chemicals you get in a variety of food sources and put them together, what affect is that having? And I think its very incumbent on us to say, that's a perfectly legitimate question. It's a question actually which nobody has ever looked at and nobody has the answer to. And so that's something we're going to take forward. I think this is a good example of where you can actually meet clear consumer concerns in a way, which is scientific and doesn't consist of simply giving people populist views, which are not science based. I think it's worth again making the point that there are benefits to consumers about all this. But they're not always easy. The local authority framework brings clear benefits because it will improve enforcement. We have better consistency and a better understanding of priorities. The BSE review. The actual benefit to consumers is you tell them the truth. I see that as a benefit. Not everyone would. But it's important to make that point. The benefit isn't that people necessarily will be safer in relation to some of the areas, the benefit is that they'll know and they can make their own choices as to what they want to do.

 Labelling. A key issue where actually the board takes the view, which I think is generally shared, 25 that the present labelling regulations in the country which are based, of course, on EU regulation, don't actually provide a very helpful, shall we say guide to Mr & Mrs Average. And we need to think about changing them, and if anyone disputes that I frankly challenge you to look at any nutritional information on any pack and ask yourself whether any normal person could understand it all. Burden of regulation is an important point for us. We have no interest in the argument that because a business is small is should be entitled to put people at greater risk. We have a lot of interest in the view that small businesses have particular difficulties in dealing with regulations and we need to find a safety regime, which is suitable, to them and doesn't impose unnecessary burdens. And we are engaged at the moment in long dialogue with small businesses to try and get out of them what the present regulations are which they really think are unfair to them, and then to reach a view as to whether we accept that. The reduction in food poisoning is something I've already spoken about. 

0Just to sum up this discussion. Not just to mention some things we think are actually important on success. The first being our decisions on the best science. We are not interested in moving to a - this is what people think so this is what we should say approach - I think that's deeply patronising. But equally, and it's the second point, we're not interested in going down the line which you may think has been trod in the past saying, well the scientists say it's all right so it's all right. Most things in this life are subject to uncertainty and risk. What we have to do is to be honest with people. Also, and it's the third point, and it goes with uncertainty, we have to be proportionate. I think that's terribly important because inevitably people become particularly worked up about this or that and may take the view that absolutely any measure is justified to deal with a particular issue. The Agency is legally obliged not to go down that route, and in my view rightly so. The Agency is obliged to take action, which is proportionate to risk, but not action, which is excessive to it. Relationship with other government departments is very important. We are part of government, we can't just do things on our own; there are some things we can do on our own, much we need to do with government departments, much we need to do to influence other government departments, and we take a lot of time in trying to have good relationships with other government departments. Working with the media. A hundred people come to a FSA board meeting. It's a drop in the ocean as to compared to the general population. The general population gets their information on food matters from the media. They get it from a wide variety of sources. I think a strong mistake government made in the past was not being prepared to give open access and facilities to media and, frankly, to deliberately try and encourage only those journalists whom they thought might be sympathetic to their point of view. We very much take the view, and we've staffed ourselves accordingly, that we actually have to offer the media a friendly service, we have to accept that we'll get some criticism from them, but that actually that is the way to communicate with the public and is actually our key resource. Working with industry. As I said to you the Food Standards Agency is in no way anti-industry. One of the things that's come out of all the conversations I've had here today, and let me say would normally come out in any discussion with the baking industry, is that actually you share many of our objectives as well, you have the same interest on safety as we have, you also have a very strong and, very proper commercial interest in actually meeting the aspirations of consumers. We're not in the position that our positions are totally apart. Quite the reverse. There's a lot of common ground. Moreover, things we do, particularly regulatory, but also in terms of the science, affect what you do. And one of the things we're very concerned about is to maintain a direct dialogue with industry. We are always happy to meet with industry, whether formally or informally. We will be honest with you and we hope that you will do the same to us in return. I think it's terribly important that we actually keep up our contacts with industry. 

Timely and accurate information. Very interesting. A lot of people believe you can have timely and accurate information. I believe you can have timely information or you can have accurate information. I'll just mention this, I'm trying to persuade somebody rather more eminent than myself at the Food Standards Agency on this point. The challenge for the Agency is to get in when an issue arises, but it's also the challenge to the Agency to give accurate information. If you're a campaigner it's very easy to get the headlines quickly and give inaccurate information. If you're, as we are, a regulatory body, it isn't. And thereby absolutely lies the road to ruin and disaster. We have got to be sure of our facts when we act, we can't take a punt, we're not interested in headline grabbing, and we're interested in giving people opinions, which are generally right and authoritative. And that means that at times we have to take more time than we would like or other people would like, to be quite sure that we've established the facts and got to the bottom of things. And that's the challenge and it's not easy, as I've indicated. 

Strategic plan. There will be a strategic plan but it's not there yet. And finally, measuring our progress. One of the things we accept, because frankly we wish it on everybody else, is that the Agency actually does have to have quite tangible measures by which its progress can be reached. It's no good people like me just turning up and saying, well I think we're doing quite well really aren't we. We actually need to have a series of programmes which can be measured, and also we need to have surveys of the public satisfaction, or otherwise, of what we do. And the Agency will be bringing forward both of these. So I hope, chairman, that gives people some idea of sort of what we're about at the Agency, but as I've indicated I very much welcome your comments and please be as hostile or as vitriolic as you like. Thank you. 

Sessional Chairman. Well thank you very much indeed, Geoffrey, that was most thought provoking. I'm sure we will have some questions that will at least keep you on your toes for a bit. So if I can ask you if you have a question just give your name and also where you come from, that would be very helpful for us. 

Question. Good afternoon. Roger Wilkinson from St Neots. I was very interested in the fact that you have open meetings of your Board. I think that's very commendable, I wasn't aware of it, obviously, it's all new. Are these regular meetings and can one just turn up or does one have to have a pre-booked seat, and is the agenda published before the meeting? And obviously where the meetings are held? Thank you.

 Answer. I'm sorry you asked the last question because I was going to say the answer to your questions is yes. But unfortunately that won’t work. The easiest way of doing this is to look us up on the web site, where we rejoice under the wonderful site of www.foodstandards.gov.uk, I always like the gov bit, and if you look under events, which is the only way you can find anything on the site, you will actually discover that it's set out quite clearly where the meetings are to be, how you can register if you want to, but you can turn up anyway. The advantage of registering, as I understand it, is that if you're lucky we do remember to send you the papers in advance. But I have had the odd complaint. I can't guarantee we do that, but in principle it does work, I am told. But certainly what does work is you are very welcome on the day, and the papers will be there on the day and you can collect them. And I should also add, one of the things we do at the end is we actually ask the audience if they'd like to make comments and ask questions, and this is extremely successful for the audience because they're as fresh as a daisy, not having had to do anything except listen to this debate, and the board are absolutely exhausted, as I am after three hours of it, so it's a very good time to come and score points. We hope to see you more. Thank you, any other questions I know this one, it's Paul Morrow from Bicester.

Question. As you said, the Food Standards Agency is a new body and its relationships with industry and body governments are involved. For us in the baking industry our sponsoring ministry has been MAFF and they're the people we answer to on labelling and additives. How do you see that changing if at all, or how do you see the future role between the Food Standards Agency and MAFF, industry section like us. 

Answer. I think that's a very good question and it's a right one to ask. The agreement we have with MAFF, which they have entered into is that on matters which we're dealing directly with we will continue to be the body with whom industry can consult directly, but that if industry decides that it really thinks these people in the Foods Standards Agency are a complete shower and aren't listening they are more than entitled to go off to MAFF as their sponsoring body and then MAFF will turn up and lobby us and say this is quite scandalous, why are you doing this. So in other words you have previously only had one bite at the cherry, now you'll get two I think is the honest answer. But we are very keen to keep our direct links with the industry for a whole variety of reasons. The first is that you have a lot of expertise out there on particular issues that we don't have, and I think the dialogue between people who may, if I can put it this way, have sort of the overall position but not the detail and not exact location with those who have the latter is terribly important. So we're very keen that industry should keep its links and keep feeling that it knows people in the Agency whom it can ring up and ask about things and so on. We very much want you to do that. The second is that what we do affects you. I mean you know that very well. And we are, quite properly, under a legal obligation to consult and take account of the interests of the people we affect. We do need to know from you what the potential impact is of things we might be proposing to do, and frankly we need to know from you whether in fact it's, in your view, completely barmy anyway. That is actually very helpful to us, and I don't have a problem with admitting to you quite frankly that things which may seem very sensible if 26 27 you are sitting in a government agency, may be absolutely barmy if you're on the ground. I'm bound to tell you I also think the converse is true, which is a good reason also to keeping up the dialogue. So I think you shouldn't feel in any way inhibited about coming to us. That's what I'd say. I don't want people in any way to feel that because we put consumers first that means in some way industries access to us is restricted. It isn't. Equally, because you have a sponsoring ministry in MAFF, you should not have any hesitation if you're fed up with us, or you don't know how to get hold of us, or there's a problem which you think MAFF ought to help you with, to go to them as well. We have quite lively correspondence with the ministry of agriculture from time to time which they conduct on behalf of the industry and let's say I think they're perfectly entitled to do it and I would never discourage it. I think it's perfectly proper for MAFF to represent the interests of the industry. We in return try and put forward the values I have mentioned, but also we are very concerned indeed about issues such as practicability, and issues about what is the economic burden that might result from a course of action, is it justified by the risk. I hope thatÍs of some help. Thank you. We have another question there. George Stevenson. Falkirk.

 Question. You mention small businesses and the burden of regulation and I'm not sure whether you're aware that certainly in the last few years there has been a huge increase of regulation, and it's not just in the food safety area. But this huge extra cost of compliance that small businesses have to cope with means that there's less resource available to do the really good stuff that we'd all like do, which is on the job training. This has been squeezed out in small businesses. You want to know why are we not coming to you and telling you. Well the problem is we're absolutely exhausted trying to deal with things that we don't really have time to get to grips with, it comes in fast and furious, often, we think poorly thought out, very little consultation, and you again say why don't you consult, because we're so exhausted dealing with these issues, and so it goes on. We've got into this sort of vicious circle and it just seems to us to be getting worse and worse and worse.

 Answer. Yes, well you might be surprised to hear that I actually have quite a lot of sympathy with what you've just said. I think you summarised very well what the difficulties the small businesses have that large organisations, on the whole, can cope with and have the staff to cope with all this stuff that turns up from government. I think for small businesses it's extraordinarily difficult. And one of the purposes of setting up this task force, which, let me say, has small business representation on it and is actually involved in talking to a lot of small businesses, is to try and get to the bottom of what in our area is really unnecessary aggravation that work causes and to try and see what we can do about it. As you know we're quite constrained, as you are, by European law and European law is not noted for its flexibility, but equally it is we who negotiate on behalf of the UK in Europe and certainly, for example, the re- negotiation of the general food hygiene directives does show some scope for actually realising that we should be going over to operators own risk base systems, and getting away from some of the, quite frankly, unnecessary and unhelpful detail requirements of the past. So I think to be honest with you George, I mean I can't claim I can solve all your problem, what I think we can say is that there is work that can be done, or has been done in this area in the past, to try and lift the burden of unnecessary regulation. And we're very much hoping that the task force will provide a way into it. But I appreciate also that it's not just burdens that come from us which are of concern to you, and I think there are hopefully lessons for the rest of government from this as well. Certainly, it is true to say that within government that the part of government which actually looks after general regulatory matters is very concerned on this issue, so it's not just us. I think there are other people acting. But as I say the difficulty is always drawing the line between what's an unnecessary regulation and what may be burdensome is actually needed. And I would have to say to you, to be quite honest, that on occasion we have had to talk to a small business over food safety issues when it's actually become quite clear that their non-compliance of the regulations would actually bring people hazards. But that doesn't invalidate your point. And it doesn't invalidate the obligation as to try, as we are, to do something about it. Thank you. We've got time for just one more. 

Question. Sylvia Macdonald. Croydon. You listed under values, independence, and under example, consumer focus not industry. But if you focus solely on the consumer doesn't that sometimes make you complicit in allowing unfair practices in 28 industry. Such as selling bread below cost. Something, which is costing the baking industry millions of pounds and thousands of lost jobs.

 Answer. I saw that example coming. Yes, I think you're general position is a perfectly fair one, which is that putting consumers first doesn't mean supporting anything that any consumer wants, if it's unreasonable. That's the first point to make. The requirement I mentioned earlier of proportionality on the agency is precisely designed to actually tackle this point. In the general position I agree with you, but I think, with respect, the way we're set up prevents us becoming compliant to unreasonable demands. The bad news, I'm afraid, is though I'm very well aware of what this industry's concern is about the loss leader selling of bread, it ain't I'm afraid something which we get involved in because we don't get involved in pricing. We have thought as to whether we ought to. I'll be quite frank with you, and I think there are some very tricky issues to tease out here as to how the interest of consumers are best served. I think it's a very interesting area, and I appreciate why it's commercially very difficult for you, don't misunderstand me. I think many consumers, if you ask them, would, as you rather imply in your question, say well actually this suits me fine, I actually like paying less for my loaf thank you very much. It is all about, of course, the issue of what is cross subsidising doing for the consumers. Is it in fact meaning that they are actually paying more for other goods without realising it and is it having a distorting effect from their point of view. It's not directly our responsibility but I do say, however, that we do have, I think, and we'll get more involved in this kind of pricing issue. It comes, I may say, in other areas as well. For example, there are quite interesting issues about how people on low incomes can get access to a healthy diet. That, of course, would include bread. That also is a pricing issue. So I'm afraid I can't offer you great joy on this point, I would say I do know your concern about this. Thank you, we have one other question if you'd indulge us on that. 

Question. Adams. Northampton. I'm very pleased that your main drive is really food safety and protecting the public. How much effort are you going to put into the education of the public in so far as the incidents of food poisoning continue to climb. The bread industry is continually blamed for the food poisoning. It's my contention that the public tends to poison themselves more than we do. For instance, a certain lawyer in Northampton accused us one time of poisoning her and it's quite clear when her doctor told the story that it was her food that she cooked the previous night that poisoned her. But as the last thing she ate was something from us she blamed us. And that, I really sincerely do believe, is one of the reasons for the climb in food poisoning, is the lack of education of the general public in this country.