Judging by its press release it seems we’ve upset the National Farmers’ Union. The Agency’s Board decided not to support relaxing the ban on processed animal proteins (PAP) in feed, and the NFU is extremely disappointed. So disappointed it not only plans to challenge the decision, but has written to the agriculture Minister to raise concerns over how the decision was reached.
The ban on PAP came into force after the BSE crisis. It was brought in for a good reason – to control the spread of BSE – and it was successful. So we’d need a pretty good reason to support lifting the ban.
The European Commission is considering partially lifting the ban, and we were asked to provide advice to Ministers. The NFU claims that the Board ignored scientific evidence and was influenced by consumer opinion. It also said that ‘a general mistrust of science or distaste about animal protein feed by consumers or board members must not override the science and risk-based approach the agency claims to take in all matters.’
It’s satisfying that the NFU recognises our commitment to basing advice on science. Yet it’s important to acknowledge that it’s not just pure science that we take into consideration when providing advice or developing policy. We also have to consider what is deliverable in terms of compliance and enforcement, and what may be acceptable to consumers and will maintain confidence in the food chain.
The Board accepted the advice of independent scientific experts that if the ban were lifted, the risk of BSE entering the food chain is probably negligible, providing effective controls are in place to prevent infective material entering feed. So the science says that ensuring the risk stays negligible depends on establishing and maintaining strong and effective controls and enforcement.
Separate ‘feed chains’ will be needed for PAP and non-PAP feed to avoid cross-contamination. And the Board considered that effective enforcement at this point is something that no one can yet guarantee, not scientists, not farmers and not the Government. So the risk could no longer be said to be ‘negligible’.
As the Agency’s remit is to put the consumer first when it comes to food and food safety, we also carried out research with consumers – we like to collect all kinds of evidence. They turned out to be against lifting the ban.
They currently feel that using PAP is unnatural, and there would be few benefits for consumers – it wasn’t as if the meat would be better quality or any cheaper. As one consumer put it, on behalf of nearly all of them, ‘why bother changing a system that isn’t broken.’ Ignoring consumers' views weakens their faith in the safety of the food chain. So no PAP for now is our advice – based on all the evidence, not just part of it.
And this is what a ‘risk-based’ approach to policy making should be – considering all the factors, based on science and evidence, balancing risks against benefits, with the consumer always coming first.