Written evidence submitted by The Food Standards Agency
Thank you for inviting me to give evidence before the Committee on 24 April on the work of the Food Standards Agency. During the session, I agreed to write with further information on: Blockchain Technology; and our work with Defra on imported food inspections post EU exit. David Rutley MP, Agriculture Minister, has written to you on preparations for imported food inspections, across our two departments. In this letter, I cover blockchain and a short update about allergen labelling of food pre-packed for direct sale, which we discussed at the hearing. I also wanted to mention the display of FHRS stickers in England, which we didn’t touch on.
Fraud and error in the food supply chain damages the industry and has a negative effect on consumer trust. We believe that data could be used more effectively across the supply chain to ensure traceability of food items and increase consumer trust.
Lord Holmes of Richmond’s 2017 report on Distributed Ledger Technologies for the Public Good made the case for using Blockchain technology as a potential tool to counter food fraud. It particularly highlighted the need to adopt a data-centric approach to improve traceability and transparency and suggested that Blockchain could provide an opportunity to improve traceability in the food supply chain.
In order to test this hypothesis, we commissioned two trials to evaluate the opportunities from the use of Blockchain:
• Collection and Communication of Inspection Results: The FSA has a legal obligation to provide the results of meat inspection to food producers. Currently, the delivery of this is affected by issues with data flow and data quality. An animal can typically have had several owners prior to slaughter and, at present, the data collected at slaughter cannot easily be made available to all historic owners of an individual animal. Additionally, with the analysis of fragmented data, it is very difficult to identify the source of conditions affecting animals. The FSA
trial builds on the DEFRA Farm to Fork initiative to test the Blockchain concept, and uses actual condition data from animals and slaughterhouses. As the Blockchain solution identifies individual animals it provides the ability to look at specific animals, co-conditions and journeys across a range of dispersion points in the supply chain.
• Export Health Certification: This trial has focused on pork exports to China. The existing certification process is resource intensive and requires about 35-50 certificates per week to be completed for pork exports to China and the USA alone. The certification is done by an Official Veterinarian working on behalf of FSA. Trade with third countries can subject the UK to complex requirements on rules of origin. Having information that is complete, accurate, auditable and sharable will mean that the burden of the exporter of collating and validating the accuracy of such information is minimised. The Blockchain enables this much more reliable data to be used by various stakeholders (e.g. industry, other Government departments), which reduces the administrative burden and the potential for error during data entry. However, the biggest benefits come from the traceability aspects of being able to assure the authenticity of the supply chain and supporting the British brand.
Both these trials have focused on a thin slice of the overall supply chain that was within the
FSA’s remit. The trials are nearing completion and have clearly evidenced the opportunities from the Blockchain. Of course, used in isolation it cannot be the silver bullet to tackle food traceability in a fragmented supply chain. Our work on data standards, to improve data quality and improving data sharing, is important to enabling more success from the adoption of Blockchain. Additionally, used in conjunction with other technologies (e.g. Internet of
Things devices) and intelligence from other approaches such as the new Strategic
Surveillance programme I discussed with your Committee, Blockchain can be a powerful tool to improve traceability particularly for food items that are harder to trace (e.g. processed food). When complete, both these trials will undergo a formal independent review to establish their success and the key learnings.
We are exploring whether the distributed model of the Distributed Ledger Technology enables industry to own and share responsibility for the Blockchain, with the regulator as just another actor. We are also keen to see how such an approach levels the playing field for all businesses – you don’t need deep pockets to be a participant.
We are engaging with and sharing our learning with the UK food industry and other Government departments (e.g. APHA, HMRC). Working with the Internet of Food Things initiative led by Lincoln University, we are looking to connect the data to the physical foodstuff. On an international stage we are engaging with the Global Food Safety Initiative and the U.S. Food and Drug Administration. With these engagements and using forums like the UK All-Party Parliamentary Group on Blockchain we will seek to identify opportunities for further work to build on the trials.
My appearance before your Committee took place in advance of the FSA Board reaching a conclusion following the Government’s consultation about allergen labelling of foods prepacked for direct sale. Last week, we held a special Board meeting to discuss the issue of food hypersensitivity (allergies and intolerances) more widely, and the specific labelling consultation.
Emerging evidence, which we will publish later this summer, suggests that the impact of a serious allergy or coeliac disease on quality of life can be as high as the most serious microbiological risks from food, and much more significant than the impacts of risks that traditional food safety systems have been designed around. One of the challenges with food hypersensitivity is the relatively paucity of science and evidence. We believe it is essential that academic and clinical research ramps up in this area, and that the NHS provide better diagnosis and improved recording of, food hypersensitivity. There has been a steady increase in allergen incident notifications and Allergy Alerts issued by the FSA over the last four years, caused by errors in business production controls. To further complicate the picture, food is being prepared, ordered, sold and delivered in new ways, and people’s food behaviour and expectations are changing quickly. This creates a challenging dynamic in which to provide public health protection and champion consumer interests in relation to food. The increased understanding of the scale of the public health issue, and its impacts on the lives of people with food allergies and intolerances, has led the Board to decide we must scale up our ambition and accelerate our action on food hypersensitivity. We want the UK to be regarded as the best place in the world for a food hypersensitive consumer. This can only mean incremental improvements – no one can yet eliminate the risk from allergies and intolerances – but we can make sustained and material improvements over time, with the right science and enough focus.
Turning to the specific labelling consultation about food pre-packed for direct sale.
Responses from business and public-sector bodies favoured measures ranging from good practice, to asking staff, to allergy-only labels on this specific food product. We considered carefully the points made by business about giving a false sense of security to consumers if full ingredient labelling was introduced, and that introducing full labelling was an additional burden on business particularly on small businesses. Ultimately, we concluded that the consumer interest was resoundingly in favour of full ingredient labelling on this specific food product. We recognise the challenges in introducing this successfully, and it will take time and careful planning and engagement with the industry to achieve the right outcome, and for local authorities to provide guidance and enforcement. In England, the responsibility for the food information regulation rests with Defra, and I will be writing to the Rt Hon Michael Gove MP Secretary of State for Defra with the Board’s advice later this week.
Finally, we did not discuss this, and I know the Committee is well aware of the FSA’s wish to see mandatory display of the Food Hygiene Rating Scheme (FHRS) sticker in all food outlets in England. FHRS display is the biggest subject in our correspondence from
Parliamentarians, and it is widely supported by local authorities and others. Display of the sticker is already required in Wales and Northern Ireland. Officials here are working on the business case for this additional regulatory measure to be introduced in England, to present to Ministers later this year.
I am grateful for your Committee’s continued interest in and challenge to the work of the FSA. If you and colleagues would like to see more of our new technology and data approaches, especially in regards to surveillance and local authority monitoring, officials would be delighted to host a briefing for you.
May 2019