Set up exactly 10 years ago this month with the remit of becoming the consumer's champion and restoring public confidence (badly dented by the BSE crisis) in the safety of its food, the Food Standards Agency (FSA) now finds itself at an important crossroads beyond its control.
The FSA's future structure and direction lie very much in the hands of politicians in particular, in the hands of the Conservative Party. The Tories' shadow health secretary Andrew Lansley has made clear his intention of stripping the FSA of its diet and nutrition activities, which would be transferred to a new Department of Public Health, should they win power at the general election.
While such a move wins the support of a number of individuals, many others fear it would jeopardise the progress made in improving the nation's dietary health over the past 10 years.
They claim the FSA's approach to raising consumer awareness about healthier diets, while working closely with the food industry on voluntary reformulation of products to improve their nutritional balance, is now a model followed by countries around the world.
"There is still an awful lot more that needs to be done on nutrition," says Sue Davies, chief policy advisor for consumer group Which?, who also sits on the Board of the European Food Safety Authority. "And it's really important that we don't lose that momentum, because the UK is generally seen as leading the way on a lot of these initiatives."
Removing the FSA's nutritional responsibilities would be a "backwards" step, fears Davies, as food policy reverted to being the political football it was prior to the FSA's formation in 2000.
However, you only have to look at the FSA's latest five-year science and evidence strategic plan to see that priorities have been set. While nutrition and health are included, food safety is clearly at the top, to accommodate what FSA chief executive Tim Smith calls a "nuclear situation" should Lansley carry out his plans.
Speaking to Food Manufacture last month, Smith accepted the possibility of the FSA losing its nutritional health responsibilities under a future Conservative government. "We face an election where we might have a different outcome for the Agency than the one we've currently got," says Smith.
But, whoever is in power after the election, Smith recognises the FSA faces some huge challenges not least in terms of financial constraints. As a result, the strategic plan "has some contingency in it". Such financial constraints worry Davies, too: "It's making sure the FSA is still able to deliver on those things in the current climate We would see safer food, healthier eating for all and informed choices as the three priorities."
Smith also fears that the tightening of public purse strings could impede food safety inspections and the policing of food standards by local authorities. "As the competent authority, we want those people to be there doing the same job as efficiently as possible for the tax payer, with minimal burden on industry, but ultimately protecting consumers."
High and lows
So what has the FSA actually achieved in its 10-year existence? While some sceptics might argue very little, most stakeholders including large parts of the food industry would be far more generous.
Independent studies have confirmed that the FSA has been remarkably successful in restoring consumer confidence in the safety of the nation's food. "In incremental stages, that trust has been built from a very low base," says Smith. "It is hard fought and hard won and we want to hold that."
Davies adds: "There is always more that we think it should be doing and things it could be doing better, but generally it has pretty much transformed the way we deal with food policy for the better." She thinks the FSA's activities in the field of nutrition from reformulation of foods to front-of-pack labelling have been a particular highlight of the past 10 years.
But it has not all been plain sailing. Problems have arisen form time to time and, the FSA would claim, lessons have been learnt. For example, the FSA conducted a review of the way it handled the Sudan 1 dye contamination incident in 2005, following bitter complaints from the industry about the disproportionate way many recalls had been made when the risks were actually very low.
Then there were the criticisms about systemic inspection and auditing failures identified by Professor Hugh Pennington's Public Inquiry report into the outbreak of E.coli O157 in South Wales in 2005.
And yet, despite it all, the FSA has proved to be a shining beacon of openness: consulting widely with all stakeholders, while being prepared to tackle some very thorny issues in public. The FSA claims its reliance on a 'science and evidence base' means it can maintain public confidence, while not being seen to pander to vested interests be they commercial or lobby group campaigns.
Again, it doesn't always get it right. Some would argue that the FSA's inquiries into aspartame to assuage the concerns of some critics of the high-intensity sweetener were a step too far, especially when there was no evidence to support it being unsafe.
Relations with industry
Smith makes no apologies for the FSA working closely with the industry to bring about changes deemed necessary, primarily through mutually agreed voluntary targets. "We know that working in co-operation with the industry is absolutely paramount," he stresses. "If you try to regulate the food sector without that co-operation and collaboration you wouldn't make nearly as much progress."
However, Smith readily admits that the FSA hasn't always got it right, particularly with the meat supply chain arguably one of the most important sectors it regulates.
"We assumed when the Agency was set up, that if we established proper ground rules and ways of working, that everybody connected with the riskier ends of the food supply chain would pretty much march to the same drum beat and they haven't. It's taken us a lot longer to co-ordinate and persuade some sections of the meat sector, for example, to join in."
Smith hopes that the integration of its Meat Hygiene Service (MHS) under the direct control of the FSA Board with effect from this month will help achieve this goal, although he recognises there is still much to be done, specifically regarding the adoption of a more risk-based approach to regulation and inspection. But progress on this front requires a change to EU legislation, which is unlikely to happen in less than five to 10 years, a timeframe which Smith describes as "alarmingly long".
Smith acknowledges the tensions that sometimes exist in the FSA's relationship with the food industry, which he mainly puts down to an issue about timing. "If we fail to communicate effectively, it's usually been about short notice, rather than the quality of the communication."
But he also argues that a little tension is probably not such a bad thing. Without it, he argues, there is the danger of consumers being mislead into believing the FSA is too close to the food industry. That said, he believes it is important for the Agency to press manufacturers in areas such as reformulation to reduce salt levels, for example. But, he claims, the FSA is open to compelling arguments from the industry, where it can demonstrate when things have gone too far. He also recognises the importance of targets being applied more equitably across different sales channels, including foodservice as well as retail outlets.
Science and consumers
One criticism that has been levelled at the FSA by the likes of Davies and others is that it hasn't always been quick enough to provide impartial advice to explain to consumers the risks and benefits associated with the use of new science and emerging technologies.
Most recently, this has been about nanotechnology, but it could equally be said for techniques such as irradiation and the use of novel antimicrobial technologies such as bacteriophages a type of virus that is effective in killing pathogens such as campylobacter on chicken.
Smith accepts the criticism. "The Agency probably hasn't done enough with the information that its scientific committees were giving it," he says. "I think the themes that emerged from [the recent Lords Science Committee report on nanotechnology] are a real learning point for the Agency."
He sees part of the FSA's responsibility being to translate scientific advances into something that doesn't unnecessarily worry consumers while giving them information about risks and benefits they need to make informed decisions.
So, it seems, the FSA has an uncertain future. But, whatever else happens, it is likely to remain the champion of the UK's food safety culture.
"We will never get it 100% right; we are only one phone call away from another serious incident. But do we feel more prepared and more ready? Yes we do," says Smith.
Predicting those unknowns is something that the Agency hopes to get better at through 'horizon scanning' by its specialist scientific advisory committees.
"We have to be mindful of where the next melamine might come from and what might happen in the event of a real disruption to an important part of the food supply chain," he comments. "But the flexibility of the Agency to respond to that is built into the structures."