A Healthier Scotland: Creating a New Food Body: Consultation Analysis

Full report of the analysis of the written responses to the Scottish Government consultation on the role and remit of the proposed new food body.


2.1 In 2010 the UK Government moved responsibility for nutrition and food labelling and standards in England away from the independent Food Standards Agency (FSA) to the Department of Health and the Department of Environment, Food and Rural Affairs, respectively. Not only did this result in the sharing of responsibility for aspects of food safety and standards across different bodies, it also brought certain functions under a Government roof.

2.2 In Scotland, Ministers' commitment to improving public health has been evidenced in recent years in their development of comprehensive policies to tackle smoking and reduce alcohol consumption. Tackling poor diet and obesity is also seen as offering much potential for improving the health of the nation. The 2010 decision by the UK Government was viewed by Scottish Ministers as posing a threat to this, by reducing clarity in where responsibility lies for all aspects of food safety and standards.

2.3 Following the 2010 decision, Scottish Ministers asked Professor Jim Scudamore to undertake a review to assess the feasibility of establishing a stand-alone Scottish FSA (FSAS) which included a Scottish meat inspection delivery body, and which maintained the existing statutory objective of the FSA, to protect consumers. The Scudamore Review adopted two principles: in recognition of Scotland's distinct and complex problems relating to diet, obesity and certain food borne diseases, food safety should not become separated from consideration of nutrition and labelling and standards; and advice on food safety, nutrition and labelling should be independent and transparent, and should, therefore, be provided by a body at arms length from central Government.

2.4 Scottish Ministers accepted all of the Scudamore report recommendations, with the scandal over horse meat serving to strengthen their argument for the establishment of a single, independent public body, at arms-length from Government, with clear responsibility for all aspects of food safety and standards. The Scottish Government wishes to hear the views of consumers and industry stakeholders on the remit and role of the new food body. Ministers envisage its main concern to be consumer protection, and that its scope could extend beyond that currently covered by the FSAS, for example, to encompass public health generally, and to enhance consumer information such as advising on health claims in food advertisements.

2.5 The Scottish Government published a written consultation paper posing 16 open questions aimed at generating views on what the new food body should do and how food safety and standards should be addressed in Scotland in the future. The consultation went live on 28 February 2013 and closed on 22 May 2013. Five consultation events also took place between end March and mid May at which stakeholders discussed the proposed new food body and provided their views.

2.6 One hundred and twenty six written responses to the consultation were submitted . Table 1 shows the numbers of responses by category of respondent. Local authorities formed the largest category of respondent, accounting for 19% of responses. Ninety three per cent of responses were from organisations and 7% from individual respondents. The full list of respondents is in Annex 1.

Table 1: Number of responses by category of respondent

Category No. %
Local authorities4 24 19
Public bodies 21 17
Industry representative bodies 21 17
Professional Associations and Unions 17 13
Third sector 14 11
Academic/Research bodies 10 8
Individual business 8 6
Consumer representative bodies 2 2
Individuals 9 7
Total 126 100

2.7 An electronic database was used to collate responses to assist analysis. This database stored free text in a systematic manner whilst providing the flexibility for amendments as the work progressed. The fields used to record the material were based on questions used in the consultation document.

2.8 The analysis was largely qualitative in nature to reflect the open questions posed. One further rationale for minimising quantitative analysis was that many respondents perceived certain questions to overlap (in particular questions one, eight, nine and ten) with respondents cross-referencing to comments made to earlier questions, rather than providing discrete commentary for each. This resulted in challenges for the analysis in determining actual numbers of respondents on each topic and the numbers of respondents holding particular views. An emphasis was therefore placed on reporting the range of views rather than determining proportions of respondents holding each view. Where numbers of those mentioning each view are recorded, these are indicative only and cannot be extrapolated to any wider population.

2.9 Throughout the report quotations from non-confidential responses are used where these illustrate and emphasise key views. The quotations were extracted from a wide range of responses with every respondent sector represented.

2.10 The following 10 chapters document the substance of the analysis. Chapter 3 examines issues of scope of the new food body and in particular whether its this should extend beyond the current scope of the FSA in Scotland. Chapter 4 looks more closely at the division of roles and responsibilities between the new food body and the Scottish Government. In Chapter 5 approaches to securing the best available independent expert advice are explored along with ways in which the new food body can establish a strong, independent evidence base for food safety, food standards and nutrition policy. Chapter 6 presents an analysis of views on appropriate statutory powers for the new food body for regulation, enforcement and monitoring, particularly in the wake of the horse meat incidents. In Chapter 7 the focus is on official food and feed controls and the way in which the new food body will work with local authorities in ensuring their delivery. Chapter 8 synthesises views on how assurance of delivery of official controls will be undertaken through robust audit procedures which meet relevant EU obligations. In Chapter 9 views are presented on potential partnerships and other relationships with the new food body, which will help it contribute to improving Scotland's health. Chapter 10 explores the topic of engagement with consumers; and Chapter 11 focuses on approaches to ensuring the new food body's independence from Government and the food industry.

2.11 Respondents were given the opportunity to provide any further relevant commentary which had not been addresses by the preceding consultation questions. Their additional responses are documented in Chapter 12.

2.12 Respondent categories have been abbreviated in the report as follows:

Local authorities LA
Public bodies PB
Industry representative bodies IRB
Professional Associations and Unions Prof A&U
Third sector Third
Academic/Research bodies Acad
Individual business Bus
Consumer representative bodies Cons
Individuals Ind


Email: Karen McCallum-Smith

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