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.



5.1 The work of the new food body will be shaped by independent, expert science and evidence, which takes full account of the Scottish landscape, whilst ensuring that decisions are informed by a balance of views. This may be achieved in part by securing access to the scientific advisory committees5 that currently support the FSA, Defra, the Department for Health and the devolved administrations in their food and feed-related work. Additional sources of science and evidence may be needed, particularly if the role or remit of the existing scientific advisory committees changes over time. It may also be necessary to identify where it needs to develop stronger links with other networks of scientific expertise, both in the UK and internationally.

5.2 The consultation asked:

Question 4: What steps do you think could be taken to ensure the new food body is able to access the best available independent expert advice it needs to underpin its work on food safety and public health nutrition in Scotland? Please give reasons.

5.3 Eighty eight (70%) of the 126 respondents addressed this question. The most common view (mentioned by 45 respondents (51% of those providing a view)) was that the new food body should secure access to the scientific advisory committees currently operating. Reasons given were:

  • avoids duplication of effort (24 mentions)
  • recognises the integrated nature of the food supply chain (12 mentions)
  • avoids unnecessary expense (4 mentions)
  • ensures access to the best available advice in the UK (2 mentions)
  • is an established and effective way of working (2 mentions)
  • there are not enough suitably qualified advisors in Scotland (2 mentions)
  • ensures consistency of advice (1 mention)
  • protects against isolation (1 mention).

5.4 Four respondents expressed caution regarding such access arrangements. Two (Prof A&U, Ind) perceived the speed of response from such committees to be slow, with meetings not frequent enough to allow for responsive, efficient provision of advice. Two (Third, Ind) questioned the independence of members, suggesting that some had close links with, or represented, parts of the food industry. One respondent (Ind) suggested that committees had difficulties collaborating on topics which required cross-committee consideration. They also suggested that the practice of fixing membership over a set period risked restricting expertise during this time.

5.5 Two respondents (IRB, Ind) recommended that the new food body should undertake a review of the usefulness of the existing scientific committees currently accessed by FSA in order to assess the extent to which they fit its purpose.

5.6 A recurring view (26 mentions) was that independent expert advice exists within Scotland, with reference made to academic institutes and research bodies, Scottish Government departments, the wider scientific community, public analyst services, NHS Health Scotland and health boards and local groups and committees. Specific mention was made of particular bodies including Health Protection Scotland, NHS National Services Scotland Division, Scottish Colloquium on Food and Feeding, Association for Nutrition, Scottish Public Health Nutrition Group, Science and Advice for Scottish Agriculture, Marine Scotland and Dunstaffnage Marine Laboratories.

5.7 Twenty five respondents argued for the new food body to make links to relevant international organisations to ensure access to independent expert advice. Their reasons were:

  • the food industry is global in nature (14 mentions)
  • to facilitate awareness of relevant developments at an international level (8 mentions)
  • to keep up with the speed at which new developments are introduced (3 mentions)
  • the best science and advice is not necessarily available in Scotland (1 mention).

5.8 Six respondents recommended that the new food body consider how best to take up opportunities to access the European Food Safety Authority as a source of advice.

5.9 Fifteen respondents commented on the new food body's access to research, arguing for it to be given sufficient funds and power to commission new research. It was generally felt that there should not be an in-house Research and Development function, but that external experts would be commissioned to provide this in an open and transparent manner. A recurring comment was that research evidence required to be of good quality and peer-reviewed in order to ensure its objectivity and competence.

5.10 Joint working with other UK bodies was suggested to commission research (PB) and to avoid duplication of effort (IRB, Cons).

5.11 A further four respondents recommended that more attention is given to utilising research, disseminating evidence and sharing good practice.

5.12 Ten respondents considered that expert advice could be tapped into within other parts of the UK, for example at Public Health England, and relevant English NGOs.

5.13 Six respondents argued for the new food body to employ and retain staff with expertise. One commented:

"The organisation needs to be led by individuals with proven expertise in the breadth of issues affecting diet, nutrition and health - including food safety, nutrition, marketing and also the socio-cultural and economic issues" (Midlothian Food and Health Alliance).

5.14 One academic recommended that staff at the new food body keep up-to-date with expert advice and information by keeping abreast of primary scientific literature, attending science meetings, participating on relevant committees and developing links with researchers in the field.

5.15 Other steps which were identified by respondents as helpful in ensuring the few food body is able to access the best available independent expert advice needed were:

  • exploiting expertise in the private sector (2 mentions)
  • establishing additional Scottish expert advisory committees with a view to these taking the lead for the whole of the UK (2 mentions)
  • appointing a Chief Scientist to be responsible for the quality of science commissioned and the evidence used, and to provide a link to the network of advisory committees (2 mentions)
  • setting up short-life expert working groups (particularly at times of crisis) (1 mention)
  • setting up steering groups of independent experts to work on specific topic areas (1 mention)
  • developing a Memorandum of Understanding between the new food body and the FSA to ensure a free flow of information and advice from expert committees (1 mention).

5.16 The consultation asked:

Question 5: Do you consider that the new food body should focus its research and surveillance activities on issues that are particularly pertinent to Scottish citizens or should it also contribute to science and evidence programmes on wider issues which have relevance to the UK as a whole? Please give reasons.

5.17 Ninety four (75%) of the 126 respondents addressed question 5. The overarching view was that issues pertinent to Scottish citizens are not divorced from those relevant to the UK as a whole and therefore the suggestion that there should be a choice of one or the other is invalid. Twenty five respondents, however, were clear that their preference was for a strong emphasis on issues pertinent to Scottish citizens in any research and surveillance activities, particularly if the resources available for these activities are limited. Typical comments were:

"It is the opinion of Health Scotland that the new food body should focus its research and surveillance activities on issues that are pertinent to Scottish citizens first and foremost, but also having the scope to contribute to science and evidence programmes on wider issues, which have relevance to the UK as a whole" (NHS Health Scotland).

"The new body should concentrate on Scottish issues but should co-operate on any overlapping issues with other bodies in other areas" (Scotland for Animals).

5.18 Arguments in favour of giving research and surveillance activities a Scottish focus included:

  • The funding comes from Scottish citizens so the focus should be on matters particularly relevant to them (IRB, IRB).
  • There are other bodies, such as the Department for International Development, which are already funding research of more global relevance (IRB).
  • Scotland-specific issues are amongst those least likely to be addressed by others (PB).
  • There is already ongoing surveillance in other parts of the UK (Acad).
  • There is a strong contingent of research experts addressing obesity in Scotland (Acad).
  • Scotland's relatively small population makes it possible to conduct regionalised research on a controllable scale with findings of benefit to wider audiences (IRB).

5.19 Some respondents highlighted what they considered to be the distinguishing factors in Scotland associated with health, diet and nutrition, which they felt gave weight to the argument of focusing on Scotland-specific issues. The factors mentioned were: prevalence of deprivation and health inequalities; poor dietary culture; food poverty; relatively high rates of alcohol abuse; relatively high rates of obesity; historically high rates of E-coli; lack of Vit D; relatively high rates of MS; poor climate; and specific food hygiene issues such as shellfish hygiene.

5.20 Although the merits of ensuring a Scottish perspective were acknowledged by most of those who responded, a common view was that the new food body should also contribute to science and evidence programmes on wider issues of relevance to the UK as a whole, and indeed further afield. The reasons given were:

  • Food businesses in Scotland link to the UK supply chain which is part of the Scottish economy (19 mentions). One respondent remarked:
    "The food chain is a global concern and Scotland sources food from around the world on a daily basis. It also exports food across the globe. Some foods produced in Scotland start life in other countries or in transnational or international waters. FSA Scotland cannot limits its scope to concerns at country level, but needs to strengthen its links and interests by the most efficient means possible, internationally" (Royal College of Physicians Edinburgh).
  • Most issues, such as obesity, do not respect national borders and those that are relevant to Scotland tend to be relevant to the UK as a whole (14 mentions). A relevant comment was:
    "All aspects of food production, manufacturing, labelling and marketing are now global, and many of the health trends affecting Scotland are not unique to Scotland. Research and surveillance must reflect this and should be able to learn from good practice across the globe" (Midlothian Food and Health Alliance).
  • Linking with wider programmes avoids duplication of effort (7 mentions).
  • Contributing to other programmes enables resources to be pooled and makes best use of limited funds (6 mentions). One individual respondent expressed their view:
    "Research and surveillance is expensive - Scotland cannot afford to 'go it alone' and have expertise in every issue of relevance to Scotland, hence a partnership with other UK bodies working on similar issues would seem the best value for public money".
  • Reciprocal research and surveillance activities reap benefits in terms of learning, for example, understanding about Scottish issues in relation to other contexts and perspectives (6 mentions, largely academics).
  • Many Scottish research institutes are internationally renowned (IRB).
  • The new food body will need to deal with both Scottish and UK issues (LA).
  • Scottish experiences cannot be separated from other geographical areas (Cons).
  • If the focus is limited to Scotland this could distort the evidence base and compromise evidence-based policy development (Prof A&U).
  • A Scotland-only focus could be perceived as parochial and failing to contribute equitably to the development of the evidence base (Prof A&U).

5.21 The consultation asked:

Question 6: Do you consider that the new food body should be responsible for the coordination of all Scottish Government funded research on food safety and public health nutrition? What steps could be taken to raise the profile of the new food body as a research funder across the UK and beyond? Please give reasons.

5.22 Eighty one (64%) of the 126 respondents addressed question 6 as follows:

Table 4: Views on whether the new food body should be responsible for the coordination of all Scottish Government funded research on food safety and public health nutrition

No. of respondents % of respondents
Yes 40 49
Yes for food safety but in partnership for public health nutrition 15 19
Yes for food safety but not sure for public health nutrition 2 2
Possibly 1 1
Mixed views 1 1
No 14 17
Commentary only 8 10
Total 81 100

NB Percentages may not total 100% exactly due to rounding.

5.23 Of those respondents who provided a view, 49% considered that the new food body should be responsible for the coordination of all Scottish Government funded research on food safety and public health nutrition; a further 19% (largely local authorities) supported the new food body coordinating research on food safety but recommended its working in partnership with the NHS, Scottish Government and local authorities on public health nutrition research. Seventeen per cent of those providing a view were opposed to the new food body taking on such responsibilities.

Views in favour of the new food body coordinating all Scottish Government funded research on food safety and public health nutrition

5.24 Few substantive reasons were provided by supporters of the proposal. Recurring themes were that such coordination appeared to be logical and would provide a joined-up approach which will reduce duplication of effort. Other comments were:

  • Provides a single point of contact for information flow (Prof A&U, LA).
  • Will enable gaps in research to be identified and addressed (Acad, Cons).
  • Could help to improve overall dissemination of lessons from research (Acad, PB).
  • Helps to maintain a focus on the key topics of improving public health and tackling inequalities (PB).
  • Makes more efficient use of resources (LA).

5.25 Some respondents qualified their support. Four respondents (IRB, IRB, PB, Acad) argued that a coordinating role would need to be underpinned by appropriate resources for commissioning, managing, reviewing, monitoring and other associated tasks. Two respondents (LA, Prof A&U) emphasised that research commissioned by the new food body will need to be in line with strategic objectives for each year of the strategic plan. Others (Acad, Ind) recommended that the new food body liaises closely with other coordinators and commissioners of research to ensure duplication is minimised. Two respondents (PB, Prof A&U) urged that the implications of the proposal (for example, for the Chief Scientist's Office) are explored further with key stakeholders such as the Scottish Government, before it is implemented.

5.26 Other stipulations requested were:

  • The core purpose and independence of the new food body should not be diluted or compromised (Cons).
  • The research agenda should encompass consumer research and engagement (Ind).
  • Smaller research projects should not be ignored (IRB).
  • The Scottish Government already has resources in place for managing research and this could be utilised (Acad).
  • In addition to coordinating research, the new food body should commit to disseminating the findings broadly:

"The key to this however.....is dissemination of research to ensure that messages are reaching the agencies that are supporting consumers within their communities: NHS staff, local authority staff and the voluntary sector. The new food body should have a role to disseminate research broadly" (Midlothian Food and Health Alliance).

Views in opposition to the new food body coordinating all Scottish Government funded research on food safety and public health nutrition

5.27 Those opposing the proposal provided a variety of reasons to support their view:

  • Coordinating, commissioning and managing research requires significant expertise which the new food body may not have (Acad, Acad, PB, Bus, Ind).
  • Responsibility should be shared with NHS Health Scotland (LA, LA, Ind).
  • The proposal risks narrowing the research agenda (Acad, PB).
  • Food system is complex and it does not make sense to separate out research on food and health from food and agriculture or food and environment. This could lead to duplication of effort and inefficiencies (Acad, Ind).
  • Dilutes the key functions of the new food body (Bus).
  • Puts "all the eggs in one basket" which could compromise the emergence of alternative or independent opinion (Prof A&U).
  • Could result in overlapping responsibilities with other bodies (Prof A&U).
  • No clear added benefits of the proposal - appears to be superfluous to the current arrangements (Acad).

Views on raising the profile of the new food body as a research funder

5.28 The most common suggestion (18 mentions) on how the profile of the new food body could be raised as a research funder was by using existing links to relevant institutions such as universities, research groups and public bodies across the UK and internationally. It was recommended (IRB, LA, PB) that the promotional work could be undertaken at conferences and other research events, with the quality of research produced contributing to profile-raising (LA, IRB). Three respondents (Prof A&U, Acad, IRB) commented that the profile of the body would be raised in line with the amount of funding it has at its disposal. One remarked:

"The profile of the new food body as a research funder will rise quickly enough if it is seen as having enough money available to support substantive projects" (Quality Meat Scotland).

5.29 One suggestion (Ind) was that pursuing "niche" research pertinent to public health in Scotland could raise the new food body's profile and also the profile of relevant research institutes and academic bodies. Another respondent (Third) recommended the introduction of a research award scheme.

5.30 Two public bodies considered that the new food body could raise its profile as a research funder by maintaining clear communication channels with NHS boards and local authorities, so that local research dovetails with nationally driven work.

5.31 The consultation asked:

Question 7: Do you have any further suggestions for how the new food body could establish a strong, independent evidence base for food safety, food standards and nutrition policy? Please give reasons.

5.32 Seventy two (57%) of the 126 respondents addressed this question. An overarching theme was that independence of evidence and approach to gathering evidence will be vital for building trust in the new food body.

Internal arrangements

5.33 Three respondents (Acad, IRB, Ind) emphasised the importance of ensuring the new food body has an experienced and well resourced research team with a broad range of expertise at the helm of its evidence-gathering operations. Broad representation on the research commissioning panel was requested (Third, Prof A&U), with transparent methodologies (Prof A&U) and internal expertise to interpret data, under the management of a Chief Scientist (Ind, Prof A&U). A strong focus on understanding consumer perspectives was recommended (Cons), with a wide range of stakeholders including consumers and consumer groups consulted prior to taking key evidence-based decisions (Cons, LA). One respondent (LA) urged that evidence-based decisions should be based on scientific reasoning rather than political pressure.

5.34 Four respondents stipulated that the research from which evidence is drawn should be peer-reviewed. The establishment of a centre of excellence/expertise for evidence within the new food body was mooted (Acad, Ind).

5.35 The importance of open and accessible communication of research evidence as part of the development of establishing a strong, independent evidence base was emphasised by three respondents (IRB, IRB, Third). NHS Health Scotland recommended that the new food body work with them to translate evidence into policy and practice through initiatives such as Knowledge into Action and evidence-informed decision-making programmes.

Building on existing networks

5.36 A common theme (17 mentions, largely local authorities) was to further the evidence base by enhancing and building upon existing networks, notably those already forged with the SFELC and the local authority food liaison groups and working with them to develop effective local sampling programmes. Seven respondents suggested that the wide membership of SFELC will help in establishing the independent nature of the evidence.

5.37 Another common recommendation (17 mentions, largely local authorities) was for national data sets such as the UK Food Surveillance System (FSS) to continue and be replicated with regulated support in place for local data collection systems to feed into the national data sets. One respondent (Prof A&U) called for the FSS working group to continue.

Liaison with external expertise

5.38 Fifteen respondents from a range of sectors attached particular importance to the new food body maintaining liaison with external expert establishments such as academic institutions, professional societies and public bodies both in the UK and further afield, to ensure the Scottish evidence base is up-to-date and independent.

5.39 There were mixed views on whether industry organisations should be engaged with to achieve a strong independent evidence base. Five respondents, three of whom were industry representative bodies, advocated involving industry organisations particularly in the planning stages of evidence gathering and application, in order to ensure practicality and efficiency. One respondent remarked:

"The new food body should have industry knowledge and stakeholder relationships that allow it to be aware, informed and up-to-date with key industry drivers. It should have a mechanism to allow it to consult with industry, particularly relating to the market effects of any initiatives relating to implementation of campaigns or projects aimed at consumers. Any such initiative should engage with the industry prior to commencement. This should be conducted to ensure consumer protection, but with greater industry buy-in" (Scotland's Rural College).

5.40 In contrast, three public bodies argued for research to be commissioned independently from industry, Government, or indeed any other body where competing interests may arise.

Collecting primary research evidence data

5.41 Common themes were that good quality, local information should be facilitated, with sample sizes appropriate to enable significantly valid analysis at regional and national level. Five local authorities advocated working with SFELC and its committees to design robust systems for information gathering. One respondent argued that that the recent food fraud incidents have "highlighted the need for accurate, 'real time' reporting abilities" (North Lanarkshire Council).

5.42 Seven local authorities described how currently local authorities submit their performance data into the UK-wide Local Authority Enforcement Monitoring System (LAEMS). Calls were made for this procedure to be reviewed with the aim of devising a more "user-friendly" system for gathering and interpreting the information.


Email: Karen McCallum-Smith

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