The Food Standards Agency is ready for the United Kingdom to leave the European unio with a new approach to understand risk and more surveillance, according to the authority’s leader.

Heather Hancock was questioned this past month by the Environment, Food and Rural Affairs Committee, led by Neil Parish. Topics included Brexit, food crime, allergens and regulation reform.

The United Kingdom held a referendum in June 2016 and voted to leave the European unio, a move that became known as Brexit. This was supposed to happen in March but has been delayed until Oct. 31.

Hancock said the agency has been planning all along for a role that assumed a no-deal Brexit.

“We did that because no matter what our future relationships are going to be we had to recreate an entire regulatory regime almost from scratch. wher we will be after exit is a central competent authority for the three countries in which we operate and I hope maintaining a close working relationship with Scotland. We think it is in the interest of consumers for this to be as cohesive as possible in areas of food safety, feed safety and standards,” she said.

“We will be doing the risk analysis so understanding what the science is about for any food or feed safety risk, we will be doing the risk management advice and presenting advice to ministers on risk management decisions. Ministers have made a commitment in due course to delegate the vast majority of decisions in risk management to the FSA but we don’t yet know what the triggers for that will be and we haven’t yet got the power to make those decisions.”

Decisions such as how to handle chlorine-washed chicken or hormones in beef have bigger implications, but the 200 reauthorizations annually for additives in feed could fall under the agency’s umbrella.

“The risks are (that the new system) has not been tried and tested,” Hancock said. “Our new approach to incidents has been running since the beginning of February and it is already generating a better set of outcomes than it was previously. We know how to do the science and risk management but there is a volume and scale that is different.”

Hancock said there is no reason why there would be an immediate change to the risk of food entering the U.K after Brexit.

“Over time that may change depending on changing trade flows and incidents, but there is no immediate need for any anxiety amongst the public or anyone else about how we cope with that. We know how to cope with that, we’ve resourced additionally in case there are pressure points for it, we’ve supported port health authorities and we’ve got a team to deploy if there were particular hot spots,” she said.

Proactive instead of reactive
Hancock said the agency deals with about 2,000 incidents a year. After it leaves the EU, the U.K. would not have access to the Rapid alert System for Food and Feed (RASFF). Britain’s relationship with the European Food Safety Authority (EFSA) remains unclear.

An FSA team has built a system to look at wher incident risk is coming from using industry sources, RASFF and FSA surveillance on international risks and trends in food safety, recall data and root cause analysis.

“Last year there was an issue with strawberries in Australia having needles inserted into them. That came in through the INFOSAN alert system and it was in the media. We knew two days before any of those alerts were provided because of the triage system we had built. By the time that news broke we had already established none of those strawberries were in the U.K,” said Hancock.

Surveillance has used mostly open data sets and cloud-based systems to do predictive modelling of wher risks might come from.

“We built the model on the basis of Turkish figs which have spikes in aflatoxin risks. We’ve now applied it across a range of food products and what it showed us is we, within the EU, control the import of Brazil nuts from Brazil because of aflatoxin risks, they are under specific official controls. But if you apply what causes the aflatoxin risk in Brazil on a wider model, you would see that same risk applies on Brazil nuts coming from Bolivia but there are no official controls,” she said.

“The reason for the difference is the regime in existence before is reactive, someone has to see something wrong with a product and then the incident management kicks off from there. What we are trying to do is predict wher there might be something happening and be on the front foot about it.”

The U.K. is also trying to strengthen ties to international networks with Steve Wearne, currently vice chair of the Codex Alimentarius Commission, hoping to become chairman of the organization and the FSA seconding someone from June to work on developing alert and intelligence sharing systems with the International Food Safety Authorities Network (INFOSAN).

Going digital and using data
Hancock said regulatory reform, known as Regulating Our Future, began in 2016.

“The heart of this proposition is the global food system is ever more complex, there is the use of data and technology, new foods, new consumer expectations; we have an out of date regulatory regime. We were starting with the visible side of things, food hygiene and moving into food standards and moving that way up. What EU exit caused us to do was start at the top and move down,” she said.

“We’ve worked through looking at building a digital registration system, we have for the first time as of the end of March, a picture of every food business in England, Wales and Northern Ireland. There is no point in it being too complex as it would dissuade businesses from doing the right thing and registering. We have to be better able to evidence that we are holding the whole regime to account.

“We are now looking at how do we improve and use data including from third party assurance schemes to make better risk-based judgements at the local level. Over time that will generate better information for local authorities on wher to go and what to prioritize such as a particular geography, establishment or food.”

The National Food Crime Unit (NFCU), founded in 2015 after the infamous horse meat scandal, was granted £2 million ($2.6 million) in additional funding for 2018-19 to help take on investigatory powers as well as its intelligence gathering activities.

Hancock said the unit is involved in complex fraud issues around adulteration and mislabeling, sometimes involving international markets and the processed food and meat sector.

“We have two major fraud investigations underway at the moment, one is Russell Hume which has been going on for 12 months and hopefully we will be able to present a case quite soon on that. In the other one, we are supporting three local authorities or police forces with other complex food fraud investigations.”

Findings from a review of meat cutting plants and cold stores were published in October 2018. The report included 19 recommendations for industry and regulators. It came after serious non-compliances were identified at cutting plants operated by 2 Sisters Food Group and Russell Hume.

Hancock added the agency will be reporting on the first six months of progress after the report in June.

Another issue was 2,4-dinitrophenol (DNP) sold to those wanting to lose weight. It is illegal to sell DNP for human consumption. The FSA said it has contributed to a number of deaths and instances of serious harm to health.

“The other thing is the sale of products which aren’t food but which are being consumed as food, sometimes in the well-being category. Products being put, quite often, from online onto the market. There are a lot of grey areas, they are not a medicine, they are not controlled under anything else so they are falling into the category of food because they are being eaten, none of us would think they were a food but they are becoming treated as novel food. That is a real big issue for NFCU because of the scale of risk to the public,” said Hancock.

“The final bit of the jigsaw is we do need time in the legislation program for some investigative powers for the food crime unit, they would be powers under the Police and Criminal Evidence Act, we don’t want powers of arrest, but they are about the ability to pursue investigations. In the short term we have agreed a protocol with the National Police Chief’s Council for forces to support us in these cases but we are still talking about the appetite of police forces to divert resources into fraud cases.”

Increased allergen focus
Hancock said the agency is seeing an increase in allergy related cases and is finding itself increasingly stretched with only one expert witness for allergies.

The FSA Board Meeting on May 8 discussed allergens and a consultation response. In October 2018, the government started reviewing allergen labeling for food that is Pre-Packed for Direct Sale (PPDS) following a Coroner’s inquest into the death of 15-year-old Natasha Ednan-Laperouse in July 2016 after eating a baguette which contained sesame seeds. Formal recommendations will be made to the Secretary of State with an announcement to follow later.

“Whatever the right measure is to take in response to this labeling issue, it has to be in the context of how we continue to move forward in protecting food allergic and hypersensitive people in a way that also doesn’t cause them to have less choice and freedoms in relation to food,” said Hancock.

“We are acutely aware of the unintended consequences of getting this wrong. If we take a step which everybody thinks is going to be a silver bullet solution to the problem of what’s in the sandwich you buy off the shelf it might encourage people not to take the other measures they need to do to protect their health.

“There has been some unintended consequences to the level of media attention such as the increase in the general disclaimer on the shelf as you go into a shop. I met with industry a couple of weeks ago to talk about this, I understand why they are doing this but there is a lot of anxiety of unintended consequences and reducing choice for food allergic people.

“Sixteen to 24 year olds are disproportionately at risk of food allergies, this is partly a behavioral thing, they are out of the home for the first time making their own food choices. One of the questions for us is whether we should prioritize the 16 to 24 year old interest in the response or we should look at the impact across the whole food allergic and hypersensitive community. We should remember since 2014 life has got a lot better for people with food allergies and intolerances eating out.”