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2000-03-22

How to obtain and evaluate data and opinions of interested parties in risk management

Presentation by Martin Frid, Swedish Konsument-Forum 
on behalf of Consumers International
 

1 Introduction

A food scare may be defined as an outbreak of illness caused by ingestion of a certain food. Even a small food scare is usually managed very carefully as such events often remain in the consumers' awareness for a long time. In each case, details of the events should be made public as rapidly as possible and no information should be withheld. Public perception should also be monitored carefully and risk managers should stay informed about all aspects of consumers' opinions related to the incident.

For consumers, there are many disparate ways of finding out about a food scare. Usually, media is quick to report of outbreaks of food poisoning or suspected contamination of our food supply. Radio and TV, especially local channels, may dispatch reporters to the scene. If government officials are available for comment, he or she may be swamped with requests for interviews by the press. Consumer organisations are often seen as a reliable source of information especially as members may provide useful information to others.

The public is often interviewed "on the spot" in food shops or on the street. This type of reporting is problematic. While it makes for good entertainment to see a housewife or a pensioner express strong sentiments about certain foods, it is rarely factual and most likely misleading for the consumer at large. On the other hand, it is my view that the consumer is always right, even when they might be scientifically wrong.

2 "Key facts" and food scares

The outbreaks that capture the attention of the media and make headlines over some period of time are only the tip of the iceberg. A few people, often children, may die while hundreds or even thousands of adults get ill. Finding the "key facts" requires detective work. 

2.1 Bacterial Contamination

Would you let your child lick the bowl after preparing cakes and cookies containing raw eggs? Would you eat a sunny-side-up egg with a runny yolk at a restaurant? Should one eat sushi? What about ground beef? Bean sprouts?

There seem to be no good estimates of the number of consumers that are taken ill by bacteria-contaminated foods in even the most developed nations. One reason is that many cases are never report to health authorities. It may also be difficult to link a disease to a certain food. For developing countries the reports are even less reliable. We ought to have such basic data in order to better evaluate the effects of increased food trade over the next few years. WHO should consider funding case studies in certain countries from different regions of the world.

Consumers are often more familiar with certain types of bacterial contamination such as Salmonella or in Japan, for obvious reasons, E coli O157:H7. Few people are aware that there are different strains of certain bacteria while other types are often unfamiliar until one is told by a doctor the name of the cause of one's nasty diarrhea, such as Campylobacter. 

2.2 "Key facts" communication

Salmonella was virtually eradicated in Sweden when I was a child due to strict border controls and quick reactions whenever an outbreak occured at a farm. My father remembers vividly the summer of 1956 when a Salmonella outbreak caused several deaths. We know that control of Salmonella enteritidis (SE) is possible. In Sweden, only five SE-infected flocks were identified between 1987 and 1994. (1) These days, however, increased trade in food as well as more foreign travel have once again taught Swedish consumers to watch out for this particular bacteria. 

Surveys should be performed to investigate the effects of a outbreak. This helps both government officials and others to understand the scope of a certain event. During a recent SE outbreak in Falkenberg, Sweden, health officials at the city government disease prevention unit made sure all sick people were directed to a certain nurse at hospital unit for special monitoring. After the outbreak, health officials follwed up the food scare by sending out a questionaire to 130 people who had been tested positive for Salmonella. 114 people answered and the the results gave some indications of the grave effects on people's lives. These are some findings two months after the outbreak:
 

  • A combined days of sickness amounting to 4.5 years 
  • A total of 150 visists to the doctor
  • 24 people had been treated at hospital (21.0 %)
  • 37 people still did not feel well (32.4 %)


One strong lesson from the Falkenberg affair was that journalists were quite willing to report "key facts" such as exact numbers of cases, even if it was obvious that the numbers would increase day by day. If there are no reports of the number of cases, media have in other food scares tended to exaggerate the seriousness of an event. "Key facts" should also include any information available about the possible sources of the contamination. In the Falkenberg affair, health officials also reported that they felt it was important to be available and answer all possible questions from journalists.

2.3 Larger outbreaks

Meanwhile, in the U.S., Salmonella enteritidis (SE) has already reached epidemic proportions. (2) As far as I know, the Centers for Disease Control (CDC) data is widely acknowledged to reflect only a small fraction of total food poisonings. A famous 1996 statement by the CDC Director David Satcher estimated that there are between 200,000 and one million cases of SE illness in the U.S. each year. The WHO report from 1997 had an important message to everyone involved in public health and consumer policy work: "...Food-borne diseases may be 300-350 times more frequent than the reported cases tend to indicate." (3) 

In 1994, the Schwan's Ice Cream that made an estimated 224,000 children sick contained only six Salmonella bacteria per half cup. It turned out that one of the ice cream's ingredients had been transported in tanker trucks that had previously carried contaminated eggs. 

The staff at Konsument-Forum helped me gather some data from three newspapers on the Internet. By searching for different types of food scare related bacteria, we could see some trends in the reporting over the past two-three years. We counted the number of articles about each type of bacteria between January 1998 and January 2000 (Table 1.). I think the numbers speak for themselves:

Table 1. Number of news articles about bacterial contamination 
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Washington Post  SeattleTimes Financial Times (UK)
Salmonella 75 86 73
Campylobacter 9 13 3
E. coli (*) 40 145 47

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(*) not including articles about genetic engineering 

2.4 Other Types of Contamination

Strong opinions associated with certain foods may have evolved over time for cultural reasons. The  French reluctance to lift its import ban on British beef because of BSE is a case in point. The debate may be historically or politically motivated, and even seen as irrational. However, noone can ignore the fact that the public may not want to be exposed to foods from a certain country. Others may argue that nationalistic emotions are protectionistic, unjustified, and unreasonable barriers to trade. 

An import ban may in my view be a better way to avoid a huge public outcry that can influence trade in other, unrelated goods. Boycotts are the last ugly resort when the public feels strong anger at certain products. In cases of toxic contamination associated with food, the emotional situation becomes precarious. In any event, consumers expect to be able to identify the food by its label. Consumers will want to avoid certain ingredients such as eggs or milk products, if they are thought to be contaminated by toxins such as a chemical not intended for consumption. Consumers have a right to know if the problem is associated with certain shops, food producers, corporations, regions or countries. 

If the contaminated product cannot be identified, the food scare may lead to a larger and more unmanageble affair that can cost tax payers and the food industry huge amounts of money. This was the case recently in Belgium were the source of the dioxin contamination was not immediately identified, and were the contaminated products had already been dispersed to a large number of shops and supermarkets. One reason for the extent of this affair was the absense of "key facts". As consumers were confronted with empty shelves in their shops, health officials had very little information about the cause of the contamination.

3 Steps in different directions

Not all actors seem to be pulling in the same direction when it comes to food safety. Consumers International is not impressed by the timid efforts from the food industry to clean up its act, even if all improvements are welcomed. Also, consumers are getting a very mixed message about hygiene.

3.1 Irradiation

I want to say a few words about consumers' perceptions of food irradiation. Some now prefer to call it "cold pasteurization" to avoid the not-so-consumer-friendly association with radioactivity. The fact is, this technology is not at all welcomed by most consumer organisations. Consumers International does not believe that irradiation can play a significant role in reducing food borne disease. 
I have not seen any reliable, independent surveys of what consumers think about irradiation. In my view, contaminated foods that are irradiated do not feel clean, fresh or inviting. 

Irradiation would not have helped us avoid the U.K. BSE crisis or the recent Belgian food scare. Any analysis of this complex situation leads inevitably to the conclusion that irradiation offers significant benefits to the food industry and allows governments to apply a quick "fix" to their contamination problems. It offers consumers very little and it can have no significant part to play in addressing the serious world-wide consumer needs for adequate supplies of safe and wholesome food. (4) 

Consumers demand that irradiated foods be labelled. On the other hand, irradiation is no guarantee that the food is not contaminated. If an irradiated food is re-contaminated, for example in the shop, the consumer has not gained anything in terms of safety. I doubt that irradiation will survive a food scare were irradiated, radura-labelled products are identified as the "smoking gun". Consumers International recently critizised meat irradiation in the U.S. Some of the conclusions are that irradiation is seen as a shortcut by the meat industry to avoid addressing the issues of dirty slaughterhouses, rampant bacterial contamination, and other impacts of industrial agriculture. (5) 

3.2 Antibiotics

What's left of consumers' trust in foods has also been shaken by the news that many bacteria are becoming resistant to antibiotics. The impact of antibiotic resistance to health-care costs is substantial. One investigator estimated that the cost in the U.S. is between 100 million dollar and 30 billion dollar. The wide range arises from different values assigned to the value of a human life. (6) More recently, the National Foundation for Infectious Diseases has estimated the cost to be 4 billion dollar annually. (7) 

Antibiotics have been called the wonder drugs of the 20th century. Even though we have known for a long time that bacteria may develop resistance to certain antibiotics, we continue to overuse them in hospitals and on the farm. Agricultural uses of antibiotics account for more than 40 percent of all antibiotics manufactured in the U.S. 

Agricultural uses include treatment of sick animals, which noone contests, but in some countries as much as 80 percent is actually used for growth promotion and improved feed efficiency. The European Union has banned most antibiotics but not all. WHO, of course, recommends terminating antibiotic use in food animals for growth promotion. (8) It is the view of many experts that the use of antibiotics and drugs put an extra burden on animals, resulting in welfare problems. The cure has become the cause of disease.

3.3 Antibacterial products

A new trend in consumer products are antibacterial tooth pastes, dish washing detergents, sprays and soaps. They are products for use in one's private home that has zinc pyrithione or triclosan added to them. According to one estimate, about 700 antibacterial products have been introduced in the U.S. since 1992.

I wonder what happened to normal hygiene. It is my view, and this is now discussed by my collegues in different consumer organisations around the world, that the corporations that sell these products take a huge risk with millions of people's lives. If bacteria develop resistance to such substances, we have lost another range of products that should be used only very prudently and in special places like hospitals, under controlled conditions. I think this is an area were governments might want to step in and act before it is too late. 

4 WTO matters

As the Codex Alimentarius Commission has been elevated to an important status by the SPS and TBT Agreements of the World Trade Organisation, one might expect it to be more cautious about direct links to the food industry. Consumers International has taken the view that in spite of the problems, we must also work with the system. 

4.1 Precaution

It is generally the view of Consumers International that the WTO as well as other trade agreements should not be inflexible in the area of foods. In the case of the EU ban on U.S. beef because of growth hormones used by the U.S. cattle industry, Consumers International thinks the EU is right to pursue a coherent, precautionary approach, especially as too little seems to be known about the actual health effects from a scientific perspective. Consumer organisations argue that the Precautionary Principle must be implemented for making food safety decisions. At the Transatlantic Consumer Dialogue meetings, there have been strong support for the Precautionary Principle by both U.S. and European consumer organisations. (9) 

No government official or spokesperson at a food company should ever argue that the consumer does not have the right to avoid certain foods, whatever the reason may be. To choose one's own diet and decide that one will not eat certain foods have been a part of the human experience throughout history. All of the world's religions have guidelines about diet for many different reasons. For Muslims and Jews, pork is thought to be "unclean" food. Recently, the view is emerging that such precautionary rules may actually be based on practical, if not always scientific, experience in the countries were the bans have evolved. Pork is often associated with parasitic infections such as trichiniasis, especially in warm countries. The WTO should allow such countries to ban certain foods based on special climatic and traditional conditions. 

Increased world trade in foods also means increased exposure to a large number of poorly tested artificial additives. While not all such products are unsafe, the precautionary approach has too often been ignored when many artificial colorings and sweeteners have been introduced. Legally, in spite of protests, they may be added to foods as long as an acceptable daily intake ADI based on animal testing is not exceeded. Critics of ADI have long warned that children are likely to ingest higher doses than what is scientifically known to be safe. 

A recent Swedish study confirmed that diabetic children often consume quite high levels of aspartame, acesulfame-K and cyclamate, three artificial sweeteners. Especially the cyclamate consumption far exceeded the ADI. (10) One can only wonder if the consumtion of a wide variety of artificial food additives makes for example children more susceptible to contracting food borne disease. We know from the long debate about breast-milk substitutes that science can give us important clues if we ask the right questions. We know, for example, that artifically fed babies have a diminished immune functioning. (11) 

4.2 Codex

Consumers International is actively involved in the Codex Alimentarius process with the aim to contribute to establishing the highest possible standards for food, including food labels. As an observer CI may submit opinions and papers to the different committees such as CCFH or CCFL. For food experts working for national consumer organisations that are a member of Consumers International, writing and/or commenting on such CI position papers is a way of improving international food standards. Another path is to encourage consumer groups to work with the National Codex Contact Points although this system does not work very well in a large number of countries. (12) 

In 1999, the CI delegation achieved impressive results against all odds at the Codex Food Labelling meeting. The CI delegation felt it had significant impact on important decisions on irradiated foods, health claims, compound ingredients as well as standards for organically produced foods. One advantage of letting accredited international consumer organisations participate is that the advice will be independent of any corporate interests.

I should also mention that the International Association of Consumer Food Organisations (IACFO) has been formed by three consumer groups from the U.S., Japan, and the U.K. IACFO now participates in many Codex meetings which means a new, strong voice for improved consumer influence especially in the SPS area.

4.3 Working with the system

Certain Codex committees are more difficult to influence than others as representatives from the food industry are very prominent at Codex meetings. The number of observers at Codex meetings has increased from 29 in 1989 to 63 ten years later. Observers may work for industry organisations such as the World Federation of Advertisers or the International Dairy Federation. Other groups represent organic farmers or the biotechnology industry (Table 2.). 

Table 2. Number of participants at Codex Commission meetings
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Year Participants Countries Observers 
1999 608 103 63
1997 459 83 38
1995 429 94 39
1993 259 70 27
1991 351 77 25
1989 281 56 29

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Among 111 organisations that may participate as observers, over 100 are directly sponsored by the food industry or represent the interests of the producers. Sometimes it is embarrassingly obvious who the delegates represent. Reading from the list of observers at the latest Codex Alimentarius Commission meeting, Konsument-Forum staff was surprised to find that the contact person from the International Sweetener Association is in fact employed by Pepsi-Cola. The contact persons from the International Life Science Institute was employed by Monsanto, Procter & Gamble and Kellogg. In another case, the contact person representing the International Frozen Food Association was an employee at Nestlé. The press has also noted that such obvious links may harm the independence and excellence of Codex. (13) 

CI participates actively at the Codex General Principles meetings. CI has contributed to the discussion on other legitimate factors (OLF) and wants the Precautionary Principle to be accepted as an OLF by Codex. The CI delegation has felt that it has been successful in framing the discussions and in inputting ideas into the debate and the content of the Codex papers.

5 Some conclusions and suggestions

Far too little is known about food scares and the effects on consumers. Reliable data seems not to exist about the many cases of bacterial contamination that occur each year. However, outbreaks cause many deaths and an enormous number of cases of disease and suffering that cost society huge amounts of money. WHO should consider funding case studies in certain countries from different regions of the world to get more reliable data that can be used as a baseline as international food trade increases.

Most consumers are often not sufficiently informed to avoid certain foods during a food scare. "Key facts" should be made available to the public during a crisis. At a minimum, labels should always provide the necessary information that allows individuals to make intelligent choices. 

Antibiotics should be banned for use as growth promoters in animal feed. Consumers should be better informed that such important drugs are overused both in hospitals and on the farm. Antibacterial products should not be sold for use at home.

The food industry must become more realistic about its desire to influence legislation and not demand unconditional deregulation in areas were consumer protection may require other, more prudent approaches. The WTO agreement has weaknesses especially in the area of international food standards. The Precautionary Principle must have a role in WTO. More dialogue with consumer organisations may help the food industry understand the strong concerns about their actions. Irradiation is one such area that should not be promoted or used as a silver-bullet approach to remedy the difficult problem of food contamination.

Consumer organisations both on the national and international level are stepping up efforts to become involved in improving food legislation and establish standards within the Codex Alimentarius system. Up until now, the food industry has been able to influence many decisions. Recently, Consumers International and IACFO are emerging as strong defenders of consumers' rights. This work should be encouraged and supported widely. 

References:

(1) International Journal of Food Microbiology, Vol. 25, 1995 
(2) Scrambled Eggs, Center for Science in the Public Interest, May, 1997 
(3) World Health Statistics Quarterly, WHO, August, 1997
(4) Food Irradiation: Solution or Threat - CI/IOCU Briefing Paper, 
         September, 1994 
(5) World Consumer, December, 1999 
(6) Med Care 27, 1989 
(7) U.S. Office of Technology Assessment report, 1995
(8) WHO Report, October, 1997 
(9) http://www.tacd.org
(10) Var Foda, Swedish National Food Agency, 1/2000
(11) Scientific American, 12:76, 1995
(12) Consumer Policy Review, Vol 7, Number 4, 1997
(13) See for example The Lancet, April 3, 1999 or The Observer, 
 March 14, 1999
 


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