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
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
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
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
Table 1. Number of news articles about bacterial contamination
||Financial Times (UK)
|E. coli (*)
(*) 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.
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
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.
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.
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.
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
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
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
Table 2. Number of participants at Codex Commission meetings
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.
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.
(1) International Journal of Food Microbiology, Vol. 25, 1995
(2) Scrambled Eggs, Center for Science in the Public Interest, May,
(3) World Health Statistics Quarterly, WHO, August, 1997
(4) Food Irradiation: Solution or Threat - CI/IOCU Briefing Paper,
(5) World Consumer, December, 1999
(6) Med Care 27, 1989
(7) U.S. Office of Technology Assessment report, 1995
(8) WHO Report, October, 1997
(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