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Hultsfred, Sweden 2000-06-30
 

European Commision
Health & Consumer Protection Directorate-General
Rue de la Loi 200
B-1049 Bruxelles

Thank You for giving us this opportunity to respond to the White Paper on Food Safety, and especially how consumers can participate in the risk anlysis process, including risk management. Association of European Consumers AEC has since its foundation 1999 worked for increased consumer information. We have recognized consumers' right to sustainable development in relation to food safety as a main focus for our work. We also work to raise awareness about environmental and ethical issues, animal welfare, and global issues. For food safety, we also consider the development and conservation of agro-genetic resources as important for consumers. 
 

Consumer information

While we support the proposals in the White Paper on Food Safety, we would like to propose that consumer information gets a more prominent role in the development of a European food safety policy. This needs to be a horizontal concern. Experts from consumer organizations need to be informed to be able to play a role in the risk analysis process, especially in the management of risks. Consumers should never feel that producers, retail or governments may hide data about food safety. To treat any food related issue as a "trade secret" will give consumers the impression that someone is hiding a "dirty secret". 

We are insisting that consumers have a right to access to scientific documents that are used in the risk assessment process, and cannot agree that corporate interests should be protected rather than human interests. Unpublished studies should generally not be used, especially if they are reporting from studies conducted at corporate laboratories or sponsored by the industry. One area we are very concerned about is intellectual property rights, were patents on DNA, especially in microbes, grains, vegetables and other foods including fish or meat may create monopolies that will not at all benefit consumers. 

Health is paramount for European consumers and after food scandals such as BSE we insist that we have a right to be an equal party of the risk analysis process. In order to participate fully, we must have access to all available information. This is also true in the field of nutrition, were new substances or foods may or may not turn out to be benificial to consumers.
 

Risk analysis

In the risk analysis process, consumers can be successfully represented by professional experts from consumer organizations at all three stages. Participants from consumer organizations are skilled at raising awareness of important matters that scientists, businessmen or politicians may overlook. In the risk assessment process, professional experts from consumer organizations can ensure that health protection and ethical concerns are taken into proper consideration. Experts from consumer organizations can assist policy makers in the risk management process by supporting or clarifying decisions that need to be communicated to other parties of the process. They will make sure that consumer concerns are heard by all parties, as well as send strong and rapid messages to all involved when decisions are not understood or appreciated by consumers. In the risk communication process, experts from consumer organizations can be the "honest brokers" that are percieved as being unbiased and fair if they have had access to information at all stages of the decision making process.

We think the risk analysis process in the European Union will benefit from increased scrutiny by professional experts from consumer organizations. This will also aid and benefit the European Union in the international arena. Specifically, we do not think the current system of FAO/WHOCodex Alimentarius standards is sufficiently transparent. Codex alone cannot guarantee that all food additives, pesticide residue, veterinary drug residue and microbes are safe. 

We insist that the European Commission must provide better information to consumers about the risks and benefits associated with controversial developments in the field of industrial food production technologies such as irradiation and biotechnology. The European Commission must work towards a situation where the JECFA and JMPR expert groups will be opened up to normal scrutiny and ensure that meetings are open to observers from consumer organizations. Otherwise, the World Trade Organization agreements, especially the SPS Agreement, will not be acceptable for European consumers.
 

Animal welfare

Animal welfare concerns are intimately connected with food safety issues. Association of European Consumers AEC thinks the White Paper of Food Safety is rather weak in areas such as animal transportation and slaughter methods. Consumers may be exposed to many contaminants such as E coli bacteria or Campylobacter that are known to cross-contaminate animals in the slaughter process. We welcome the proposals for safe animal feed as this has often been neglected until now. Please do not ignore the need for safe drinking water. Also unhealthy substances such as naturally-occuring stress hormones may contaminate the meat as a direct result of long transports of live animals. 

Slaughter methods that cause unnecessary stress and/or pain for the animals must be banned and the monitoring needs to be improved. It must be recognized that zoonotic diseases cost society a lot of money. We especially urge the European Commission to step up activities at the International Office of Epizootics to develop international animal welfare standards. Good standards should be based on a cradle-to-grave approach that take into account the importance of sustainable animal breeding methods.

Consumer organizations can participate more actively in the risk management process if certain demands are fulfilled. Mandatory animal welfare labels are probably the quickest way of giving consumers a way to influence the current situation, especially in a crisis of confidence, as more consumers become aware of the ethical issues involved. We support the current push towards country-of-origin labels for meat and we think this should be extended to other meat product groups as well. The traceability of food products through proper documentation is important from the animal welfare perspective as this can be used to ensure that a mandatory animal welfare label becomes reality as soon as possible. Egg labels is another area that certainly need to be improved and were animal welfare concerns must be considered. Improved standards and regulations for fish products also need to be considered as many consumers are questioning the environmental aspects of over-fishing while they may also want to avoid products from unsustainable fish farms.

Conclusion

We strongly urge You to make sure that consumers get the proper information they need in order to make informed choices about new developments in the fields of food and agriculture. We want to be involved in the risk analysis process, including risk management, on an equal basis with other experts. In the democratic market place, consumers are as important as the producer. We, as European consumers, generally enjoy good consumer protection but will look forward to continue to work with You towards better food safety.

Sincerely
 

Bengt Ingerstam  President
	Martin Frid Assistant on Food Safety