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CEO of the Food Safety Authority of Ireland Dr Pamela Byrne talks to Catherine Reilly about the expansive role of the Authority and the growing and complex nature of food safety risks
“We see food safety as primarily the protection of public health and that is something that is really critically important,” Dr Pamela Byrne (PhD), CEO of the Food Safety Authority of Ireland (FSAI), told the Medical Independent (MI).
Referencing the 2020 World Health Assembly resolution calling on member states to strengthen efforts on food safety, Dr Byrne stated: “You need to continually invest in food safety, because the minute you become complacent about food safety, that is when things go wrong. That is what we always say to food businesses.
“The legal obligation to put safe food on the market is on the food businesses; our job is to verify that they do so. And where they don’t, we take the appropriate action that is required to correct that… so we don’t end up in a situation where we have a public health crisis on our hands.”
The FSAI is a statutory, independent and science-based regulatory enforcement body dedicated to protecting public health and consumer interests in the areas of food safety, hygiene, integrity, and authenticity. This remit involves a wide range of activities.
Enforcement orders served on food businesses are a particularly well-known aspect of its work, especially those cases where rodent activity or the presence of cockroaches are identified. In 2019, some 49,501 food businesses were under the supervision of official agencies that have service contracts with the Authority.
In the same year, the FSAI issued over 100 public warnings about food being recalled or withdrawn from the markets through food alerts and food allergen alerts. In support of food incidents, in 2019 the Authority carried out 205 risk assessments and provided more detailed advice for 10 food incidents and one significant outbreak of Salmonella.
Other areas of activity include food sampling, provision of technical support to official partner agencies, audits of the food control system and targeted audits of food businesses, as well as investigations.
Furthermore, the FSAI produces scientific reports to inform public health policy and guidance at the request of the Department of Health. Recent reports have made recommendations on vitamin D supplementation in older adults and the nutritional needs of toddlers and pre-school children, for example.
A new FSAI scientific committee, chaired by Consultant Microbiologist Prof Martin Cormican, has recently been appointed by the Minister for Health.
Having access to independent science to inform risk assessments is critically important, added Dr Byrne.
The FSAI is not a research-funding organisation, but has a “serious appetite” for research and evidence. “We work with research-funding organisations across the State, to identify and articulate what are our scientific priorities and then they include those in their research-funding calls.… Where there is a food safety component to those proposals, we would be involved in the evaluations.”
The Authority has “significant scientific excellence” within the organisation, including about 30 staff with PhDs.
Currently, there are two postdoctoral researchers working with the Authority through Science Foundation Ireland’s public service fellowships programme.
These projects are focused on data analytics for signals of emerging food safety risks; and assessment of the safety of probiotic foods on sale targeted at vulnerable groups in Ireland.
“We have quite an expansive mandate and, of course, we don’t work alone,” explained Dr Byrne. “We are very much part of a system of controls and while we oversee and coordinate the control system in Ireland, we work very closely with the official agencies.”
These agencies include the HSE (Environmental Health Service), Department of Agriculture, Food and Marine, Local Authority Veterinary Service, Sea Fisheries Protection Authority, and Marine Institute, among others. According to Dr Byrne, the expertise at the Authority is “well recognised internationally”. She said the European Commission has pointed to Ireland as a country “which has a strong control system and many of our team are used to build up capacity in other European countries”.
Dr Byrne said the Authority leverages its international networks to help ensure the integrity of the food system, the organisation and its control systems.
“Members of the team are members of the International Commission on Microbiological Specifications for Foods. I have been involved in co-founding the international heads of food agencies forum. We engage very strongly at a European level through the Heads of Food Safety Agencies. And we are also very much involved in Codex, which is the international standard setting body.”
The FSAI has also contributed to the work of the World Health Organisation on several occasions, most recently on allergens.
“We are constantly looking and identifying areas for improving the control system we have,” underlined Dr Byrne, “because the food system we live in and get food from is a global system…. We are bringing in food from so many different countries and Ireland is also then exporting food to 180 markets across the world.”
Despite many positives, however, the FSAI has been facing issues of considerable concern. As previously reported by MI, a FSAI board meeting in February 2020 discussed a letter from the Chair of the audit and risk committee regarding the “stark funding situation” and “the concern over the viability of the FSAI”.
At the time, a FSAI spokesperson said the resourcing constraints arose from pay restoration, non-pay-related Brexit activities, and an increase in the resources required to meet legal obligations. A FSAI board meeting in November 2020 heard that without additional resources, the Authority would not be able to “keep up with the changing, growing number and complexity of food safety risks”.
MI asked the FSAI’s CEO about the emerging risks and the current funding situation. According to Dr Byrne, there are a number of “significant threats” to the global food system that have, or may have, implications for food safety.
The threats centre around climate change; the global nature of the trade environment; and changing consumer preferences. These all create “a very dynamic environment”, which can drive the emergence of new hazards.
“These new hazards can be new or more virulent pathogenic bacteria or viruses from other parts of the world, new marine toxins from algal blooms” and emergence of toxins that were only previously seen in warmer waters, as examples.
“Then there are also some consumers favouring under-cooked or raw food, which can be a challenge from a food safety perspective….”
Dr Byrne also referred to considerations around policy dynamics at European level. Under the European Green Deal, for example, the EU is targeting net zero carbon emissions by 2050.
“From that Green Deal has emerged a new ‘farm to fork’ strategy, which is very focused on the concept of sustainability and a sustainable food system, and that talks about cutting pesticides, it talks about reducing fertilisers, it talks
about increasing the amount of organic farming in the European Union. All of these are important for the environment, for biodiversity and to meet consumer demands.
“[Such developments] do potentially require us then to look at what new risks might emerge from this – the shift in farming practices or manufacturing practices as the system moves to one that is more sustainable.”
The FSAI monitors emerging risks though its own mechanisms and as a member of the European Food Safety Authority’s emerging risks exchange network.
“In order for us to be able to identify those risks and take action to mitigate those risks, we need to make sure the resources that we have been given through the funding from the Department of Health are used to best effect,” outlined Dr Byrne.
“And it is fair to say food systems have become more complex, the legislative environment has become more complex, and on top of that, over the last couple of years, we have been dealing with Brexit and as well as that now, Covid-19.”
Dr Byrne acknowledged “it has been identified at board level that there are challenges around resources”.
She said that “we continue to prioritise the resources we have been given against the areas of highest risk and just are really focused on doing everything we possibly can to protect consumers”.
“Last year we received an increase from the Department of Health, which we are very grateful for, and we have obviously used that to best effect.”
In recent years the FSAI has undertaken extensive work in regard to Brexit. This has included assisting food businesses to prepare for import controls for food coming from Great Britain.
“One of the areas we are now focusing on is the export certification requirements. Obviously a number of Irish businesses export to the UK and we have been working with our colleagues across Government to make sure the export certification system that is in place for those businesses meets the requirements for Great Britain, that will apply from 1 October 2021.”
The Authority is also examining the extent to which the UK may diverge from EU food law in future years and the potential implications for food safety.
Covid-19 has presented a myriad of additional demands. These included enabling FSAI staff to work safely from home, which was fully achieved within six weeks. The Authority has engaged with businesses throughout the pandemic, ensuring they have specific advice around food safety, such as actions required after periods of closure.
“Last year we did see, and we are still digging into the reasons behind this, a significant increase in the number of illegal food businesses, which meant that our investigation team was very, very busy,” she noted.
One high profile case concerned a ‘sushi business’ operating illegally from a bedroom in Dublin and advertising through Instagram.
“This was quite amazing for us, actually, that anybody would think it was appropriate and safe to operate a sushi business from a bedroom,” commented Dr Byrne.
“This product was delivered all over Dublin. Instagram was the platform through which people bought this product and it was heavily driven by Instagram influencers saying ‘this product is absolutely wonderful, you have to give it a go’.”
As the ‘business’ was operating in a domestic dwelling, the FSAI involved An Garda Síochana to obtain court orders to enter the premises and take enforcement action to protect public health.
The rapidly expanding market of food supplements is another highly demanding area for the FSAI.
“There is a legislative framework for food supplements. We continue to enforce that legislative framework through the inspection regime we have in place and the control system we have,” outlined Dr Byrne.
“It is a very, very complex sector. There are a substantial number of products on the market and coming into Ireland, that may not necessarily be legal….”
Any company wishing to put a food supplement on the Irish market must notify the FSAI and provide a copy of the product label. The FSAI assesses whether the label is compliant with legislation governing food supplements and health and nutrition claims.
The growth of cannabidiol (CBD) products has presented a significant challenge. Many of these products which come from outside of Ireland have not been notified to the FSAI, contrary to legal requirements, and are traded online.
A FSAI survey on CBD products on the Irish market, published in 2020, revealed that the majority of products analysed were in breach of various articles of food law and some posed potential safety risks for consumer. These products were all on sale in stores and sampled by HSE environmental health officers on behalf of the FSAI.
Some 37 per cent of the products tested had a tetrahydrocannabinol (THC) content that could result in safety limits set by the European Food Safety Authority being significantly exceeded. In addition, the analytically determined CBD content in over 40 per cent of samples varied significantly (>50 per cent) from the declared CBD content.
Furthermore, 34 per cent of the samples were classified as novel foods and require authorisation before being placed on the EU market.
THC is a controlled substance in Ireland with no tolerance level set in the Misuse of Drugs Act, 1977. In food, THC is considered a contaminant with no permitted threshold in the EU.
The European Food Safety Authority has established an acute reference dose of 1µg/kg body weight, above which the safety of ingested THC cannot be guaranteed.
“Sixteen products with THC were removed from sale and we issued a food alert last year,” noted Dr Byrne.
“We have ongoing monitoring of the CBD products on the market at the moment and we have a number of actions pending.”
In April the FSAI issued a warning for consumers about the danger associated with eating edible products, such as jelly sweets, containing cannabis components. This warning followed a number of recent incidents whereby edible products containing significant levels of THC were intercepted by An Garda Síochana and Revenue’s Customs Service.
“In at least one incident, sweets containing cannabis oil were consumed by a number of teenagers, one of whom subsequently suffered serious adverse health effects requiring hospitalisation,” according to the Authority’s statement. The particular sweets were apparently purchased online with the packaging carrying explicit warnings to eat the sweets cautiously and that a significant concentration of THC was present.
The FSAI has set up a multiagency taskforce involving An Garda Síochana, HSE, Food Standards Agency Northern Ireland, Forensic Science Ireland, and Revenue “to look at how we might be able to remove illegal food products containing controlled substances from the market”, according to Dr Byrne.
One of the difficulties faced by the FSAI, and the reason that multiagency collaboration is required, is that many of these products are being sold through the internet and coming through various online sales platforms.
“We are progressing and taking action against those business that are claiming that there is, for example, CBD in the product, but there may be no CBD or very little… despite what is said on the label,” outlined Dr Byrne.
“So this is an area of ongoing concern for us. It is also an area of ongoing activity. All I can say at the moment is we are focused on this and we have a number of different teams set up looking at various different aspects of this. We are only going to be able to achieve success in this area by working collaboratively with a number of other organisations of the State.”