I thank the Chairman and the members for the invitation to speak to the committee about this incident. My formal role in the management of the incident was as a member of the expert advisory committee convened under the auspices of the Food Safety Authority of Ireland, FSAI, to advise the chief medical officer. I was chief executive officer of the FSAI between 1998 and 2002. As the first CEO, I contributed to setting up the authority as a science-based consumer protection agency. It was created in the aftermath of BSE when consumer confidence was damaged in respect of the safety of beef, the regulatory process and the industry's commitment to produce safe food.
I was a member of the management board of the European Food Safety Authority, EFSA, since its inception in 2002. Between June 2006 and June 2008 I was the chairperson of its board. This was a period when EFSA became fully operational in the areas of risk assessment and risk management. The BSE crisis and the Belgian dioxin crisis were two of several factors that precipitated a reform in EU food law and the creation of EFSA.
As members heard yesterday from the EFSA representative, that authority is engaged in risk assessment and risk communication but not in risk management. I am not employed by any of the competent authorities and my role in this matter was as a volunteer.
As this is the third day of the committee's deliberations and because members are now familiar with the chronology of events, I do not propose to repeat what they have heard from previous speakers. I will focus instead on some key points, make a few suggestions and try to answer any questions members may have.
With regard to risk communication, an additional task I attempted was to assist the chief medical officer and the authorities in communicating the details of the incident to the public. We tried to explain to the public why the Irish authorities took the action they did. This was not easy. Trying to reassure the public there was no need for them to worry if they had eaten pork products containing identified dioxin levels while at the same time telling them it would not be ideal to continue eating these products was challenging. With the intense media coverage in Ireland, Irish consumers, while unhappy and angry with the situation, quickly understood that although it is illegal to have these chemicals in food, continuous exposure over a prolonged period would be required to develop adverse health effects. Several Irish journalists managed to convey the concept that toxicity relates to bio-accumulation and body burden. In Ireland, people understood it was because of deficiencies in our traceability systems that a total rather than a focused recall was necessary.
However, many people were angry that so much good food had to be destroyed and that taxpayers' money that might have been spent in the health and education sectors was now being diverted to prop up the agrifood industry. Other Irish consumers questioned the morality of wasting all this good food when a third of the world's population is starving.
In other jurisdictions where the incident was not a major national issue, the same media coverage was not devoted to explaining exactly what these findings meant in terms of human health. Although there was a tsunami of coverage in many member states about toxins in pork, the writers did not offer the same detail in explaining this complex issue and in showing that continuous exposure is needed to develop an adverse health effect. As a result, confidence in Irish pork products suffered.
However, the decisive action taken by the Irish authorities, coupled with the risk assessment by the EFSA and the associated communications from both the EFSA and the European Commission, helped allay the fears of anxious and confused consumers and international purchasers of Irish pork products throughout the EU and further afield. Therefore, although we were in a position to try to reassure Irish citizens, we did not succeed in reassuring citizens in other countries until European agencies got into the ring and tried to explain the situation to them.
Regarding the proportionality of the response, there have been many questions as to why we pushed the nuclear button. In 1999 the Government in Belgium faced a very similar situation when livestock feed was contaminated with dioxins. It did not ignore the situation. It took an active decision that the risk was minuscule and did not warrant alarming the public. It thought that was a rational decision to take.
However, subsequently the information leaked out and the politicians and authorities were heavily criticised for concealing these facts from the public. The Minister for Agriculture was forced to resign, then the Minister for Health and finally the whole Government fell. They were accused of concealing information from the public and wholesale panic ensued regarding the safety of all Belgian food.
The argument was that industry and profit had been put before public health. Belgian chicken, poultry and dairy products were withdrawn and the US banned certain categories of food from the entire EU. Even Belgian chocolates were withdrawn globally because they could have contained milk from cows that ate the contaminated feed. There was no proper risk assessment done at that time, the situation got completely out of control and the incident dragged on for many months and caused huge financial and reputational damage to the Belgian food industry.
The Irish Government took the opposite approach and went public as soon as it was made aware there were dioxins in a subset of pork output. By ordering a total recall in this instance ongoing exposure was stopped and public health was no longer being put at risk. As already described to the committee by other speakers the inability to identify contaminated product in the marketplace made a more selective and less costly recall impossible.
Based on the total diet survey undertaken in Ireland by the FSAI, the initial rapid risk assessment by it concluded that given a total recall of pork products, adverse human health effects were not likely. A subsequent risk assessment by the EFSA was not that different in its conclusion from the initial Irish one.
Irish pigmeat and fat from Irish pigs is exported to the EU and further afield. One food processor in Belgium which provides pig fat to the manufacturing industry noticed an increase in PCBs in composite finished product containing pig fat from several member states since September. The September date is interesting. People wonder why we focus on September. It is because it is when the problem first appeared. The processor was trying to identity which country the contaminated fat had come from.
Although the level of PCB in the finished product had not exceeded the maximum legal limit it had crept up from a baseline of zero and this is what caused alarm. France and the Netherlands had also identified PCBs in products they suspected had come from Ireland and once Ireland shared its initial findings with them it confirmed their suspicions. The authorities in those countries would have alerted the EU public if Ireland had not done so.
On the basis of the emerging findings in other member states and results from Ireland it is likely the Commission would have introduced safeguard measures to restrict the export of pork and pork products from Ireland, pending investigations of the situation. These measures would have been similar to those introduced during the Belgian crisis. The Irish Government had to take decisive action or controls would have been imposed upon it.
It would not have been an option for Irish authorities to leave illegal contaminated product on the marketplace. Exposure of consumers to potentially contaminated product was limited by the total recall and destruction of the pigs that had consumed the contaminated ration. Due to the shelf life of processed pork products it was theoretically possible that had the problem not been identified and decisive action taken consumers could have been exposed to contaminated product for much longer periods, which would increase the likelihood of adverse health effects.
Regarding delays by other member states in identifying the source of the contamination, dates in September and October were mentioned as being when other member states identified problems. This incident highlights that Ireland is not alone in experiencing difficulty in tracing pork products. Processing product in large manufacturing facilities in all member states, with co-mingling and blending of raw material from several countries, makes traceability challenging. This contributed to delays in Dutch, Belgian and French food businesses identifying from which member state the PCB-contaminated material had come from. The level of PCB in food is an indicator of the amount of industrial pollutants in the food chain or environment. Ireland has no heavy no industry and no waste incinerators and would be not be considered as a member state having a high risk of PCBs in the food supply.
There is an ongoing surveillance system of Irish dairy cattle undertaken on behalf of the EPA in Cork that has confirmed extremely low levels of approximately one-tenth of the acceptable statutory limit of dioxins and dioxin-like PCBs in milk. This emphasises Ireland's low incidence of PCB in the food chains. The implicated food businesses in the other member states were testing raw ingredients from their suppliers attempting to identify the source of the contamination. I imagine because of the history of the low PCBs in our food chain the intensity of sampling of raw ingredients from Ireland may have been low or non-existent so they did not suspect that we were the source of the problem. The investigation and activities undertaken by the Department of Agriculture, Fisheries and Food were swift and thorough from the first positive identification of a pig through the national residue monitoring programme to the subsequent identification of the mill producing the contaminated feed, the restriction of all the farms that received the contaminated ration, and the supervision of the recall and destruction of the suspect product and implicated livestock. The initial sample was taken on 19 November and the decision based on the risk assessment of the FSAI to require the food industry to recall all products was taken on 6 December. People have commented on the delays but compared with other similar international incidents this response was extremely rapid.
On 8 December the results became available from samples taken from cattle on 11 of the beef farms where the contaminated rations had been fed. Traces of PCB were found in fat from animals on three of the farms. Most of the cattle that had eaten the ration were still alive on the farms which were now restricted and would not be sent for slaughter. Approximately 3,000 cattle that may have eaten the ration had been slaughtered since 1 September. Beef is not cured like ham or smoked like bacon and a large proportion of it works rapidly through the food chain and is consumed within a fortnight. Due to the BSE crisis there is a legal requirement for much more comprehensive traceability of beef than pork, and carcass quarters and prime cuts are very ease to trace. The destination of most of the other carcass components can be ascertained. The industry quickly moved to detain all easily identifiable output from the 21 implicated farms still in the supply chain. The Department confirmed that of the 120,000 cattle farmers in Ireland only 21 had received the contaminated feed and the FSAI concluded that there was no concern for public health and the actions taken were appropriate. It was suggested that rather than destroy all these cattle each one be tested and any found clear of dioxin be allowed into the food chain. The cost of doing the full dioxin test however is over €1,000 which is more than the animals were worth so this would not have been economically feasible.
While traceability is a component of every food safety management system it is not in itself a guarantee of safety, for example, the recycler at the centre of this incident had good traceability systems to identify his suppliers of raw ingredients and his customers. The traceability system in pork products is not as comprehensive as many believed it to be especially once pig meat enters the processing sector and becomes sausages and processed meats, liquid fat and some hams. Traceability to the processor on the day of production was possible but not all the way back to the individual farm. There is more complete traceability in small operations and artisan production.
The legal requirement is basic and people were compliant. It is possible to have much more elaborate traceability systems but it is challenging when there is commingling and blending of products from many sources and countries. Comprehensive traceability systems exist in other sectors but to track all ingredients would require a major review of how meat is processed and involve associated costs. The onus should be on industry to develop traceability systems proportionate to the risk associated with their products and processes so that if recalls are necessary they can be managed effectively.
Some people have raised the issue of recycling in connection with this incident. Waste from the human food chain must be dealt with. In this incident the problem was not feeding recycled bread and confectionery to animals but feeding contaminated recycled bread and confectionery. The alternatives to recycling in a regulated plant with strict controls are rendering, which is more costly, or delivering waste directly to farmers which is more risky. Handling waste in a cost-effective manner is key to managing overheads aggressively to maintain the competitiveness of the Irish food industry. Feeding waste containing meat is banned because of the risk of foot and mouth disease but feeding other waste human food to pigs is common practice in many jurisdictions.
Investigations into the cause of the incident continue and it is the subject of a Garda inquiry. One early hypothesis was that the dioxin like compounds may have originated from plastic wrappings that may have remained on the product during processing. This was discounted as the temperature of the process was not high enough to generate dioxins from plastic.
There was a similar incident with dioxin contamination of pork from Chile last year and the problem was not identified by the Chilean authorities. It was identified by Korea which notified the international authorities and the Chileans were sanctioned. The source of the problem was a copper additive which had come from recycled electrical cables. When the copper was being extracted from the electrical cables, it heated up and melted the plastic. In that case the temperatures were much higher. The source of the problem in our case appears to be oil used to fuel a drying machine. The operator had been using recycled vegetable oil and changed to recycled mineral oil. However, it appears that the recycled mineral oil was contaminated with transformer oil. The Rikilt laboratory, one of the referent laboratories in Holland, confirmed that the congener profile of the PCBs in pork fat suggested the source was transformer oil and was able to do this fairly early.
The performance of the Food Safety Authority of Ireland in this crisis demonstrated the benefits of having an independent agency focused on consumer protection with the trust and confidence of citizens, operating in an open and transparent fashion. Over the course of the first two days of the incident it dealt with more than 10,000 calls to its helpline, regularly updated its website and kept the media apprised of developments. As one of the first EU national independent food safety agencies created in response to the BSE crisis, the FSAI has been a model for the agencies created in many other member states and countries outside the European Union and assisted many of them in their start-up phases. Therefore, a good relationship has been built between the FSAI and the competent authorities in other jurisdictions and with DG SANCO and the EFSA. This has proved invaluable in instilling confidence in the approaches being taken in Ireland to manage the incident and help reassure other authorities. The FSAI is represented on the EFSA emerging risk working groups which aim to anticipate future threats in order that preventive actions can be taken.
In the light of the role of the FSAI in this incident, there is something we need to consider. Perhaps the decision in the last budget to amalgamate the Food Safety Authority of Ireland, the Irish Medicines Board and the Office of Tobacco Control should be reviewed to ensure their visibility, brand, consumer protection focus, international connections and reputation are not lost. We have something that is special which is a model for other member states. It proved its worth in this case. Consumers can see that this is an agency which puts their interests above all else. It had no role in negotiating compensation packages for the industry or in protecting industry. Its role was to protect consumers' health.
Risk categorisation of food and feed businesses is a key area being discussed by the committee. Businesses should be categorised on the basis of five factors: the hazards associated with the raw ingredients; the hazards associated with their process; the hazards associated with their finished products; their food safety controls and management capabilities; and finally and importantly, the consequences of a major non-compliance. We should treat equal risks along the food chain with the same attention from the national inspectorate. However, this is not the case. Inspection frequency and intensity varies across the food chain, ranging from some businesses having a permanent presence of inspectors to others being inspected annually or even less frequently. Some of the discrepancy results from legal requirements. However, it behoves us to look at how we deploy our national inspectorate to deliver the most benefits in terms of consumer protection and protection of the industry.
There is a move by the competent authorities from inspecting premises to auditing their food safety management systems. The latter satisfies the authorities that the food business has procedures in place to produce safe food on an ongoing basis, whereas the former just gives a snapshot of how things are on the day of the visit. This move needs to be accelerated to ensure the activities of the national inspectorate are adding maximum value. People talk about how many times a premises was inspected. One good systems audit can be much more effective than numerous inspections.
The food chain is only as secure as its weakest link. There should be no gaps in the continuum of supervision from mills to the point of sale to consumers. The Food Safety Authority of Ireland has responsibility for the national inspectorate through service contracts from the farm gate forward. Animal feed controls and animal health and animal welfare controls on the farm are undertaken by the Department of Agriculture, Fisheries and Food. Although these controls are not carried out under service contracts with the Food Safety Authority of Ireland, this does not make them in any way inferior. The legal requirements are that member states shall ensure efficient controls are carried out regularly on a risk basis and with appropriate frequency so as to achieve the objective of Regulation 882/2004, taking account of identified risks associated with animals, feed or food, feed or food businesses, the use of feed or food or — this is an important one — any processed material, substance, activity or operation that may influence feed or food safety, animal health or animal welfare.
Regulation 853/2004 stipulates that food business operators operating slaughterhouses must, as appropriate, request and receive, check and act upon food chain information which must accompany the livestock. That has not been transposed in Ireland but the exact information to be included must be agreed nationally by the industry and the competent authorities but should contain details of any diseases on the holdings, the result of any tests for zoonotic agents or residues and could also include details of the rations fed or any other information deemed relevant. The official veterinarian is to verify that animals are not slaughtered unless the slaughterhouse operator has been provided with and checked relevant food chain information.
On support for Ireland the food island, this incident was a disaster for Ireland the food island and the lessons must be learned. The recall was costly and disruptive for many international purchasers of Irish product, particularly those in the added value sector, and relationships and alliances that took years to build have been damaged. Several companies overseas had Ireland as their sole supplier and the consequence of this dioxin incident has caused them to review the position with negative commercial consequences for many Irish businesses.
Although the decisive action of the Irish authorities minimised the damage to the reputation of Ireland and was praised by the competent authorities in other jurisdictions and the Commission, serious reputational damage has been done to Ireland's image as the clean, green food island. If one keys "Irish pork" into any of the Internet search engines, one will get a litany of stories about this dioxin incident that we will have to live with for years to come.
Repairing the damage to the valuable market sectors will not be achieved by marketing campaigns by Bord Bia alone. We must be able to demonstrate that we have the animal health status and robust food safety management and control systems to support any claims we make about the safety and quality of our products.
This is an important point. Primary responsibility for producing safe food rests with the food business operators and they must be aggressive in the pursuit of high standards. If the legal requirement is the pass level in the examination, conscientious food business should be on the honours paper.
Our food businesses are constantly changing their scale, processes and the associated risk profile. The competent authorities must also adapt and be in continuous improvement mode to ensure we have an infrastructure in place to protect both consumers and support the Irish food industry. We must be proactive rather than reactive to anticipate problems and take preventive action, and we must constantly update our surveillance mechanisms and move from passive to active, sentinel and targeted surveillance to provide us with good epidemiological data to ensure we know where we stand.
Effective surveillance is necessary to establish the priority areas for attention, monitor trends, detect and delineate outbreaks, identify emerging pathogens and evaluate our interventions to ensure they are working, whether they are biosecurity initiatives, vaccination programmes, new hygiene regimens or whatever.
Absence of evidence is not the same as evidence of absence. If we are accused of a problem in the international arena, we must have evidence to defend ourselves. We need data to support any claims we make about levels of pathogens or chemical contaminants in our supply chain.
On the chemical front, using animals to monitor the environment can generate useful data. A novel animal health surveillance scheme operated by Cork County Council on behalf of the Environmental Protection Agency could be examined to determine if it has applications for other areas of the country. It is demonstrating levels of dioxins well below the maximum statutory levels permitted in marketable milk for human consumption, much lower in comparison with other European countries. When people challenge us about our dioxin levels, we have data from that Cork study to show them. We need to strengthen our reference laboratory facilities for both forensic microbiology and chemical analysis to support our surveillance initiative.
The next crisis will not be another dioxin crisis but related to microbes. Standardisation of fingerprinting pathogens and the development at the European Centre for Disease Prevention and Control, which links together the reference laboratories, the epidemiologists and the disease detectives, means the facility now exists to track microbes causing human illness or identified in food or feed through the EU food chain and further afield to the site of production. If someone becomes ill anywhere in Europe, that bug can be fingerprinted and it could be tracked back to us. In the past, Ireland could export product that would never be tracked back to us if it was contaminated but we now have this facility.
In summer 2008 a pan-European outbreak of salmonella agona originated in Ireland. That highlighted several deficiencies in our controls and laboratory capability. In 2006, during the cryptosporidiosis outbreak associated with the public water supply in Galway, the samples had to be sent abroad for definitive identification of pathogens, which is far from satisfactory. In Ireland, we need to develop and maintain a database of definitively typed isolates identified in feed, livestock food and humans in order to facilitate investigations of outbreaks, the tracking of pathogens through the food chain and the provision of comprehensive surveillance data.
We cannot afford a repeat of this dioxin crisis or the emergence of a similar one. The likelihood is that the next such crisis will be caused by a zoonotic agent. It is crucial, therefore, that we ensure the health status of our livestock is the best in Europe. There is data which shows that there is plenty of room for improvement. For example, the recent survey carried out by the EFSA demonstrates that there is a significant problem with salmonella in the national pig herd. There was an outbreak of listeriosis in Canada last summer during which 22 people died. It would be naive to think that such an outbreak could not happen in Ireland. Similarly, there were several outbreaks of VTEC in the US in recent times. This is a pathogen to which Irish people are also exposed.
I suggest that a multidisciplinary horizon scanning group be convened. The membership of this group should comprise industry representatives — including the primary producers — forensic microbiologists and toxicologists, animal and public health specialists and food scientists. This would ensure that Ireland will be in the vanguard when it comes to animal health and food safety standards. If we are serious with regard to marketing Ireland as "the food island", we should ensure we put in place an infrastructure to support our food industry that is second to none. All sectors of the food industry must play their part and exercise their responsibility to produce safe food and protect their brands and reputations. In addition, the competent authorities must ensure that official controls are risk-based and proactive.
I thank the Chairman and members for the opportunity to address them. I will endeavour to answer any questions they may wish to put.
