Two academics have looked at the scale of declared conflicts of interest (COIs) in UK food policy-making agencies.
Erik Millstone, from the University of Sussex, and Tim Lang, of the Centre for Food Policy, City University London, assessed COIs at the Food Standards Agency (FSA) and Department for Environment, Food and Rural Affairs (Defra). They said if the FSA is to eliminate and avoid corporate capture, its board and advisory committees should not include anyone with COIs that deserve to be declared.
Conflicts of interest are important because they may undermine public confidence in decision-making and challenge the FSA as it tries to build trust.
Professor Susan Jebb, FSA chair, said the agency wants to hear the views and perspectives from all those with an interest in food including academia, industry, civil society groups and members of the public.
“We know that everyone has a view that is shaped by their own experiences and we have a clear code of conduct that acknowledges the potential risks. When people provide us with formal advice through our scientific committees and advisory bodies, we have clear processes in place so that their interests are declared and this information is publicly available,” she said.
The study looked at nine scientific advisory committees and found each of them included members declaring interests at some point with some panels having more experts with COIs than without.
Food regulators are at the interface of science and policy, and they should have robust and reliable mechanisms for identifying and addressing commercial conflicts of interest among the members of their boards and advisory committees, according to the paper published in Nature Food.
Building and keeping trust
Food scandals like bovine spongiform encephalopathy (BSE) and microbiological contamination such as Salmonella in eggs led to the formation of institutions including the European Food Safety Authority (EFSA) and national counterparts such as the FSA. Their creation and reforms were supposed to ensure a separation of science from policy and to separate responsibility for regulating farming and food businesses from policy responsibility for sponsoring them because the interests of producers and consumers can conflict.
Millstone and Lang said interactions between scientific and political considerations are inevitable and are critical to the institutions’ operations and decisions. Policy judgments guide the framing of the issues that are, and are not, addressed by scientific risk assessors and also guide the scientists’ selection and interpretation of evidence.
Commercial representatives in key regulatory decision-making and expert advisory bodies can provide insider knowledge but may also allow such interests to influence decisions.
Millstone and Lang previously argued that no one with a commercial COI linked to farming or the food industry should be a member of the FSA’s board or advisory committees. They said such people should not participate in official processes to interpret evidence for policy decision-making.
Conflicts of interest can influence judgments about what should and should not be counted as a relevant risk, how evidence is selected and interpreted, and who gets the benefit of the doubt. They can also impact how much of which kinds of evidence can be deemed necessary or sufficient to support recommendations to permit, forbid or restrict the use and sale of ingredients, products and processes.
Conflicts by committee
Over time, the FSA’s guidelines on what warrants a declaration of a COI have changed and vary from body to body. The proportion of FSA Board members who declared COIs peaked in 2008 but has since declined. The study provides numbers for nine food chain scientific advisory committees. Each of them has included members declaring conflicting interests.
Two of three committees reporting to the Department for Environment, Food and Rural Affairs including the Expert Committee on Pesticides have majorities reporting COIs. At the Advisory Committee on Releases to the Environment, which advises Defra ministers on the safety and acceptability of GM crops, only one of seven members declared no COIs in 2022. The other six have COIs with 16 different corporations.
On the FSA’s Science Council, the proportion declaring COIs has been rising, and in November 2022 there was a six-to-five majority. Of the FSA’s five topic-focused committees, all had majorities with COIs at some stage. The ratio for the Advisory Committee on Microbiological Safety of Food went from six declaring COIs and 12 not in 2021 to 12 declaring interests and five not in 2022.
In 2020, the Committee on Toxicity of Chemicals in Food included 12 people who declared COIs and nine who did not. By November 2022, nine declared interests, while 15 did not.
Jebb said there is no evidence to suggest that any bias has influenced the work of the FSA.
“We will keep our approach to managing potential conflicts of interest up to date, and in line with all relevant government guidance. We will also continue to strive to ensure that decisions are made with consumer interests front and center of our thinking and to be transparent in our decision-making.”
With concerns about COIs and contested scientific decision-making rising in other countries globally, Millstone and Lang said it would be useful to do similar exercises for other countries’ food, health, and environmental standards-setting bodies. The approach could be applied to institutions such as EFSA and the Codex Alimentarius Commission.
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