Honest Food 

the Campaign for Independent Food


PO Box 16141 London SE1 4ZH

Telephone: 020 8740 7194

E-mail: honest-food@countryside-alliance.org





Paul Dray

Animal Disease Control Division

1A Page Street

London SW1P 4PQ


September 4, 2002


This is not really a formal opinion on last Friday’s meeting, more of an informal contribution, which I was not able to make quite as well as I had hoped (not least because of my problems with London Underground). I feel that my comment became lost in the need not to discuss current legislation, particularly the Animal Health Bill, whereas I was trying to raise a wider issue, one which is, in my opinion, very important for future animal health and welfare strategy.


There is a strong feeling among farmers and other food producers, which Honest Food shares, that legislation and regulatory regimes are promulgated with far too great haste and without proper scientific consultation. Much of the scientific base given for several pieces of recent primary and secondary legislation is very shaky and has been disproved by a number of highly regarded scientists both in this and other countries. Many of them feel that they are not listened to and their well-founded opinions are passed over. Many of them share the anxiety expressed by producers and retailers, as well as legislators and relevant organizations that the laws and regulations passed on the basis of defective scientific evidence are then entrenched, make life very difficult for animal and livestock owners and, subsequently, for food producers and consumers, and are difficult to change, let alone remove. May I remind you of the problems and difficulties, as well as real hardship that were caused (and, actually, still being caused) by the Meat Hygiene Service and the meat inspection regulations? That, too, was a non-discussable subject for a while. Several commissions and reports and years of campaigning were needed before the slightest changes were made. The disappearance of the slaughterhouses contributed to the problem of over-long animal journeys that, in turn, contributed to the spread of FMD.


One of the greatest problems producers, retailers and customers face is the propensity for legislation and regulation on the basis of the precautionary principle. That is the very opposite of scientific thinking and argument. In fact, it is largely emotion turned into regulation. The idea that we must have regulation, no matter what, until it can be proved to be the right regulation is basically wrong. It is what makes life for small and medium-sized businesses particularly difficult and prevents development and new ideas.


These are very basic ideas, but I thought they might be useful as a preliminary contribution to the debate. I look forward to future meetings and discussion documents.




Yours sincerely,






Helen Szamuely (Dr)

Director, Honest Food (a Countryside Alliance campaign)