Day 038 - 19 Oct 94 - Page 35
1 MR. MORRIS: If I seem not to be listening I am, but I am also
2 preparing my next question, so do not let that stop you.
3 Do the SCF and JECFA consider the need for a compound as
4 well as the safety issue and balance the two?
5 A. I was surprised to read in Professor Walker's evidence
6 the suggestion that the Scientific Committee for Food and
7 the Joint Expert Committee on Food Additives do consider
8 need, because that is not the impression I had formed.
9 I had formed my impression both by reading the documents
10 which they have published, all the reports they have
11 published, and conducting interviews with the scientific
12 secretariat and members of the committee.
13
14 When Professor Walker suggested that the Scientific
15 Committee For Food addressed need as well as safety, I was
16 surprised by that and, I must say, I do not find any
17 documentary evidence to support it.
18
19 As far as JECFA is concerned, they explicitly do not
20 address need. Insofar as that is addressed at all under
21 the World Health Organisation, Food & Agriculture
22 Organisation joint programme, that question is supposed to
23 be addressed by an organisation called the Codex
24 Alimentarius Commission and, particularly, their Food
25 Additive Committee. So, I think the brief answer to your
26 question is, to the best of my knowledge, notwithstanding
27 one comment to the contrary by Ron Walker, I thought they
28 did not address need.
29
30 Q. But when the bodies that do pass additives as safe or not
31 unsafe, or whatever, do they take the need for an additive
32 into consideration? I do not mean just JECFA, I am talking
33 about the policy makers?
34 A. Well, in the UK, formally speaking, the arrangement is
35 supposed to be that the Committee on Toxicity in the
36 Department of Health addresses the question of safety in
37 abstraction from the question of need. The Food Advisory
38 Committee addresses need in abstraction from the question
39 of safety, and then the Minister makes a judgment on the
40 advice of those two committees.
41
42 In practice, I do not think it works that way. So that,
43 for example -- I do not think -- this applies to the
44 international committees too -- if one is going to make a
45 case for need for food additive, the case can be made most
46 strongly in respect of preservatives, since preservatives
47 have a direct, protective role in respect of human health.
48 They inhibit the growth of pathogenic bacteria in food and
49 the same cannot be said, for instance, of colours or
50 sweeteners or emulsifiers or flavouring agents.
51
52 Consequently, it is understandable that we can find (and
53 that we do find) a greater willingness to tolerate evidence
54 of long term adverse effects in respect of preservatives
55 than we do in respect of those other groups of compounds.
56 That is a pattern that we can find in all of these three
57 committees. So, there is that implicit recognition that
58 one makes a judgment about benefits and risks and not just
59 about risk. By making a judgment about benefits opposed to
60 risks, one is implicitly making assumptions about need and
