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

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