The Commission's dioxin strategy is a response to recent food dioxin crises, particularly the Belgian incident in 1999. It is intended to reduce dioxin levels in food, the main source of human exposure, by around 40% to ensure that consumers do not exceed tolerable intakes.
Proposals were finalised in July to impose statutory maximum and action limits on dioxins in foodstuffs and animal feed (ENDS Report 319, pp 45-46 ). It is anticipated that limits will also be set for dioxin-like polychlorinated biphenyls when sufficient data are available.
The proposals would require Member States to monitor dioxin levels in food and feeds. Exceedences of the action limit would trigger investigations into the source of contamination, while food or feed exceeding the statutory limit would be condemned as unfit for consumption.
At a meeting of the EU Standing Committee on Foodstuffs in July, the UK was one of five Member States which abstained in a vote on the proposals. A qualified majority was not obtained, leaving Member States to try to hammer out alternative proposals.
The UK's position was outlined in a recently released paper discussed by the Food Standards Agency's Working Party on Chemical Contaminants in Food (WPCC) in April. The FSA expressed its view that the limits "will achieve relatively little in terms of reducing consumers' exposures while presenting serious problems for enforcement and imposing disproportionate costs."
Instead, it recommended that limits should be set high enough "not to outlaw unavoidable background levels of contamination but to identify and remove gross contamination."
Dr Richard Burt, head of the FSA's contaminants division, explained that the Commission's proposals "would do nothing to shift the spread of public exposures toward zero." Monitoring milk, for example, would probably find cases where the limits were being exceeded, but excluding these sources would have "little effect" on exposures of the local population, he said.
"The key point at present is that farmed fish, meat and dairy producers are unable to control dioxin levels. To introduce a legal system which penalises them would, I think, be unjust," he told ENDS.
Instead, the FSA prefers source reduction measures. "We need a beginning-of-pipe solution. And setting limits will not prevent what happened in Belgium," Dr Burt said. But he conceded that most of these possibilities had in fact already been achieved in the UK through integrated pollution control, and that the policy amounted to letting current contamination levels from UK sources subside.
Dioxin intakes from food in the UK have fallen by 82% since 1982, mainly due to tighter controls on incinerators and other industrial processes (ENDS Report 308, pp 13-14 ). However, it is far from certain that the trend will continue. Indeed, the Commission notes in the preamble to its proposals that exposures appear to be rising in some Member States.
If dioxin limits were to be imposed, the FSA would prefer action limits considerably above present dioxin levels, Dr Burt said. In contrast, the Commission's proposed action limits are very close to the dioxin levels routinely found in food.
Dr Burt also thought that statutory limits would be "more trouble than they are worth" because of the costs of enforcement. Dioxin analysis is extremely expensive, costing over £1,000 per sample.
The FSA is also concerned about the practicality of the proposals. Many Member States have no analytical capacity, Dr Burt said, and it was doubtful whether the legislation would be enforced.
Another problem is that including dioxin-like PCBs in future would mean raising the limits by 50%. Dr Burt believes this would prove politically difficult.
Dr Burt added that he did not believe current levels of dioxin exposure to be hazardous, even though exceedence of the tolerable daily intake in many people meant that there had been "some erosion of safety factors."
The FSA was established in response to food crises such as mad cow disease and E. coli O157, and the perceived bias towards farmers in the Ministry of Agriculture, Fisheries and Food (MAFF). According to its recent five-year strategic plan, the FSA's guiding principles include "putting the consumer first" and "being an independent voice".
In fact, many of the FSA's views on dioxins appear to be those of MAFF. And there is little evidence of consumers' interests being voiced at the WPCC meeting, let alone given priority.
Dr Burt pointed out that there were consumer representatives on the WPCC. ENDS contacted members of Friends of the Earth, the Consumers Association and the National Consumer Council present at the meeting to find that they were either not present or not knowledgeable about dioxins in food.
The FSA was challenged over the issue of dioxins in food last January when a BBC2 documentary, Warnings from the Wild, revealed that farmed salmon contained high levels of dioxins and PCBs. The chemicals are bioaccumulated from their diet of feed prepared from European fish meal and oil.
In response, the FSA has pointed to the dietary advantages of eating oily fish. But it has failed to tell consumers that they can have these along with reduced exposure to dioxins and PCBs by eating fish from the southern hemisphere, where contamination levels are generally much lower.
Dr Burt commented that in order to do this the FSA would have to advise consumers not to eat farmed salmon. "Is that a proportionate statement?" he asked.
The FSA was obliged to conduct a cost-benefit analysis in deciding how to carry out its functions, he added, but he denied that this hampered its ability to inform the public. "There hasn't been an appropriate venue in which to raise [dietary dioxin] issues."
Gwynne Lyons, scientific advisor to the World Wide Fund for Nature (WWF-UK) commented that the FSA "displayed an ostrich-head-in-the-sand attitude to reducing dioxin exposures."