 Welcome to the 33rd meeting of the Health and Sport Committee in 2018. Can I ask everyone in the room please to ensure that mobile phones are off or on silent and ask not to record our film proceedings as we will be doing that as the Parliament? The first item on our agenda is a declaration of interest. In accordance with section 3 of the code of conduct, I invite George Adam to declare any interest relevant to the remit of the committee. A brief declaration should make clear to any listener the nature of any interest. Thank you, convener. I don't have any relative interests other than the fact that my wife is MS, a long-term condition, so that might be a reason for wanting to be in the Health and Sport Committee, and I confess I'm a support. Apart from that, that's the only thing to regard health and support. I can declare. I think we should all resist the temptation to comment on these matters at great length on the record. I'm sure we'll have many conversations off the record in due course. Thank you very much, George, and welcome to the committee. Can I also take this opportunity to record the committee's thanks to Keith Brown for his short but constructive period as a member of the committee? The second item on our agenda is scrutiny of Food Standards Scotland. We have been dealing with a number of Brexit-related SI notifications in which Food Standards Scotland has either been involved or in the development or will have, due to transfer them to them in the event of a no-deal Brexit. This session is an opportunity to explore how Food Standards Scotland operates and how it interacts with other key bodies such as local authorities and the Food Standards Agency and equivalents and other jurisdictions in relation to preparation for Brexit. I welcome to the committee the chair, Ross Finney, Elspeth Macdonald, Deputy Chief Executive, Gary Moonean, Heddle Corporate Services, and Jeff Ogle, chief executive. Can we start, perhaps, and invite you to explain some of the specific characteristics of Food Standards Scotland as an organisation? As the minister has told us, you differ from other similar bodies in that you are directly accountable to Parliament. Can you talk us through how that works in practice? How is it that you can be directly accountable to Parliament when appointed by Scottish ministers and how do those relationships actually work? Thank you very much, and can I just say that my colleagues and I are very pleased to be before you this morning, and we hope that in answering your questions we'll be able to illuminate, we'll not necessarily be able to answer every question. That would, I think, maybe be the reason for the level of expectation perhaps too high. If I start with your first point, convener, that is that Food Standards Agency was created as a UK body just immediately prior to devolution. It was the creation of the then Labour Government who had a commitment to address concerns about how food standards matters were being dealt with. There had been concerns that the proposition that Government ministers who understandably were promoting the food industry were perhaps not best placed to be taking an objective view about breaches of food health and safety standards. The then Government appointed the Philip James inquiry who reported, and unsurprisingly it concluded that there was an inherent conflict of interest between ministers generally promoting food and then having to adjudicate. The recommendation that created Food Standards Agency and which was further developed as the matter went before Parliament was that a Food Standards Agency should be a non-ministerial department of government. That dictum, established in 1998, was followed on by the Scottish Government and the Scottish Parliament when it enacted the Food Safety of the Food Scotland Act of 2015. That's the background as to why we are in that different position. As you rightly say, convener, there is then again the issue of how to do that if you are then appointed by Government. That is, I think, there is still a bit of a tenuous kind of issue there. The only way that that comes about in terms of trying to separate the how and who runs what is that there is absolutely no provision within the act that allows ministers to interfere with how Food Standards Scotland discharges its statutory responsibilities in relation to food health and food safety. There is just no provision within the act that would allow them to do that. In terms of the body itself, it's a body corporate, as we've explained in the papers. We have eight non-executive directors who are appointed, as you say, by ministers. Then the matter separates out slightly because although Jeff Ogle was originally appointed by ministers because we were the first body, all subsequent appointments as the Office of Chief Executive, the act provides that that appointment will be made by the board. So, again, trying to improve that separation to which you referred, and of course, as a normal corporate body, the board is charged with the responsibility of setting the strategic direction of food standards within the ambit of the legislation that we are charged to deal with, and the executive are charged with delivering the strategic objectives that are set. So, that's the broad thrust of how it works, but I hope that that helps to explain the rather unusual position of being a part of government, or sorry, being alongside government, but not actually being an integral part of government. That's very helpful, and certainly sets the wider context. In that context, then, how has the process worked, for example, around the matters that we're looking at currently around, for example, the no Brexit deal regulations that this committee has considered? In other words, while you have this unusual status of standing to one side from government, clearly there are urgent matters of government business with which you are intimately connected, and it would be very interesting to understand again, are you directed to take these matters forward, are you asked to take these matters forward, on what basis is that put in place? I'll bring Jeff in for the detail, but again, I'll deal with the overarching provisions, if members of the committee will allow me. If you look at the act, the act is, in the early sections, quite explicit about our powers in relation to food regulation and also to diet and the assistance to the Scottish diet not being deleterious to the health of the Scottish population. However, there are also provisions that state that ministers can invite food standards to provide advice in matters where ministers deem us to have competence that would be relevant in discharging that sort of issue. So, for example, because we are all charged, before I get to Brexit, just by way of example, because we are charged with issues of diet and nutrition, we have been asked by ministers to provide a lot of advice in the way in which they have constructed their policy in relation to diet and obesity. So, that's on a day-to-day basis. Now demonstrably, given that 96 per cent of all the food legislation and standards that we prosecute emanate from Europe, the Government concluded that we might have some useful and relevant expertise that might assist them in particularly the issue. So, that's how we became involved and the provisions in the act are clear that they can ask us to do that and it would be ludicrous as a part of government for us to be saying, well, you know, you can't do that. So, that is the basis of which we do it and I'll ask Geoff maybe just to elaborate a little on how we get involved or else, but in fact who perhaps has done more on that side. Yeah, so, I mean obviously on the legislation, we are working with the Scottish Government and across the breadth of issues dealing with Brexit, we are working with Scottish Government officials as necessary. I think it goes back to Ross's point. We're not part of the Scottish Government, but we are part of the Scottish Administration. So, to that extent, the issues affecting food and food safety are entirely relevant to the Brexit issues and therefore it's important that we work with Scottish Government officials as close as we possibly can. Thank you, convener. Good morning, panel. I'm interested in how progress towards the outcomes that you have proposed or how you want to achieve things. How do you measure your progress towards the outcomes that you've set? Yes, in terms of meeting the strategic plan, we've got two or three things. First of all, we were very concerned as a new body that we should look afresh at just the kind of measurement and the kind of reporting that should come to the board. We were very conscious about the debate, which has taken a lot in this place and elsewhere, that public bodies have a really serious tendency of either measuring themselves in terms of inputs or outputs and actually not measuring what the outcomes are of the very strategy that they've set. You will find in the papers that we presented with our submission a report that we received, which actually tries very hard to measure the various strategic objectives that we have set and to measure the progress that is measured in terms of outcomes. I have to say to you that that is not easy. I do not pretend that it is, and you will find that other public bodies have indeed abandoned trying to do that because it can get into the two difficult blocks. We have been running this now for almost four years and we were determined not to give way on that because we do believe that our ability to explain to you and to explain to the wider public who are the people we are trying to defend here, that we can achieve these. We have reports that are measured in that terms. We also have a reporting mechanism that comes to the board on a regular basis, measured in more conventional terms, but we are finding that the board is finding that if it is seeing its actual progress in outcomes terms, it also highlights where we are not making progress. It is not an easy option, but it is telling us whether that strategic objective is being measured or not. We have put in place measurements that you would expect, particularly in relation to finance and accountability, but on the broader strategic objective, that is how we have done it. The document that you have an example of in the papers that we submitted is trying to give how we and the research reporting that we get before the board at board meetings. Two of the outcomes that are measured would be that food is safe, so we are measuring contamination or canflobac or E. coli, and that food is authentic. Are those two of the outcomes that you are measuring? The two are critical. First of all, is it safe? Our primary concern is with the consumer. We are a consumer-facing organisation, so our number one priority is the protection of the consumer. For the consumer's interests, we have to be sure that it is safe. That is point number one. Point two, it also has to be what it says it is. The consumer is not going to take kindly, even if it meets the test of being safe, the consumer is not going to be defrodded by picking up a pack of this or that or the next thing, only to discover that it is not what it says it is. The need for public confidence in the food that we eat requires it to be both safe and authentic. Those are both measures that we—if there are strategic objectives—receive reports regularly on that. It seems that people in Scotland are quite focused on having food that is quality and authentic, and it basically says what it is on the tin. Absolutely. All the research that we do in terms of following consumer demand indicates that that is the case. We will probably come on to that later, convener, but when we get to the question of what are people looking at in the middle of the Brexit bubble, one of the things that these very same consumers are indicating, the one thing that they do not want to see are any diminution in the food safety standard. I think that the horse meat incident, which happened some years ago in 2013, certainly changed consumer attitudes around authenticity. Prior to that, I think that the primary focus was on safety. I think that the horse meat incident certainly made consumers much more aware of authenticity as a particular issue as well. I know that I have brought it up in other committees about the protected geographical indication status of our food in Scotland, so Scotland brand is a really positive brand that people seem to seek. I will move on and ask my next question. In your submission, you stated that, as a result of Brexit, you will need to consider a review of documents, including your strategy and corporate plan, and the memorandum of understanding with the Food Standards Agency and your statement of performance of functions. That sounds like quite a significant issue that needs to be taken forward. Are you engaging in the review right now? Is it underway and when can we expect to see the reviews complete? Well, there are two elements to that. In terms of the performance of functions and how we operate, I do not in any way want these words to be interpreted as being cheeky, but if we only knew what the outcome was, we might be able to draft the revisions. However, I think that in direct answer to your question, the one that is particularly—I mean, they are all relevant because clearly we will have to change, but the one document which either Usworth or Jeff can elaborate on is the memorandum of understanding which we have between ourselves and the Food Standards Agency. Now, that document, as it stands—in fact, it's actually got an amendment at Goddusill to it—is very, very important because, even in the present circumstances, it's pretty important both to consumers and to food producers, food manufacturers that there aren't unnecessary differences that are just for differences' sake. I mean, there are things we do slightly differently here in Scotland from Food Standards Agency, but that document regulates how we share information, how we actually work together, and how we collaborate in the relationship both at the top end of the organisations and throughout the executive. Now, we have taken the view that it will be very important going forward irrespective of precisely what the nature of that is that that very good relationship should continue, and we have agreement with Food Standards Agency that both of us have made representations to our respective Governments that that memorandum of understanding ought properly to be the basis of how Food Standards Agency should collaborate. We had a meeting with Food Standards Agency, both boards talking about a different area of co-operation, but we have actually approved a little memorandum setting out how we suggest that this should form the basis of our going forward. The other documents, yes, we've given them thought to that, but I think really we'll have to prioritise what we do and until we know the actual better shape of precisely what is going to emerge from Brexit, then I think to revise some of these documents because they have served as well. There's no doubt that part of how we deliver our functions needs revision anyway. I mean, I think after four years that would be right and proper, but we're not about to embark on the revision process, but we have highlighted the importance of the memorandum of understanding. In relation to the memorandum of understanding in particular, and I think I spoke about this when I gave evidence to the committee recently with the Minister about some of these Brexit statutory instruments, you'll be aware that there's a lot of work on going across the Administrations to develop some frameworks of ways that we will work collaboratively across the UK in future. I think that we very much see the memorandum of understanding between the FSA and the FSS as a good foundation for that. As the chair outlined, it describes how we co-operate and collaborate currently, but we'll certainly require to be updated because, for example, it has content within it that is about how we deal with European matters, how we share access to scientific advisory committees etc. There's quite a lot of detail in there that will be highly relevant in relation to the ways that we work in future through some UK-wide framework arrangement and also elements of the MOU that will just simply have to be updated because, for example, the section that deals with how we will handle European issues will be different. I'll just go on to my next question then. I'm interested in whether you've risk assessed how Brexit might affect your ability to meet your key objectives on food consumption, healthier diets and food consumer interests. Brexit is just in everything that we talk about now, so I'm curious about risk assessment for that impact. There's two issues really. One is the impact and the second issue is the timing of that impact. That depends on the nature of the deal and the form of the exit going forward. For example, if there is a withdrawal agreement and there's a two-year transition window then the impact is slightly less. It gives us more time to plan and adapt to make the changes that we need to. If it's a no-deal scenario then the impact is pretty immediate. Subject to the form of exit would depend on what we had to do. In terms of risk assessment, we are now collectively looking much more significantly at no-deal planning. A key element of that is the continuation of food supply. In terms of risk assessment, most of the focus is on no-deal consequences and the immediate impact of that. Clearly, a transition period gives us more time and it will have an impact, but obviously we've got more time for plan for it to prepare for it. In terms of consumer issues and the risks, I think that there are concerns around availability and price and certainly in a no-deal scenario. If there is an imposition of tariffs then that would feed into food price inflation and food availability is likely to reduce, at least in the short term, and costs would also likely to increase as well. On the organisational point of view, understandably and naturally the risk of Brexit appears on our risk register prominently and therefore is subject to scrutiny by our audit and risk committee who in turn report to the board on whether they are of the view that we are addressing the issue adequately or not. Food standards is about feed supply as well as food supply. There are issues when we are looking at food supply chains for our agricultural businesses, which are huge in Scotland. Are there issues that Brexit might impose on our feed supply for our farmers? Yes. Everything that applies in relation to what we describe about food applies equally in relation to feed. For example, a lot of the legislation, the fixing legislation, the notifications that you've been looking at over recent weeks, a number of these have been related to feeding staffs. There are some quite complex European law around animal feeding staffs that will all need to be fixed in the same way that the food law will to ensure that that can operate in the event of a no-deal exit. Our preparations in relation to contingency planning for whatever exit eventually happens cover feed in the same way that it covers food. We are working with the feed industry stakeholders and with other bodies. I want to bring in Brian Whittle on other matters before we go down Brexit in great detail, but can I simply ask him very briefly, are you confident in the event of a no-deal that all the work that you've described will be in place in readiness on 29 March if it is required? At this stage, I would not give a high degree of confidence. That's very interesting and I have no doubt colleagues will come back to that. Brian Whittle. Thank you again. Good morning to the panel. I'm actually interested just to follow on from the line of questioning there around key objectives on food consumption and healthier diets and food consumer interests. I wanted to talk particularly about your impact and the elimination of responsibilities with local authorities. As far as I can see, Scotland produced some of the highest-quality food in the world and yet, when we look at things like the Excel procurement contract, only 16 per cent of that contract is procured from Scotland. For me, if we want to get into Brexit, it seems to me that things like that are being hidden behind Brexit. These are things that we should be impacting now and could be impacting now that have absolutely nothing to do with Brexit. From your perspective, what impact and what leverage can you have in those kind of issues currently that surely would lead to improving the objectives that you've set out? That's a tricky question because, as you're aware, you're drifting to the question of absinthe ensuring that you have the highest possible standards, but you're not. Actually, we don't have powers to control quite what the procurement rules of those standards. That's not within our... We are quite... Asked to advise. We're only asked to advise insofar as the product might not meet the relevant food safety standard. I'm not wanting to pick with you, but I'm seriously... Our duty is about the level and the standard that is made. We have to ensure that what is on the consumer shelf meets that standard. We're not able to direct in a way of the actual procurement. My point here is that we drive, as you said, 96 per cent of your standards are taken from European legislation, but the UK drives that standard. We have a very high standard of food in this country, so we've driven a lot of that legislation in Europe. I think that what I'm struggling here is to understand why we're now suggesting that the UK, because of Brexit, will drop its standards. It doesn't make any sense, but why would we drop our standards to a level so that we couldn't trade with Europe? Why would we do that? Sorry, I don't understand that either. Also, we make clear to anyone who approaches us, because we have had. We have had people saying, it's rather curious, because they use an odd form of language. They say, oh, good, we're getting out of Europe. Does that mean that these wretched regulations will go? Now, it's a kind of use of language, because I don't think they quite understand these regulations on the very basis upon which we've achieved the standard to which you refer. So, as far as we in Food Standards Scotland are concerned, the only way that standards commensurate with cost and risk is up. It's not down. There's absolutely no way that we would support. And indeed, the work that we're doing with Food Standards Agency is to make clear that our objective and the food industry supports that. And much just as importantly, the consumer supports that there should be no diminution in food standards as a consequence of Brexit, and we're quite clear about that. I think the point is illustrated around the difference between domestic and international markets. So, when you're exporting, it's essentially the country that you're exporting to sets the standard. When you're looking at a domestic market, some countries do do this. They have, if you like, a different standard for a domestic market than they do for an international market. Our clear view and the consumer clear view is that there should be no diminution in standard. Clearly, when you get into issues around negotiation in terms of trade, then obviously food standards, equivalents and alignment, etc. are all part of that negotiation and discussion. So, the issue around standards in the UK and the question for us in Scotland is, in a post-Brexit world, what is the standard? Certainly, the advice and views of consumers is very strong that they like the standards that we have now. They would not expect to see a diminution in it and actually converse with it and hope to see the standard improve even further. The reason that I'm asking this is your sort of work with local authorities is that... I recognise that you haven't done procurement into local authorities, but it's just this tension here that seems to me around the fact that we're talking about Brexit causing this importing of what we would be classes. That's the sub-standard food and yet the very food that we produce in this country to the highest standard gets exported and then we are importing into that Excel contract food of not of that standard. So, it's something that I don't understand. Why are we not focusing on what we can do and what we can improve on? Well, I think that the point there at the moment as a member of the EU, any trade agreements that the EU has with other countries, let's take an example for New Zealand, New Zealand has to show compliance with EU law. That applies to any country exporting to the EU, has to either comply with EU law or the EU has to accept that the system of controls and standards in that other country is equivalent to the EU standard. So, the underlying premise is that anything being imported into the EU is at least of an equivalent standard to the EU or meeting the EU standard. In a post Brexit scenario where the EU is effectively setting its own standard, the question is at what level do you want to set that standard? All the work that we are doing in terms of the legislation is to transfer over the existing EU statute book onto the UK statute, so our starting position on an exit would be the EU standard. Would you accept that the standard of food that we are producing here in Scotland is of the highest standard and way above the line of the EU? Yes, I think both in terms of quality, the quality of produce and safety of produce. I think that the UK is one of the highest in the world. Alex Cole-Hamden Good morning to the panel, particularly to my old friend and colleague Ross Finlay. It's great to see you, Ross. Thanks very much for all your remarks so far. It's been very illuminating. I'd like to come back to the issue of the development of UK-wide frameworks on food and feed safety, hygiene and nutrition health. How exactly are you contributing to the development of those frameworks? What are the rules of engagement and what have you been doing prior to the establishment of those frameworks? At the highest level, I suppose, the rules of engagement are set out in the principles that were agreed by joint ministerial committee. I think that it was back in October 2017, so there was a high-level set of principles that would guide the work around how to take forward these discussions about how UK-wide frameworks would work in future in the event of leaving the EU. That has certainly been the guiding point in terms of the high-level rules. In terms of the work that we have been doing, I can say with confidence that we have been extremely active with our counterparts in the Food Standards Agency and also in various parts of the Welsh and Northern Irish Administrations, and also with Department of Health and with DEFRA, because the areas of policy that we cover in FSS are actually the responsibility of three separate Whitehall departments. We're working with Food Standards Agency on food and feed safety, we're working with DEFRA in relation to food standards, composition and labelling, and we're working with Department of Health and Social Care on nutrition and health claims and various aspects of nutrition composition. It has been a very resource-intensive exercise. I think that the area where we have made the most progress is with the Food Standards Agency. Developing that future framework is the most advanced of the three that we are involved with. As you will be aware, the areas that are defined as perhaps requiring a UK-wide framework in future are those areas of policy where there is an intersection between EU law and devolved competence. We have these three broad areas that capture a lot of the work that we do. Food and Feed Safety and Hygiene work that has been between ourselves and the Food Standards Agency has been the most advanced of these three. It has been a very collaborative exercise. At the moment, of course, all of this is at the officials' level and all of these discussions are without prejudice to where ministers may want to form views at the end of the day. At the official level, it has been a very collaborative and inclusive process. We have brought a great deal of expertise, knowledge and experience to that work. In fact, the UK Government published a report on progress in November 14, in terms of updating on progress with those frameworks. This one was identified as one that had made good progress. The other two areas are still under development. There is work on going and making again pretty good progress in relation to nutrition and health claims. I know that your committee has been looking at the fixing instrument in relation to nutrition. There is the work that we are doing with DEFRA around food standards, food composition and labelling. That is again progressing. In all of these areas, although it would be fair to say initially bearing in mind the tension and difficulties between the administration about the outcome of the referendum, and seeing the imposition of some of these UK-wide frameworks, we have made a huge amount of progress. This is becoming a much more collaborative and constructive exercise. Scottish ministers have been very clear that they absolutely see the value of having UK-wide approaches in many areas going forward, but those have to be agreed and not imposed. We are very much in the agreeing space rather than the imposing space. That is certainly very good to hear. One of the things that would seem to jar against that in the context of the devolution landscape in which we find ourselves is the issue of policy divergence. We have discussed that quite extensively in this committee. What would you say are the practical and regulatory implications for policy divergence between the devolved and reserved administrations? How do you thread the needle for retaining those common frameworks whilst creating an environment where policy divergence can take place? We are not on the power to regulate that. We have made clear, however, that it would be enormously helpful if, on a UK basis, we were clear about the principles that would be employed in developing a single market within the UK. I think that the absence of those principles makes the very question that you posed difficult to answer, because the work that we are contributing in this sphere is very much regulated by what the GMC agreement said. It is quite explicit, understandably, because the Scottish Government would not have signed up to it. It had expressedly the view that it would not disturb the devolution settlement. Where you are moving into, with respect, territory, where you are then looking at a bigger picture, not just in relation to food, but the whole single market issue, there have been no principles articulated. That would be helpful, because then, just as you have within Europe at the moment, not everybody is absolutely the same, but the principles are laid out. You can go and look at them. You can see that they have certain principles that deal with overriding public interest. In cases of overriding public interest, as defined, you can have differences between administrations, but we do not have that. Therefore, we are working at the moment within the rules and the box that we are contributing to. Can I just add? The other point to make is that, in this sense, a post-Brexit landscape is not different in some ways to the pre-Brexit landscape, because there is a degree of co-operation now already. On reformulation, for example, it is a UK-wide programme. In some areas that we are responsible for, if you take the challenges around obesity, it is a UK-wide problem. The issues are degrees of difference, but the solutions are not actually different. No-one has got to come up with a brilliant idea that nobody else has thought of. The issue is really around having policy solutions where it makes sense for policy solutions to be on a UK-wide basis. That is the important point, because we believe that that is in the best interests of Scottish consumers versus coming up with occasions where we say that we need a different approach, because the different approach is in the best interests of Scottish consumers. When we're into that second space, that's when you're getting into the potential policy divergence, but we do have that now in some respects. Good morning, panel. Can I continue with a female relationship with the Food Standards Agency? How do your powers relate to those held by the Food Standards Agency and what access do you have to their expertise and facilities? The relationship that we've got with FSA is long-standing. All of us, prior to working for Food Standards Scotland, worked with the FSA. The relationships are well established. I don't know if I don't look at it, but I've known the FSA chief executive executive for 30 years, so I think that helps. I think that there is a depth of quality of relationship that helps. However, we are extremely conscious that we're not always going to be here, so you can't rely on personal relationships in their entirety. You have to make sure that you have the systems processes in place, which is why some of the discussion that I was talking about around the MOU is so important. I think that it's fair to say that we have a lot of dialogue with the FSA on a whole range of issues. For example, on incident management, that can be a Scotland-only type issue, or it can be a UK-wide issue. When it's a UK-wide one, we're working very closely with the FSA. In areas of policy, we have got diet and nutrition, so we don't deal with them so much on that, but in other areas, for example, around food science, we work quite closely with them. Things like the Campyla Bacta programme, again, we joined in with the FSA on that. We don't wet ourselves to everything the FSA does, but we do have a close relationship with them. In terms of the UK, there are two separate food competent authorities. One is FSA and one is FSS. Since the vote to leave the European Union, has your relationship become stronger because you've had to cooperate more in things? I suppose that it has, yes and no, I think, is the answer to that. Certainly it has been challenging on occasion. I think it was certainly difficult on occasions because of the strictures that were replaced in terms of communication. I'd say that over the last nine months or so, it has got a lot better and there's been much more sharing of information, which has certainly helped. I think in the times of challenge and differences, and we still do have differences, but we've got a depth of relationship, which means that we can be pretty open and frank with each other. Usually we do work through the issues that we've got. What was important when we were established and why I think we wanted to work very hard at having a good relationship was that the overriding view from consumers and from food producers was quite simply, yep, okay, we can understand why you may have two different bodies, but for goodness sake, we're not interested in just difference for different sake. So in order to make sure that we didn't do that, we worked very hard right at the outset to make sure that the executives knew each other, but with the new board and their board, we worked very hard at board level and at chair and chief executive level to make sure that we developed a sensible and working relationship with them. Just perhaps come in and you asked a point about access to resources, and I think I may again have referenced this when I was here before you a month or so ago. The FSA is quite significantly bolstering its resources in relation to scientific risk assessment as part of its EU exit planning. They have made very clear that that additional scientific capacity will be available to Food Standards Scotland to draw upon in relation to scientific risk assessment that we may wish to ask them to undertake or to do jointly. That is also relevant in the context of the scientific advisory committees that provide advice to the administrations across the UK. There are a number of independent scientific advisory committees that FSA in the food safety territory provides the secretary at four, and we will continue to have access to those committees. Again, the arrangements that said that out are covered in the MOU. Thank you very much, Miles Briggs. Thank you, convener, and good morning to the panel. I wanted to follow into David Torrance's question with regard to consultation, which FSA has undertaken. In terms of industry and producers, what sort of consultation you have been undertaking around Brexit? We have heard some of the challenges outlined but some of the opportunities, potentially, which your consultees are telling you. On Brexit specifically, we have had a fair amount of consultation. I have certainly had regular dialogue with most of the major retailers in the last month or so. I have spoken to four of the six. I also talk frequently with the Scottish Food and Drink Federation and the Scottish Retail Consortium. Obviously, on areas of industry, we have contacts with the meat industry representatives and fisheries as well. There is a fair amount of discussion in terms of mutual sharing of information. We have not yet got into detail on particular subject issues. There has been one recently around health marks, but in terms of the practical changes that industry will need to make, there will still be some of that consultation. The consultation that took place around the fixing instruments and the issues that you have been considering in this committee, were organised on a UK-wide basis because they are UK-wide fixing instruments and Scottish stakeholders were included in that. We are also shortly about to go out to consultation on some of the fixes that we are going to need to make to our domestic regulations to our SSIs. Obviously, we will be arranging that from FSS and that will be going out this side of Christmas. I suspect that there is a unique space in food where there is an obligation in EU law for us to consult on changes to food law, where other departments might not consult on some of what they might see as minor changes. We have an obligation in law to consult. That is certainly an area that is pretty active for us. In terms of that space in which we found ourselves, where do you see potential opportunities? We have spoken about regulation. I do not think that any of us around this table wants to see poorer standards. In terms of this opportunity to look where Scotland and UK-wide is, are there opportunities being highlighted to you, especially around food labelling that you have mentioned? No. I do not think that so much people are highlighting to us opportunities at this stage. I think that much of the feedback that we are getting is around wanting to understand the practical consequences. I think that the lack of certainty and clarity means that what is more on stakeholders' minds at the moment is, can you provide as much certainty and clarity as possible and as soon as possible so that we can prepare? I think that there is more in that territory at the moment than about saying. In the future, we could do X, Y and Z. Good morning, Mr Finnie. Welcome back to the Parliament. I am interested in the financial implications to Brexit. I noticed in the draft financial management plan that you mentioned that there are several significant risks around Brexit and the impact it has on the organisation. It is financial sustainability that looks to be very risky at best. How are you managing those financial risks that you foresee, as you have mentioned in the plan? At a high level, we initially started this financial year by allocating out of our core budget to help with Brexit preparation. We were then given some specific funding by the Scottish Government that was specifically related to Brexit. That has helped in terms of easing that financial pressure, but we are still expecting to spend about £1.3 million out of our Brexit preparation for this year. In terms of the financial implications going forward, we are back into that it depends territory because the nature of the deal and the form of the exit inform us of what the financial implications are. As we said, you will see that there is a broad range and Gary can go into a bit more detail, but certainly the no deal has far more of a significant financial implication because you effectively have to set yourself up as a stand-alone entity. We would not be able to rely on any of the facilities or access arrangements that we currently have as part of the EU. Clearly, in a deal situation and again subject to the nature of the deal and subject to what might be agreed with regard to access to institutions, et cetera, et cetera, that may ease the financial implications with regard to exit. At the moment, can we be quite precise in terms of financial implications? No, we cannot. That is why we have quite a broad range, unfortunately. Gary, do you want to add to that point? Yes, thanks. I think that Geoff's made the point about the mitigation of the risk in-year in terms of the additional Brexit consequentials funding that we got through the process in the summer. We have been heavily engaged with Scottish Government officials on the fiscal implications of Brexit and took part in some work recently to better articulate the cost, as Geoff said, because of the uncertainty around that. It is a very wide-ranging number, but we have established a programme to look at the impact of Brexit on the organisation and Scotland and the consumers. That is another strand of work that we have undertaken to separate the specific Brexit-related work from our essential co-activity or day-to-day business. As part of that work, we are looking at capacity and capability requirements, so we are starting to cost them up, but it is very much a kind of early stages in terms of the finances. One of our—as a board—at very top level, our concerns are that, if you look at the range of functions that we are asked to discharge, a very high percentage of those are statutory functions. So there is not much discretion in terms of, well, we will do a little bit of less food safety here and a little no. No, I think that the consumer expects us to maintain the very high standards to which Mr Whittle referred to earlier and which are absolutely precious to the Scottish food industry. So if we do not have much discretion, we can always make some element of movement, where therefore asking ourselves, well, if we do not and are not able to argue successfully for additional resource, then the question on us will be a really bad choice of which of those statutory functions are we going to just discharge. That is a choice that my board wants to get into. I was going to come on to that particular one because you mentioned that you might have to drop one of your functions as it is at the moment. Obviously, it is interesting that you did get consequentials, so taking it very seriously that you did get that to proceed to where you are at the moment. So you will have to wrestle, I presume, then as a board, and it may be that you will have to drop one of your current functions, but there is no indication as to what that would be. We would have to assess that very carefully. We would have to assess the risk involved with it. In this forum or any public forum at the moment, I am not going to speculate unnecessarily on that, but it is a fact that we are not simply crying words. We have assessed as best we can what we require to deliver within the current budget, as I indicated a moment or two ago. There are not too many elements within that that are of a discretionary spend nature, and therefore we are going to get up against the hard bone of our statutory functions. We certainly would be arguing very forcibly that we cannot afford in the public interest to not be discharging those functions, but there will be requirements. The Brexit thing is not just about it's another thing because the rules are changing. You are actually changing the rules so that whether it is the consumer or the producer understands these different changes in the rules. It is all got to do with back to basics as to how you deliver your function. It is very difficult to say that you would do a little bit of that. The Brexit thing is not just a luxury. It will require changes to rules, regulations, changes to practice procedures, and that has all got to be in place. It is in place to deliver what the public are looking to depend on the food safety standards that we are exercising. Certainly from an executive perspective I think we would be presenting the board with both the choices and the consequences. Clearly on a statutory basis there is not exactly much wriggle room really. The issue is really around where you might make the reductions on non-statutory areas. On the face of it that might seem a simple saving measure, but it is also an important part in delivering your statutory functions around food safety or some of the issues around obesity. It is being clear around the consequences of those difficult choices that will have to be made and having absolute transparency around what those consequences are likely to be. I hate to use a pun food for thought, but it certainly is. I would take to think that it would be around Scotland the brand or something like that, which is obviously very well known. You are looking at the capacity and capability review. Will that be part of the capacity and capability review? Discussing, dropping something, will that be part of it and when will that be produced? It is a kind of it depends question really, because if we are getting for example more money from the Scottish Government and it is not quite the full amount that we have asked for, then again we are back into what can we do with what we have got. That might mean that we can protect some of the existing functions without sacrificing those because of the consequences of Brexit. If we got some of the money then we will still need to do for example surveillance activities under Brexit, but we might be able to do slightly less surveillance and do it in a slightly different way. I think certainly we would have to look at the way we could deliver most effectively with the resource that we have got. I think that applies regardless of the amount that we end up with. That will be the underlying focus really. What is it that we can do most effectively and most efficiently with the money that we have got? Far from me to put words into people's mouths but it looks like you are looking for more money. Is it not everybody though? The capacity and capability review that I have mentioned is looking at European and you would in your submission need some more money for that. Is there a date for that completion? Will it be completed if Brexit goes ahead before March 2019? Do you have a look for the completion? As Gary said, some of the work is already going on with regard to the financial consequentials and that will be aligned to the budgetary processes. Just as an illustration, Elspeth talked about the FSA getting more resource than they are. Our understanding is that they are looking to increase their staffing just on risk assessment by about 60 whole time equivalent staff. It seems to us that if we are to be able to represent the interests of Scotland and Scottish consumers within that space then that cannot be done on existing resource because the output of 60 whole time equivalents is given our organisation in totality is only 200 then the volume of activity generated by 60 extra people is not something that we can manage with what we have got. The question is how do we manage with that additional output and that goes back to the early discussion around do we stop doing things to put more people into that area or have we got more money so we can have more staff or whatever. It is really a pick and mix option and at the moment we do not have sufficient information and detail both in terms of solutions and financials to be really clear on what the answer might be. It might be unsatisfactory but unfortunately that is the position. I will follow up with what you are expecting to get from the Scottish Government and what the budget says in 2018-19. The note that I have here is that you estimate that additional funding of between 0.7 million and up to 5.75 million will be required to deliver the new obligations post Brexit. Is it additional 0.7 million allocated to your sales and the draft budget enough to mitigate any of the risks that we have been speaking about? That range is determined by the nature of the deal. The nearer we are to the current situation, the less financial cost there is, the further we are from the existing system or the existing procedures etc. In no deal territory, the more cost there is. The way that it is being dealt with at the moment, the EU consequentials are being dealt with separately from the general Scottish Government budgetary process. We are plugged into the Brexit financial consequentials but we have not got any answers to that yet. It was just to clarify the 0.7 additional budget in the draft budget. The existing budget that we have is 15.3 at the present time. That has been rolled forward into the 2020 draft budget that has just been discussed recently. The additional 0.7 million that you see there to round up to 16 is a result of a 300,000 transfer as the delivery fee to official controls is transferred into Food Standards Scotland as of 1 April. There is also an allocation for annually managed expenditure, which is a non-cash provision for our pension liability that was transferred over as Food Standards Scotland. That is what the additional 0.7 million is that you would see in the draft budget. Just for clarity, you have received £700,000, which is for specific additional responsibilities. You have a standstill cash terms, a main core budget for your ordinary responsibilities and at the moment you have no additional allocation for dealing with EU consequences but you expect to be able to have access to those for next year as required. I am interested in the continued relationship with the European Food Standards Agency. It is important that we continue to engage with scientists, researchers and people across Europe that are quite knowledgeable. The whole purpose of the European Food Standards Agency set up was post-BSE outbreak. As a nurse who has looked after people who had a result of Crushfield's Jacob's disease and diagnosing people in the operating room, it is quite a scary time to be thinking about food supply and things like that. I am interested in what challenges will be faced with a continued requirement to engage with science and research so that we continue to have the best food supply chain safety. Clearly, the formal arrangements in future between the European institutions and the UK will be all part of the UK Government's negotiations. We recognise in Food Standards Scotland the value of staying close to the European Food Safety Authority and using as many of our informal channels to do that as we possibly can. We are already quite well connected with them. We have our chief scientific adviser, Professor Norwell Strachan, who is closely involved with the European Food Safety Authority. He has very good connections. I think that we recognise that when in future, if the UK is out with the EU, it will be more of a requirement to invest more resources and more effort in maintaining these relationships than might currently be the case. EFSA has an annual science conference and we sent a number of our scientists to that conference this year because we fully recognise that we want to still be connected and have access to the relevance of the science and analysis and analytical work that is carried out by EFSA that we are able to still benefit from that. Although there is still a way to go in terms of what formal relationships there might be between the UK and EFSA in future, there is a lot that we are doing and that we recognise that we need to continue to do in terms of maintaining these informal relationships and building these as best we can. I believe that with a no deal in about 101 days, you can assure me that you are continuing to have robust conversations and engagement with the European Food Standards Agency so that a good relationship is continued. That is certainly what we are seeking to do and we are building those networks that we already have trying to build upon them and certainly we would envisage continuing to invest in those relationships because we see the importance and the relevance of what EFSA does to our remit. I will say a more general point. As EFSA, we have put quite a lot of effort into international collaboration because we recognise that a lot of the challenges are international challenges. If you take, for example, whole genome sequencing, in terms of the help and support that can give you in terms of dealing with microbiological threats, that is a significant scientific development and organisations like CDC in the States are leading the exponents of it. We have sent staff over to CDC earlier this year as well. Earlier this year we worked with EFSA and we held one of the codex conferences in Edinburgh where we had 30 odd countries, 60 odd delegates from across the world, came to Edinburgh and had their international meeting here. For us, we recognise the importance of the international networks. Going back to some of the points around the interests of Scotland, it is important for us to promote Scotland in that international framework. That is what we have done and will continue to do. What happens when... Will Food Standards Scotland adequately be able to make its own assessments? For instance, if there is a terrible trade deal negotiated with the United States, an example would be that the cell count in dairy and milk is the thresholds allowed to be higher in America than it is in Scotland, for instance. The dairy produce in America means that the cell count is an indicator of milk quality and the higher the cell count means that cows need to be treated for mastitis. That means that if we are milking cows that are causing pain for certain levels in America, how does that affect the Scottish consumer? Will we have to accept produce that comes with different thresholds that might not be acceptable for the people in Scotland? That is a good question. The process that we are working through now is going forward. We think of it in terms of a three-step process, risk assessment, risk management and risk communication. We already undertake some forms of risk assessment now, so every time we have an incident, for example, nine times out of ten, we will do some form of risk assessment anyway. In the examples that you have, the risk assessment that we would undertake would be the scientific element of it, but we would also take other relevant factors into account. For example, consumer attitudes, relevant animal welfare in your particular question, animal welfare issues might be part of that risk assessment. In terms of the decision making and how and where that rests, that is part of the ongoing debate with UKFSA. The initial indications are that initially ministers would be looking to make risk management decisions. Our responsibility would be to be open and transparent with our risk assessment, so it is clear what the advice is that we are providing and what that advice is to ministers. Once a risk management decision is made by ministers, if they have accepted entirely the risk assessment and the recommendations, that leads you to one decision. If ministers took a different decision to our recommendations, then the responsibility is for ministers in terms of their explanation of that decision. Your question touched on whether we have the resources to do that sort of work. As Geoff has already alluded to, we have quite a lot of scientific expertise in the organisation at the moment that undertakes risk assessment in relation to food incidents and various other things. As part of the capacity and capability work that we have been doing, we are looking again at what other areas might we need to bolster in terms of risk assessment, technical and particular scientific disciplines that we perhaps need to bolster in the organisation. That points back to the discussion that we had a little bit earlier about being able to access some of that technical expertise and additional resource that the Food Standards Agency is developing in the rest of the UK. There is activity in a number of fronts to make sure that we have as much of that resource available as we can. Thank you very much. You mentioned the Centre for Disease Control in the United States, but clearly the European Food Standards Agency has a range of different networks and contacts around the world, and you also mentioned that you are developing your own. Are you in a position where in the event that you no longer had access to EFSA's global networks, would you and or the FSA be able to substitute for that in short order or would that be a whole new stream of work after the 20th of March? The focus at the moment is on bolstering UK capability. I think that the issue really with EFSA is the kind of being involved in the way we are at the moment might well change, but for example EFSA risk assessments would still be in the public domain. We would still have access to some of the risk assessment conclusions that EFSA is reaching. From a UK perspective, that would be part of our evidence base in terms of our own risk assessment. We have talked a lot earlier about how we have best practice with the EU. It has arguably got the best food safety regime in the whole of the world. One of the key tools that we are aware of, which has been very effective, is the rapid alert system for food and feed, set up in 1979. Can you tell me and the committee a bit more detail how that works for you in practice? The RASA system is an EU-wide system. The way it works in practice is basically an alert system that works across the EU, in particular where food may have been exported within the EU. At the moment, most incidents that we deal with are UK related. What happens is that when we are dealing with an incident, we will talk to the business and we will find out one of the key elements of an incident management is the traceability to find out where effective food may have gone to. If that food has gone to other countries, then we are obliged to use the RASA system to provide an alert to other countries with the traceability and the food information so that their food authorities can take action accordingly. Obviously, it works in converse, so you may remember the issues around Fipron earlier on in the year. If there is an incident in another EU member state that spills over into the UK, then those other member states would alert us. It is a kind of EU-wide alert, but it would alert us to issues within the UK that stem from a European country. In a simplistic summary, would it be fair to describe it as some form of breakdown service for food safety with its round-the-clock notifications? That is a pretty good analogy. I did work hard to be very spontaneous. One of the issues that I looked at earlier was the groupings involved here. As you know, it is effectively the 28, the EU 28 and the FTA countries plus Switzerland. It has worked really well since 1979. Have you looked in your RIS register about the scenario that would have a no deal that would be out effectively in the cold? Obviously, no country has ever left the EU, so on one level we don't know what is going to happen. If we are not part of this very efficient system, what is going to happen? Have you looked at countries that are not part of this, such as North Africa, Ukraine and so on in Eastern Europe? What happens there? What benefits do they get? How do they operate? If we are not part of the club, we are not going to get the benefits. There is an international network of food safety authorities called INFASAN. The RASF system does feed into the INFASAN system. One of the options is looking at greater use of INFASAN. The other thing is that some of the RASF information is also publicly available as well. While it is within a community area, some of it is public as well. The point that I would make about RASFs is that, even in a no deal scenario, it seems to me that this is an area of mutual interest because it is around consumer protection. Assuming in a no deal scenario the UK continues to export to the European Union and assuming we had an incident in the UK which potentially posed a threat to consumers in Europe, it seems it would be in the interests of Europe to have some method of exchange with the UK to protect European consumers. In that sense, there is an argument to say retention of RASFs. Whether we can get to that conclusion obviously is subject to negotiation, but certainly in terms of a clear mutual benefit in terms of public health protection, RASFs it seems to me is one of those unique areas where you can clearly say from a public health and protection of public health perspective that continued sharing of information would make sense. What you have described seems very rational to me. If I have learnt anything in this place that Brexit negotiations haven't been very rational to date, if we find that we have left the EU in March and we haven't got a deal, how quickly can you sign up to the World Health Organization? Clearly we are part of the World Health Organization, we are part of the UK. How quickly can we sign up to their alerts? What discussions have you had with the FSA about their scenario planning for a no deal because obviously we are doing this on a UK basis? I'm not sure on the timing, I'd have to come back to you on that particular point. In terms of dealing with the consequences around RASFs in terms of exit, we are working with the FSA in terms of ongoing resilience around food safety and incident management. There is a stream of activity specifically looking at all of the issues related to food incidents and the whole RASF information system approach. We are certainly aware that FSA has been doing some work within FSA. In terms of how quickly we could turn that system on, I'd have to come back to you on that. I looked earlier at a couple of top 10 alerts from the UK to give some flavour, no pun intended, on the sort of issues that have been raised. Salmonella was number one in terms of alerts and pesticide residues were the other, which is all good, excellent practice. My personal nightmare is that we go for a no deal scenario, we withdraw from the alert system and suddenly there's an alert for Salmonella from an EU country that we don't for some reason pick up in the UK. We have an outbreak here purely not because we're not being rational because your point was very well made but because the bureaucracy is such that we're not fully part of the alert system. We will withdraw from this in March if we have a no deal scenario. I think that's quite worrying. I do accept that there are other worldwide systems that we can plug into. Will we be able to do that immediately? Will it be as good as the current alert system that we have? In terms of awareness, one of the streams of activity that both ourselves and the FSA are looking at is the kind of increasing surveillance activity and what we call horizon scanning. Part of that surveillance is actually looking at what is happening elsewhere. For example, if there was a Salmonella outbreak in Europe, there's a very high likelihood that the media would pick that up and our horizon scanning surveillance would also then pick that up. I think where we are in terms of discussions with individual member states or relationships with individual member states and relationships with the European Commission and, for example, the Food Forward Network suggests that if that particular issue was happening then we would probably get the information that we needed to be able to deal with that incident. In terms of the level of detail around infosan and what that provides, again I'd have to come back to you on the detail on that, but my understanding is that the massive information that is provided would go into that infosan system. You may want to write back on that, because I appreciate that it's quite technical. I'm quite reassured by what you've said that with the public notifications that are available, both with the World Health Organization and with the relationships that you've got with other European countries, a system will still exist in two ways. The key point of thought is that the gold standard that we have is world beating. We know that from everything that we've read about. The EU has got the best system of food safety and this alert system is probably the best in the world. We're going from a gold standard five star to something that might be lesser than that. What will we lose going from the rapid alert system that we have in Europe to the World Health Organization system, which is good, but I don't think it's the same level as we have in intensity in Europe? I suppose, again, it depends on the form of negotiation, but in terms of incident management and the application of racifs, then every member state pretty much takes the same approach. You identify the incident, you do a series of actions around the traceability. Fundamental to that is the scientific risk assessment that tells you the degree of risk there is to consumers. I suppose the risk is actually around the level of information we can get access to, because obviously if we can get access to other countries' risk assessments, then we can just look at it and add to it. If we can't get access to it, then we're potentially having to do a risk assessment from scratch. Having said that, on some issues, for example, certainly on microbiology, salmonella, campylobacter, E. coli, we're pretty thorough in understanding those risks. In terms of something like a microbiological outbreak around salmonella, we're pretty much clued on around what the risk assessment is and where, in particular, threats are to consumers in terms of vulnerable groups, etc. To be honest, I'm not sure there's a clear answer to the question, because it depends on the nature of the risk that exists, and then the level of information we can get, plus the information that we already have. I just wanted to follow on from a point that Emma Harper made. One of the issues that seems to be raised a lot is the potential trade deals with other countries that would allow what we would class as substandard food to come in and pervade within our country. One of the things that you mentioned is communication with the public. I wonder whether we are currently with that. Do you feel that there's enough marketing, education around food standards, social food around health and nutrition? Is that happening just now? Is it happening enough? Is that part of our protection, if you like, against substandard food coming into the country? Certainly, in a lot of our preparations for Brexit, so since not long after the referendum, we have carried out a number of separate sets of consumer engagement to talk to consumers about what they understand about current food systems, what they understand in the context of the exit from the EU, what their concerns and anxieties or indeed opportunities might be around some of this. We've done a number of waves of that work, and I think that has helped us to get a very clear sense. I think that both the chair and Geoff have mentioned that already. This morning that consumers have very clearly told us that they don't necessarily know a lot of the detail of the current systems and they don't necessarily feel that they need to know a lot of the detail of the current systems, but they have confidence in them and they trust them and they don't want that to be diminished. In addition to that, we do a biannual consumer tracker, and we've been doing that since we were established, so that allows us again to follow consumer perceptions of a number of things, of us as an organisation, for example, how they trust us, their awareness of us, but also since the referendum, we have asked a number of Brexit-related questions, and that has allowed us to see over the passage of time, those concerns expressed particularly around anxieties, perhaps about increased price of food and whether their choices in relation to food might be different in future. So there are some very specific things we've done about talking to the public and listening, very importantly listening to the public about what they feel about this. I think that in the wider context, consumer engagement and talking and listening to the public has been a really important part of our work, and we've done that through a number of routes. We've done some very focused consumer engagement on particular issues. Somebody has already mentioned Campelabacter, again, understanding and talking to consumers about risks there and controls, and on the other side of our remit around the diet and obesity work, again, engagement with the public, engagement with consumers to help us, develop our interventions and develop our consumer messaging in ways that are most useful and most relevant is really important. I think that we have, since we were set up as an organisation, spent a lot of time and effort in listening to and engaging with the public, and since the referendum we've certainly done a number of specific strands around listening to, as I say, concerns or indeed opportunities that the public think there might be around Brexit. Just to repeat, the point that we made the last time to you, Mr Whittle, is that as far as we're concerned, as an organisation, we see our job is to, at the very minimum, is to be advocating the maintenance of those standards. So, if any governments are in discussions on trade deals, not for us to get into the politics of that, but it is, I think, our duty to be making clear what we believe if there are threats to the standards that we believe we should be maintaining. Now, beyond that, I think that that's the matter for a political debate, but certainly we would not want to deviate from defending those standards as long as we are able and as long as they are forming the statute and the statutory basis for food standards in this country. Can I finally just ask for the committee's greater understanding, if you would like to say a word or two about any links you may have with the NHS on food safety issues, and in particular with the special boards of the NHS in Scotland on food safety issues, which may be helpful for us in our future considerations? What we certainly really is with those, I mean, Health Protection Scotland are a major player because they are the repository of the best intelligence we have in terms of epidemiological work, and clearly, as Jeff was alluding to earlier, in a lot of those messages of different types of incidents, you're very dependent upon the traceability of what you're trying to do. We also have huge connections with the whole public health and the whole panoply of public health in the work that we're doing, particularly on that part of our statutory duty in relation to the diet and having a diet that is not injurious to public health. So, we're very closely with the whole range of, well, they're now being brought together into a slightly more cohesive element, but we live very closely with them in that work. Thank you very much. Now, in answer to questions today, you've said that you cannot, at this stage, have a high degree of confidence in your readiness to deal with the consequences of a no-deal outcome in the next few weeks. Clearly, the committee would be very keen to be kept fully appraised of that level of readiness and in the circumstances which will clearly unfold over the next few months and would be grateful if you could do that. I think you're also committed to keep us or to respond in more detail to David Stewart's questions around infosan and the timing and the mechanisms that would allow us, if we needed to, to substitute for our connections with European Food Standards Agency going forward. So again, be very useful to the committee to have that information in due course. Can I thank you very much for your attendance today and for responding so fully to the questions asked? That certainly assists us in considering the regulations which we continue to receive in relation to your areas of responsibility and indeed in our wider world. Thank you very much. Thank you very much. We'll suspend for a few minutes and then resume in private.