Professors Chris Elliott and Brian Green reveal how newly released Committee on Toxicity minutes expose fundamental flaws in the Food Standards Agency’s partial nitrites review. They set out why the review must be withdrawn and replaced with a comprehensive, scientifically robust assessment that reflects the full body of evidence.
It is said a week is a long time in politics but the same can be said for food safety! When Professor Green and I published our recent piece in New Food, questioning the scientific basis of the Food Standards Agency’s (FSA) review on nitrites in processed meats, we did so knowing full well that we would face pushback from the FSA. And so we did.
The headline message the FSA subsequently communicated was simple and confident: there is little or no new evidence that nitrites used in processed meats increase cancer risk.
Yet the newly released minutes show that the COT did not share that confidence – and neither did the authors.”
The FSA’s on-the-record response was: “There is no evidence that removing nitrates or nitrites makes processed meat safer”. This is simply not true if a holistic view of the ‘evidence’ is taken.
Suggesting that our national regulator may have got things wrong is not something we did lightly. However, we believed then, as we still do, that protecting public health requires scrutiny, honesty and the courage to challenge flawed science when it attempts to pass as authoritative.
In the past week, our concerns have been fully vindicated – and in ways more stark and troubling than we could have anticipated. Thanks to a Freedom of Information request, minutes from a private session of the FSA’s own Committee on Toxicity (COT) have come to light.
The meeting minutes reveal that the very committee responsible for reviewing the evidence underpinning the FSA’s stance had deep misgivings about the commissioned report: the report intended to reassure the public that nitrite-cured meats pose little cancer risk. The COT minutes we refer to had not been made public by the FSA, but, due to the pressure they must now feel under, were finally published just a few days ago. The FSA had stated that COT had peer reviewed the report, but within the minutes the following is stated: “The report had already been peer reviewed by several COT Members” and therefore was presented as a paper “largely for information.” This does seem to be highly contradictory.
The FSA commissioned consultancy firm RSM UK to conduct a partial “rapid evidence review” at a cost of £90,000 to the taxpayer. The headline message the FSA subsequently communicated was simple and confident: there is little or no new evidence that nitrites used in processed meats increase cancer risk. Yet the newly released minutes show that the COT did not share that confidence – and neither did the authors. The COT minutes highlight the weaknesses, the rushed nature of the study and that it involved “limited resources.” The Committee members questioned key elements of the review’s design, scope and scientific validity.
Among the Committee’s most serious concerns were:
The Committee members questioned key elements of the review’s design, scope and scientific validity.”
Due to “time constraints” animal studies were excluded entirely – a fundamental flaw. Anyone familiar with carcinogenic risk assessment knows that animal data are a cornerstone of understanding mechanism and biological plausibility. We flagged this major shortcoming in our article.
To be “efficient” evidence was ranked using journal impact factors. An impact factor is not, and has never been, a valid measure of scientific quality. Some of the most detailed and relevant toxicology studies appear in highly specialised journals with modest citation profiles. To down-rank them because they are not published in more glamorous journals is scientifically indefensible. We flagged this major shortcoming in our article.
The Committee’s minuted concerns show that what was commissioned was a partial review that was narrow, selective and structurally biased, favouring a conclusion of “minimal concern”. This is exactly what was produced. The FSA has continued to publicly present the review as if it were solid, comprehensive and endorsed by independent scientific scrutiny. Yet, the newly released COT minutes tell a very different story. Thus we are not alone in our opinions; fellow scientists could also see the obvious shortcomings.
This, in our opinion, is how trust is lost. Not through scientific disagreement but through a lack of scientific rigour. This is not simply an argument about bacon. It is a test of how we expect public health regulators to operate. Should we accept evidence reviews that exclude relevant science? Should we accept policy conclusions built on selective interpretation of data? Should we accept public communications that aim to smooth over uncertainty? We think not.
We should expect transparency, scientific rigour and the precautionary principle applied where cancer risks are plausible, evidenced and preventable. The FSA, since its creation (Food Standards Act 1999), has been required to: ‘Put consumer protection first’ and ‘act on potential risks even when scientific certainty is incomplete’. On these fronts they have failed.
What must happen now
As has The Coalition Against Nitrites, of which we are proud members, we call upon the FSA to:
- Withdraw the RSM rapid review
- Commit to undertake a full review of ALL existing scientific evidence, including human, mechanistic and animal data
- Re-examine commercially proven nitrite-free curing alternatives.
There is far more besides that could be carried out, but we believe this is the minimum required to restore scientific credibility in the agency.
Some will inevitably frame this as a dispute between campaigners and regulators. It is not. It is a dispute between credible science and a highly flawed process. It is about what level of evidence is required before our Food Standards Agency acts properly to protect public health.
Meet the authors
Professor Chris Elliott
Chris is Professor of Food Safety and Founder of the Institute for Global Food Security at Queen’s University Belfast. He served as Pro Vice Chancellor responsible for the Medical and Life Sciences Faculty between 2015 and 2018 and has published more than 450 peer-reviewed articles, many of them relating to the detection and control of agriculture, food and environmental contaminants.
His main research interests are in the development of innovative techniques to provide early warning of toxin threats across complex food supply systems. Chris led the independent review of Britain’s food system following the 2013 horsemeat scandal.
Professor Brian Green
Brian Green, BSc, PhD, is Professor of Molecular Nutrition at the Institute for Global Food Security, Queen’s University Belfast. His research explores dietary metabolites – bioactive compounds derived from food – and their roles in human health. His team develops advanced targeted mass spectrometry techniques to uncover biochemical pathways linking diet to disease.
Current research themes include:
- Dietary and metabolic factors influencing disease onset, with recent emphasis on neurodegenerative disease and cancer
- Characterisation of novel micronutrients and their physiological functions
- Nutrients and dietary components that modulate immune responses or support therapeutic interventions
- Discovery of food biomarkers for accurate dietary intake assessment.
Through this work, Professor Green aims to advance nutritional strategies that promote health and reduce disease risk worldwide.
