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Thank you for your request of 30 December 2005 made under the Freedom of

Information Act 2000 for the following.

• Copies of documentation discussing the safety of Farmed Salmon in


relation to PCB contamination, particularly in relation to the paper (Hite et
al) published in Science in January 2004.

• Copies of any advice given to the Scottish Executive, Crown Estate and
other official bodies on the safety of Scottish Salmon in this regard.

• Copies of correspondence and attached materials exchanged between the


FSA and listed organisation following on this topic between September
2003 and July 2004:

• In addition I would like to be informed about the process by which The


FSA decided that the report in Science was based on 'outdated science'
(John Krebs in the Guardian, 10 January 2004) and not cause for concern
leading to the information released to the press and on the FSA website
such as that dated 8 January 2004 :
http://www.food.gov.uk/multimedia/faq/salmon080104/

A copy of the information we hold is enclosed. Please note that this includes
information from the whole of the FSA and not just FSA Scotland.

Under section 21 the Act, we are not required to provide information that is
already reasonably accessible to you. Therefore, where this is the case we
have provided the link to the information that is available on the Agency’s
website.

I also wish to advise you that Food Standard Agency UK did not have any
correspondence with the cited organisations: Fish Farming companies,
Chrome consulting, Grayling, Salmon of the Americas, Society for Positive
Aquaculture Awareness. We also do not hold any information relating to
Crown Estate on this matter

A small amount of information that has been obscured has been withheld
under section 40 of the Act as personal information (such as names,
telephone / fax numbers, postal and email addresses) which if disclosed
would contravene the data protection principles of the Data Protection Act
1998.

If you have any queries about this response, please contact me. Please
remember to quote the reference number above in any future
communications.

If you are unhappy with the way the Agency has handled your request for
information, you should write to: Mr Alan Harvey, FSA Complaints Coordinator
and ask for an internal review. Alan’s address is Food Standards Agency,
Room 620 Aviation House, 125 Kingsway, London, WC2B 6NH (email:
alan.harvey@foodstandards.gsi.gov.uk).
Copies of the following are attached:

Correspondence between MP and Sir John Krebs dated 16 January 2004 and
13 February 2004 (Annex 1a and 1b)

Submission to Deputy Minister for Health and Community Care (Annex 2)

Submission to Northern Ireland Minister (Annex 3)

Reply to MSP dated 10 February 2004 (Annex 4)

Reply to MSP dated 29 October 2003 (Annex 5)

Minute of a meeting held between FSAS and Scottish Quality Salmon on the
issue (Annex 6)

The Agency released the following statement, which was temporarily placed
on our website.

'Risk assessments for dioxins are carried out by comparing intakes from the
diet (and other sources) with safety guideline levels established by
independent expert scientific committees.

Information on the levels of dioxins in our diet and individual foodstuffs is


obtained by surveys carried out by the Food Standards Agency. The recent
findings of dioxins in salmon reported by American researchers is in line with
earlier work by the FSA. The question that needs to be answered is why have
the American researchers advised against eating farmed salmon, except on a
very occasional basis, whereas the FSA has advised that salmon can
continue to be eaten regularly as part of a healthy balanced diet.

The answer lies in the different approaches to setting safety guideline levels
used by the US Environmental Protection Agency (EPA) compared with the
other bodies such as the US Food and Drug Administration, the World Health
Organisation, the Scientific Committee on Food which advised the European
Commission and the UK’s Committee on Toxicity.

In their risk assessment the EPA does not take into account the mechanism
by which compounds cause cancer. Dioxins are known to cause a wide
variety of toxic effects, including cancer, in laboratory animals when exposed
to high levels over a lifetime. They have also been found to cause
reproductive toxicity in laboratory animals. The EPA risk assessment
approach for dioxins, which has been evolving since 1991, but has not been
finalised, assumes that any level of exposure to dioxins carries with it some
risk, albeit small, of getting cancer.

The WHO assessment took into account the mechanism by which dioxins
cause cancer. They have concluded that dioxins are ‘non-genotoxic’
carcinogens, for which it is possible to establish a threshold of toxicity. In
2001, experts advising the WHO concluded that provided exposure to dioxins
is kept below this threshold then there will be no adverse effect upon health.
The safety guideline value was then set below the threshold to allow for some
uncertainties in the precise nature of the effects and extrapolation from
animals to man.

The levels of dioxins in salmon are such that normal exposure via the diet
would not lead to intakes above the safety guideline value. There are clearly
established benefits from eating oily fish such as salmon because it contains
factors that are protective against cardiovascular disease. For this reason,
independent experts agree that the benefits of eating one portion a week of
oily fish such as salmon far outweigh any possible risks. The FSA therefore
advise consumers to eat oily fish, such as salmon, as part of a healthy
balanced diet.'

The following additional information is relevant to your request

The SACN/COT report did not discuss the Hites risk assessment, only
mentioning the similarity of the dioxin concentrations to those from the MAFF
study (see para 3.6 on page 54 of the link titled SCAN Report below).

The 2001 COT statement on TDI for dioxins refers to the EPA approach to
risk assessment of dioxins, noting that it has been under review since 1991
(relevant to the "outdated science" quote). Statement makes clear that COT
agreed with the 2001 SCF and JECFA (WHO) approach to risk assessment. It
is in the SACN/COT report as annex 5.

The chairs of COT, COC and SACN were informed of the Hites paper and
FSA response, but did not specifically comment.

Please find below links to the relevant information that is readily accessible:

The Agency (John Krebs) response to the article in science January 2004
http://www.food.gov.uk/news/newsarchive/2004/jan/sciencestudysalmon

FSA news release regarding the response to the Science Article Jan 2004
http://www.food.gov.uk/news/pressreleases/2004/jan/sciencesalmon

Two information sheets referred to in the press release


i) MAFF/JFSSG Information Sheet 1999/184 dioxins and PCBs in UK and
imported marine fish
http://archive.food.gov.uk/maff/archive/food/infsheet/1999/no184/184diox.htm

ii) FSA Information Sheet 2001 Total Diet Study dioxins and PCBs in food
http://www.food.gov.uk/science/surveillance/fsis-2003/fsis382003

FSA your questions answered - Salmon Study in science Magazine


http://www.food.gov.uk/multimedia/faq/salmon080104/

SACN meeting papers where April 2004 (available via the SACN website)
http://www.sacn.gov.uk/meetings/subgroups/fish/2004_04_14.html
SACN Report
http://www.food.gov.uk/news/newsarchive/2004/jun/fishreport2004

Press Release New oily fish advice published June 2004


http://www.food.gov.uk/news/pressreleases/2004/jun/oilyfishadvice0604press

Oily fish Q& A June 2004


http://www.food.gov.uk/multimedia/faq/oilyfishfaq/

Press Release – The science of assessing the dioxin risk in food


http://www.food.gov.uk/news/newsarchive/2004/jun/scienceriskdioxins

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