FOOD STANDARDS AGENCY

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                      FOOD STANDARDS AGENCY
             GUIDANCE NOTES ON ARTICLES 14-16 and 18-20 OF
            THE GENERAL FOOD LAW REGULATION (EC) 178/2002


Introduction

1. These Guidance Notes have been produced with the aim of providing
   informal, non-statutory advice on compliance with the requirements of
   Articles 14-16 and 18-20 of Regulation (EC) 178/2002.

2. We have taken account of the previous Food Standards Agency Guidance
   Notes on this Regulation issued on 10 March 2005. These previous
   Guidance Notes included EC Guidance issued on 20 January 2005. We
   have also taken account of the responses to the public consultation on the
   EC Guidance in July 2005. The FSA view is that these new Guidance
   Notes are more appropriate for food businesses in the UK.

3. The notes should be read in conjunction with the Food Safety Act 1990
   (Amendment) Regulations 2004 (No. 2990), the General Food Regulations
   2004 (No. 3279)1 or, as appropriate, the Feed (Hygiene and Enforcement)
   Regulations 2005 (see Annex). Food and feed businesses are required to
   comply with these articles, which are about safety of food and feed,
   traceability, notification of food and feed safety incidents and withdrawal
   and recall of unsafe food and feed.

4. These Notes and the examples in them should not be taken as an
   authoritative statement or interpretation of the law, as only the Courts can
   decide whether, in particular circumstances, an offence has been
   committed under the relevant Regulations. It is the responsibility of
   individual organisations to ensure their compliance with the law.
   Organisations with specific queries may wish to seek further advice from
   their home Food or Feed Authority, i.e.

        •    their local authority2;

        •    for imported food but not feed, their port health authority3;

        •    the Food Standards Agency; or

        •    in relation to feed in Northern Ireland, the Department of Agriculture
             and Rural Development (DARD).

Purpose of Regulation (EC) 178/2002



1
  In Northern Ireland, the Food Safety (Northern Ireland) Order 1991 (Amendment) Regulations
(Northern Ireland) 2004 (No. 482) and the General Food Regulations (Northern Ireland) 2004 (No. 505).
2
  In Northern Ireland district councils only.
3
  Ibid.



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5. Regulation (EC) 178/2002 of the European Parliament and of the Council,
   lays down the general principles and requirements of food law, establishes
   the European Food Safety Authority and lays down procedures in matters
   of food safety. It came into force on 21 February 2002, although certain
   key provisions applied only from 1 January 2005. The principal aim of this
   Regulation is to protect human health and consumers’ interests in relation
   to food.

6. It applies to all stages of production, processing and distribution of food
   and feed, but there is an exemption for primary production for private
   domestic use, and the domestic preparation, handling, or storage of food
   for private domestic consumption.


Definitions

7. A number of terms are defined in Articles 2 and 3 of the Regulation and,
   since they are used in the Guidance, these are included here for ease of
   reference. For the purposes of Regulation (EC) 178/2002:

  •   ‘food’ or (‘foodstuff’) means any substance or product, whether
      processed, partially processed or unprocessed, intended to be, or
      reasonably expected to be ingested by humans. ‘Food’ includes drink,
      chewing gum and any substance, including water, intentionally
      incorporated into the food during its manufacture, preparation or
      treatment. It includes water after the point of compliance as defined in
      Article 6 of Directive 98/83/EC and without prejudice to the
      requirements of Directives 80/778/EEC and 98/83/EC.

      ‘Food’ shall not include:

      (a) feed;

      (b) live animals unless they are prepared for placing on the market for
          human consumption;

      (c) plants prior to harvesting;

      (d) medicinal products within the meaning of Council Directives
          65/65/EEC and 92/73/EEC;

      (e) cosmetics within the meaning of Council Directive 76/ 768/EEC;

      (f)   tobacco and tobacco products within the meaning of Council
            Directive 89/622/EEC;

      (g) narcotic or psychotropic substances within the meaning of the
          United Nations Single Convention on Narcotic Drugs, 1961, and
          the United Nations Convention on Psychotropic Substances, 1971;



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    (h) residues and contaminants.

•   ‘food law’ means the laws, regulations and administrative provisions
    governing food in general, and food safety in particular, whether at
    Community or national level; it covers any stage of production,
    processing and distribution of food, and also of feed produced for, or fed
    to, food producing animals;

•   ‘food business’ means any undertaking, whether for profit or not and
    whether public or private, carrying out any of the activities related to any
    stage of production, processing and distribution of food;

•   ‘food business operator’ means the natural or legal persons
    responsible for ensuring that the requirements of food law are met
    within the food business under their control;

•   ‘feed’ (or ‘feedingstuff’) means any substance or product, including
    additives, whether processed, partially processed or unprocessed,
    intended to be used for oral feeding to animals;

•   ‘feed business’ means any undertaking whether for profit or not, and
    whether public or private, carrying out any operation of production,
    manufacture, processing, storage, transport or distribution of feed
    including any producer producing or storing feed for feeding to animals
    on his own holding;

•   ‘feed business operator’ means the natural or legal person
    responsible for ensuring that the requirements of food law are met
    within the feed business under their control;

•   ‘retail’ means the handling and/or processing of food and its storage at
    the point of sale or delivery to the final consumer, and includes
    distribution terminals, catering operations, factory canteens, institutional
    catering, restaurants and other similar food service operations, shops,
    supermarket distribution centres and wholesale outlets;

•   ‘placing on the market’ means the holding of food or feed for the
    purpose of sale, including offering for sale or any other form of transfer,
    whether free of charge or not, and the sale, distribution, and other forms
    of transfer themselves;

•   ‘risk’ means a function of the probability of an adverse health effect and
    the severity of that effect, consequential to a hazard;

•   ‘risk analysis’ means a process consisting of three interconnected
    components: risk assessment, risk management and risk
    communication;




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      •   ‘risk assessment’ means a scientifically based process consisting of
          four steps: hazard identification, hazard characterisation, exposure
          assessment and risk characterisation;

      •   ‘risk management’ means the process, distinct from risk assessment,
          of weighing policy alternatives in consultation with interested parties,
          considering risk assessment and other legitimate factors, and, if need
          be, selecting appropriate prevention and control options;

      •   ‘risk communication’ means the interactive exchange of information
          and opinions throughout the risk analysis process as regards hazards
          and risks, risk related factors and risk perceptions, among risk
          assessors, risk managers, consumers, feed and food businesses, the
          academic community and other interested parties, including the
          explanation of risk assessment findings and the basis of risk
          management decisions;

      •   ‘hazard’ means a biological, chemical or physical agent in, or condition
          of, food or feed with the potential to cause an adverse health effect;

      •   ‘traceability’ means the ability to trace and follow a food, feed, food
          producing animal or substance intended to be, or expected to be
          incorporated into a food or feed, through all stages of production,
          processing and distribution.


Article 14 (Food safety requirements)

What the Article says

8. This Article prohibits food being placed on the market if it is unsafe. It is
   deemed to be unsafe if it is considered to be:

       (a) injurious to health;

       (b) unfit for human consumption.

9. Although these terms were used in Section 8 of the Food Safety Act
   19904, their meaning in the Regulation is not necessarily the same and will
   be determined by the European Court. The factors listed in Article 14 (3)-
   (5) were not part of Section 8 and are new to UK food law. These factors
   should be taken into account when determining whether food is injurious
   or unfit. Food that is considered to be either ‘injurious to health’ or ‘unfit’ is
   deemed to be unsafe under Article 14(2), and it follows that such food is
   subject to the withdrawal, recall and notification requirements of Article 19.




4
    Article 7 of the Food Safety Order (Northern Ireland) Order 1991.



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10. There is no longer an offence under Section 8 of the Food Safety Act 1990
    of selling food which fails to comply with the food safety requirements.
    Instead, an offence of failing to comply with the food safety requirements
    of Article 14(1) is created by Regulation 4(b) of the General Food
    Regulations 20045, as amended (see Annex).

How we believe businesses can comply

11. The food safety requirements in Article 14 apply to sales and supplies,
    including one-off sales and supplies free of charge. The requirements of
    this Article are not limited to ‘food business operators’. The aim is to
    protect public health by covering all eventualities, with the exception of
    private domestic consumption, which is exempted by Article 1(3). It
    should be noted that this exemption does not extend to food produced by
    individuals for charitable and similar events.

12. Article 14(3) – 14(5) indicate what factors need to be taken into account
    when determining whether food is injurious to health or unfit. Article 14(3)
    requires that the normal conditions of use of the food, such as cooking,
    should be taken into account. Article 14(4) requires that the particular
    health sensitivities of specific categories of consumers be taken into
    account where the food is intended for that category of consumers. So,
    for example, food intended for consumers requiring a gluten-free diet could
    be considered to be injurious if it were found to contain gluten.

13. Conversely, the general requirement not to market unsafe food is not
    breached simply because a certain group of people are particularly
    susceptible to be injured by it. Food intended for general consumption is
    not injurious for the purposes of this Article because some people are
    allergic or intolerant and so liable to be injured by it.

Food that is injurious to health

14. Once a hazard is identified which might make food injurious to health, an
    assessment of the associated risk should be carried out, taking the factors
    in Article 14(3) and (4) into account. Not all hazards that might be found in
    food are controlled by specific regulations. Food could be injurious to
    health without exceeding a particular legal limit. For example, this could
    apply when glass, which is not a specifically banned substance, is found to
    be present in food, or if, for example, a hazardous chemical not specifically
    identified by legislation on contaminants in food is found to be present.
    The key point is that once a hazard of any kind has been identified, the
    need to assess the risk is paramount.

15. When there are concerns that a particular food may be injurious to health,
    food businesses then have to consider how serious the risk is. Risk
    assessment in this context means addressing two key questions:


5
    In Northern Ireland, the General Food Regulations (Northern Ireland) 2004 (No. 505).



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   •   what is the harm that might be caused?

   •   how likely is it?

16. There is a range of reputable, expert organisations that are able to advise
    on particular cases.

Food that is unfit

17. The central concept of unfitness is unacceptability. Food can be rendered
    unfit by reason of contamination, by the presence of foreign objects, by
    unacceptable taste or odour as well as by more obvious detrimental
    deterioration such as putrefaction or decomposition.

Food not in compliance with food safety legislation

18. Where food is found to be in breach of specific legislation governing its
    safety, it will be presumed to be either injurious to health or unfit for human
    consumption and thus ‘unsafe’ for the purposes of Article 14. For
    example, a breach of a particular legal limit within legislation on
    contaminants in food would raise the presumption that the food was unfit
    for human consumption in the light of Article 14(5). In such a case, an
    assessment should still be carried out, considering the factors in Articles
    14(3)-(5) in the light of the legislation on contaminants in food. If that
    assessment shows that the food is neither injurious to health nor unfit for
    human consumption it would not be regarded as unsafe for the purposes
    of Article 14. However, it would still be in breach of the legislation on
    contaminants in food.


Article 15 (Feed safety requirements)

What the Article says

19. This article prohibits feed being placed on the market if it is unsafe, i.e. if it
    either:

   (a) has an adverse effect on human or animal health;

   (b) makes the food derived from food-producing animals unsafe for
       human consumption.

20. The definition of unsafe (for human consumption) is that in Article 14(2).

21. Animal feed is deemed to be safe if it complies with specific Community
    provisions governing feed safety, where such Community provisions exist.
    The provisions include, for example, maximum permitted levels of
    undesirable substances (contaminants such as lead, arsenic or aflatoxin
    B1), conditions governing the authorisation, marketing and use of feed
    additives, and prohibitions on certain ingredients. However, enforcement


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       authorities may also impose restrictions on, or require the withdrawal of,
       consignments of feed if they believe that the feed is unsafe even though it
       otherwise complies with feed law requirements. The decision to impose
       restrictions or require withdrawal will be a matter of judgement by the
       enforcement authority.

22. The feed safety requirements of this Article apply to all stages of the
    production, transport, storage, supply and sale of animal feed, including
    producers producing, processing or storing feed for feeding their own
    animals, one-off sales and supplies free of charge. The aim is the
    protection of both animal and human health, in the latter case by ensuring
    the safety of animal products (meat, dairy products and eggs) for human
    consumption.

How we believe businesses can comply

23. Where a potential hazard in feed has been identified, the feed business
    operator should carry out an assessment to ascertain if food derived from
    food-producing animals which have been given that feed is safe. This
    assessment should take into consideration all available information,
    including any maximum permitted levels for substances causing the
    potential hazard, where such limits exist.

24. It should be noted that in addition to this requirement under Regulation
    (EC) 178/2002, offences are committed by anyone who places on the
    market animal feed which does not meet the requirements of other feed
    legislation, e.g. feed that exceeds maximum permitted levels of
    undesirable substances.

Article 16 (Presentation)

What the Article says

25. This Article stipulates that the labelling, advertising, and presentation of
    food shall not mislead consumers. The Article applies to those involved in
    occasional events as well as to food businesses. The wording of Article
    16 says that it is without prejudice to more specific provisions of
    Community law. Therefore, Article 16 is an additional measure. It does
    not overrule or otherwise affect other legal provisions, whether at
    Community or national level, and so applies additionally to the Trade
    Descriptions Act 1968 and Section 15 of the Food Safety Act 19906.
    Section 15, which implements the requirements of Article 2 of the Food
    Labelling Directive 2000/13, continues in place. Unlike Section 15, Article
    16 applies in case of a one-off supply free of charge, subject to the
    exemption in Article 1(3) for private domestic use.




6
    Article 14 of the Food Safety (Northern Ireland) Order 1991.



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26. Article 16 also applies to the labelling, advertising and presentation of
    feed. There are also other provisions on the labelling of feeds, which are
    set out in Schedule 3 of the Feeding Stuffs Regulations 2005.

How we believe businesses can comply

27. This Article covers misleading labelling and advertising. It also covers
    cases where a consumer is misled as to the nature, substance or quality of
    the food by the setting in which food is displayed. This could apply, for
    example, if a synthetic cream cake was displayed in a chill cabinet in such
    a way as to give the impression that it contained fresh dairy cream.


Article 18 (Traceability)

What the Article says

28. Under this Article, food and feed businesses are required to

   •   identify their suppliers of food, feed, food-producing animals and any
       other substance for incorporation into food or feed,

   •   identify the businesses to which they have supplied products, and

   •   produce this information to the competent authorities on demand.

29. The requirements of Article 18 of the Regulation apply to food and feed
    business operators at all stages of the food chain. This includes primary
    producers, manufacturers, wholesalers, retailers, transporters,
    distributors, those dealing in the purchase and sale of bulk
    commodities, and caterers. A food or feed business would also include
    any business that trades in food or feed, even if they do not take physical
    possession (food/feed broker). Also included are charities where these
    meet the definition of food business, and businesses importing from third
    countries, even though their supplier is not within the EU. The
    requirements do not, however, extend to suppliers in third countries.

30. The products covered are ‘food, feed, food-producing animals, and any
    other substance intended to be, or expected to be, incorporated into a food
    or feed.’ So, for example, seeds will be subject to the traceability
    requirements only if these go directly into a food product. Live animals
    supplied for eventual use in food would constitute “food producing
    animals” and would be subject to the traceability requirements. Veterinary
    medicines, pesticides and fertilisers do not fall within the scope of the
    Regulation as they are not within the definition of ‘food’ under Regulation
    (EC) 178/2002.

How we believe businesses can comply




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31. Taken at face value, the only information Article 18 requires food and feed
    business operators to provide is the name of businesses who supply them
    and to whom they supply their products, i.e. one step back – one step
    forward. However, EC law should be interpreted according to its purpose,
    and account has to be taken of the relevant recitals and role of Article 18
    in supporting the notification requirements of Articles 19 and 20. It follows
    that, as a minimum, traceability records should also include the address of
    the customer or supplier, nature and quantity of products, and the date of
    the transaction and delivery. It is expected that the provision and retention
    of this type of information is already standard practice in basic invoicing.

32. This requirement should not be taken as meaning that businesses
    necessarily need a dedicated traceability system. It is the need to produce
    information that is important, not the format in which it is kept.

33. Article 18 requires that the traceability records be made available on
    demand. As the purpose of the traceability provision is to assist with
    withdrawals and recalls of unsafe food, food and feed businesses should
    have their records sufficiently organised and available to be produced
    within the short timescale needed for them to be of use in any such
    withdrawal or recall.

34. The Regulation does not specify how long traceability records should be
    kept. Again, this article should be interpreted according to its purpose in
    supporting the notification requirements of Article 19. It is for businesses
    to decide how long they should keep their records, bearing in mind the
    nature of the food or feed, its product life, and the circumstances under
    which they might be required to produce records, should a notification
    under Articles 19 or 20, or assistance to enforcement authorities, be
    subsequently required. However, failure to produce such documentation
    constitutes an offence.

35. Food retailers are not required to keep records of sales to the final
    consumer (since consumers are not food businesses). Wholesalers
    supplying to retail outlets are required to keep records. Where a retailer
    knows that it is supplying to another food business, for example a catering
    outlet, traceability requirements should be adhered to. Caterers such as
    restaurants will need to keep traceability records of inputs, but will not be
    required to keep records of supplies to the final consumer.

36. The traceability requirements of Article 18 apply without prejudice to more
    detailed sector specific requirements. These include the mandatory
    labelling requirements at the point of sale for fresh and frozen beef; the
    mandatory cattle identification and registration scheme and the rules
    relating to consumer information for fish and fish products sold at retail,
    where commercial documentation (e.g. sales note, invoice) is the usual
    means of providing this information through the chain.

37. Article 18 does not require internal traceability, i.e. the matching up of all
    inputs to outputs. Nor is there any requirement for records to be kept


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   identifying how batches are split and combined within a business to create
   particular products or new batches. For example, a cake manufacturer
   would not need to specify which batch of flour went into which cakes.

38. Other EC feed legislation (Regulation (EC) Feed Hygiene 183/2005)
    specifies in more detail the information that must be recorded by different
    categories of feed business operators to ensure traceability. This
    requirement is set out in the record-keeping sections of Annexes I and II of
    Regulation 183/2005.


Article 19 (Withdrawal, recall, and notification of food)

What the Article says

39. This places obligations on food businesses to recall, and/or withdraw, food
    from the market if it is not in compliance with the food safety requirements
    of Article 14, to notify competent authorities (their Home Authorities and
    the Food Standards Agency), and to collaborate with these authorities on
    action taken to avoid or reduce risks posed by the food.

40. Article 19(1) requires that, where a food business operator considers or
    has reason to believe that a food which it has imported, produced,
    processed, manufactured or distributed is not in compliance with the food
    safety requirements, and has left the immediate control of the initial food
    business, the food should be withdrawn from the market and notified to the
    competent authorities. (Article 19(3) identifies where there is an obligation
    to notify immediately.)

41. The obligation to withdraw/recall arises when a food business operator
    considers or has reason to believe that a food is unsafe. The test is an
    objective one. Where products may have reached the consumer, there is
    an obligation on food businesses to inform consumers effectively and
    accurately of the reason for the withdrawal of the product and where
    necessary recall products already supplied. The reason given should
    provide details as to why the product is unsafe.

42. Article 19(2) imposes a requirement on food business operators
    responsible for retail or distribution activities, which do not affect the
    packaging, labelling, safety or integrity of food. The purpose of this
    provision is to ensure that such food business operators also play their
    part in the withdrawal of food not in compliance with food safety
    requirements, and in passing on relevant information.

43. Article 19(3) imposes an obligation on food business operators to inform
    the competent authorities immediately if food that they have placed on the
    market may be injurious to human health (see Definitions section for
    clarification of ‘placing on the market’).




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44. Article 19(4) requires that food business operators co-operate with the
    competent authorities on action taken to avoid or reduce risks posed by a
    food that they supply or have supplied.

How we believe businesses can comply

Withdrawal/Recall

45. For the purposes of these Guidance Notes, the terms ‘withdrawal’ and
    ‘recall’ mean:

   •   ‘Withdrawal’ means the process by which a food is removed from the
       market up to and including the retail stage, and including action by food
       producers, packers, distributors, wholesalers and retailers, as
       appropriate.

   •   ‘Recall’ means the process by which consumers are advised, for
       example, by means of public notices and other publicity, to return food
       supplied to them.

46. Food Business Operators must as a minimum withdraw from the market
    food failing to meet the food safety requirements specified in Article 14.
    Where this is insufficient to provide the required level of health protection
    to consumers, they must recall the product.

47. The withdrawal of food from the market may take place at any step along
    the food chain and not only at time of delivery to the end consumer. The
    obligation to withdraw from the market applies when the following two
    cumulative criteria are met:

   •   When a food is considered by the operator (at any stage of the chain)
       as being unsafe (Article 14). In making this judgement, the operator
       will need to consider the normal conditions of use of the food by the
       consumer and at each stage of production, processing and distribution.

   •   Where the food has left the immediate control of that food business
       operator.

48. The wording “has left the immediate control of that initial food business
    operator” stresses that the initial food business operator is no longer able
    to take action by itself to remedy the non-compliance, but needs to
    request/require co-operation from other operators it has supplied. The
    words “of the initial food business operator” are important. It means that
    the food has left, for example, the processing unit and is in the hands of
    another operator (change of step inside the food chain).

49. We consider that it is the responsibility of any ethical business to let
    suppliers know of any problems in order to protect human health. If an
    operator considers that a raw material or an ingredient is not compliant
    with food safety requirements, it should inform its supplier of this non-


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   compliance. The supplier will then have reason to consider or to believe
   that a food not under its immediate control is non-compliant with the food
   safety requirements. This supplier should, therefore, withdraw the affected
   food from the market and notify this withdrawal to the competent
   authorities.

50. Where retailers sell a branded product that does not meet the food safety
    requirements, the brand owners will be responsible for notification and
    withdrawal/recall, but the retailer is required to co-operate as necessary
    under Article 19(2).

51. In addition to the requirements of Article 19(1), competent authorities can
    advise food business operators to withdraw a food which is under their
    immediate control whenever such measures are justified.

Notifying competent authorities

52. When a food business operator withdraws a food in accordance with
    Article 19(1), it should notify this withdrawal to the competent authorities.
    Where products may have reached the consumer, a food business must
    also inform consumers of the reason for the withdrawal of the product and,
    if necessary, recall from consumers products already supplied to them.

53. If food that does not meet food safety requirements has not left the
    immediate control of the food business operator, removal of the food from
    the food chain does not constitute a withdrawal and there is therefore no
    obligation to notify the competent authority.

54. Important: Article 19 (3) states that if an operator at any stage of the food
    distribution chain considers that food which it has placed on the market
    may be injurious to health, they shall immediately notify the competent
    authorities and detail the action taken to prevent the risk. The assessment
    as to whether the food might be injurious to health should be objective
    (see paragraph 13). Under Article 19(3), operators are also required not to
    prevent or discourage anyone from co-operating with the competent
    authorities to prevent, reduce or eliminate the risk arising from a food.

55. Businesses should submit the necessary information under Article 19(1) or
    19(3) to the Agency’s Incidents Branch
    (http://www.food.gov.uk/foodindustry/foodfeedform or fax: 020 7276 8446),
    to the local authority where the food business operator is based, and in the
    case of imports, the relevant port health authority.


Article 20 (Withdrawal, recall, and notification of feed)

What the Article says

56. This places obligations on feed business operators to recall and/or
    withdraw feed from the market if it is not in compliance with feed safety


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    requirements (see paragraph 17 above), and to notify competent
    authorities.

How we believe businesses can comply

57. A feed business operator which considers or has reason to believe that a
    feed which it has imported, produced, processed, manufactured or
    distributed does not comply with feed safety requirements should withdraw
    it from the market and notify the competent authorities. Operators
    responsible only for feed retail and distribution activities should still initiate
    recall action of affected product that it has in its possession or has
    distributed.

58. All feed business operators must immediately inform the competent
    authorities (the enforcement authority and the Food Standards Agency) if it
    has reason to believe that a feed placed on the market may not satisfy
    feed safety requirements and indicate the action being taken to prevent
    the risk arising from the use of the feed. All feed business operators are
    required to co-operate with the action being taken by other feed business
    operators and competent authorities. This will include passing on
    information to enable affected products to be traced.

59. The notification procedure for feed incidents is the same as for food
    incidents (see paragraph 54.)


Enforcement

60. Regulation 3 of the General Food Regulations 2004 designates food
    authorities, port health authorities, and the Food Standards Agency as the
    competent authorities in relation to food7. Enforcement authorities are
    specified in Regulation 6 as food authorities or port health authorities in
    relation to Articles 14, 16, 18 and 19 of Regulation (EC) 178/2002. The
    Agency is specified as an additional enforcement authority in relation to
    Articles 14 and 19 to allow, for example, for the flexibility of the Meat
    Hygiene Service enforcing Regulation 178/2002 requirements in meat
    plants, where this would be more effective.

61. This means that port health authorities or local authorities8 are responsible
    for enforcing all provisions. However, the Agency is an additional
    enforcement authority in relation to the enforcement of the food safety
    requirements, and also recall, withdrawal and notification requirements
    under Article 19 under certain circumstances. This is to allow, for
    example, for the flexibility of the Meat Hygiene Service enforcing these
    requirements in meat plants, where this would be more effective.



7
  Regulation 3 of the General Food Regulations (Northern Ireland) 2004 designates district councils
only.
8
  Ibid.



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62. The Regulations also specify offences in relation to the above
    requirements and impose penalties for these offences. These penalties
    are consistent with those currently in operation under the Food Safety Act
    19909 for food law offences.

63. In Great Britain, local authorities (mainly trading standards departments)
    are responsible for enforcing the feed provisions of Regulation (EC)
    178/2002. In Northern Ireland, the enforcement authority is the
    Department of Agriculture and Rural Development. This duty to enforce
    the provisions is set out in the Feed (Hygiene and Enforcement)
    Regulations 2005. There are separate Regulations for England, Scotland,
    Wales and Northern Ireland. These Regulations also specify offences for
    contravention of the feed provisions of Regulation (EC) 178/2002 and
    related penalties.


Further information about these Guidance Notes

64. Enquiries about, and further copies of these Guidance Notes may be
    obtained from:

                             Bill Drennan
                             Room 115C
                             Food Law Policy Branch
                             Food Standards Agency
                             Aviation House
                             125 Kingsway
                             London WC2B 6NH

Tel:                020 7276 8138
Fax:                020 7276 8193
E-mail:             guidance@foodstandards.gsi.gov.uk

65. Any queries specific to feed should be addressed to:

                             Joseph Nicholas
                             Room 415B
                             Animal Feed Unit
                             Food Standards Agency
                             Aviation House
                             125 Kingsway
                             London WC2B 6NH

Tel:                020 7276 8462
Fax:                020 7276 8478
E-mail:             joseph.nicholas@foodstandards.gsi.gov.uk

66. In Northern Ireland, for general queries please contact:

9
    In Northern Ireland, the Food Safety (Northern Ireland) Order 1991.



                                                    14
                                   DRAFT



                    Trevor Williamson
                    General Food Hygiene and Incidents Unit
                    Food Standards Agency Northern Ireland
                    10c Clarendon Road
                    Belfast BT1 3BG

Tel:         028 9041 7713
Fax:         028 9041 7728
e-mail:      trevor.williamson@foodstandards.gsi.gov.uk

67. In Scotland, for general queries please contact:

                    Jacqui Bunyan
                    Local Authority Food Law Enforcement Branch
                    Food Standards Agency Scotland
                    6th Floor, St Magnus House
                    25 Guild Street
                    Aberdeen
                    AB11 6NJ

Tel:         01224 285175
Mobile:      07876 131648
e-mail:      jackie.bunyan@foodstandards.gsi.gov.uk

68. In Wales, for general queries please contact:

                    Phil Morgan
                    Food Standards Agency Wales
                    11th Floor
                    Southgate House
                    Wood Street
                    Cardiff CF10 1EW

Tel:         029 2067 8913
e-mail:      phil.morgan@foodstandards.gsi.gov.uk




                                      15
                                              DRAFT


ANNEX

Legislation relevant to Regulation (EC) 178/2002

1. The draft Regulation was subject to an extensive consultation process with
   stakeholders. It was published in the Official Journal No. L 31 on 1
   February 2002, and can be accessed via the Commission’s web site at:

http://europa.eu.int/eur-lex/en/archive/2002/l_03120020201en.html

2. Although as a Regulation it is directly applicable in Member States, there
   was a need to introduce new enforcement powers and penalties in relation
   to the new obligations on food and feed businesses in Articles 14 – 20 of
   Regulation (EC) 178/2002, which have applied from 1 January 2005. The
   necessary changes to domestic food and feed law have been effected by
   means of Statutory Instruments under the Food Safety Act 199010, the
   Agriculture Act 1970 and the European Communities Act 1972.

Food Safety Act 1990 (Amendment) Regulations 200411

3. These Regulations are made under the European Communities Act 1972.
   The case law of the European Court of Justice makes clear that it is not
   open to Member States to retain provisions in national legislation in so far
   as they duplicate, gloss or conflict with directly applicable provisions of EU
   Regulations. These Regulations therefore narrow the scope of the public
   consultation requirement in Sections 40 and 48 of the Food Safety Act
   199012 so that it does not apply in cases where the public consultation
   requirements of Article 9 of Regulation (EC) 178/2002 apply.

4. The Food Safety Act 1990 (Amendment) Regulations 2004 bring in the
   new definition of ‘food’ contained in Regulation (EC) 178/2002 (see
   Definitions). This new definition excludes medicinal products within the
   meaning of Directive 2001/83/EC. This meaning is based on the
   presentation of a product as treating or preventing disease in humans, or
   its use with a view to correcting, restoring or modifying physiological
   function. However, certain borderline products for medicinal use which are
   not medicinal products within the meaning of Directive 2001/83/EC are
   now included in the new definition. It will continue to fall to the Medicines
   and Healthcare Products Regulatory Agency (MHRA), on behalf of the UK
   licensing authority, to determine whether a product is a medicinal product
   within the meaning of the Medicines Directive on a case by case basis,
   having regard to the overall presentation and function of the product.

5. The new definition of food automatically applies to other legislation that
   uses the previous definition in the Food Safety Act 1990, for example the
   Food Standards Act 1999 and the Food and Environment Protection Act
   1985, as well as to Regulations and Orders made under all these Acts.

10
   In Northern Ireland, the Food Safety (Northern Ireland) Order 1991.
11
   Ibid.
12
   Articles 39 and 47 of the Food Safety (Northern Ireland) Order 1991.


                                                  17
                                            DRAFT



6. The revised definition of food excludes live animals unless they are
   prepared for placing on the market for human consumption, oysters for
   example.

General Food Regulations 2004 (as amended by the Official Feed and Food
Controls (England) Regulations 2005)13

7. The main purpose of these Regulations is to create offences under UK law
   and provide enforcement powers in respect of obligations applying from 1
   January 2005 under Regulation (EC) 178/2002. These are Articles 12, 14,
   16 (in so far as it relates to food), 18 (in so far as it relates to food
   business operators), and 19.

8. ‘Food business’ and ‘food business operator’ are defined in Article 3.2 and
   3.3 of Regulation (EC) 178/2002. In particular, ‘food business’ means ‘any
   undertaking, whether for profit or not, and whether public or private,
   carrying out any of the activities related to any stage of production,
   processing and distribution of food’. The expression ‘stages of production,
   processing and distribution’ is defined in Article 3.16 and covers all stages
   from and including primary production (as defined in Article 3.17) up to
   and including sale or supply to the final consumer. For example, the
   activities of farmers, importers, manufacturers, wholesalers, distributors,
   transporters, retailers and caterers are covered.

9. The extent to which home-producers or charities fall within the definition of
   ‘food business’ will need to be decided on a case-by-case basis. The
   definition uses the expression ‘an undertaking’, which implies a certain
   continuity of activities and a certain degree of organisation. If you have
   any doubt as to whether you operate a food business or not, then you
   might wish to consult their Home Authority for further advice.

Feed (Hygiene and Enforcement) Regulations 2005

10. These Regulations create offences and penalties in relation to the feed
    provisions of Regulation (EC) 178/2002. These are Articles 12, 16 and 18
    (in so far as it relates to feed or feed business operators) and Articles 15
    and 19. The Regulations also designate the authorities responsible for
    enforcing the provisions and provide those authorities with enforcement
    powers (e.g. powers of entry, seizure and detention of suspect feed).

Legislation in the devolved administrations

11. Following the process of devolution, food and feed legislation is now
    commonly made on a separate basis in England, Scotland, Wales and
    Northern Ireland. However, it was decided that it would be appropriate for
    the Regulations enforcing food aspects of Regulation (EC) 178/2002 to
    apply to Great Britain. Details of the separate Regulations applying in
13
  In Northern Ireland, the General Food Regulations (Northern Ireland) 2004 (No. 505) as amended by
the Official Feed and Food Controls Regulations (Northern Ireland) 2006.


                                                18
                               DRAFT

Northern Ireland, which differ only in the powers under which they are
made, and the food authorities given the responsibility for enforcement,
can be found in the footnotes. There are separate Regulations enforcing
feed aspects of Regulation (EC) 178/2002 for England, Northern Ireland,
Scotland and Wales.




                                  19
PARTIAL REGULATORY IMPACT ASSESSMENT: DRAFT FOOD
STANDARDS AGENCY GUIDANCE ON GENERAL FOOD LAW
REGULATION (EC) 178/2002

TITLE OF PROPOSAL

1. Food Standards Agency (FSA) Guidance Notes on Articles 14-16 and 18-
   20 of the General Food Regulation (EC) 178/2002 (subsequently referred
   to as ‘the Regulation’.)


PURPOSE AND INTENDED EFFECT OF MEASURE

Objective

2. This Regulatory Impact Assessment (RIA) represents our analysis of the
   impact of introducing national guidance. The Agency view is that these
   new Guidance Notes are the most appropriate guidance for food
   businesses in the UK.

3. These new FSA Guidance Notes provide advice on compliance with legal
   requirements covering food and feed safety, traceability provisions and the
   need to notify, withdraw and/or recall products not conforming with the
   food and feed safety requirements applying under the Regulation.

4. Stakeholder comments will be used to determine whether the guidance in
   these Notes is proportionate. Responses refining our preliminary estimates
   of the costs and benefits of the Guidance Notes or highlighting costs and
   benefits that do not feature in this RIA are particularly welcome.

Background

5. Regulation (EC) 178/2002, laying down the general principles and
   requirements of food law, establishing the European Safety Authority and
   laying down procedures in matters of food safety, came into force on 21
   February 2002. The draft Regulation was subject to an extensive
   consultation process with stakeholders in 2001. It was published in the
   Official Journal No. L 31 on 1 February 2002, and can be accessed via the
   European Commission’s web site at

      http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32002R
      0178:EN:HTML

6. Whilst the Regulation came into force on 21 January 2002, certain key
   provisions applied only as from 1 January 2005. These included new food
   and feed safety requirements, new traceability requirements and
   measures to ensure effective product recall/withdrawals and notification to
   competent authorities.




                                      20
7. Although the Regulation was directly applicable in Member States, there
   was still a need to make changes to domestic legislation, to introduce new
   enforcement provisions and to ensure conformity with EU law.

8. FSA Guidance Notes on the new food requirements were originally issued
   on 31 December 2004. EC Guidance was issued on 20 January 2005,
   which replaced the Food Standards Agency guidance on Articles 11, 12
   and 16-20. An amended version of the FSA Guidance Notes on this
   Regulation was issued on 10 March 2005, which referred to and included
   a copy of the EC Guidance. The current FSA Guidance Notes have taken
   account of all this previous guidance.

9. In July 2005 the Agency consulted on how the EC Guidance had been
   working in practice. In view of the responses to this consultation exercise
   and the extra costs the food industry said it was incurring due to following
   the EC Guidance, the Agency has decided to issue its own guidance,
   which it believes is the most appropriate guidance for food businesses in
   the UK.

Rationale for Government Intervention

10. In the responses to the consultation in July 2005, some stakeholders
    commented that following the best practice recommendations in the EC
    Guidance would incur substantial costs due to the length of time records
    should be kept and unnecessary burdens resulting from the need to
    produce traceability records immediately on demand. These
    recommendations are not specified in the legislation itself.

11. The new FSA Guidance Notes address these concerns and include

    •   greater discretion to food businesses over time requirements for
        keeping traceability records;

    •   changing the need for immediate production of traceability records in
        certain cases to a need to produce these within “a short timescale”;
        and

    •   concentrating on the requirements of the legislation and providing
        minimal advice on good practice.

12. The overall aim is to have informative and accurate guidance on the
    Regulation, so that the public health protection offered by the Regulation is
    achieved without imposing disproportionate burdens on either business or
    enforcers.


CONSULTATION

•   Within Government



                                       21
13. The Agency is consulting with the Cabinet Office, the Small Business
    Service, the Department for Environment, Food and Rural Affairs and the
    Department of Trade and Industry. The Agency has also consulted the
    European Commission on the status of the EC Guidance.

•   Public Consultation

14. There was extensive public consultation during the negotiations on the
    Regulation in 2001. This was followed by a public consultation on
    domestic enforcing legislation and FSA Guidance Notes, which took place
    in August 2004. Regulatory Impact Assessments were produced for both
    of these consultation exercises, which concluded that the cost implications
    of complying with the Regulation would not be significant (as it reflected
    existing business practice).

15. Revised FSA Guidance Notes, incorporating the EC Guidance on Articles
    11, 12 and 16-20 of the Regulation, were widely circulated to stakeholders,
    including industry groups, on 10 March 2005. In addition, they were placed
    on the Agency’s website.

16. In July 2005 a public consultation was carried out on the EC Guidance to
    Articles 11, 12 and 16-20 of the Regulation to inform the Agency’s
    negotiating position on an EC review of the Guidance. Replies to the
    consultation indicated that there were significant costs to food business
    operators arising from the EC Guidance, primarily owing to suggested best
    practice on traceability, not legally required under Article 18 of the
    Regulation.

17. This consultation seeks views on the cost impact of implementing the new
    FSA Guidance Notes as the most appropriate guidance for food
    businesses in the UK.


OPTIONS

18. Two options have been considered:

Option 1

19. Do nothing. Do not introduce new FSA Guidance Notes on the Regulation.
    The current EC Guidance would remain as the primary advice on
    compliance with legal requirements.

Option 2

20. Introduce new FSA Guidance Notes on the Regulation as the most
    appropriate guidance for food businesses in the UK on Articles 14-16 and
    18-20.




                                      22
COSTS AND BENEFITS

Sectors and groups affected

21. All food businesses (including small businesses); voluntary organisations
    and charities that fall under the definition of a “food business” in Article 2 of
    the Regulation; and local authorities. There are approximately 346,000
    food businesses in the UK.

22. The British Retail Consortium estimated in 2006 that complying with the
    EC Guidance would require major retailers to develop new IT systems,
    generating a one-off cost of £37m, as well as maintenance costs of £19m
    over five years. Those estimates relate to the 15 largest food retailers,
    which account for more than 85% of all food sales in the UK.

23. The cross-Government Administrative Burden Measurement Exercise
    conducted in 2005 estimated the administrative burden for all food
    businesses to comply with the EC Guidance to be £16 million annually.
    This does not include the burden incurred by business in complying with
    the legal requirements of the Regulation.

Benefits

24. Option 1: Food businesses would not have to change practices adopted in
    order to follow the EC guidance.

25. Option 2: The new FSA Guidance Notes remove the additional burdens
    resulting from the recommendations of the EC guidance, which will lead to
    a decrease in the administrative burden borne by food businesses. The
    results of previous consultations on the Regulation and the associated
    domestic General Food Regulations 2004 suggest that the new FSA
    Guidance Notes would not impose costs on businesses in excess of what
    they incur during their normal course of operation. It is therefore estimated
    that the introduction of the new FSA Guidance Notes would remove the
    majority of the administrative burden created by following the EC
    Guidance, identified as £16 million annually in the Administrative Burden
    Measurement Exercise .

26. In addition, the new FSA Guidance Notes are more concise than the EC
    Guidance and help to clarify the requirements of the Regulation. They
    should be easier for food business operators and others who work with
    food to follow.

27. The new FSA Guidance Notes ask businesses to judge for themselves
    how long it is necessary to keep traceability records (to ensure they can
    comply with Article 19 should action be necessary), rather than the 5 years
    in most cases recommended in the EC Guidance. For large retailers,
    these savings are likely to be negligible as the records are kept


                                         23
   electronically, but for the majority of food businesses that keep paper
   records, the benefit could be substantial. Evidence received in response to
   last year’s consultation on the EC Guidance suggests that the benefit from
   having to store records for periods of less than five years could be £14,000
   per year for a typical food manufacturer. Another food company with 300
   workers reported that the requirement to keep records for three years
   would force them to build suitable storage facilities at a cost of £15-20,000.

28. The removal of the need to supply traceability information immediately,
    where the severity of the incident does not justify it, will mean that the
    requirement becomes more proportionate in these cases.

Costs

29. Option 1: There would still be the estimated cost of £16 million annually to
    food businesses from following the best practice recommendations in the
    EC Guidance.

30. Option 2: The new Agency Guidance Notes are less stringent than the EC
    Guidance, and any costs should be “business as usual” costs only.
    Previous RIAs support that view, indicating that the costs of compliance
    with the requirements of the Regulation would not be significant.

31. There will, however, be a one-off additional cost of reading and
    understanding the new FSA Guidance Notes. Assuming that it takes 30
    minutes for a manager to complete that task, and relying on the wage
    rates and overheads used in the Administrative Burden Measurement
    Exercise, that cost is estimated to be worth £3.65 million.

32. If you can identify aspects of the new FSA Guidance Notes that incur
    additional costs for your business, please specify what these will be, on an
    annual basis, and provide examples.

Administrative burden of keeping traceability records

33. The Regulation does not specify the time period for keeping traceability
    records. The Commission’s best practice guidance suggested that for
    most products records should be kept for a minimum of five years.
    Responses to the consultation exercise on the EC Guidance indicated that
    this was unnecessary and would result in disproportionate cost for food
    businesses. This was confirmed by the Administrative Burdens
    Measurement Exercise. The new FSA Guidance Notes say that it is for
    businesses to decide how long they should keep their records, bearing in
    mind the business risks that would be posed by the unavailability of
    records that would be required should a withdrawal/recall notification of
    unsafe food be necessary.

34. The EC Guidance classifies traceability information in two categories, the
    first to meet the legal requirements and the second to be followed as best
    practice. Responses from food businesses to the consultation exercise on


                                       24
   the EC Guidance indicated that following such best practice guidance
   could result in additional costs. The new FSA Guidance Notes therefore
   focus primarily on the legal requirements. We believe that the new FSA
   Guidance Notes would not impose any administrative costs to
   business that they do not already incur through the normal course of
   business. We would welcome comments on this. (Please do not
   include costs that result from complying with the legal requirements
   of the Regulation).


CONSULTATION WITH SMALL BUSINESSES: THE SMALL FIRMS
IMPACT TEST

35. Small businesses may find it less of a burden not to have to produce
    traceability records immediately, and are likely to find the more concise
    nature of the Guidance Notes helpful in understanding the requirements.
    Conversely, it is possible that modification of record-keeping systems to
    accommodate the FSA Guidance Notes would impose a one-off cost that
    would be easier to bear by larger businesses. However, given that the
    requirements of the Guidance Notes are not as stringent as those of the
    EC Guidance, we consider it likely that companies could keep their
    existing record-keeping systems and there is therefore no reason to
    believe that the Guidance Notes might put small businesses at a
    disadvantage.

COMPETITION ASSESSMENT

36. The introduction of the new FSA Guidance Notes is not anticipated to have
    any significant impact on competition in the food sector.


ENFORCEMENT, SANCTIONS AND MONITORING

37. The FSA Guidance Notes are not legally enforceable. However, any
    person who contravenes or fails to comply with any of Articles 14(1), 16 in
    so far as it relates to food, 18(2) and 18(3) in so far as they relate to food
    business operators and Article 19 of the Regulation is guilty of an offence
    under the General Food Regulations 2004 (as amended), and the
    Guidance Notes might be used by courts in their interpretation of the
    Regulation. Local authorities will use the provisions of the Agency
    Guidance Notes when inspecting premises.

38. A review of the impact of the new FSA Guidance Notes will be conducted
    within 2 years of publication.


                     SUMMARY AND RECOMMENDATION

39. To be added following the consultation.



                                        25
MINISTERIAL DECLARATION

40. To be added following the consultation.

Contact Point

Name:        Bill Drennan
E-mail:      guidance@foodstandards.gsi.gov.uk
Division:    Consumer Choice, Food Standards and Special Projects
             Division
Address:     Room 115B, Aviation House, 125 Kingsway, London WC2B
             6NH
Telephone:   020 7276 8138
Date:        30 October 2006




                                      26
INTERESTED PARTIES

1990 TRUST (THE)                          ANIMAL HEALTH TRUST
3663                                      ANIMAL MEDICINES INSPECTORATE
4 CHILDREN                                ANIMAL TRANSPORTATION ASSOCIATION
4 THE FORUM                               ANNE THURLOW
A H ALLEN & PARTNERS                      ANZFA
A POORTMAN (LONDON) LTD                   APAG
A WATSON & CO LTD                         APARTADO DE CORREOS 129
ABBEY VETERINARY GROUP                    APLIN AND BARRETT LTD
ABBOTT LABORATORIES LTD                   AQUINAS COLLEGE
ACACIA FOODS LTD                          ARABIAN SEAFISH UK LTD
ACADEMY OF CULINARY ARTS                  ARAS SERVICES
ACORN FEED PRODUCTS LTD                   ARKARIUS LIMITED
ACTION ON SMOKING AND HEALTH (ASH)        ARMITAGE BROS PLC
ADAS GLEADTHORPE                          ASDA STORES LTD
ADAS HOLDINGS LIMITED                     ASHURST MORRIS CRISP
ADM                                       ASHWELL ASSOCIATES
ADVERTISING ASSOCIATION                   ASSOC OF BRITISH PHARMACEUTICAL
ADVERTISING STANDARDS AUTHORITY           INDUSTRIES
ADVOCACY LTD                              ASSOC OF CEREAL FOOD MANUFACTURERS
AFC / COMMITTEE BRITISH STANDARDS         ASSOC OF MALT PRODUCTS
INSTITUTION                               MANUFACTURERS
AGRI-EUROPE                               ASSOC OF PUBLIC ANALYSTS OF SCOTLAND
AGRICULTURAL & ALLIED WORKERS             ASSOC. FOR IMPROVEMENTS IN MATERNITY
AGRICULTURAL AND FOOD RESEARCH            ASSOCIATE PARLIAMENTARY FOOD AND
COUNCIL                                   HEALTH FORUM
AGRICULTURE & COUNTRYSIDE BOARD           ASSOCIATED BRITISH FOODS PLC
AIC (AGRICULTURAL INDUSTRIES              ASSOCIATED BRITISH NUTRITION
CONFEDERATION)                            ASSOCIATION OF CONVENIENCE STORES
AIR CARGO ADVISORY SERVICES               (ACS)
AIRLINE OPERATORS COMMITTEE CARGO         ASSOCIATION FOR CONSUMER RESEARCH
AL NEMEH FOOD INDUSTRYS CO LTD            ASSOCIATION FOR PUBLIC HEALTH
ALAN TURNER CONSULTANCY                   ASSOCIATION OF AGRICULTURAL
ALCONTROL LABORATORIES                    EDUCATIONAL STAFF
ALFA CHEMICALS                            ASSOCIATION OF BAKERY INGREDIENTS
ALLERGY ALLIANCE                          MANUFACTURERS
ALLIED BAKERIES LTD                       ASSOCIATION OF BREAST FEEDING
ALLIED BREWERIES LTD                      MOTHERS
ALLIED BREWERY TRADERS ASSOCIATION        ASSOCIATION OF BRITISH ABATTIOR
ALLIED DOMECQ                             OWNERS
ALLIED MEAT IMPORTERS LTD                 ASSOCIATION OF BRITISH CHAMBERS OF
ALLSPORTS INTERNATIONAL LTD               COMMERCE
ALPHAMAX LTD                              ASSOCIATION OF BRITISH HEALTH CARE
ALSTEAD                                   INDUSTRIES
AMERICAN PEANUT COUNCIL                   ASSOCIATION OF BRITISH SALTED FISH
AMICUS                                    CURERS AND EXPORTERS
ANDREW SMITH                              ASSOCIATION OF BUTTER AND CHEESE
ANGLO-SCOTTISH FISH PRODUCERS'            PACKERS
ORGANISATION LTD                          ASSOCIATION OF CEREAL FOOD
ANIMAL AIRCARE                            MANUFACTURERS
ANIMAL HEALTH DISTRIBUTORS                ASSOCIATION OF CHEESE PROCESSORS
ASSOCIATION (UK) LTD                      ASSOCIATION OF FISH CANNERS
ANIMAL HEALTH TRADE ASSOCIATION


                                     27
ASSOCIATION OF INDEPENDENT CROP        BELSO'S (UK) CEREALS LTD.
CONSULTANTS                            BERNARD MATTHEWS FOODS LTD
ASSOCIATION OF LICENSED MULTIPLE       BERRY EMBRYOS
RETAILERS                              BERRY OTTAWAY AND ASSOCIATES LTD
ASSOCIATION OF LIVESTOCK EXPORTERS     BERRYSTOCK FEEDING CO
ASSOCIATION OF LONDON AUTHORITIES      BEST FOODS UK LTD
ASSOCIATION OF LONDON CHIEF            BESTWAY CASH AND CARRY LTD
ENVIRONMENTAL HEALTH OFFICERS          BEVAN ASHFORD (LIBARIAN)
ASSOCIATION OF LONDON CHIEF HEALTH     BIBRA INTERNATIONAL
OFFICERS                               BICODE LTD
ASSOCIATION OF LONDON GOVERNMENT       BIDEFORD TRAWLERMEN'S CO-OPERATIVE
ASSOCIATION OF MEAT INSPECTORS         LTD
ASSOCIATION OF MEDICAL                 BIOWHITTAKER UK
MICROBIOLOGISTS                        BIRD AND BIRD
ASSOCIATION OF PORT HEALTH             BIRD FOOD STANDARDS ASSOCIATION
AUTHORITIES                            BIRDS EYE FOODS LTD
ASSOCIATION OF PRIVATE MARKET          BIRMINGHAM CITY COUNCIL
OPERATORS                              BIRMINGHAM CITY LABORATORIES
ASSOCIATION OF PUBLIC ANALYSTS         BIRMINGHAM LIBRARY SERVICES
ASSOCIATION OF RADICAL MIDWIVES        BISCUIT CAKE CHOCOLATE &
ASSOCIATION OF SCOTTISH SHELLFISH      CONFECTIONARY ALLIANCE
GROWERS                                BISHOP BURTON COLLEGE OF AGRICULTURE
ASSOCIATION OF SEA FISHERIES           BLYTH BOROUGH COUNCIL
COMMITTEES OF ENGLAND AND WALES        BMMA
ASSOCIATION OF UNPASTEURISED MILK      BOLTON MBC
PRODUCERS AND CONSUMERS                BONGRAIN UK LTD
ASSOCIATION OF VETERINARIANS IN        BONNIA PETITE BANQUETING LTD
INDUSTRY                               BOOKER CASH & CARRY
ASSOCIATION OF VETERINARY SALES        BOOTS COMPANY PLC
MANAGERS                               BORDER SHEEPSKIN LIMITED
ATLANTIC BAR AND GRILL                 BOURNE SALADS
ATLANTIC CONTAINER LINE UK LTD         BOURNE STIR FRY
AUSTRALIAN EMBASSY                     BOWYERS (WILTSHIRE) LTD
AUSTRALIAN HIGH COMMISSION             BRAVE BROS FOODSERV LTD
AUTOMATIC VENDING ASSOCIATION OF       BRETBY ANALYTICAL CONSULTANTS LTD
GREAT BRITAIN                          BREWING RESEARCH INT
AVON GLOS AND SOMERSET ENVIR MONIT     BRIDGE FARM DAIRIES LTD
COMM                                   BRITISH ASSOCIATION
AYLESBURY VALE COMMUNITY HEALTHCARE    BRITISH CHEESE BOARD
BABY MILK ACTION GROUP                 BRITISH ALPACA SOCIETY
BAKERY AND ALLIED TRADES ASSOCIATION   BRITISH ANGORA GOAT SOCIETY
BARBER INDEX                           BRITISH ASSOCIATION OF CANNED &
BARBOUR INDEX PLC                      PRESERVED FOOD
BARNARD AND GOODING GOAT'S MILK LTD    BRITISH ASSOCIATION OF FEED
BARNET COUNCIL                         SUPPLEMENT AND ADDITIVE
BAYER PLC                              MANUFACTURERS LTD
BBC GOOD FOOD MAGAZINE                 BRITISH ASSOCIATION OF PLANT BREEDERS
BBC REFERENCE LIBRARY                  BRITISH BAKERS LTD
BBSRC                                  BRITISH BISON ASSOCIATION
BCVA                                   BRITISH BROSH MAKERS ASSOCIATION
BEDFORD BUSINESS CENTRE                BRITISH CARAMEL MANUFACTURERS ASSOC
BEE SERVICES                           BRITISH CATTLE VETERINARY ASSOCIATION
BEE FARMERS ASSOCIATION OF THE UK      BRITISH COFFEE ASSOSCIATION
BELASCO T/A SASSCO                     BRITISH COMPRESSED GASSES
BELL DAVIE                             ASSOCIATION


                                  28
BRITISH CONFECTIONERS ASSOCIATION       BRITISH SUGAR REFINERS ASSOCIATION
BRITISH DENTAL ASSOC                    BRITISH TROUT ASSOCIATION
BRITISH DIABETIC ASSOCIATION            BRITISH UNITED TURKEYS LTD
BRITISH EGG INDUSTRY COUNCIL            BRITISH VETERINARY ASSOCIATION
BRITISH EGG PRODUCTS ASSOCIATION        BRITISH WILD BOAR ASSOCIATION
BRITISH ESSENCE MANUFACTURERS           BRITVIC LTD.
ASSOCIATION                             BRIXHAM TRAWLER OWNER'S ASSOCIATION
BRITISH ESSENTIAL OILS ASSOC            BROADLAND FOODS LTD
BRITISH FARMERS DEER ASSOCIATION        BUCKINGHAMSHIRE HEALTH AUTHORITY
BRITISH FEATHER CO LTD                  BURGER KING LTD
BRITISH FERMENTATION PRODUCTS           BURGES SALMON SOLICITORS
BRITISH FISHERMEN'S ASSOCIATION         BURGESS SUPAFEEDS
BRITISH FOOD MANUFACTURING INDUSTRIES BURY TRADING STANDARDS DEPT
RESEARCH ASSOCIATION                    BUSH BOAKE ALLEN LTD
BRITISH FREE RANGE EGG PRODUCERS        BUSINESS IN SPORT AND LEISURE
ASSOCIATION.                            BUTCHERS HALL
BRITISH FROZEN FOOD FEDERATION          C L AUDITING SERVICES
BRITISH FRUIT & VEGETABLE               C/O FOOD AND DRINK INDUSTRY DIVISION
MANUFACTURES ASSOCIATION                CADBURY SCHWEPPES PLC
BRITISH FUR ASSOCIATION                 CALYMPEX LTD
BRITISH GOAT SOCIETY                    CAMBRIDGE MANUFACTURING COMPANY
BRITISH HERBAL MEDICINE ASSOCIATION     LTD
BRITISH HIGH COMMISSION                 CAMERON MCKENNA
BRITISH HONEY IMPORTERS AND PACKERS CAMPBELLS
ASSOCIATION                             CAMPDEN FOOD AND DRINK RESEARCH
BRITISH HOSPITALITY ASSOCIATION         ASSOCIATION
BRITISH INDEPENDENT GROCERS             CAMRA (CAMPAIGN FOR REAL ALE LTD)
ASSOCIATION                             CANFIELDS FARM
BRITISH INSTITUTE OF AGRICULTURE        CAPTIVA BRANDS INT.
CONSULTANTS                             CARDINAL HEALTH
BRITISH INSTITUTE OF INNKEEPING         CARVER WILDE COMMUNICATIONS
BRITISH LEATHER CONFEDERATION           CASELLA
BRITISH MARINE FINFISH ASSOCIATION      CASELLA GMSS LTD
BRITISH MEAT FEDERATION                 CATERER AND HOTEL KEEPER MAGAZINE
BRITISH MEDICAL ASSOCIATION             CATERERS MARKETING AND ADVISORY
BRITISH NUTRITION FOUNDATION            SERVICE
BRITISH PASTA PRODUCTS ASSOCIATION      CATERING EQUIPMENT MANUFACTURERS
BRITISH PEPPER AND SPICE                ASSOCIATION
BRITISH PEST CONTROL ASSOCIATION        CATERING EQUIPMENT SUPPLIERS ASSOC
BRITISH PIG ASSOCIATION                 CATERING UPDATE
BRITISH PORT ASSOCIATION                CATHAY PACIFIC AIRWAYS
BRITISH POTATO COUNCIL                  CATTLE TECH LTD
BRITISH POULTRY COUNCIL                 CBI SMALL AND MEDIUM ENTERPRISE
BRITISH REFRIGERATION ASSOCIATION       COUNCIL
BRITISH REGULATORY AFFAIRS              CELCAA
BRITISH RETAIL CONSORTIUM (BRC)         CENTRAL LIBRARY
BRITISH RICE ASSOCIATION                CENTRAL MIDDLESEX HOSPITAL
BRITISH SANDWICH ASSOCIATION            CENTRAL PUBLIC HEALTH LABORATORY
BRITISH SOCIETY OF ANIMAL PRODUCTION    CENTRAL SCIENTIFIC LABOATORIES
BRITISH SOCIETY OF PAEDIATRIC DENTISTRY CENTURA FOODS
BRITISH SOFT DRINKS ASSOCIATION         CEREAL INGREDIENTS MANUFACTURERS
BRITISH SOLUBLE COFFEE PARKERS AND      ASSOCIATION
IMPORTERS ASSOCIATION                   CEREAL PARTNERS WORLDWIDE
BRITISH STARCH INDUSTRY ASSOCIATION     CHAMBER OF SHIPPING
BRITISH SUGAR PLC                       CHANNEL 4


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CHARTERED INSTITUTE OF ENVIRONMENTAL   COUNCIL FOR THE PROTECTION OF RURAL
HEALTH                                 ENGLAND
CHEMICAL & FEEDS LTD                   COUNSEL LTD
CHEMIST & DRUGGIST                     COUNTRY HARVEST NATURAL FOODS LTD
CHERRY VALLEY FARMS LTD                COUNTRY LANDOWNERS ASSOCIATION
CHEW VALLEY HIDE & SKIN CO LTD         COUNTRY LANDOWNERS AND BUSINESS
CHILD ACTION PREVENTION TRUST          ASSOCIATION
CHILDREN'S SOCIETY                     COURAGE LTD
CHILLED FOOD ASSOCIATION               COVENT GARDEN MARKET AUTHORITY
CHITTY WHOLESALE LTD                   COVENTRY HEALTH AUTHORITY
CHRISTIAN AID                          COVINGTON & BURLING
CHRISTIAN SALVESEN LTD                 CP KELCO UK LTD
CIAA                                   CRAB PROCESSORS' ASSOCIATION
CITES TEAM, HM CUSTOMS & EXCISE        CRAIG WHITEHOUSE CONSULTANCY
CITY OF LONDON                         SERVICES
CITY OF YORK COUNCIL                   CRANSWICK MILL LTD
CIVIC CATERING ASSOCIATION             CREAMERY PROPRIETORS ASSOCIATION
CLIFFORD CHANCE                        CROCODILE CREEK
CMA UK                                 CRODA COLLOIDS LTD
CO-OPERATIVE GROUP                     CROMARTY FIRTH PORT AUTHORITY
CO-OPERATIVE UNION LTD                 CROP PROTECTION ASSOCIATION
CO-OPERATIVE WOMENS GUILD              CROWN CHICKEN LTD
COCA COLA GREATER EUROPE               CUMBERLAND COUNTY COUNCIL
CODE MONITORING COMMITTEE              CUMBRIA COUNTY COUNCIL
COELIAC UK (LTD)                       CUSSONS UK LTD
COFFEE TRADE FEDERATION (THE)          CUSTOM PHARMACEUTICALS LTD
COLD STORAGE AND DISTRIBUTION          DAILY MAIL
FEDERATION                             DAIRY CREST LTD
COLIN SHEPHERD MP                      DAIRY INDUSTRY ASSOCIATION LTD
COMMITTEE OF ADVERTISING PRACTICE      DAIRY INDUSTRY FEDERATION LTD
COMMUNITY AND PRIORITY CARE SERVICES   DAIRY INGREDIENTS (UK) LTD
COMMUNITY FOODS LTD                    DAIRY TRADE FEDERATION
COMMUNITY NUTRITION GROUP              DALEGETY PRODUCE
COMPASSION IN WORLD FARMING            DALEHEAD FOODS LTD
CONFEDERATION OF BRITISH INDUSTRY      DANISH BACON COMPANY PLC
CONFEDERATION OF BRITISH WOOL          DANISH EMBASSY
TEXTILES LTD                           DARLINGTON CATTLE BREEDING CENTRE
CONSORTIUM OF CATERERS &               DAVID T BOYD
ADMINISTRATORS (IN EDUCATION)          DAVTECH
CONSULTANT NUTRITIONIST & DIETITIAN    DAWN FOODS LTD
CONSUMERS FOR HEALTH CHOICE            DAWNFRESH FOODS
CONSUMERS' ASSOCIATION                 DAYLA SOFT DRINKS LTD
CONTINENTAL FOOD SUPPLIES LTD          DAYLAY FOODS LIMITED
CONTINENTAL PASTAS LTD                 DEBENHAMS PLC
CONTINENTAL WINE EXPERTS LTD           DECHERT
CONTRACT FOODS LTD                     DECLERCQ TRADING
CORNISH FISH PRODUCERS' ORGANISATION   DEFENCE CATERING GROUP
LTD                                    DEFRA
CORNISH GUILD OF SMALLHOLDERS          DEFRA - BASD
CORNWALL COUNTY COUNCIL                DEFRA - CPU
CORNWALL INSHORE FISHERMEN'S           DEFRA- EUROPEAN UNION INTERNATIONAL
FEDERATION                             DEFRA-FDID A, FMI BRANCH
CORNWALL SEA FISHERIES COMMITTEE       DEL MONTE FOODS (UK) LTD
COUNCIL FOR RESPONSIBLE NUTRITION      DELBANCO MEYER & CO LTD



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DEPARTMENT FOR CULTURE MEDIA AND            EUROCOMMERCE
SPORT                                       EUROFINS SCIENTIFIC LTD
DEPARTMENT FOR INTERNATIONAL                EUROPA FOODS LTD
DEVELOPMENT                                 EUROPEAN CATERERS ASSOCIATION
DEPARTMENT OF AGRICULTURE AND               EUROPEAN CEREAL INGREDIENTS
FISHERIES                                   ASSOCIATION
DEPARTMENT OF HEALTH                        EUROPEAN FEDERATION OF HONEY
DEPARTMENT OF LOCAL GOVERNMENT &            PACKERS AND DISTRIBUTORS
THE ENVIRONMENT                             EUROPEAN FOOD LAW ASSOCIATION (UK
DEPARTMENT OF TRADING STANDARDS             SECTION)
DEPT OF AGRICULTURE FOR NI                  EUROPEAN MODERN RESTAURANT
DEPT OF CLINICAL VETERINARY MEDICINE        ASSOCIATION
DEPT. OF FOOD SCIENCE & TECHNOLOGY          EUROPEAN MOLASSES IMPORTERS & DIST
DESIGN AND TECHNOLOGY ASSOCIATION           ASSOC
(DATA)                                      EUROPEAN PUBLIC POLICY ADVISORS UK
DESSERT & CAKE MIXES ASSOCIATION            LTD
DEVON DIRECT SERVICES CATERERS              EUROPEAN SPICE ASSOCIATION
DEVON SEA FISHERIES COMMITTEE               EUROPEAN UNION OF WHOLESALE WITH
DHSS/NI                                     EGGS, EGG PRODUCTS, POULTRY AND GAME
DIABETES UK                                 (EUWEP)
DIETETIC DEPARTMENT                         EUROWAY ASSOCIATES LTD
DIETICIAN'S DEPARTMENT                      EVERSHEDS
DIMERCO EXPRESS (UK) LTD                    EVILLE & JONES V.F.H.
DIRECT SELLERS CO-OPERATIVE LTD             EXETER TRAWLERMEN'S ASSOCIATION
DOANE PET CARE UK                           F GUTKIND & COMPANY
DOMESTIC FOWL TRUST                         F HOFFMAN - LA ROCHE LTD
DOVER HARBOUR BOARD                         FACULTY OF PUBLIC HEALTH MEDICINE
DOVER PORT HEALTH                           FACULTY OF THE ENVIRONMENT
DOW CORNING COORDINATION CENTER             FAMILY FARMERS ASSOCIATION
DRUCES AND ATTLEE                           FARM AND FOOD SOCIETY
DTI, CONSUMER AFFAIRS C                     FARM RETAIL ASSOCIATION
DUGDALE NUTRITION LTD                       FARMHOUSE CHEESEMAKERS LTD
DUNN NUTRITION LABORATORY                   FAYRE OAKS LTD
DURHAM COUNTY COUNCIL                       FDB DISTRIBUTION LTD
E BOTHAM & SON LTD                          FDF SERVICES
E SLINGER & SONS LTD                        FED OF OILS SEEDS AND FATS ASSOC
EALING TRADING STANDARDS                    (FOSFA)
EAST DEVON FISHERMEN'S ASSOCIATION          FEDERATION OF BRITISH PORT WHOLESALE
EAST MIDLANDS AIRPORT                       FISH MERCHANTS' ASSOCIATION
EASTERN SEA FISHERIES COMMITTEE             FEDERATION OF AGRICULTURAL CO-
EDLONG COMPANY LTD (THE)                    OPERATIVES
EDWARD PAUL & CO (GROCERS) LTD              FEDERATION OF CITY FARMS AND
ELLIOTT AND COMPANY                         COMMUNITY GARDENS
EM CONSULTANTS                              FEDERATION OF DANISH PIG PRODUCERS
EMA CARGO WEST                              AND SLAUGHTERHOUSES
ENDS                                        FEDERATION OF FRESH MEAT
ENVIRONMENT AGENCY                          WHOLESALERS
ENVIRONMENTAL HEALTH BRIEFING               FEDERATION OF MILK GROUPS (UK)
ENVIRONMENTAL SERVICES                      FEDERATION OF OILS, SEEDS & FATS
ENVIRONSAFE LIMITED                         ASSOCIATION LTD
ESSENTIAL TRADING CO-OPERATIVE LTD          FEDERATION OF SMALL BUSINESSES
ETHICAL CONSUMER RESEARCH                   FEDERATION OF SYNAGOGUES
ASSOCIATION                                 FEDERATION OF WHOLESALE DISTRIBUTORS
EURO COOP                                   FEED FAT ASSOCIATION
EURO ENVIRONMENTAL CONTAINERS               FERRERO UK LTD


                                       31
FI DATA SERVICES                        FRESH PRODUCE CONSORTIUM (UK)
FIBRISOL SERVICE LTD                    FRIENDS OF THE EARTH UK LTD
FINDUS LTD                              FROMAGES DE FRANCE LTD
FISHER CHILLED FOODS LTD                FROZEN & CHILLED POTATO PROCESSERS
FISHERMANS FEATHERS                     ASSOCIATION
FISHERMENS' FEDERATION OF               FRUIT & VEGETABLE CANNERS ASSOCIATION
NORTHUMBERLAND                          FRUIT IMPORTERS ASSOCIATION
FISHMONGERS COMPANY                     FRUIT PREPARATION MANUFACTURERS
FLEETWOOD FISH PRODUCERS'               ASSOCIATION
ORGANISATION LTD                        FSA - MSN
FLOOR 1W                                FSA ANF
FMF-CODE MONITORING COMMITTEE           FSA FLSCPD 'C'
FOLKESTONE FISHERMEN'S ASSOCIATION      FSA NORTHERN IRELAND
FOOD & HEALTH RESEARCH                  G R LANE HEALTH PRODUCTS LTD
FOOD ADDITIVES AND INGREDIENTS          G R MICRO LTD
ASSOCIATION                             G'S MARKETING LTD
FOOD ADDITIVES INDUSTRY ASSOCIATION     GAME CONSERVANCY TRUST
LIMITED                                 GARDNER MERCHANT
FOOD AND DRINK FEDERATION               GATEGOURMET LONDON
FOOD AND DRINK INDUSTRY DIVISION        GEEST PLC
FOOD BRAND GROUP (THE)                  GENERAL CONSUMER COUNCIL FOR
FOOD BRANDS GROUP                       NORTHERN IRELAND
FOOD BROKERS LTD                        GENERAL DIETARY LTD
FOOD CASINGS ASSOCIATION                GENERAL MANAGER-OPERATIONS
FOOD CERTIFICATION INTERNATIONAL LTD    GEOGE ADAMS & SON (HOLDINGS) LTD
FOOD COMMISSION                         GEOLOGISTICS LTD
FOOD ETHICS COUNCIL                     GEORGE HARKER AND COMPANY LTD
FOOD FROM BRITAIN                       GERARD J HOMAN LTD
FOOD INGREDIENTS BUREAU                 GERBER FOODS/SOFT DRINKS LTD
FOOD LABELLING AGENDA                   GHR FOODS LTD
FOOD LABELLING AND STANDARDS            GILBERT KOSHER FOOD
FOOD MANUFACTURERS FEDERATION           GILBERTSON & PAGE LTD
FOOD POLICY RESEARCH UNIT               GIN AND VODKA ASSOCIATION OF GREAT
FOOD POLICY UPDATE                      BRITAIN
FOOD REGULATORY AFFAIRS CONSULTING      GIRACT
LTD                                     GIRAG SA
FOOD SAFETY TRAINING SERVICES           GLENRYK (UK) LTD
FOOD STANDARDS AGENCY (SCOTLAND)        GLOUCESTERSHIRE COUNTY COUNCIL
FOOD TRANSPORT CAMPAIGN                 GOAT ADVISORY BUREAU
FOODAWARE                               GOAT VETERINARY SOCIETY
FOODFEN                                 GOAT'S MILK PROCESSORS FEDERATION
FOODS CASINGS ASSOCIATION               GOLD CROWN FOODS LTD
FORUM OF PRIVATE BUSINESS               GOLD LINE FEEDS LTD
FORUM PRODUCTS                          GOLDEN ACRES LTD
FOSFA INTERNATIONAL LIMITED             GOOD HOUSEKEEPING MAGAZINE
FPMA                                    GOODMAN DERRICK
FPS INTERNATIONAL                       GORDON CONRAD LTD
FR BENSON & PARTNERS LTD37942           GOSPORT COMMERCIAL FISHERMEN'S
FRAMPTONS LTD                           ASSOCIATION
FREEDOM FOODS                           GRAIG FARM ORGANICS
FREELANCE DIETITIAN AND CONSULTANT TO   GRAIN & TRADE FEED TRADE ASSOCIATION
APRO UK LTD                             GREAT YARMOUTH MEDITERRANEAN
FREIGHT TRANSPORT ASSOCIATION           HERRING EXPORTERS' ASSOCIATION
FRESH FRUIT & VEGETABLE INFORMATION     GRIMSBY FISH DOCK ENTERPRISES LTD
BUREAU                                  GRIMSBY FISH MERCHANTS ASSOCIATION


                                   32
GRIMSBY FISH PRODUCERS' ORGANISATION HUNTINGDON LIFE SCIENCES
LTD                                   HUSH
GRIMSBY FISHING VESSEL OWNERS'        HYGIENE AND NUTRITION IN FOOD SERVICE
ASSOCIATION                           I B FOOD MARKETING LTD
GRIMSBY SEINERS' ASSOCIATION LTD      IAN ROSS ASSOCIATES
GUILDHAY LTD                          IBP INTERNATIONAL INC EUROPE
H M PRISON SERVICE CATERING GROUP     ICE CREAM ALLIANCE LTD
H T WEBB AND CO LTD                   ICE CREAM FEDERATION
HACKNEY LONDON BOROUGH OF             ICEBRIT LTD
HAFOD                                 ICM MARKETING LTD
HALAL FOOD AUTHORITY                  ILS LTD
HALDANE FOODS GROUP                   INDEPENDENT FOOD RETAILERS
HAMPSHIRE SCIENTIFIC SERVICE          CONFEDERATION
HARINGAY LONDON BOROUGH OF            INDEPENDENT TELEVISION COMMISSION
HARRIS ASSOCIATES LTD                 INFANT & DIETETIC FOOD ASSOCIATION
HARRISON GMBH                         INFORMATION CENTRE TRADING
HARRODS OCCUPATIONAL HEALTH & SAFETY STANDARDS INSTITUTE
DEPT                                  INSTITUTE OF AGRICULTURAL MEDICINE
HARTWELL FOOD RESEARCH LTD            INSTITUTE OF ARABLE CROPS RESEARCH
HARVEY FOODS LTD                      INSTITUTE OF CONSUMER SCIENCES
HARWICH FISHERMANS' ASSOCIATION       INSTITUTE OF FISHERIES MANAGEMENT
HASSAS (LONDON) LTD                   INSTITUTE OF FOOD RESEARCH
HCIMA                                 INSTITUTE OF FOOD SCIENCE AND
HEAD OF FOOD SCIENCE                  TECHNOLOGY
HEALAN INGREDIENTS LTD                INSTITUTE OF GROCERY DISTRIBUTION
HEALTH DEVELOPMENT AGENCY             INSTITUTE OF MECHANICAL ENGINEERS
HEALTH EDUCATION AUTHORITY            INSTITUTE OF PRACTITIONERS IN ADVERTIS
HEALTH HYGIENE & SAFETY CONSUTANCY    INSTITUTE OF PROFESSIONALS, MANAGERS
HEALTH VISITORS ASSOCIATION           AND SPECIALISTS
HEATHER PAINE ASSOCIATES              INSTITUTE OF REFRIGERATION
HENRY HIRST (PROVISIONS) LTD          INTERNATIONAL CENTER FOR HEALTH AND
HERBISON                              SOCIETY
HERTFORD FOODS LTD                    INTERNATIONAL FEDERATION OF ESSENTIAL
HILLSDOWN HOUSE                       OILS AND AROMA TRADES
HILLSIDE ORNAMENTAL WATERFOWL         INTERNATIONAL FISH MEAL AND OIL
HM CUSTOMS & EXCISE                   MANUFACTURERS ASSOCIATION
HOLCHEM LABORATORIES LTD              INTERNATIONAL FLIGHT CATERING
HOLLAND AND BARRETT                   INTERNATIONAL FOOD LINK LTD
HOLSTEIN UK                           INTERNATIONAL MEAT TRADE ASSOCIATION
HOME GROWN CEREALS AUTHORITY          INTERNATIONAL ROAD FREIGHT OFFICE
HONEY ASSOCIATION                     ISLE OF MAN FISH PROCESSORS'
HOSPITAL CATERERS ASSOCIATION         ASSOCIATION
HOTEL & CATERING INTERNATIONAL        ISLE OF MAN FISHERMEN'S ASSOCIATION
MANAGEMENT ASSOCIATION                ISLE OF SCILLY SEA FISHERIES COMMITTEE
HOTEL AND CATERING INSTITUTIONAL      J C GILBERT
MANAGEMENT ASSOC                      J SAINSBURY PLC
HOTREC                                J WHARTON (SHIPPING) LTD
HOUNSLOW (LONDON BOROUGH OF)          JAFFE
HOWARD LONG INTERNATIONAL             JAMES BUDGET SUGARS LTD
HP BULMER LTD                         JAMES BURDEN LTD
HP FOODS LTD                          JAMES GROVE & SONS LTD
HULL FISH MERCHANTS PROTECTION        JAMES HALL
ASSOCIATION                           JAMES PAGET HOSPITAL
HUMANE SLAUGHTER ASSOCIATION          JAMES ROBERTSON AND SONS LTD
HUMBERSIDE COUNTY SCIENTIFIC SERVICES JARDOX CONCENTRATED PRODUCTS LTD


                                    33
JAYTEE SEAFORDS LTD                     LAW COMMISSION
JC DUDLEY & CO LTD                      LAW LABORATORIES
JEFFORY DAVIES & DAVIES LTD             LAW LABORATORIES LTD
JESS SHIRLEY & SON LTD                  LAWCODE
JETRO (JAPAN TRADE CENTRE)              LAWDATA LTD
JG QUICKE & PARTNERS                    LBL (COOKED MEATS) LTD
JK FOODS UK                             LEATHERHEAD FOOD RESEARCH
JOHN & PASCALIS                         LEATHERHEAD FOOD RESEARCH
JOHN BIFFEN MP                          ASSOCIATION
JOHN DAVIES & CO                        LEE KUM KEE (HONG KONG) FOODS LIMITED
JOHN HALL (ANIMAL FEEDS) LTD            LEEDEX PUBLIC RELATIONS
JOHN HOGARTH LTD                        LEEDS AND DISTRICT FISH FRIERS'
JOHN LEWIS PARTNERSHIP                  ASSOCIATION
JOHN RUSSELL ASSOCIATES                 LEEDS CITY COUNCIL
JOHN SUTCLIFFE & SONS (GRIMSBY) LTD     LEICESTER CITY LIBRARIES
JOHN WEST FOODS LTD                     LEICESTERSHIRE COUNTY ANALYSTS LAB
JOHN WHARTON MEATS LTD                  LEICESTERSHIRE LIBRARIES AND
JOHN WYETH & BROTHER LTD                LEICS. COUNTY TRADING STANDARDS DEPT.
JOHNSON'S SEA ENTERPRISES               LEWIS SILKIN SOLICITORS
JOHNSTON CONSULTING                     LICENCED ANIMAL SLAUGHTERERS &
JOINT BREASTFEEDING INITIATIVE          SALVAGE ASSOCIATION
JOINT CONSULTATIVE COUNCIL FOR MEAT     LINKING ENVIRONMENT AND FARMING (LEAF)
TRADE                                   LINX PRINTING TECHNOLOGIES PLC
JOINT FOOD SERVICE INDUSTRY GROUP       LIQUID FOOD CARTON MANUFACTURERS
JOINT HOSPITALITY INDUSTRY CONGRESS     ASSOCIATION
JPG SERVICES                            LIVERPOOL CHAMBER OF COMMERCE AND
JPHP CONSULTANTS                        LIVERPOOL CITY COUNCIL
JRH BIOSCIENCES                         LIVERPOOL TRADING STANDARDS SERVICES
K J LOVERING & CO LTD                   LIVESTOCK & COMMISSION FOR N.I.
KARLSHAMNS LTD                          LIVESTOCK AUCTIONEERS ASSOCIATION
KATSOURIS BROS LTD                      LOCAL AUTHORITIES CO-ORDINATORS OF
KEDDER TRAINING                         REGULATORY SERVICES (LACORS)
KEITH ANDERSON SERVICES                 LOCAL AUTHORITY CATERERS ASSOCIATION
KELLOGG COMPANY OF GREAT BRITAIN LTD    LONDON BOROUGH OF BRENT
KENT AND ESSEX SEA FISHERIES            (ENVIRONMENTAL HEALTH)
COMMITTEE                               LONDON BOROUGH OF EALING
KEY COUNTRY FOODS LTD                   LONDON BOROUGH OF ENFIELD
KEYNOTE                                 LONDON BOROUGH OF HARROW
KIMPTON BROTHERS LTD                    LONDON BOROUGH OF HAVERING
KITCHEN RANGE FOODS LTD                 LONDON BOROUGH OF SOUTHWARK
KRAEBER (UK) LTD                        LONDON CENTRAL MARKETS
KRAFT FOODS INTERNATIONAL               LONDON CHAMBER OF COMMERCE AND
KRAFT JACOBS SUCHARD LTD                INDUSTRY
KWIK SAVE STORES LTD                    LONDON FOOD CO-ORDINATING GROUP
L B CROYDON FOOD TEAM                   LONDON FOOD STUDY GROUP
LA LECHE LEAGUE (GB)                    LONDON RETAIL MEAT TRADERS ASSOC LTD
LABORATORY ANALYTICAL &                 LONG ASHTON RESEARCH ASSOCIATION
BACTERIOLOGICAL SERVICES                LONGDAY FOODS LTD
LABORATORY OF THE GOVERNMENT            LOOE FISHERMEN'S PROTECTION SOCIETY
CHEMIST                                 LOVELL WHITE DURRANT
LACORS                                  LOWESTOFT FISH PRODUCERS'
LAKELAND FOODS LTD                      ORGANISATION LTD
LANCASHIRE COUNTY COUNCIL               LOWESTOFT INSHORE FISHING VESSEL
LANWADES BUSINESS PARK                  OWNERS' ASSOCIATION
LARD ASSOCIATION (THE)


                                   34
LOWESTOFT TRAWL FISH MERCHANTS'         MILK DEVELOPMENT COUNCIL
ASSOCIATION LTD                         MILK FOR SCHOOLS
LYNDALE FOODS LTD                       MILK QUALITY FORUM
M & J SEAFOODS                          MILL STREET
M D C FOODS LTD                         MILLENNIUM FRESH FOODS LTD
MACCLESFIELD BRANCH OF THE NFU          MILLFORD HAVEN SHELLFISHERMEN'S
MACFARLANES                             ASSOCIATION
MALTON BACON FACTORY LTD                MILUPA LIMITED
MALTSTERS ASSOC OF GREAT BRITAIN        MINSTREL PA SOLUTIONS LTD
MALVERN CHEESEWRIGHTS                   MJSR ASSOCIATES
MANOR BAKERIES LTD                      MONARCH FOOD INT LTD
MANSFIELD COMMUNITY HOSPITAL            MONITOR GROUP
MAPLE LEAF FOODS UK LTD                 MONSANTO PLC
MAPLE LEAF MILLS LTD                    MOULVALEY FARMERS LTD
MARCUSE GLUES AND CHEMICALS             MR J MAKIN
MARDON PLC                              MR R MCKINLEY
MARKS & SPENCER PLC                     MRS EM FARLEY
MARLOW FOODS LTD                        MRS M YOUNGS
MARR FOODS LIMITED                      MRS S EADE
MARS CONFECTIONERY LTD                  MRS V GARLAND
MARSHALL FARMER LTD                     MS P MARGIOTTA
MARUBENI EUROPE PLC                     MS S BOND
MARYVALE FARMS                          MULTILABELS
MATERNITY ALLIANCE                      MUREX BIOTECH LTD
MATTHEW CLARK PLC                       MURRAY VERNON LTD
MCCONOMY & CO LTD                       MUSKAAN LTD BRIGHOUSE BUSINESS
MCCORMICK (UK) PLC                      VILLAGE
MCDONALDS'S RESTAURANTS LTD             N.I. AGRICULTURAL PRODUCERS'
MCKENNA AND CO                          ASSOCIATION
MCKEY FOOD SERVICE LTD                  N.I. FOOD & DRINK ASSOCIATION
MD FOODS PLC                            N.I. MEAT EXPORTERS ASSOCIATION
MEAD JOHNSON NUTRITIONALS               NABMA
MEADOW VALE FOODS LTD                   NATIONAL ANIMAL HEALTH & WELFARE
MEAT & LIVESTOCK COMMISSION             PANEL
MEAT HYGIENE SERVICE                    NATIONAL ASSOCIATION FOR MATERNAL &
MEAT INDUSTRY LIAISON GROUP             CHILD WELFARE
MEAT TRAINING COUNCIL                   NATIONAL ASSOCIATION OF MASTER
MEDEVA PHARMA                           BAKERS
MEDICAL AND VETERINARY SUPPLIES LTD     NATIONAL CONSUMER FEDERATION
MEDICAL RESEARCH COUNCIL                NATIONAL FEDERATION OF FISHMONGERS
MEDICINESAND HEALTHCARE PRODUCTS        LTD
REGULATION AGENCY                       NATIONAL ASSN. OF POULTRY SUPPLIERS
MELIA WHITE HOUSE HOTEL - LOMONDO LTD   NATIONAL ASSOCIATION OF BRITISH AND
MELLING AND ARDERN LTD                  IRISH MILLERS
MERCK LTD                               NATIONAL ASSOCIATION OF CATERING
MERRYDOWN WINE PLC                      BUTCHERS
METROPOLITAN POLICE SERVICE             NATIONAL ASSOCIATION OF CIDER MAKERS
MICHAEL TREND MP                        NATIONAL ASSOCIATION OF CITIZENS
MICROFERM LIMITED                       ADVICE BUREAUX
MICRON2                                 NATIONAL ASSOCIATION OF HEALTH STORES
MICROPHARM                              NATIONAL ASSOCIATION OF MASTER
MIDDLE ENGLAND FINE FOODS               BAKERS, CONFECTIONERS AND CATERERS
MIDWIVES INFORMATION & RESOURCE         NATIONAL ASSOCIATION OF PERRY MAKERS
SERVICE                                 NATIONAL ASSOCIATION OF SPECIALITY
MIKE GILES MEAT LTD                     FOOD & DRINK PRODUCERS


                                   35
NATIONAL ASSOCIATION OF SPFDP: FOOD      NATIONAL SHEEP ASSOCIATION
FROM NORTHUMBERLAND                      NATURAL ADHESIVE CO LTD
NATIONAL ASSOCIATION OF SPFDP:           NATURAL RESOURCE INSTITUTE
HAMPSHIRE FARE                           NCH ACTION FOR CHILDREN
NATIONAL ASSOCIATION OF SPFDP: ISLE OF   NESTLE UK LTD
WIGHT FINE FOODS                         NET-TEX AGRICULTURE LTD
NATIONAL ASSOCIATION OF SPFDP: KENTISH   NETHER HALL
FARE                                     NEW PRIMEBAKE
NATIONAL ASSOCIATION OF SPFDP: MIDDLE    NEW ZEALAND MISSION TO THE EUROPEAN
COUNTIES SPECIALITY FOODS                COMMUNITIES
NATIONAL ASSOCIATION OF SPFDP: SHIRE     NEWHAVEN (SUSSEX) FISH & FLAKE ICE
FOODS                                    SOCIETY LTD
NATIONAL ASSOCIATION OF SPFDP: TASTE     NEWLYN FISH MERCHANTS' ASSOCIATION
OF ANGLIA                                NEWSPAPER SOCIETY (THE)
NATIONAL ASSOCIATION OF SPFDP: TASTE     NEX-TEX AGRICULTURAL
OF THE SOUTH EAST LTD                    NORFOLK RURAL COMMUNITY COUNCIL
NATIONAL ASSOCIATION OF SPFDP: TASTE     NORTH DERBYSHIRE HEALTH AUTHORITY
OF THE WEST                              NORTH EASTERN SEA FISHERIES
NATIONAL ASSOCIATION OF SPFDP:           COMMITTEE
YORKSHIRE PANTRY                         NORTH HERTFORDSHIRE NHS TRUST
NATIONAL ASSOCIATION OF WOMEN'S CLUBS    NORTH SEA FISHERMENS' ORGANISATION
NATIONAL BEEF ASSOCIATION                LTD
NATIONAL BOARD OF CATHOLIC WOMEN         NORTH WESTERN & NORTH WALES SEA
NATIONAL CHILDBIRTH TRUST                FISHERIES COMMITTEE
NATIONAL CONSUMER COUNCIL                NORTHAMPTONSHIRE COUNTY COUNCIL
NATIONAL CONSUMER FEDERATION             NORTHUMBERLAND SEA FISHERIES
NATIONAL DAIRYMEN'S ASSOCIATION          COMMITTEE
NATIONAL DRIED FRUIT TRADE ASSOCIATION   NORTON ROSE
NATIONAL EDIBLE OIL DISTRIBUTORS         NORWEGIAN FOOD CONTROL AUTHORITY
ASSOCIATION                              NOTTINGHAM CITY HOSPITAL TRUST
NATIONAL FARMERS UNION ENGLAND &         NOTTINGHAM TRENT UNIVERSITY
WALES                                    NOTTINGHAMSHIRE COUNTY COUNCIL
NATIONAL FARMERS' UNION (ENGLAND)        NOVARTIS CROP PRODUCTION UK LTD
NATIONAL FEDERATION OF INLAND            NPA
WHOLESALE FISH MERCHANTS                 NUTRICIA
NATIONAL FEDERATION OF BRITISH PORT      NUTRITION AND DIETETIC DEPARTMENT
WHOLESALE FISH MERCHANTS                 NYLABONE LTD
NATIONAL FEDERATION OF FISH FRYERS LTD   OAKFIELD (FOODS) LTD
NATIONAL FEDERATION OF FISHERMEN'S       OAKLAND FAST FOOD
ORGANISATION                             OAKLEIGH MANUFACTURING
NATIONAL FEDERATION OF POULTRY MEAT      ORNAMENTAL FISH INDUSTRY UK LTD
MERCHANTS                                OSGROW 2000
NATIONAL FEDERATION OF WOMEN'S           OXFORD DIOCESAN SYNOD
INSTITUTES                               OXFORDSHIRE COUNTY COUNCIL
NATIONAL GAME DEALERS ASSOCIATION        OXOID LTD
NATIONAL GAMEKEEPERS ORGANISATION        PAI LTD
NATIONAL HEART FORUM                     PASTA FOODS LTD
NATIONAL INSTITUTE OF MEDICAL            PASTA REALE
HERBALISTS LTD                           PEEL HOLROYD & ASSOCIATES
NATIONAL MEAT TRADERS ASSOCIATION        PEERLESS FOOD PRODUCTS
NATIONAL OFFICE OF ANIMAL HEALTH         PEPSI COLA INTERNATIONAL
NATIONAL PHARMACEUTICAL ASSOC            PERCHARD'S
NATIONAL RENDERERS ASSOCIATION           PERFECTA FOOD INGREDIENTS
NATIONAL RESOURCES RESEARCH              PERIODICAL PUBLISHERS ASSOCIATION
DEPARTMENT                               PERRY SCOTT NASH


                                    36
PERSHORE GROUP OF COLLEGES              REFERENCE AND INFORMATION LIBRARY
PESTICIDES ACTION NETWORK UK            REFRIGERATED FOOD INDUSTRY
PET CARE TRUST                          CONFEDERATION
PET FOOD MANUFACTURERS ASSOCIATION      REFRIGERATION INDUSTRY BOARD
PETER BLACK HEALTHCARE LTD              REGULATORY AFFAIRS JOURNAL
PETER THOMSON GROUP PLC                 REINDEER FOODS LIMITED
PETER VASSALLO LTD                      RESPONSIBLE USE OF MEDICINES IN
PETTIFOR MORROW                         AGRICULTURE (RUMA) ALLIANCE
PICKLES AND SAUCES ASSOCIATION          RGB COFFEE LTD
PILSBURY                                RHM FOODSERVICE
PIZZA TWO FOUR LTD                      RHM FROZEN FOODS LTD
PLAIN ENGLISH CAMPAIGN                  RHM INGREDIENT SUPPLIES LTD
PLUMA UK LTD                            RHM TECHNOLOGY LTD
PLYMOUTH CONSUMER GROUP                 RIDPATH PEK LTD
PLYMOUTH TRAWLERS OWNERS'               RIO PACIFIC FOOD SEVICES LTD
ASSOCIATION                             (FUNNYBONES)
POLAR FURS LTD                          RIO TRADING CO (HEALTH)LTD
POLITICS INTERNATIONAL                  RIVERSIDE ANIMAL FEEDS
POOLE AND DISTRICT FISHERMEN'S          RME ASSOCIATES
ASSOCIATION                             ROAD HAULAGE ASSOCIATION LTD
PORT SUTTON BRIDGE LTD                  ROBERT JACKSON MP
POTATO GROWERS ACTION GROUP             ROCHE CONSUMER HEALTH
POTATO MARKETING BOARD                  ROCHE PRODUCTS LIMITED
POULTRY CLUB OF GREAT BRITAIN           RODFIELDS LTD
POULTRY WORLD                           ROSE MAUND EXPERIMENTAL FARM
PRE-PACKED FLOUR ASSOCIATION            ROSEMEAD 105
PRECISION LABELLING SYSTEMS LTD         ROSS YOUNGS INTERNATIONAL LTD
PREMIER INTERNATIONAL FOODS             ROTHERHAM HEALTH AUTHORITY
PREPARED FISH PRODUCTS ASSOCIATION      ROYAL ASSOCIATION OF BRITISH DAIRY
PRESTON COUNTY LABORATORY               FARMERS
PRINCES SOFT DRINKS                     ROYAL COLLEGE OF GENERAL
PROCESS QUALITY MANAGEMENT GROUP        PRACTITIONERS
PROCHILE                                ROYAL COLLEGE OF MIDWIVES
PROTEIN TECHNOLOGY INTERNATIONAL        ROYAL COLLEGE OF NURSING
PROVISION TRADE FEDERATION LTD          ROYAL COLLEGE OF OBSTETRICIANS
PUBLIC HEALTH LABORATORY SERVICE        ROYAL COLLEGE OF PAEDIATRICS AND
PUBLIC HEALTH MEDICINE ENVIRONMENTAL    CHILD HEALTH
GROUP                                   ROYAL COLLEGE OF PATHOLOGISTS
PURA FOODS LTD                          ROYAL COLLEGE OF VETERINARY
Q LABORATORIES LTD                      SURGEONS
QUAKER OATS LTD                         ROYAL DANISH EMBASSY
QUALITY ASSURANCE DEPARTMENT            ROYAL INSTITUTE OF PUBLIC HEALTH AND
QUALITY MILK PRODUCERS LTD              HYGIENE
QUEEN ELIZABETH HOSPITAL                ROYAL NETHERLANDS EMBASSY
QUEST INTERNATIONAL                     ROYAL PHARMACEUTICAL SOCIETY OF
R F BROOKES                             GREAT BRITAIN.
R P M INTERNATIONAL LTD                 ROYAL SOCIETY OF HEALTH
R.N.I.B.                                RSPCA
RALSTON PURINA                          RUDDOCK & SHERRATT
RANK HOVIS LTD                          RUDOLPH DESCO LTD
RARE BREEDS SURVIVAL TRUST LTD          RVC
RAY WHITNEY ESQ OBE MP                  RYECROFT FOODS LTD
RCC REGISTRATION AND                    RYVITA CO LTD
REAPERS                                 S MOORES
REED BUSINESS PUBLISHING                S.M.A. NUTRITION


                                   37
SAFEPHARM LABORATORIES LTD               SOUP & GRAVY MANUFACURERS ASSOC
SAFEWAY STORES PLC                       SOUTH AFRICAN HIGH COMMISSION
SAINSBURY'S SUPERMARKETS LTD             SOUTH BANK UNIVERSITY
SALMON AND TROUT ASSOCIATION             SOUTH DEVON & CHANNEL SHELFISHERMEN
SALT UNION MANUFACTURERS LTD             LTD
SAMSON GEMMEL CHAIR                      SOUTH EAST FISHERMEN'S FEDERATION
SAMUEL SMITH BREWERY                     SOUTH WEST HANDLINE FISHERMEN'S
SANDERS PRODUCTS LTD.                    ASSOCIATION
SANDWELL INFORMATION SERVICE             SOUTH WESTERN FISH BUYER'S AND
SARA LEE PERSONAL CARE UK LTD            PROCESSORS' ASSOCIATION
SBS/REGULATORY ISSUES TEAM               SOUTH WESTERN FISH PRODUCERS'
SCHOOL OF SCIENCE AND TECHNOLOGY         ORGANISATION LTD
SCHOOL OF VETERINARY SCIENCE             SOUTHERN COMMERCIAL FISHERMEN
SCHWEPPES EUROPE                         SOUTHERN SEA FISHERIES COMMITTEE
SCOTTISH CONSUMER COUNCIL                SOUTHERN SEA FISHERIES DISTRICT
SCOTTISH DAIRY ASSOCIATION               FISHERMEN'S COUNCIL
SCOTTISH EXECUTIVE RURAL AFFAIRS DEPT.   SOUTHRIDGE ASSOCIATES
SCOTTISH FOOD CO-ORDINATING              SOUTHWARK PUBLIC ANALYST DEPARTMENT
COMMITTEE                                SOVEREIGN FOOD GROUP
SCOTTISH LANDOWNERS FEDERATION           SPECIALIST CHEESEMAKERS ASSOCIATION
SDF FOODS LTD                            ST BARTHOLOMEWS HOSPITAL
SDIA                                     ST IVEL LTD
SEA FISH AUTHORITY                       ST IVEL PROVISIONS
SEA FISH INDUSTRY AUTHORITY              ST MARY'S
SEAFOOD LABORATORIES LTD                 STAFFORDSHIRE COUNTY COUNCIL
SEAFOOD MARKETING INTERNATIONAL PLC      STATES COMMITTEE FOR AGRICULTURE
SEAFOOD PROCESSORS ASSOCIATION LTD.      STATION ROAD
SEASONING AND SPICE ASSOCIATION          STEPHEN RHODES ASSOCIATES (SRA)
SEED CRUSHERS & OIL PRODUCERS            STILTON CHEESE MAKERS' ASSOCIATION
ASSOCIATION                              STOCKTON HIDE & SKIN CO LTD
SEROTEC LTD                              STRATEGIC AFFAIRS DIRECTOR
SEVEN SEAS LTD                           STRATEGY RESEARCH & ACTION LTD
SHELLFISH ASSOCIATION OF GREAT BRITAIN   STRATFORD UPON AVON FOODS
SHS INTERNATIONAL LTD                    STUTE FOODS LTD
SIGMA ALDRICH CO LTD                     SUFFOLK SMALL HOLDERS ASSOCIATION
SIMMONS AND SIMMONS                      SUGAR BUREAU
SIMPKINS PARTNERSHIP                     SUPERSIRES LTD
SINCLAIR ANIMAL & HOUSEHOLD CARE LTD     SUPPORT TRAINING SERVICES LTD
SLOUGH BOROUGH COUNCIL                   SURREY TRADING STANDARDS
SMALL BUSINESS SERVICE                   SUSSEX GAME FARM
SMALL INDEPENDENT BREWERS                SUSSEX SEA FISHERIES COMMITTEE
ASSOCIATION                              SUSTAIN - THE ALLIANCE FOR BETTER FOOD
SMITHFIELD MURRAY                        AND FARMING
SMITHKLINE BEECHAM CONSUMER CARE         SUTTON LONDON BOROUGH OF
SNACK, NUT AND CRISP MANUFACTURERS,      SVS DEFRA
ASSOCIATION                              SWIFT COMPUTER SYSTEMS
SOCIETY FOR PROMOTION OF NUTRITIONAL     T&GWU FOOD DRINK AND TOBACCO GROUP
THERAPY                                  TAMESIDE M B C
SOCIETY OF DAIRY TECHNOLOGY              TAS INTERNATIONAL
SOCIETY OF FOOD HYGIENE TECHNOLOGY       TATE & LYLE
SOIL ASSOCIATION                         TATE & LYLE EUROPE
SOMERFIELD STORES LTD                    TCS CELLWORKS LTD
SOMERSET COUNTY COUNCIL                  TEA PACKERS ASSOC
SOMERSET SCIENTIFIC SERVICES             TEC INDEXIES
SONEVOL S.A.                             TECHNICAL INDEXES


                                    38
TESCO PLC                              THE MILL HOUSE
TESCO STORES LTD                       THE NATIONAL DAIRY COUNCIL
TETLEY GB LTD                          THE NATIONAL FEDERATION OF MEAT AND
THAMES VALLEY SCHOOL OF HOSPITALITY    FOOD TRADERS
STUDIES                                THE NATIONAL FOOD ALLIANCE FOR BETTER
THAMES VALLEY UNIVERSITY               FOOD AND FARMING
THAMES VALLEY UNIVERSITY WOLFSON       THE NEWSPAPER SOCIETY
INSTITUTE OF HEALTH SCIENCES           THE PIZZA , PASTA & FOOD ASSOCIATION
THE FOOD CLUB                          THE PORT OF FELIXSTOWE
THE AIR CONDITIONING AND REFRIGERATION THE POTATO PROCESSORS ASSOCIATION
INDUSTRY BOARD                         THE RAYNE INSTITUTE
THE ALLIANCE OF INDEPENDENT RETAILERS THE RESTAURANT ASSOCIATION
THE BCCA                               THE RICE ASSOCIATION
THE BINDING SITE LTD                   THE ROAD HAULAGE ASSOCIATION LTD
THE BISCUIT, CAKE, CHOCOLATE &         THE ROYAL COLLEGE OF PAEDIATRICS AND
CONFECTIONERY ALLIANCE                 CHILD HEALTH
THE BRISTOL PORT COMPANY               THE ROYAL COLLEGE OF PHYSICIANS
THE BRITISH ASSOCIATION FOR SHOOTING THE ROYAL COLLEGE OF SURGEONS OF
AND CONSERVATION                       ENGLAND
THE BRITISH DEER SOCIETY               THE ROYAL SOCIETY FOR THE PROMOTION
THE BRITISH INSTITUTE OF CLEANING      OF HEALTH
SCIENCE                                THE RT HON JOHN PATTEN MP
THE BRITISH MEDICAL ASSOCIATION        THE SAINSBURY LABORATORY
THE BRITISH OAT AND BARLEY MILLERS     THE SCOTCH WHISKY ASSOCIATION
ASSOCIATION                            THE SEAHAM HARBOUR DOCK COMPANY
THE BRITISH RETAIL CONSORTIUM          THE SOCIETY OF FOOD HYGIENE
THE BRITISH SHEEP DAIRYING ASSOCIATION TECHNOLOGY
THE CHINESE TAKEAWAY ASSOCIATION (UK) THE SOCIETY OF INDEPENDENT BREWERS
THE CLERK AND SUPERINTENDENTS OFFICE THE SOCIETY OF OCCUPATIONAL MEDICINE
THE COFFEE TRADE FEDERATION            THE SUGAR BUREAU
THE COOKERY & FOOD ASSOCIATION         THE UK FEDERATION OF F.A.C.E
THE DAIRY COUNCIL FOR NORTHERN         THE UK RENDERER'S ASSOCIATION
IRELAND                                THE UNION OF INDEPENDENT COMPANIES
THE FERTILIZER MANUFACTURERS           THE UNITED REFORM CHURCH
ASSOCIATION                            THE WHITEHOUSE CONSULTANCY LIMITED
THE FISH PRODUCERS' ORGANISATION LTD THE WINE AND SPIRIT ASSOCIATION OF
THE FLOUR MILLING & BAKING RESEARCH    GREAT BRITAIN AND NORTHERN IRELAND
ASSOCIATION                            THE WOMENS ENVIROMENTAL NETWORK
THE FOOD CONSULTANCY                   THE WORSHIPFUL COMPANY OF BUTCHERS
THE FOOD HYGIENE BUREAU LTD            THERAPEUTIC ANTIBODIES
THE FREEDOWN FOODS CO LTD              THOMAS EUROPE
THE GAME FARMERS ASSOCIATION           THOMPSON AND CAPPER LTD
THE GROSVENOR CONFECTIONERY            THORNTONS PLC
COMPANY                                TILBURY CONTAINER SERVICES
THE GUILD OF FINE FOOD RETAILERS C/O   TIM BRIDGESTOCKE ASSOCIATES
FORTNUM & MASON PLC                    TOWN AND COUNTRY PETFOODS LTD
THE INCORPORATED NATIONAL              TOWNSWOMENS' GUILDS
ASSOCIATION OF BRITISH & IRISH MILLERS TRADE UNION CONGRESS
LTD                                    TRADING STANDARDS INSTITUTE
THE INSTITUTE OF REFRIGERATION         TRADITIONAL FARM FRESH TURKEY ASSOC
THE INTERNATIONAL SOCIETY FOR          TRANSOCEANIC MEAT CO LTD
PHENYLKE                               TRANSPORT & GENERAL WORKERS UNION
THE LAW SOCIETY OF SCOTLAND            TREATS ICE CREAM LTD
THE LONDON SCHOOL OF ECONOMICS AND TULIP INTERNATIONAL (UK)
POLITICAL SCIENCE                      TULIP INTERNATIONAL (UK) LTD


                                    39
UK ASSOCIATION OF FISH MEAL              VEGA RESEARCH
MANUFACTURERS                            VEGAN SOCIETY (THE)
UK ASSOCIATION OF FROZEN FOOD            VEGETARIAN ECONOMY AND GREEN
PRODUCERS (UKAFFP)                       ALLIANCE
UK ASSOCIATION OF MANUFACTURERS OF       VERNER WHEELOCK ASSOCIATES LTD
BAKERS YEAST                             VETERINARY CLINICAL SCIENCE DEPT
UK CHEESE GUILD                          VILIGANT COMMUNICATION
UK COMMITTEE FOR UNICEF                  VILLA SOFT DRINKS LTD
UK FISH MERCHANTS' AND PROCESSORS'       VITACARE LTD
ASSOCIATION                              VIVA
UK MAIZE MILLERS' ASSOCIATION            VOLUNTARY ACTION CUMBRIA
UK REGISTER OF ORGANIC FOOD              WAFCOL CA DIVISION OF ARMITAGE BROS
STANDARDS (UKROFS)                       PLC
UK RENDERERS ASSOCIATION LTD             WAGG FOODS LTD
UK SWEET SPREAD ASSOCIATION              WAITROSE LTD
ULLAPOOL BOAT OWNERS' ASSOCIATION        WALKER & SONS (LEICESTER) LTD
ULSTER FARMERS UNION                     WALSALL METROPOLITAN BOROUGH
UNIGATE (ST IVEL )                       COUNCIL
UNIGATE EUROPEAN FOOD                    WANDSWORTH COMMUNITY HEALTH
UNIGREG LIMITED                          COUNCIL
UNILEVER PLC                             WARBURTONS LTD
UNION OF CONSTRUCTION, ALLIED TRADES     WARNER LAMBERT CONFECTIONERY
AND TECHNICIANS                          WARRANT LOGISTICS LTD
UNION OF SHOP DISTRIBUTIVE AND ALLIED    WASTE FOOD FEEDERS ASSOCIATION
WORKERS                                  WATCHBEL LTD
UNIPATH LTD                              WEDDEL SWIFT
UNISON                                   WEETABIX LTD
UNITED BISCUIT UK LTD                    WEST DORSET SAFE ENERGY CAMPAIGN
UNITED FISHERMEN'S ASSOCIATION           WEST YORKSHIRE COUNTY COUNCIL
UNITED GROUP RMD                         WESTERN RESEARCH LABORATORIES
UNITED KINGDOM REGISTER OF ORGANIC       WESTLER
FOOD STANDARDS                           WHITBREAD PLC
UNITED STATES EMBASSY (USDA)             WHITWORTHS FOODS GROUP LTD
UNIVERSAL TRADER LTD                     WI COUNTRY MARKETS LTD
UNIVERSE FOODS INGREDIENTS               WILLIAM MORISON SUPERMARKET
UNIVERSITY OF BIRMINGHAM                 WILTS. TRADING STANDARDS DEPT.
UNIVERSITY OF BRISTOL                    WILTSHIRE DIRECT SERVICES
UNIVERSITY OF CENTRAL LANCASHIRE         WINE AND SPIRIT ASSOC
UNIVERSITY OF HUDDERSFIELD               WINE STANDARDS BOARD
UNIVERSITY OF LEICESTER                  WIRRAL FOODS LTD
UNIVERSITY OF LIVERPOOL                  WOMEN'S FOOD AND FARMING UNION
UNIVERSITY OF NEWCASTLE                  WOMEN'S NATIONAL COMMISSION
UNIVERSITY OF NOTTINGHAM                 WORCESTER COUNTY COUNCIL
UNIVERSITY OF READING                    WORCESTER SCIENTIFIC SERVICES
UNIVERSITY OF SURREY                     XYROFIN (UK) LTD
UNIVERSITY OF SUSSEX                     YORK NUTRITIONAL LABORATORY
UPS                                      YORKSHIRE AND ANGLIA FISH PRODUCERS'
VAN DEN BERGH FOODS LTD                  ORGANISATION LTD
VAN LUIN POULTRY & MEAT PRODUCTS LTD     YORKSHIRE PANTRY (THE)
VANDERMOORTELE (UK) LTD                  ZENECA BIO PRODUCTS




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