Professors Chris Elliot and Brian Green question the FSA’s motivation behind its recent pseudo review into the safety of nitrates and nitrites, noting its patchy research and apparent lack of vigour in protecting the UK public.
Behind bacon’s pink sheen lies a chemical additive under scrutiny, and a question of how evidence shapes UK food safety decisions.
Ten years ago, the International Agency for Research on Cancer (IARC), part of the World Health Organization (WHO), placed processed meat in the same carcinogenic category as tobacco and asbestos. This shocked many, us included; yet the Coalition Against Nitrites believes the data to be compelling. However, in the intervening decade, according to the opinion of a group of leading experts (including ourselves), the UK Government has done virtually nothing to limit dietary exposure to nitrites. Take a look at the depth and breadth of scientific and political leadership this grouping represents in Table 1.
Instead of asking how we can reduce or replace these additives, the FSA seems to have asked how we can justify keeping them in our processed meat…”
Cancer Research UK estimates that more than 5,000 cases of colorectal cancer a year are linked to diets high in processed meats. That represents over 50,000 avoidable cases since the WHO report ten years ago. And by taking the British Journal of Cancer estimate of the cost to the NHS of treating such cancers, the bill in that period has likely reached £3 billion – funds that could have been spent building new hospitals or employing extra doctors or nurses. But alas, no action has been taken.
We do not write this article with enthusiasm or relish, but there comes a time when extreme disappointment and frustration warrants a public intervention, despite the subject of our disappointment being an agency for which we have great respect. This high-calibre agency has served the public well in many instances, but in this instance it has failed to proactively protect UK citizens. We are of course referring to the Food Standards Agency (FSA).
For those of us who have spent much of our careers working to keep food safe, there are few things more frustrating than regulators taking the easy road when the scientific evidence demands their action. Keeping potentially harmful elements from our food, be it pesticides, drugs, mycotoxins or other nasty chemicals, is a vital role of the FSA – and it ordinarily fulfils this role well. But it seems to have taken a very different stance on another class of chemicals – given its inaction to date and the agency’s recently published partial review on the safety of nitrates and nitrites as food additives in processed meats.
At first glance, the report appears an earnest attempt to reassure the public that everything is under control; that there’s ‘nothing to see here’. On closer inspection, a cacophony of weaknesses becomes apparent. The report takes a highly selective approach and uses an incomplete evidence base, failing to include some of the most important studies published on the topic. This all points to a deeply concerning unwillingness to grasp what the data, in its totality, truly means for human health. When we compared this side-by-side with the comprehensive, rigorous and transparent work of the European Food Safety Authority (EFSA), the FSA’s approach feels like a pale imitation of true scientific risk assessment.
To explain, this is not just an academic dispute between two agencies in terms of processes. This relates to how seriously each has taken the evidence available of potential harm due to the unnecessary addition of toxic chemicals to the processed meat we consume.
EFSA: a model of rigour
Let us consider the approach of EFSA and how this kind of risk evaluation should be done. EFSA’s panels don’t cut corners – far from it. Obtaining a place on a panel is no mean feat, with the experts who are finally recruited having undergone a rigorous selection process. A total of 17 experts were selected for this particular panel, some of whom we know professionally and have the greatest respect for. This panel goes back to first principles, re-examining every thread of data from published toxicological studies, exposure assessments, metabolic pathways and even the chemistry of how these additives behave during cooking and in the human body.
There is a risk, and this risk must be managed.”
In its most recent comprehensive re-evaluation published in 2023, EFSA revisited sodium and potassium nitrite and nitrate – the additives that give cured meats their distinctive colour and flavour, and that have been used for preservation. The panel did not merely review selected parts of the literature; they dissected it all in minute detail. Toxicology data, animal studies, human epidemiology, genotoxicity, carcinogenic potential –all were carefully scrutinised to ensure sound, evidence-based conclusions were reached.
The panel modelled actual dietary exposure across the population, factoring in not just additives, but also natural sources in vegetables and water. And their conclusion? For certain population groups, particularly children and those consuming higher volumes of processed meat, total exposure could exceed safe limits. In the world of food safety this is a clear red flag. The panel worked systematically at their task for around two years, including a public consultation in their deliberations. The conclusions were arrived at carefully but unambiguously: there is a risk, and this risk must be managed.
The EFSA panel recognised the technological benefits of these additives but challenged whether their current-use levels were still justified. In acknowledging where uncertainty still exists, rather than using that uncertainty as an excuse to do nothing, EFSA treated it as a reason to act cautiously. This scientific opinion published in the highly respected EFSA Journal led directly to the change in legislation in the EU, which reduced the levels at which these dangerous chemicals can be used during meat processing. This is how an effective food-safety science process is conducted: it is transparent, comprehensive, data-driven and above all, leads to evidence-based policy that puts the consumer first.
The FSA’s approach
Now let’s consider the FSA’s report – or more accurately, its partial literature review. The document is presented as a “rapid evidence assessment,” which should immediately ring alarm bells. Rapid reviews can be thought of, at best, as useful for scoping an issue; but they are no substitute for comprehensive risk assessments, nor should they provide the basis for good government policy.
The first and most obvious issue we have is who actually wrote the review. We did not recognise any of the named authors; upon checking, it seems they work as consultants for a private company. Their professional credentials are not stated, but as far as we can determine they are not food scientists or toxicologists, and it’s not clear they hold any scientific qualifications related to the subject matter. The FSA does mention two external experts that were involved in the project, but neither were listed as being co-authors, which is strange.
This is in stark contrast to the panel of specialist experts that EFSA enlisted, each of whom put their names to the report.
Furthermore, to our utter astonishment, the FSA report deliberately excluded extremely important peer-reviewed animal studies from their deliberations. Anyone who has spent any time in the world of toxicology will tell you that’s a fatal flaw. Animal data are often where early warnings come from – any food scientist or toxicologist will tell you it is fundamentally important and the FSA’s failure to acknowledge this signals real trouble. Excluding this data is like reviewing how a football match is going, while only watching one of the teams playing.
Not only did it disregard this important part of the evidence base, but it also arbitrarily cut out other pieces of published evidence because they disapproved of the scientific journals they were published in; or simply because these were published before 2017.
In all the systematic reviews we have read we have never encountered exclusion criteria akin to those used here. Why these big omissions? The authors actually tell us in the review: they were too pushed for time. This hardly screams robustness. And the time element to all of this we will come back to.
Next comes the language used in the partial review. Throughout the FSA’s report, phrases like “the evidence is inconclusive”, “no consistent association has been established” and “the research is in its early stages” are sprinkled liberally. To us this is the language of hesitation and deflection – akin to collecting splinters from sitting on a policy fence. Such language we believe intentionally underplays risk. Of course, uncertainty is part of all science but the difference lies in what you do with it. EFSA looked at the same uncertainty and said: ‘There’s enough concern here to warrant reductions’ but for the FSA report…. ‘well, we can’t prove for certain it’s dangerous, so let’s just keep calm and carry on.’
We have serious concerns that such an approach risks undermining trust in the FSA. Why would the agency use such language, one might ask? Was guidance given to the authors to downplay the potential risks of nitrites in processed meats? This cannot be, as the experienced and professional public servants in the FSA would know this to be deeply improper, but it would not be surprising if members of a sceptical and inquisitive public began to ask questions given the notable weaknesses so easily identified in this so-called ‘review’.
Depth vs superficiality: two philosophies of food safety
The contrast between the two agency approaches is not just about data; we see a more fundamental contrast in philosophy. EFSA operates on the principle that the public should be protected even when uncertainty exists: proactive rather than reactive. The FSA, in this case, seems rather more interested in protecting its own historic decision-making processes above all else.
We need to be clear: nitrates and nitrites are not trivial additives. Their chemistry allows them to form N-nitroso compounds when they are added to meat which is then cooked – substances known to be carcinogenic.”
EFSA’s processes are laborious – as those who have worked on their panels can attest – but with good reason. Each evaluation is peer-reviewed and debated in open session; the public is consulted and the outcome published in full, complete with data gaps and limitations.
The FSA’s review offers insufficient transparency about how studies were selected or weighted. Who decided to exclude so many potentially important publications? And here we must return to the concept of time. It was published just in time for the tenth anniversary of the WHO report linking processed meats and cancer – quite a coincidence. After ten years of inactivity, why was there a need to fast-track a report like this rather than support research to help fill the evidence gaps and commission a proper systematic review?
And so, we are left with a document that allows a spokesperson for the Department of Health and Social Care to state: “The Food Standards Agency have made it clear that the link between nitrates and nitrites and cancer remains inconclusive”. This may help reassure ministers, but believe us, it does nothing to reassure anyone with an understanding of the underpinning science. If the FSA really wanted a review that validated the status quo rather than challenged it, they certainly got what they paid a group of consultants for.
We need to be clear: nitrates and nitrites are not trivial additives. Their chemistry allows them to form N-nitroso compounds when they are added to meat which is then cooked – substances known to be carcinogenic. EFSA’s scientific opinions have made this crystal clear for years. And yet, instead of asking how we can reduce or replace these additives, the FSA seems to have asked how we can justify keeping them in our processed meat.
In an era where consumers are more aware than ever about what goes into their food, the UK’s food regulator should be setting the gold standard, not settling for the bare minimum. We used to pride ourselves on leading the world in food-safety science. This report does nothing to uphold that tradition. What it does do, however, is risk undermining the public’s trust. We expect the FSA to be independent, science-led and precautionary. Instead, this feels like a political exercise dressed up as an evidence review. A decade on from the WHO report and this is the best they can do – really?
A missed opportunity for the UK
The FSA’s review could have been an opportunity – a chance to show that post-Brexit Britain would not compromise on scientific excellence. Instead, it feels like an exercise in going through the motions. The report’s central message, “the evidence is inconclusive”, is a masterclass in political fence-sitting. Or is it? We wonder if there is another agenda at play here. Could the FSA be resisting the removal of harmful chemicals from processed meat because it prefers we eat less meat altogether, and confirming that these chemicals are unsafe would undermine such a goal – particularly if they were removed completely? Indeed, if the British meat industry was to remove nitrites from its bacon and ham, it could well be the most effective and positive move for UK pig farmers, processors and meat retailers for many years, given the overwhelming public clamour for nitrite-free alternatives.
Meanwhile, the EU has already moved to tighten limits for nitrates and nitrites in meat products. Its meat industry has been given a clear signal: adapt, innovate, or fall behind. Indeed, European Parliament Resolution B9-0307/2023 specifically calls on the meat sector to move in this direction. The FSA, meanwhile, is content to wait and watch – tantamount to saying we’re content to lag behind and leave our citizens at greater risk than those on the other side of the Channel. The signal to the UK meat industry is… do nothing. Recently, alongside fellow scientists and members of the original WHO expert panel, we wrote to Wes Streeting, UK Health Secretary, calling for urgent action. France and the EU are already tightening limits and moving towards safer alternatives, but in our opinion and others, the UK is falling behind. Why? Perhaps this article will help to initiate some answers.
Table 1: Coalition Against Nitrites – Members List
- Professor Chris Elliott OBE (Queen’s University Belfast – Institute for Global Food Security)
- Professor Denis Corpet (IARC 2015 co-author)
- Professor Walter Willett (Harvard TH Chan School of Public Health)
- Professor Paolo Vineis (Imperial College London)
- Professor Loïc Le Marchand (University of Hawaii Cancer Center)
- Professor Robert Turesky (University of Minnesota)
- Dr Dariush Mozaffarian (Tufts University – Food is Medicine Institute)
- Lord James Bethell (former UK Health Minister, Conservative)
- Sharon Hodgson MP (former Shadow Health Minister, Labour)
- Dr Anisha Patel (GP & bowel-cancer survivor)
- Richard Ramos MP (Democratic Movement)
- Antonella Cardone (CEO, Cancer Patients Europe)
- Floriana Cimmarusti (Director General, SAFE – Safe Food Advocacy Europe)
- Richard Tice MP (Deputy Leader, Reform UK)
- Jim Shannon MP (Health Spokesman, DUP)
- Baroness Natalie Bennett (former Green Party leader)
- Susan Murray MP (Liberal Democrat)
- Dr Xiaobei Pan (Queen’s University Belfast)
- Baroness Joan Walmsley (Liberal Democrat)
- Guillaume Coudray (researcher and author, ‘Who Poisoned Your Bacon?’)
- Professor Brian Green (Queen’s University Belfast)
- Baroness Jenny Jones (former Deputy Mayor of London)
- Baroness Margaret Ritchie (former SDLP leader)
- Baroness Janet Whitaker (Labour)
- Lord John Hendy KC (Labour)
- Baroness Emma Nicholson (Conservative)
- Baroness Angela Harris (Liberal Democrat)
New Food has invited the Food Standards Agency to respond to the points raised in this article.
Meet the authors
Professor Chris Elliott
Chris is Professor of Food Safety and Founder of the Institute for Global Food Security at Queen’s University Belfast. He served as Pro Vice Chancellor responsible for the Medical and Life Sciences Faculty between 2015 and 2018 and has published more than 450 peer-reviewed articles, many of them relating to the detection and control of agriculture, food and environmental contaminants.
His main research interests are in the development of innovative techniques to provide early warning of toxin threats across complex food supply systems. Chris led the independent review of Britain’s food system following the 2013 horsemeat scandal.
Professor Brian Green
Brian Green, BSc, PhD, is Professor of Molecular Nutrition at the Institute for Global Food Security, Queen’s University Belfast. His research explores dietary metabolites – bioactive compounds derived from food – and their roles in human health. His team develops advanced targeted mass spectrometry techniques to uncover biochemical pathways linking diet to disease.
Current research themes include:
- Dietary and metabolic factors influencing disease onset, with recent emphasis on neurodegenerative disease and cancer
- Characterisation of novel micronutrients and their physiological functions
- Nutrients and dietary components that modulate immune responses or support therapeutic interventions
- Discovery of food biomarkers for accurate dietary intake assessment.
Through this work, Professor Green aims to advance nutritional strategies that promote health and reduce disease risk worldwide.
