Hard Cheese

Draft response to Food Standards Scotland's consultation on its regulatory strategy.

Nothing is without risk. All foods have health benefits and disbenefits, some of which are now well understood and some which aren't. Attempting to create a perfectly safe food environment is beyond the scope of modern dietary science. In particular an auto-immune system which is never challenged does not develop resilience necessary for good health; for example, pasteurisation has been associated with the rise in allergies.

There's no doubt that FSS policy to date has been highly detrimental to small innovative food businesses. The destruction of Errington's Cheeses stock on the basis of tenuous and unproven evidence - effectively, on the basis of pure prejudice - has had a very chilling effect on the ability of small food businesses in Scotland to raise capital and find investors. This runs directly against your proposed outcome of 'Enabling business compliance and growth', and detracts sharply from your proposed outcome of 'FSS is a trusted, empowered and effective regulator'.

It is obviously imperative that FSS use 'evidence based decision making', but that 'evidence' has to be open and transparent, and FSS has to be able to communicate clearly to the public exactly on what evidence its decisions are made. Otherwise there will be a widespread perception that FSS favours large industrial processors over smaller artisan businesses.

Commodity milk production in Scotland is now viable only at scales which militate against acceptable standards of animal husbandry, and which generate very little rural employment. If we're to retain a viable population in remote rural areas we must be able to create more jobs per thousand hectares, which means we must be able to add value to primary production at the farm gate; which means in turn that we must process our primary products into higher value products which escape the commodity pricing trap. This observation is made all the more true post Brexit, when we're likely to be forced to compete with food produced in global markets in which standards of animal husbandry are significantly below those which would be acceptable here.

If Foods Standards Scotland are able arbitrarily and impunity to close down any small food business,  this will result in increased rural poverty and depopulation, and lead to more villages ceasing to be able to support services such as shops and schools. Food standards do not exist in a vacuum, but in a wider context of policy objectives and desiderata. We could achieve perfectly healthy food production in Scotland by ceasing to produce any food in Scotland, but that would have serious social and economic consequences, as well as consequences for food security and resilience.

Obviously it is more complex and more costly to inspect and monitor many small producers distributed over remote rural areas than a few large industrial plants in urban settings. Obviously there are risks associated with small scale food production. Obviously there is a role for regulation and for inspection. But FSS must reverse the perception which it has established that it closes smaller businesses arbitrarily and without compelling evidence.

As you say in 2.10a, 'establishing trust is vital'. You are signally failing to achieve this.

In summary, bland words about 'evidence based decision making', 'transparency', 'minimising burdens on business' and 'promot[ing] mature and open relationships' are easy to write, but much harder to implement; and you have got off on a bad foot.

While I broadly welcome the words in your draft strategy, I have much less faith in your ability or even willingness to make good on them.

A rant concerning bees and poison

This is the text of an email I have just sent to Richard Lochhead MSP (Richard.Lochhead.msp@scottish.parliament.uk), the current Minister for Rural Affairs. I very strongly urge you to write to him, too. I strongly urge you not to copy my text, not least because my text is extremely intemperate, but also because the more different messages he gets from different people the more persuasive it will be.

Standingstone Farm,
Auchencairn,
DG7 1RF

Dear Richard Lochhead

I was shocked and angered to see on the BBC website today that you are backing the interests of foreign pesticide manufacturers over the vital interests of Scottish farmers.

Without bees, there will be no neeps with your haggis; no kale, either. There will be no raspberries to serve afterwards. There will be no rapeseed oil to fry your mars bar. Without bees, we shall have no plums, sour or otherwise. We shall have no apples. There will be no heather on the hills. No clover will fix the nitrogen in our pastures, no wild flowers will bloom in our meadows.

To put all that at risk to save two years of poison-peddlers profits is shameful, contemptible, unworthy of you and of this nation.

I have worked for the SNP at every election these past forty years. Just yesterday, I was on the street campaigning for Yes Scotland. But you make me wonder why I bothered. What is the point in seeking independence for this nation if you will sell our interests to foreign agribusiness at the drop of a hat? Independence is worth having if - and only if - it makes a change. You seem determined to persuade me that it will not.

Shame on you.

Simon Brooke

Auf Essen in Deutschland

I've spent the week in Germany, where I've been performing a safety audit on a device made by a German subsidiary of a Swiss company on behalf of an English subsidiary of a French company. I write this sitting in France, fifty metres from Switzerland, while waiting for a plane to fly me to the Netherlands and thence home to Scotland. It's all remarkably painless.

But let's talk about Germany. Lots of the things you thought you knew (or I thought I knew) about Germany turn out to be true - or at least, turn out to be true of small towns on the fringes of the Schwartzwald. My view might be slightly influenced by the company I was auditing, by the fact that that Swiss-owned engineering company was absolutely obsessive about quality in everything they did (including hospitality). It was engineering of the kind I associate with Germany: always up to a quality, never down to a price. Over-engineered rather than under-engineered; good and thoughtful design, but emphasising sturdiness and durability over style.

The taxis were spotlessly clean, their drivers unfailingly courteous. The factory was clean and efficient and all the staff positive, relaxed, confident and happy to explain their work. The hotel was extremely well fitted and comfortable (and clean), the rooms generous and luxurious, the staff helpful, friendly and welcoming. They were mostly middle aged, not young; I think almost entirely local; and the ratio of staff to guests higher than you'd find in anything but the most upmarket British hotel. Yet the cost of a room was exactly the same as in a grubby corporate flea-pit in East Kilbride - where you would not have got the delicious and varied breakfast.

Which brings me to food. The company we were auditing treated us as guests; not only did they provide us with restaurant-quality lunch each day in their staff canteen, they took us out to dine every night, at a total of three different restaurants; twice the one belonging to our hotel, once a modern restaurant in the local administrative centre, and once... I'll come to that.

So what is German food like? Sausages and sourkraut? Chips and cream-cakes? Errr... no. We did eat a little sourkraut - several varieties of it, all good. We ate noodles, of kinds I'd never heard of before, let alone seen - nothing like Italian noodles. We ate dumplings. We once ate chips - once. We ate a simply extraordinary quantity of meat. We ate home made icecream. I didn't eat sausage at all (although a number of varieties were available at breakfast). Slightly to my disappointment I didn't eat a proper Schwartzwald Kirsche Torte - I could have, but I simply didn't have room (my abstemiousness at breakfast was for the same reason). I have eaten more this week than I eat in an average fortnight.

So, what is the food like? In one word, delicious. Extraordinarily good. Exceptional. Second, in my experience, only to Malaysia. Everything was of superb quality, freshly prepared, not over fancy. The effete over-complicated confections of British television cooking were nowhere to be seen; nor was fast food, or junk food. In the urban centres we did see a few Indian, Chinese and Vietnamese restaurants, and we did see sausageinnabun shops. But the places we went to served food which was proudly local, unashamedly German, unquestionably fresh-cooked and utterly excellent.

Until the very last night - last night - which was completely different. We drove up into the forest, up steeply climbing twisting roads which would be a joy to cycle in summer, to an ancient farm-house turned gasthof. The whole place was wooden, over four hundred years old. We went into a simple, homely dining room which would hold twenty people at the most, but which was empty but for a man sitting alone and the four of us. A pretty young waitress who spoke no English brought us simple paper menus, and came back after a few minutes to take our order. I chose a venison ragout with noodles, which sounded good.

So much, so normal. And then it all changed.

Mien host came in, a tall and powerful old man called Saxo, wearing casual countryman's clothes. He spoke a little English but was much more comfortable in German. He sat down with us for a few minutes, talking, and then said he'd shot a wild pig, and would we like some? After not a lot of discussion, we agreed we would. Was it spit-roasted, someone asked? No, it had been baked in the oven, after the bread he'd be serving with it. Saxo also said he had some mead, would we like to taste?

He disappeared into the back, and shortly reappeared bearing an enormous ox horn in a wrought iron stand. I joked that it must be an aurochs horn, but in truth I don't know where he got one so big; it wasn't old, and was by far bigger the horn of any domestic breed I know of except perhaps a Texas long-horn. He offered this to us and I realised it was full of mead. How much mead fills a horn like that? I haven't a clue, but it must have been at least two litres. I was certain that between four of us - and one a driver - we'd never empty it. So we chatted round the table with Saxo, and drank his (wonderful) mead, passing this epic horn from hand to hand, until the chef appeared.

The chef was a man as big as Saxo, and with the sort of belly on him a good chef should have. He greeted us, spoke to Saxo, and they both disappeared into the back. After a few moments they reappeared, bearing a trencher. A trencher? it was at least four feet by two, of sturdy oak. It filled the table, clearly leaving no room for such effete nonsense as individual plates. On it. besides two baked quarters of a substantial pig and a large loaf of rough bread cut into thick slices, were two large crocks of gravy, baked apples, baked potatoes, sweet corn, and a mountain of roughly chopped mushrooms (which, it transpired, were the only ingredient which had been bought in). Oh - and four very sharp knives. No forks.

Four people - four people could not possibly eat all this.

Four people very nearly did. There were some potatoes left at the end, and an apple, and perhaps a kilo of pork on the shoulder. We gorged ourselves. We all gorged ourselves, despite having already overeaten for three days, because it was so extraordinarily delicious, so utterly delectable.

And when, finally, we thought we had eaten all we possibly could and the trencher had been removed, the pretty waitress (who, it transpired, was not German but from Drakula's home village in Transylvania) persuaded us all to have some home-made ice-cream with advocaat; and Saxo reappeared and persuaded us to have a schnapps. The waitress and the other guest (an engineer from Bratislava in Slovakia) joined us, and together we conversed in a happy mixture of German, English, French, a bit of Italian, a bit of Dutch, and some Slovak, while the mead horn continued to circulate.

We could have had that meal - in that place, in that environment - any time in the past four hundred years; there was an electric light but it was no brighter or more intrusive than a candle lamp. Apart from the potatoes and sweet corn, we could have had it any time in the past millenium.

At the end of it all we went back to the hotel very late. I was drunker than I've been in twenty years - and probably happier. The mead horn? It was empty.