In the term of office that has now expired (July 2015 to June 1018) the FEEDAP Panel developed and adopted 208 Scientific Opinions (including the guidance documents) in 21 sessions (including three Open Plenaries). The new Panel (as of July 2018) is smaller and has more female members than before. It comprises 17 (previously 21) members including 10 (previously 5) female scientists. Four members come from Spain, three from Italy, two from Portugal, and one each from Bulgaria, Denmark, Germany, France, Greece, the Netherlands, Slovenia and the Czech Republic. The four classic “animal nutritionists” come from Bulgaria, France, Greece and Spain. 12 previous members with together 120 years of experience as risk assessors on the FEEDAP Panel have now left the Panel. Nine with altogether 42 years of relevant FEEDAP experience have remained. We wish the new Panel a good start and every success.
At the time of publication of this article, the two authors are no longer members of the FEEDAP Panel. After twelve and nine years of membership respectively, it was time to stop, perhaps something they realised themselves, given their age. How does the Authority itself see this? In 2017 EFSA modified the rules in such a way that after nine years of membership (three terms of office) in one body, there must be a stop, regardless of whether or not the three times three years follow on directly from each other (as has been the case so far). Now all that counts is the total number of years. This might make sense, as it puts a stop to the “ageing” of the bodies and makes room for younger people, as well as opening scope for new ideas and insights. It might be counterproductive, because it removes experience from the body, takes an at least temporary loss of competence into account, and adds to the weight of the authority (the unit and its scientific officers) to the detriment of the experts (the Panel members). As a result there is for example a growing risk of the guidance documents of the FEEDAP Panel being interpreted all too literally in future. The analogous interpretation of the content, which was originally intended, may then disappear into the background instead and possibly even be forgotten, because the interpretation of the guidelines must be consistent across the years. At the same time consistency is always in conflict with new findings resulting from scientific progress. Careful balancing and transparency of the decision-making path are indicated here.
The authors – Gerhard Flachowsky and Jürgen Gropp – are long-serving members of the EFSA Panel on Additives and Products or Substances in Animal Feed (FFEDAP). They report on the work of the FEEDAP Panel. The articles contain personal views and representations, not those of EFSA or the EU. Consequently they do not necessarily coincide with the viewpoints of EFSA or the EU. As experts working on behalf of EFSA, the authors are subject to certain confidentiality obligations.
Internationally EFSA, and hence also its bodies, have earned a considerable reputation after 15 years of existence. The NRC (the National Research Council of the USA), for example, determined “that the EFSA as an independent European authority is a core element of European safety assessment of foods and feeds. The EFSA reports are independent scientific opinions and can also represent a basis for research priorities in the field of animal sciences”. As FEEDAP Panel members, we can fully agree with the last sentence. Not all assessments can be undertaken completely without doubt. Frequently a greater or lesser residue of uncertainty remains, which could urgently do with further research in order to achieve greater certainty in the risk assessment. EFSA has no funds for this and no budget for experimental studies, although the founding act of EFSA (Reg. (EC) No. 178/2002) states under consideration 48: “The authority should also be able to commission scientific studies necessary for the accomplishment of its duties.” Now EFSA is certainly not intended to develop into a further European research promoting institution. However, a small budget for “firefighting actions”, which could substantially reduce particular cases of uncertainty or contribute to the further quantification required, would certainly be appropriate. It would also be desirable for EFSA to be able to make its own suggestions in the nomination procedure for staffing the Panel, such as is already possible and practiced today when it comes to staffing the working groups. A revision of the founding act which is currently pending in the EU Parliament should help to eliminate the said deficits.
On the occasion of the nomination of the experts for the term of office 2018-2021 by the Management Board in March 2018, the Chair of the Board stated that more still needs to be done to encourage talented scientists from hitherto under-represented Member States to apply. She also stressed the significance of membership in working groups which support the work of the Panel as a gateway into the scientific community of EFSA. However, the authors doubt whether this is the right approach towards pooling the knowledge of the European Community in EFSA’s risk assessment. Don’t the number of scientists in the individual Member States, the total research budget of a Member State, the number of “peer reviewed” publications – to mention just the few other criteria – play an important or even greater role? Readers may draw their own conclusions and compare these with the staffing of the FEEDAP Panel.
In this discussion it is also necessary to ask how high the time input for a member of the FEEDAP Panel is to be assessed. Let us assume that the majority of possible candidates for Panel membership come from universities or national research institutions. All the people working there have a tight schedule of teaching obligations, their own research work and publications, (self-)administration, committee work, the obligation to canvass for third-party funds, supervision of students and doctoral candidates etc. Taking an average workload into account, about six plenary sessions (two and a half days in Parma) are held every year for the FEEDAP Panel and a large number of working group sessions (each Panel member is also a member of at least two working groups with about 10 to 15 session days, about half of which take the form of audio-web half-day conferences). Furthermore, for members from Northern Europe and certain Central European countries, a full day will be required for travel to and from the meetings in Parma (which does not have an international airport) and these days can only be used to a very limited extent for other work. Consequently the “average” Panel member is away from the office for about 30 days (+ six travel days) with a further 10 to 15 half-days of conferences.
After reckoning the total number of hours required for work at meetings, the same number can be added on top of this for preparatory work. Many employers (especially in the Nordic countries) do not want to tolerate this. What ambitious young research scientist can take on this work without risking his/her career? Who can be advised to apply? Pensioned senior scientists have sufficient time. However, this is not a promising alternative either. This cannot be what EFSA wants. The question of how to tackle this dilemma remains unanswered. Is the EFSA system reaching its limits here? The revision of the Founding Act mentioned above provides for greater integration of the Member States (their experts) in the scientific committees. So does this mean that remedies are in sight? On the other hand implementation of this “good intention” is subject to the Directives of the Member States. At the same time, however, this would increase the influence of the Member States and the EU Commission on the results of the EFSA assessments– the authors fear that this could harm EFSA’s independence.
Work on the EFSA Panels, in the multinational bodies, is extremely interesting, not only because we learn a lot of new things, because we can learn new things nearly every day and also pick up ideas for our own research and teaching, or simply because it is fun – no, it affects our lives because we can experience and breathe Europe. We meet colleagues on the Panels, in the working groups and in the Shuttle from Milan or Bologna to Parma and possibly on the way back, not only colleagues from other scientific disciplines, – no, from other nationalities too with their different educational, socialisation and rational thinking mode backgrounds, different logics. At the beginning one can hardly believe that everything will go well. How can one reach an agreement under these circumstances? But, after discussions of various lengths, we come to a joint conclusion, a uniform assessment of the risk. It is a highly rewarding experience that Europe with its different representatives can work, that it really lives and is not a lifeless construct of political technocrats. The European Union has potential for development! When confronted with reservations against Europe in table talk over a glass of beer, we often deeply regret our incapacity to pass on this experience directly. Those who are lucky enough to work with colleagues from the Member States in a European body become convinced Europeans and have no chance of becoming anything else. This is also an important conclusion, our very own personal conclusion, from 15 years of work in and for EFSA and a great chunk of hope for the future.
As we say goodbye, we can only hope that we have aroused your interest as readers in the purpose and results of the FEEDAP work and to voice our regret that we must now bid you farewell. We would also like to thank EFSA, for approving our suggestion that we report on the work of the FEEDAP Panel, and the publisher (especially Mr Bernd Springer) for investing trust and confidence in us and always accepting our – frequently excessively long – contributions.