Food Standards Agency

This article is part of the Foodspin project of Spinwatch.

The UK's Food Standards Agency (FSA) describes itself as 'an independent food safety watchdog set up by an Act of Parliament in 2000 to protect the public's health and consumer interests in relation to food.' In 2002 the FSA produced a two-year update on its activities. 'Our independence is vital if we are to succeed in putting consumers first', read the introduction. Government minister Margaret Beckett reinforces the message that 'the Food Standards Agency... is very much an independent agency and an independent voice in government'.

'Putting consumers first' and 'being independent' are, in fact, listed as 2 of the FSA's 3 'guiding principles'. The Agency also lists as a key aim earning 'people's trust by what we do and how we do it'. This emphasis is unsurprising. The main reason for the establishment of the FSA was the collapse in public trust which occurred during the BSE crisis, when civil servants within the then Ministry of Agriculture Food and Fisheries (MAFF) were widely perceived as putting the interests of producers ahead of those of consumers. The FSA's independence from 'industry interests' is of 'paramount importance', according to the head of the FSA, Sir John Krebs. Krebs was replaced by Deirdre Hutton, who was chair between 2005 and July 2009. As of May 2010 the chair is Jeff Rooker.

FSA spins organic food

In 2009 the FSA announced the findings of a study it had commissioned from the London School of Hygiene and Tropical Medicine (LSHTM) into the nutritional status of organically grown food as compared with conventionally grown food. LSHTM’s team of researchers, led by Alan Dangour, reviewed all papers published over the past 50 years that related to the nutrient content and health differences between organic and conventional food.

This is how the FSA announced the findings:

An independent review commissioned by the Food Standards Agency (FSA) shows that there are no important differences in the nutrition content, or any additional health benefits, of organic food when compared with conventionally produced food. The focus of the review was the nutritional content of foodstuffs.

But Dangour's analysis came in for heavy criticism. An article in the Sunday Times reports:

Of 162 relevant studies identified, only 55 were deemed to be of “satisfactory quality”. While the 55 studies did show that organic food had higher levels of acidity and phosphorous, and conventional food had more nitrates, Dangour concluded that these results were irrelevant.

“There is no shortage of phosphorus in our diet and acidity is about taste. Neither have any relevance to public health,” said Dangour. The FSA concluded that the analysis turned up no “statistically significant” differences between organic and non-organic food for 20 of 23 nutritional categories.

A legitimate question to ask is: if these two elements (phosphorus and acidity) are irrelevant to public health, then why include them in the study? This is especially so because a number of studies on organic vs conventional food show that nutrients widely accepted to be beneficial are higher in organic food.

Even if the FSA study is taken at face value, it's hard to know how Dangour reached the conclusion he did. Peter Melchett, policy director of the Soil Association, commented on the FSA study: “I’ve read the report and the devil is in the detail. The detail clearly shows there are real differences in nutrition.”

The FSA researchers did acknowledge higher levels of some beneficial nutrients in organic compared with nonorganic foods. In organic vegetables the research recorded 53.7% more beta-carotene — which is believed to help protect against heart disease and cancer — as well as 38.4% more flavonoids, 12.7% more proteins and 11.3% more zinc.

But the FSA insists these were not relevant because of the overall level of statistical error in the research!

Melchett replies that Dangour selected unreliable reports. “They included ‘shopping basket’ studies [analyses of items people have bought without taking account of factors such as date of harvest], which are very variable and unreliable,” said Melchett.

“If you include such studies, you get lots of variation, allowing you to declare the whole thing statistically insignificant. It is supposed to be a report, not an opinion piece. But it is designed in a way that almost guarantees they are able to claim there is no difference."

FSA excludes the biggest-ever study on organic food

Most bizarrely, the FSA excluded from its study the most recent science, a major and expensive (£12 million) EU-funded study, called by the Sunday Times "the biggest research project in the world to look into the differences between organic and non-organic."

The four-year peer reviewed study, led by Carlo Leifert, professor of ecological agriculture at Newcastle University, found that organic milk contained 60% more antioxidants and healthy fatty acids than normal milk. Results from his crop studies suggest vitamin levels are up to a fifth higher in organic tomatoes, wheat and onions. These findings were announced in 2007.

The journalist Jon Ungoed-Thomas reported the findings in an article for the Sunday Times called, "Official: organic really is better". The article said:

The study found that organic fruit and vegetables contained as much as 40% more antioxidants, which scientists believe can cut the risk of cancer and heart disease, Britain’s biggest killers. They also had higher levels of beneficial minerals such as iron and zinc.

In a separate article, the Sunday Times noted that other study findings also found that organic food contained higher levels of beneficial nutrients:

Last summer a 10-year study by the University of California comparing organic tomatoes with those grown conventionally found double the level of flavonoids - a type of antioxidant thought to reduce the risk of heart disease. Other studies show milk having higher levels of omega3 fatty acids, thought to boost health.

The Sunday Times added the following telling statement to its coverage of the EU study:

The evidence from the £12m four-year project will end years of debate and is likely to overturn government advice that eating organic food is no more than a lifestyle choice.

Indeed, the public might reasonably expect the Food Standards Agency to welcome the study's findings. But it did no such thing. It merely "confirmed that it was reviewing the evidence before deciding whether to change its advice. Ministers and the agency have said there are no significant differences between organic and ordinary produce."

Then it commissioned its own study from Dangour's team at the LSHTM to go over the same ground as the EU study, to exclude its findings ... and come up with the opposite conclusion.

Commenting on the 2009 FSA study, Leifert said: “They have ignored all the recent literature as well as new primary research which shows the heath advantages of organic,” he said. “They admit in their own research that some compounds are 50% higher in organic. How can you call that a non-significance?”

He added: “I’m not happy and I intend to rip their study apart in scientific journals.”

The FSA refused a Freedom of Information request from the Sunday Times journalist Jon Ungoed-Thomas for disclosure of FSA discussion papers or internal assessments of research into the nutritional benefits of organic food compared to conventional food from 2006 and 2007, and documents relating to the FSA's official stance on organic food and its benefits. The FSA took over 14 weeks to answer the request and its excuse for not giving the information was that the balance of the public interest favoured non-disclosure. It seems that the public is not allowed to know how the FSA reaches decisions on a matter as vital to the public interest as the food that we eat.

Independence undermined

Prof Philip James, who drew up the blueprint for the FSA, told the investigative journalist, Andy Rowell, that there were two key decisions that have tended to undermine the blueprint and the agency's independence. 'When you look at the way the FSA was organised, they managed not to make the staff independent of the civil service which we'd identified as critical for establishing its independence', says James. In addition, 'they appointed senior MAFF staff to the senior echelons of the agency, when I'd made it quite clear from our analysis of previous experience with Health and Safety that you needed to bring in outsiders'. According to Prof James, this then had the knock-on effect of alienating others involved in developing the FSA blueprint who 'suddenly saw the final decisions' being 'controlled by MAFF' and so 'immediately asked for a transfer' out of the agency.

At the same time, Prof James says, those who might have had the breadth of experience to challenge vested interests via the FSA's council and board were deliberately excluded. Anyone who had been prominent in the food debate and 'knew anything about the problems' was, according to James, 'automatically removed from the shortlist' to the council and the board.

FSA's stance on GM and organic food not evidence-based, says review

In 2005 Baroness Dean conducted a review of the FSA under Sir John Krebs. She said that with regard to GM and organic foods:

the perception of the vast majority [of stakeholders] was that the Agency had deviated from its normal stance of making statements based solely on scientific evidence, to giving the impression of speaking against organic food and for GM food. This view was expressed not only by stakeholders representing organic and GM interest groups, but by those who would be regarded as supporters and natural allies of the Agency.

She recommended:

It is clear that many stakeholders believe the Agency has already made policy decisions on these issues and is not open to further debate. The Agency should address the perceptions of these stakeholders who have now formed views of the Agency founded on their belief that the basis upon which the Agency’s policy decisions were made was flawed.

Krebs

The FSA's first chief officer was Geoffrey Podger, a full time civil servant and previously career bureaucrat in MAFF and the Department of Health. The FSA's first head, Sir John Krebs, is a leading Fellow of the Royal Society. A member of the Zoology Department at Oxford, his specialty is bird behaviour rather than farming or food safety. However, Sir John had previously assisted MAFF by designing the 'Krebs experiments' to investigate whether badgers are responsible for the increasing incidence of TB in cattle. These controversial experiments lead to the slaughter of 20,000 badgers. As the experimental approach was one already stronghly favoured from within MAFF, some see the 'Krebs experiments' as symptomatic of Krebs' willingness to toe the MAFF line.

Pro-GM

If the experiments had made Krebs controversial prior to his appointment, things got worse since. On the day it was announced that he was becoming the head of the FSA, he publicly endorsed GM food in interviews, saying all GM products approved for sale in the UK 'were as safe as their non-GM counterparts'. Even prior to his appointment, he was already on record as saying that criticisms of GM food were 'shrill, often ill-informed and dogma-driven'. Some have suggested that his historic support for GM food may have been a factor in his being offered the top job at the FSA.

The FSA takes its advice on GM foods from exactly the same committee, ACNFP, that previously advised government ministers. By accepting this arrangement without question and by holding a position from day one that all approved GM products 'were as safe as their non-GM counterparts', the FSA under Krebs has brought an unquestioning attitude to the status quo. This contrasts notably with Krebs' and the FSA's combative stance on organic food. Interstingly, it is in the context of organic food that Krebs' has asserted the 'paramount importance' of the FSA's independence from 'industry .

But just as worrying as the FSA's attack on organics, in the eyes of many, has been its role in backing the position of the US government and the biotechnology industry in opposing strict EU labelling and traceability rules on GM foods and animal feed. Its position has been condemned by the Consumers' Association who 'remain bitterly disappointed at the anti-consumer stance' taken by the FSA. 'An open and transparent system of labelling, coupled with effective traceability mechanisms, will provide the best basis for consumer choice', said Sue Davies, the Association's Principal Policy Adviser. In contrast to the FSA position, a survey undertaken for the Consumers' Association in the summer of 2002 showed that 94 per cent of consumers think that food containing GM ingredients should be labelled.

The FSA has also been accused of seeking to weaken guidelines on GM at an international level. A report from Dr Michael Hansen of America's Consumers Union, and a Consumers International representative, at the Codex Ad Hoc Working Group on Allergenicity (10-12 September, Vancouver), comments on the role of Nick Tomlinson of the UK Food Standards Agency at the meeting. 'The representative from the UK, Nick Tomlinson, played a key role in producing the weak guidelines, along with Canada and Australia supporting the US. Tomlinson helped to push the notion that the guidelines should be more general in scope (even though the explicit terms of reference called for developing "detailed procedures" (for assessing allergenicity) and never objected to abandoning the decision tree.'

2002 saw the publication of an FSA-commissioned study by researchers at the University of Newcastle to see if GM DNA survived human digestion or transfers to gut bacteria - possibilities that have been dismissed by the biotech industry in spite of existing evidence to the contrary in rodents. The study found that GM DNA survived in the small intestine but did not survive passage through the colon; however, alarmingly, bacteria in the gut had taken up GM DNA. Research leader Prof Harry Gilbert played down dangers, saying, 'There is some evidence of gene transfer, but it is at an extremely low rate and therefore it probably does not represent a significant risk to human health'. The FSA spun the research into meaning that GM foods are safe, a conclusion disputed by other human geneticists, such as Dr Michael Antoniou of Guy's Hospital, London, who said the results indicated the need for extensive GM food testing.

Other GM-related FSA research has proven equally controversial. A proposed 18-month study aimed at monitoring the health effects of consuming GM foods was dismissed by a leading epidemiologist as 'worthless'. While a professor of food microbiology pointed out, 'It took decades to prove the link between smoking and ill health, and that was fairly obvious. I wouldn't expect them to find anything meaningful in 18 months.' (BBC: GM eating habits study 'worthless')

Public Debate on GM

In March 2003 the FSA again came under criticism over its alleged pro-GM bias during the UK's Public Debate on GM. In particular, debate materials developed by the FSA were widely condemned as biased. In a joint letter to the FSA a number of leading UK organisations, including the National Federation of Women's Institutes and the UK's largest trade union, UNISON, condemned not just the 'biased materials the FSA had created for the debate' but the FSA's complete failure to co-operate with the Government-sponsored GM Public Debate, which was being run by an independent Steering Group set up at arms length from Government in order to minimise bias. 'There is a strong consensus amongst consumer and environment organisations,' the letter said, 'that the published views and statements of the FSA and its Chair are indistinguishable from those of the pro-GM lobby and do not properly represent public health and consumer interests.' (Attack on food safety chief for GM crop ' bias ') Such concerns were dismissed by Sir John in the media and at a FSA Board Meeting on 13th March.

In May the same group of organisations again charged Sir John and the FSA with 'manipulating the GM Debate and misrepresenting the views of the public'. The accusations mirrored those made in a report by the FSA's own Consumers Committee, namely that the FSA produced 'incomplete and therefore biased' materials on GM that 'ignored existing concerns about GM food', and that the FSA failed to consult its own Committee about the GM Debate. Contributors to the Consumers Committee's report , released on the 6th May 2003, included representatives of the Consumers Association and the National Consumers Council.

The FSA also came under attack over the various consultation activities it organised separately from the main debate and without consulting stakeholders or its own Consumers Committee or the debate Steering Group. In particular, it stood accused of 'spinning' the results of these consultations in order to make their conclusions seem more supportive of GM.

For instance, in its press release reporting the various findings of a 'Citizen's Jury' it had organised on GM, it failed to mention, the Jury's key conclusion that: 'More time is needed to understand the long-term environmental implications of GM crops before farmers start to grow them in the UK - growing GM crops in the UK would be irreversible and might eventually reduce choice'. Given that the whole point of the Public Debate was to help the Government decide whether or not to allow commercial growing of GM crops in the UK, the FSA stood accused of concealing 'the most significant finding of its Citizen's Jury - namely that such a decision should be postponed.'

A public letter to Sir John from nine national UK organisations concluded, 'The FSA is clearly guilty of bias and manipulation of the facts on GM issues. As the FSA was established in part to restore consumer confidence in national food policies we wish to know how you intend to redress the situation, represent the real views of consumers and restore the trust of all the consumer and citizen groups that you have now lost on the GM food issue.'

After the conclusion of the Debate, The House of Commons Environment, Food and Rural Affairs Committee also seemed less than impressed by the FSA's contribution to the Debate. In a published report on the results of the Committee's investigation into the Conduct of the GM Public Debate, the Committee noted, We would value an explanation from the Food Standards Agency of its decision to undertake a 'public debate' of its own about GM food, why it chose to do so at the time that it did, what was the cost to public funds of its initiative, and how its work relates to the other strands of the public debate. We would also be keen to learn of future plans for the Agency to study public opinion about GM food.' (Paragraph 38)

FSA spends half a million pounds on PR exercise for GM industry

On 26 May 2010, GeneWatch UK's Director, Dr Helen Wallace, resigned from the Steering Group for the Food Standards Agency's GM dialogue. The Steering Group met on 27 May to agree a GBP450,000 bid and GBP50,000 evaluation for its public dialogue on GM crops and food. Additional money will be spent on paying the civil servants and consultants who will be managing the exercise.

The budget was approved by the former Government and is overseen by the FSA, which is chaired by pro-GM former Labour agriculture minister Jeff Rooker.

A Genewatch press release said Freedom of Information requests and internal documents show that the dialogue is an integral part of the GM industry's PR strategy. This involves claiming non-existent future benefits ('GM will feed the world') whilst portraying step-by-step contamination of GM-free shipments into Britain and Europe as inevitable and lobbying to weaken regulation.

Wallace writes in her letter that tender documents from one of the companies bidding to run the GM Dialogue showed they have been working with a multinational agrochemical and seed company “to develop concepts which link agri-business with important global issues (such as climate change, water scarcity, deforestation, etc) and position the company as a positive force”.

The same company’s tender sets out how they will avoid engaging with anyone with strong views on GM and avoid publicity.

In her letter of resignation, Wallace said:

I joined the Group with some scepticism and it has now become clear to me that the process that the FSA has in mind is nothing more than a PR exercise on behalf of the GM industry. In my view, this would be a significant waste of £500,000 of taxpayers’ money.

Freedom of Information requests that have been passed to me show that the FSA met with the industry group the Agricultural Biotechnology Council (ABC) on 21st September 2009 to discuss a “GM public engagement programme”. On 1st October 2009, the ABC advised the FSA “abc welcomes the opportunity to provide suggestions on the individuals and groups that would add value to the FSA GM engagement Steering Group. We support this activity and understand the importance of this initiative; however we believe GM must be presented as an option within the wider context of food security as part of a solution to feeding a growing population. It is important that when consumers are thinking about GM, they are considering the future as much as the present”. The industry also suggested edits to a draft FSA report to the Food Strategy Task Force, which claims that lack of demand and rising costs will drive out non-GM feed supplies and that GM and non-GM feed should no longer be segregated. In a subsequent report, DEFRA and the FSA support the industry’s line that ‘zero tolerance’ of unapproved GM crops in the EU threatens food supplies.

Dr Wallace said: "Taxpayers will be shocked that a former minister is blowing public money on a PR exercise on behalf of GM companies".

Spinning Farmed Salmon

According to Spinning Farmed Salmon:

The first major line of attack (on a paper in Scinence titled Global Assessment of Organic Contaminants in Farmed Salmon)was simply to ignore the data and attack the standards against which the data had been evaluated. But in a stunning series of errors the UK government and salmon industry responses fundamentally misinterpreted the science and criticised the paper on grounds which were simply scientifically irrelevant. Scottish Quality Salmon claimed that the authors ‘seem to have misapplied an already suspect risk model developed by the US Environmental Protection Agency’. The director of the UK government’s Food Standards Agency raised the EPA model explicitly. Sir John Krebs wrote a letter to the Guardian arguing that ‘The EPA ... bases its risk assessment on out-of-date science from 1991. The WHO takes into account the mechanism by which dioxins cause cancer. It concluded in 2001, using independent experts, that so long as dioxins were kept below thresholds, there would be no adverse effect upon health.’ In a statement at the time the FSA elaborated on this claiming the EPA approach ‘has been evolving since 1991, but has not been finalised’.

There is indeed an EPA process in progress since April 1991, but it is not the standard used by the authors of the paper. It is however, useful to examine the extent to which the process beginning in 1991 supports the case made by the FSA. . The report ‘Exposure and Human Health Reassessment of 2,3,7,8- Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds’ was revised in 1994 and on subsequent occasions, with the most recent draft being published in December 2003.

According to the FSA, Krebs view was based on a report produced by the UK government Committee on Toxicity. This 2001 report was published under the title COT statement on Dioxins and PCBs. This report does not, however, seem to support the view that the EPA process is based on dated or flawed science. The COT report did take a different view on the EPA approach, but not on the basis that it was outdated.

The COT report notes that ‘The EPA provided an excellent comprehensive review of the literature on developmental and reproductive toxicity, and although some new studies had emerged since it was written these did not have a major impact.’ So, on two counts (the fact that the process was regularly revised and that the most recent version was some two years more up to date than the FSA’s own science) Krebs statement that the process was based on ‘out of date science’ is simply wrong. In fact the EPA process was more up to date (December 2003) than the FSA’s own preferred report (2001).

But more incredibly the FSA approach was not the standard used in the paper in Science. Rather, the consumption advice was based on a different EPA process which assessed a different set of contaminants (PCBs as a whole, toxaphene and dieldrin). Given in note 25 of the paper this is: U.S. EPA, Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories. Volume 2: Risk Assessment and Fish Consumption Limits (U.S. EPA, Washington, DC, ed. 3, 2000). The Science article said nothing whatever about dioxins in relation to consumption. The researchers specifically excluded dioxins from their conclusions because of the varying regulatory standards. The FSA approach was, therefore, entirely mistaken.

Most critics of the study preferred to ignore the existence of the EPA altogether and claim that the findings were well within health and safety limits. John Webster sometimes described by SQS as their ‘scientific adviser’, ‘stressed that the PCB and dioxin levels found in Scottish salmon were significantly lower than the thresholds set by international watchdogs such as the European Union, the Food Standards Agency (FSA) or even the US FDA.’ This is almost true but entirely irrelevant. It is the level of dioxins and ‘dioxin like PCBs’ that were lower than the WHO and EU standards. This is quite different to PCBs as a whole. In fact, neither the WHO nor the EU has established standards for consumption levels of PCBs as a whole or for toxaphene and Dieldrin. So the SQS approach was entirely irrelevant too.

The erroneous response of the FSA and the salmon industry set the tone for other official agencies in the UK, which explicitly rested on the FSA as lead advisor. Thereafter all official agencies presented a united front downplaying the risk as being inside WHO, EU and FDA guidelines. This was simply false. At best this approach was irresponsible, incompetent and scientifically illiterate. At worst, it was a calculated deception.

FSA officials' pro-corporate activities and corporate affiliations

Sir John Krebs has not been alone among the FSA's top officials in attracting criticism. As the Sunday Herald reported in March 2003, "The credibility and independence of Scotland's food safety watchdog have been thrown into doubt in the wake of accusations that its top official is in favour of genetically modified food and a friend of big business." The 'top official' was Dr George Paterson, director of the Scottish arm of the FSA and former director general of Health Canada's Food Directorate, the Canadian government's food safety watchdog. Paterson has been linked to major food safety scandals in Canada. The first involved fast-track approval for a Monsanto GM crop – an article in 1999 in the Ottawa Citizen newspaper named Paterson as the author of a leaked memo describing a private deal which resulted in swift approval for two new kinds of GM potatoes made by Monsanto. The second scandal involved the overriding of internal government scientists' health warnings on a Monsanto GM product, Posilac, otherwise known as rbST or rBGH.

• Deirdre Hutton, the chair of the FSA from July 2005, has strong corporate links, including shares in GlaxoSmithKline, Tesco, Unilever, BskyB, and Scottish Radio to a value of approximately £43,500. [1]

• Tim Smith was appointed the new chief executive of the FSA in November 2007. Smith is the former Chief Executive of Arla Foods UK plc, the UK's leading dairy company and largest fresh milk supplier to the UK’s supermarkets. It is responsible for major food brands, Anchor, Lurpak and Cravendale. As at 2009 the company is part of Arla Foods amba, Europe's largest dairy manufacturer.

Board members' corporate links

There have also been concerns about a number of members of the FSA board who have been part of organisations with an avowedly pro-GM agenda. These include:

• Prof Jeya Henry [2], an FSA board member from April 2000 - April 2003, who is on the advisory board of the pro-GM Social Issues Research Centre.
• Prof Andrew Miller[3], an FSA board member from April 2003, who as General Secretary of the Royal Society of Edinburgh took the lead role in seeking to reassure the Scottish Parliament's Health and Community Care Committee over the safety of GM Crop Trials - the Committee were not convinced by his evidence.
• Richard Ayre [4], an FSA board member from September 2001, who is a member of the advisory council of the pro-GM lobby group Sense About Science.
• Vernon Sankey, an FSA board member from September 2001, who is a former Board member of the Grocery Manufacturers of America and a former Council member of the UK's Food and Drink Federation.
• Graham Millar a former vice-Chair of Quality Meat Scotland a meat industry promotional group; with shares in Unilever and Cadbury Schweppes [5];
• Maureen Edmondson a former Mars executive and an active member of the International Life Sciences Institute, the leading food industry front group) [6];
• Alan Gardner A vice president of the Farmers Union of Wales.[7]
• Nelisha Wickremasinghe

Board Members 2010

• Jeff Rooker Chair
• Ian Reynolds
• Graeme Miller
• John Spence
• Maureen Edmondson
• Sue Atkinson
• Tim Bennett
• Margaret Gilmore
• Clive Grundy
• Michael Parker
• Chris Pomfret
• Nancy Robson
• David Cameron, FSA

FSA PR agencies

Edelman

In 2003/4 the global PR firm Edelman reported the FSA as a client. Among its other clients in the UK were a list of fast food and pharma companies including:

Aventis Pharma, Burger King International, Merck Sharp & Dohme, Novartis, PepsiCo, Pfizer Health Solutions, Pfizer Consumer Health, Procter & Gamble, Roche Diagnostics, Snack Nut and Crisp Manufacturers Association (SNACMA). The Toy Industries of Europe is also listed as a client which has a direct interest in the FSA's work on advertising to children. These clients raise questions of a potential conflict of interest.

Luther Pendragon

In 2006 the PR firm Luther Pendragon listed the FSA as a client. Also listed are the following media and fast food/alcohol clients which present a potential conflict of interest:

• Bloomberg Television
• BMG
• British Phonographic Industry
• British Video Association
• Broadcasting Policy Group
• Cable & Wireless
• Guinness Ireland Group
• History Channel
• McDonald's
• Telewest
• Warner Bros
• Wrigley

Freshwater UK

In 2008, The FT list the FDA as a client of Freshwater UK