Testing a toolbox for impact assessment of food safety regulations: Maximum levels for T-2 and HT-2 toxins in the EU

In the EU, all major draft laws must be subject to a regulatory impact assessment. The aim of socio-economic research in the MoniQA Network of Excellence is to develop a toolbox for impact assessment of food safety regulatory proposals. The aim of this contribution is to present a draft of such toolbox with its application to a case study, regarding a proposal on setting maximum levels of T-2 and HT-2 toxins in cereals and cereal products. Such toolbox is based on multi-criteria analysis rather than cost-benefit analysis, which cannot be complete and reliable in most situations due to major difficulties: poor data availability; difficulty in isolating confounding factors like weather and market forces; probabilistic outcome of some actions; uncertainty in compliance levels; different timing in the occurrence and discounting of costs and benefits. We argue that a multi-criteria analysis method dealing with both fuzzy linguistic and stochastic quantitative variables - which take into account uncertainty - is the best way forward to an ex ante comparison of alternative policy options, especially in the food safety area, where the effect on public health - not precisely quantifiable - is the most important impact as giving the rationale for a regulatory proposal. The proposed toolbox involves a preliminary qualitative assessment of the likely impacts of each of the policy options considered, with a coding/scoring procedure, in order to identify the greatest impacts. Then, a feasibility filter considers availability of data necessary for impact quantification, in terms of monetary and time constraints for data collection. The subsequent quantitative assessment is performed with different methodologies for the most important impacts. Finally, a fuzzy multi-criteria analysis approach – which allows for a combination of qualitative and quantitative measurements - is used to arrive to a ranking of the policy options. The alternative policy options considered for the case study are: 1) maintaining the status quo; 2) setting ‘soft’ maximum levels; 3) setting ‘strict’ maximum levels. Cereals susceptible to T2/HT2 contamination are wheat (durum and soft), oats, barley, maize, and rye, but the wheat and oats are the most susceptible. This type of regulation would prominently imply impacts on public health, conduct of businesses, public authorities, and SMEs. The application of multi-criteria analysis shows a dominance of the ‘status quo’ option. All data used for this example are based on expert consultation and statistical databases, but, due to time constraints and the main aim of the research (testing the draft evaluation toolbox), the outcome of the analysis should not be taken as relevant for a real policy decision process. This case study shows the potential of the toolbox, which will be improved and tested with additional case studies in the remaining years of the MoniQA project.