Ensuring Safe Food: From Production to Consumption (1998)

The following pages summarize in the committee's words the key points from the presentations given at the public workshop on April 29-30, 1998 (see agenda at end of summary). The workshop was organized in three phases: first, two speakers presented information concerning international food safety systems and organizational strategies to the committee. The second phase was organized to assist the committee in gathering feedback from various stakeholders concerning the current food safety system and changes that would lead to a more effective system. The committee asked these presenters to respond in writing and provide oral testimony to the following questions:

• What works well in the current US food safety system?
• What changes would lead to a more effective food safety system?
• What types of changes would be detrimental to an effective food system?

The third phase was designed to provide an opportunity for public comment regarding the US food safety system.

Copies of the written testimonies submitted to the committee by workshop presenters are available from the National Academy of Sciences' (NAS) public information file. Information on accessing these documents is available from the NAS website at http://www.nas.edu.

• A disassociation of regulatory and inspection activities may be evolving in international systems that are undergoing change.
• In Canada, the regulatory component is divided among agriculture, health, and environmental divisions. A fee for service system is being utilized, which needs to be assessed as to its overall budget impact.
• Finland has a unique system. It is a small country with responsibilities distributed between political and technical cabinets.
• In New Zealand, inspection is privatized.
• It is difficult to determine whether changes in food safety systems in other countries have improved the situation, because there are no benchmarks from which to measure improvement or progress.
• Most countries have emphasized the use of external expertise in developing effective food safety systems.

• It is possible that changes in the current US food safety system could result in the worst of both worlds.
• EPA was organized partly on topic and function. Their organizational plan was not entirely implemented.
• Localizing efforts in one agency may reduce priority for the issues in other agencies; however, focus by one agency reduces duplication.
• Combining efforts in one agency will also increase visibility of the issue. Since the formation of the EPA, environmental activities have increased.
• Strong leadership is critical.
• It is important to know whether changes in organization are being recommended based on function or based on cost efficiency. Reasons for changes must be clearly explained.
• Often changes suggested to increase effectiveness may not result in cost savings.
• It will be difficult to develop new approaches and attitudes without breaking up the old system.
• The separation of regulatory efforts from research efforts is likely to lead to better science.

• Animal Agriculture Coalition (Gary Weber)

• supports HACCP, partnerships, and the use of science and technology; and
• no need for more regulation to solve problems.

• The National Council of Farmer Cooperatives (Thomas VanArsdall)

• farmers want to produce safe food based on sound science (not headlines);.
• government should ask only for what it needs as farmers are busy; and
• in respect to change, urges pragmatic incrementalism.

• United Fresh Fruit & Vegetable Association (John Aguirre)

• prefer government ''guidance" to regulation; cooperation is key;
• opposed to a single food safety agency as present food safety problems are not due to the lack of a single food agency;
• does not support mandatory HACCP for all foods;
• noted multiple instances of misguided responses by local officials to food contamination outbreaks (publicly blaming the wrong commodity), which led to producer and consumer harm; and
• need more consumer education.

• The United Egg Producers (Donald McNamara)

• egg producers answer to multiple agencies;
• industry has programs to deal with risk and these good faith efforts work well;
• need cooperative working relationships with government as a partner; and
• need improved risk assessment.

• Grocery Manufacturers of America (Steve Ziller)

• US has safest food supply, but can do better;
• change focus, not structure as will not make food safer to reorganize, but can make food safer if focus resources;
• agencies need resources: scientists and dollars;
• agencies must focus on real problems;
• resist knee-jerk reactions, show leadership, less political science, and more real science; and
• USDA continuous inspection uses scarce resources.

• National Food Processors Association (Rhona Applebaum)

• US has perhaps the safest food supply;
• FSIS has not always performed well, but HACCP is opening the process and becoming more transparent;
• media has great power;
• focus improvement on better cooperation among agencies;
• focus on actual risks and put resources there;
• need uniform approach across federal and state governments;
• do not need single agency, just coordinate; and
• most cost effective to fix current system.

• American Meat Institute (James Hodges)

• current statute gives USDA no on-farm authority;
• FSIS has greater resources then FDA, but fewer establishments to regulate as meat and poultry are the most regulated foods;
• ability of FSIS to tailor efforts to risks is limited;
• need more understanding of food production principles; and
• FSIS should focus on verifying that food is safe rather than mandating how it gets safe, but not calling for suspension of continuous inspection.

• International Dairy Food Association (Cary Frye)

• industry recognizes need to control pathogens;
• HACCP should not be mandatory for dairy foods;
• agencies need to be open minded, science based;
• better state/federal cooperation needed; and
• need uniformity in regulations.

• National Fisheries Institute (Richard Gutting)

• present system works well;
• seafood industry has partnerships with FDA and academia;
• FDA is slow to respond to international seafood concerns;
• loopholes in present system exist as sport fisherman deliver directly to restaurants (no HACCP program);
• need science based information to make decisions; and
• need more training and education.

Summary: common themes of all panel members were the need for

• more public education, expanded government role at all levels;
• increased communication and coordination among agencies;
• more strengthening of research programs;
• better coordination and transfer of technology; and
• risk-based program with increased resources to accomplish the tasks, especially in FDA (resources).

• International Food Additive Council (Andrew Ebert)

• international harmonization is essential in order to facilitate US trade in the increasingly competitive world market; and
• state and local regulations must be compatible with national regulations.

Food Distributors International (John Block)

• the US food system works because the food distribution industries are committed to a safe food supply; and
• food distributors have developed their own HACCP system.

Society of the Plastic Industry, Inc. (Jerome Heckman)

• food packaging does not seem to be a public health or safety problem; and
• 1997 FDA Modernization Act reduced the premarket notification system for food contact substances to 120 days.

Summary: common themes of panel members were the need to

• increase reliance on academia, as the government science base has and is eroding;
• give more responsibility to industry, with government providing knowledge for HACCP operations;
• increase FDA funding to meet its statutory mandate;
• eliminate or clarify and expedite FDA and FSIS duplication of efforts; and
• coordination FDA and FSIS regulations for same product.

• Center for Science in the Public Interest (CSPI, Caroline Smith DeWaal) and Public Voice for Food and Health (Robert Hahn)

• both recommended a single food safety agency; and
• food safety regulatory programs should not be linked with food marketing programs.

• Consumers' Union (Mark Silbergeld)

• need "substantial consolidation" (which may be in the form of a single agency) to set standards, enforce the standards, and direct research;
• both CDC and EPA should remain outside food safety regulatory mechanisms; and
• need a single federal food safety research plan that is efficient and goal oriented.

Summary: common themes for all panel members were - agencies sometimes have authority but lack political will to implement agreed upon solutions-example: Salmonella hazard in eggs;

• USDA and FDA need similar authority;
• need more outcome-oriented research programs;
• resources of agencies are not adequate to the task;
• agencies' responses and actions are not uniform;
• stakeholders often do not know who is in charge of a particular food safety issue, and federal employees frequently do not know either; and
• an ideal food safety system is coordinated, comprehensive, unified, hazard based, and streamlined. It has adequate funding and authority and strong educational programs.

• Food Marketing Institute (Jill Hollingsworth)

• retailers have developed training programs for employees;
• "Fight BAC" could be a model food safety program; and
• need a single food safety voice as supermarket chains may have operations in multiple states and retailers deal with many federal, state, and local regulatory officials (one retailer reports to 88 different regulatory authorities).

• National Restaurant Association (Judy Dausch)

• need to ensure that food safety agencies coordinate and harmonize their food safety standards;
• development of national food safety standards should be based on risk and current available science;
• need to increase funding for food handler training programs; and
• need mandatory training and certification programs for state and local food safety inspectors.

• United Food and Commercial Workers Union (Jackie Nowell)

• food handlers have a key role in influencing food safety;
• food handlers often have low socioeconomic status;
• food handler positions often provide no sick leave or other benefits, thus workers may come to work sick;
• language barriers and high turnover limit the effectiveness of training programs; and
• new regulations (HACCP) require time to implement, and have unanticipated effects on worker conditions (temperatures that are higher/lower than the comfort zone, exposure to cleaning agents).

• Association of Food and Drug Officials (Dan Smyly)

• need to enhance effectiveness of federal, state, and local infrastructure currently in place rather than start over; and
• develop a blueprint for a vertically integrated national food system with input from all the major stakeholders.

• National Association of State Departments of Agriculture (Richard Kirchhoff)

• need to improve food safety education for consumers;
• HACCP system is a sound approach; however, parts of system (food animals) are left out of the regulatory scheme; and
• need more resources directed toward food imports.

• Council of State and Territorial Epidemiologists (Dale Morse)

• much public health activity is local;
• resources are in short supply and downsizing is occurring;
• need greater intra- and interagency coordination on major outbreaks;
• need to update technology; and
• allocate more resources to strengthening infrastructure for outbreak  investigations.

• Institute of Food Technologists (Bruce Stillings)

• all food safety related functions should be placed in a single food safety agency;
• what works well: US has one of the safest food supplies in the world, regulating foods for biotechnology is science-based, and use of HACCP approach to inspection;
• food safety and public health must be primary purpose of food safety system, let industry address quality issues;
• food safety programs must encompass all aspects of food safety; and
• base food safety programs on risk assessment.

• American Public Health Association (Eric Juzenas)

• need single centralized, independent food safety agency to eliminate inconsistencies, gaps, and overlaps;
• what works well: good sanitation standards, food and nutritional supplement labeling, and food additives approvals;
• need mandatory recall authority;
• need to identify risks of imported foods;
• need food safety risk communication;

• need regulation of fruits and vegetables;
• need to address increasing resistance of pathogens to antimicrobials;
• need to address concerns about stress placed on animals during production;
• need improved surveillance system;
• need better coordination among state, local, and federal food safety programs;
• changes detrimental to national food safety program would be privatization of public health labs and too narrow a focus on a risk assessment; and
• if no agency has a primary responsibility for food safety, difficult to interest any agency in assisting with and focusing on food safety concerns.

• Michael Taylor, former Deputy Commissioner for Policy of the Food and Drug Administration and Acting Administrator of the Food Safety and Inspection Service at US Department of Agriculture.

• the current reactive-based system dates back to beginning of the century;
• shifting to science-based, preventive framework is the right track;
• for new system to be successful, need to deploy resources in a new way, and to develop preventive strategies on system-wide basis;
• current statutory and organization framework are obstacles to success due to fragmented nature of food safety research and misallocation of inspection resources;
• need to pursue organizational change due to a present lack of clearly defined responsibility and accountability; and need statutory reform.

• Lester Crawford, former Administrator of the Food Safety and Inspection Service

• present system is disorganized;
• National Advisory Committee on Microbiological Specifications in Foods, which involves four departments working effectively together, works well;
• USDA conflicts associated with both promoting and regulating agriculture does not work well; and
• no system for congressional oversight.

Summary: common themes by both Michael Taylor and Lester Crawford

• prevention of chronic illness and long-term public health concerns are different from food safety concerns;
• inspection and regulation should not be separated;
• resistance to change within FDA and USDA comes from both internal and external sources;
• any changes should be premised not on reducing staff and saving money but on re-deploying, modernizing and upgrading;
• problems with food safety research: not enough money, spread out from points of control and regulation, not a high priority in US research establishment, externally driven or investigator driven rather than a tool for achieving the food safety initiative;
• CDC should be a generator of fundamental knowledge; and
• need to address communication barriers among CDC, FDA, and FSIS.

• Food Animal Concerns Trust (FACT, Richard Wood)

• need a single food safety agency that has a single mission focusing on food safety, has clear roles and responsibilities, has regulatory authority joined with enforcement powers, and has farm-to-table regulatory responsibilities.

April 29-30, 1998

National Academy of Sciences Lecture Room

Wednesday, April 29

8:30 am Welcome

Allison Yates, Study Director

John Bailar, Chair, Committee

9:00 am International Perspectives for Ensuring Safe Food

Ian Munro, CanTox, Inc.

9:45 am Organizational Strategies

J. Clarence (Terry) Davies, Resources for the Future

10:30 am Break

Ensuring Safe Food: Multi-Faceted Viewpoints

10:45 am Food Producers Panel Presentations

Gary Weber, Animal Agriculture Coalition

Thomas Van Arsdall, National Council of Farmer Cooperatives

John Aguirre, United Fresh Fruit and Vegetable Association

Donald McNamara, United Egg Producers

11:35 am Food Processors Panel Presentations

Steve Ziller, Grocery Manufacturers of America

Rhona Applebaum, National Food Processors Association

James Hodges, American Meat Institute

Cary Frye, International Dairy Foods Association

Richard Gutting, National Fisheries Institute

12:35 pm Lunch

1:30 pm Food Ingredients, Food Packaging, and Food Distribution Panel Presentations

Andrew Ebert, International Food Additive Council

John Block, Food Distributors International

Jerome Heckman, The Society of the Plastics Industry, Inc.

2:10 pm Consumer Panel Presentations

Caroline Smith DeWaal, Center for Science in the Public Interest

Mark Silbergeld, Consumers Union

Robert Hahn, Public Voice for Food and Health

2:50 pm Food Handlers Panel Presentations

Jill Hollingsworth, Food Marketing Institute

Judy Dausch, National Restaurant Association

Jackie Nowell, United Food and Commercial Workers Union

3:30 pm Break

3:45 pm Open Forum and Discussion

Richard Wood, Food, Animals Concerns Trust

4:30 pm Concluding Remarks, John Bailar

Thursday, April 30

8:30 am Welcome

John Bailar

8:40 am State and Local Regulator Panel Presentations

Dan Smyly, Association of Food and Drug Officials

Richard Kirchhoff, National Association of State Departments of Agriculture

Dale L. Morse, Council of State and Territorial Epidemiologists

9:20 am Stakeholders in Policy Development

Bruce Stillings, Institute of Food Technologists

Eric Juzenas, American Public Health Association

10:00 am Break

10:15 am Former Federal Government Food Safety Officials

Michael Taylor, former Deputy Commissioner for Policy of the Food and Drug Administration and former Administrator of the Food Safety and Inspection Service at the US Department of Agriculture

Lester Crawford, former Administrator of the Food Safety and Inspection

Service at the US Department of Agriculture

11:00 am Closing Remarks, John Bailar