By Michael R. Taylor - 12/11/07 04:30 PM EST
The Bush administration’s new plans for improving import safety and strengthening the Food and Drug Administration’s domestic food safety program are a classic case of the glass being half full and half empty. The plans contain many important ideas and elements on which Congress should build in modernizing the food safety system, but they fall short of establishing a modern, preventive system that can be effective in today’s enormously complex global food system.
The plus side begins with the simple fact that the Bush administration has recognized finally that government has a role to play in food safety and that its scientific and regulatory tools need to be strengthened. The administration also has embraced, at least verbally, many of the concepts that food safety experts and authoritative bodies, like the National Academy of Sciences and the Government Accountability Office, have been recommending for years.
Key concepts include the importance of preventing food safety problems rather than simply reacting after people are hurt, building food safety in from the farm to the table and using risk analysis to guide priority setting and resource allocation in the government’s program.
The FDA plan is particularly strong on these points and presents a very positive vision of a revitalized food safety program that is harnessing the best science to provide national leadership in improving food safety. This is as it should be. And that vision for FDA’s role makes the glass at least half full.
The defect in the FDA plan unfortunately goes to the heart of what is required to have a modern food safety system that is effective in preventing food safety problems. And, as ironic as it may be for the Bush administration, the defect involves an over-reliance on the role of government and an under-reliance on the role of the food industry.
The unavoidable reality is that government doesn’t make food and government can’t make it safe. That’s the industry’s job, and it’s the most fundamental duty food producers and processors owe to America’s consumers. Government’s job is oversight. It should set standards for food safety and hold the industry accountable for meeting them through strict inspection and enforcement.
In a prevention-oriented food safety system, the most fundamental standard government should establish is simple: Any business involved in producing, processing and marketing food must have a plan for making it safe, based on modern preventive controls. Many leading food processors and retailers not only know this but already implement very effective systems to prevent food safety problems. They know food safety doesn’t just happen; it’s the result of a plan.
The problem is that many of the nation’s 44,000 food manufacturers and processors, 114,000 food retailers, and 935,000 restaurants do not have effective food safety plans. And the Bush administration proposals would allow this to continue. Rather than calling for Congress to establish a duty for all food businesses to have an effective plan for making food safe, the administration merely seeks authority for FDA to mandate preventive controls on a case-by-case basis and only if FDA can demonstrate through rulemaking that a particular food is associated with “repeated, serious adverse health consequences or death.”
This is a policy of reaction, not prevention. It puts the burden of understanding the risks inherent in any food operation on FDA, rather than on the business running the operation. And it empowers FDA to hold companies accountable for prevention only after people have gotten hurt. The fact is that FDA already has this power and has exercised it by mandating preventive controls for seafood and fruit juice.
As the lessons of Chinese imports and domestic produce have taught, this ad hoc approach to prevention is not good enough. It leaves FDA reacting to and trying to solve problems that the food industry should be held accountable for preventing in the first place. FDA needs more resources to do its food safety job — a point not addressed in the recent proposals — but it will never have enough resources to do industry’s job as well.
But let’s call the glass half full. Congress should embrace the many positive elements of the administration’s proposals and use them as a springboard for the badly needed transformation of our food safety system into a modern, preventive system that properly harnesses the capacities of both industry and government to make food safe.
Taylor is a research professor at the George Washington School of Public Health and Health Services. He was deputy commissioner for policy at the Food and Drug Administration and was administrator of USDA’s Food Safety and Inspection Service.