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Consumers Union's Food Safety Wishlist

by: Jill Richardson

Thu Apr 16, 2009 at 08:00:00 AM PDT


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Consumers Union just published a food safety wish list. Details below. My question to everyone: Do you agree with these ideas? Should there be exemptions for small producers? If yes, what should they be?
Jill Richardson :: Consumers Union's Food Safety Wishlist
  • Food Facility Inspection: All facilities regulated by the FDA, foreign and domestic, should be subject to mandatory, regular FDA inspection, with higher-risk facilities inspected on a more frequent basis - at a minimum once a year. Between 2003 and 2006, FDA domestic food safety inspections decreased 47 percent on average, Currently, domestic food production facilities are inspected once every 5 to 10 years, foreign facilities even less frequently.
  • Traceability: Food should be able to be easily traced throughout the supply chain. [CU specified to me that they intend increased traceability measures aimed at the FDA, not the USDA. That's important because the National Animal ID System, which I oppose, is under the USDA. In other words, CU isn't calling for NAIS.]
  • A Substantial Increase in Resources for FDA: FDA is an agency currently unable to do its job and a significant increase in appropriations for the agency is essential.
  • Mandatory recall authority: The FDA and USDA must be given mandatory recall authority.
  • Disclosure of retail consignees: The FDA should be required to inform consumers of the supermarkets, restaurants, schools, and nursing homes that have received recalled food.
  • Process Controls: Production facilities should be required to develop food safety plans to identify hazards and implement such measures to reduce hazards.
  • FDA Border Inspections: FDA inspects less than one percent of food imports at the border. This must be significantly increased, especially for high-risk foods. [The EU inspects either 20 or 50 percent of seafood at the border, depending on the risk of the individual item]
  • Whistleblower Protection: Federal employees must be protected from the threat of being fired, demoted, suspended, or harassed as a result of providing information or assisting in the investigation of a violation of a food safety law.
  • Civil Penalties: Food companies must be subject to civil penalties for violating food safety laws.
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the biggest problem I see is for cooperatives. (4.00 / 4)
Frequently, small farmers sell to a cooperative, where crops are combined and sold. I'm not sure how Ocean Spray, a cranberry cooperative, could trace back to individual farmers once the cranberries are combined, for example.

This will be, and should be, a total nightmare for industrial producers.

I see there might be a lot of record-keeping for small farms and small restaurants; again, like NAIS, a book-keeping function that they don't have time and staff do perform.

I agree with the notion of inspections, and would add that, like in the restaurant industry, they should be random, with no prior warning an inspection will happen.


Transparency of their OWN processes, (4.00 / 2)
transparency on proposed rule-making, transparency of hiring, that whole revolving door with Big Ag and Pharma needs a sterilizing TON of sunlight doused on it.

They need a real comment system, where the public can not only provide inputs, but track that their inputs are visible to other members of the public.  No black holes for embarassing comments.  There's a lot of good that many small voices could contribute to the overall system.

And a real working group to step through the small producer supply chain, from grown on farm/made in small kitchen to farmers market, or similar pathway.  See what the issues are and engage real conversation about best practices and impacts of proposed rules.

And absolutely NO on the NAIS/NAIS-style approach.  Creepy stuff, when it gets into small numbers.

An FDA mission statement focused on health, healing, prevention.


Here's what I think (4.00 / 1)
Food Facility Inspection: Yes, inspect them, but have different levels of observation for different facilities.  Slaughter houses should have inspections no less than monthly, should be unannounced and unpredictable, and inspectors and facility owners and workers should not be allowed to communicate with one another, verbally, at any time.  It should be formal, all interaction should be in writing and there should be serious consequences for violations of this rule.  Canning facilities should have different regulations and inspection procedures, as should packaging of frozen produce.  Producers of frozen, ready to bake items should also have different regulations and inspection procedures.
Tracability:  Again, specific to the producer and their marketing model.  Producers who sell directly to vendors, such as farmers who sell directly to stores, restaurants, etc. should have very limited requirements because their farms are going to be visited by USDA, and the vendor will probably be the very best of inspectors, cause once he buys it, it's his.  Factory farms, should they continue to exist ;), should be inspected at all points of production and distribution simply because of the nature of their operations..lots of opportunity for contamination. I've always wondered about the frozen veggies, and fresh veggies, how are they cleaned, and with what?  One of the primary reasons I like to grow my own veggies is because I wash them with a good spray before I pick them, then that water doesn't go down the drain it just waters the plants.
Substantial increase in resources for FDA:  They are currently underfunded on purpose.  They just CAN'T protect us they don't have the resources or personnel, see?  We need to have enough inspectors to do proper inspections in a timely manner.  And we need to employ the scientists we are about to educate.
Mandatory recall: Yes
Process controls: Yes, simple and based on simple effective methods
FDA border inspections:  Yes
Whistleblower protections:  Yes
Civil penalties:  Absolutely, with a steep scale.  Harsh penalties for severe infractions that threaten spread of disease, and a risk of being shut down.

That's my 20 cents worth of opinion.
 


Slaughterhouses are already (0.00 / 0)
inspected daily. They aren't allowed to operate w/o a USDA inspector present.

"I can understand someone from Iowa promoting corn and soy, but we are not feeding the world, we are feeding animals and soft drink companies." - Jim Goodman

[ Parent ]
I don't like that set-up (4.00 / 1)
the inspector is part of the operation and is too familiar to remain independent.

[ Parent ]
That's totally a fair point (0.00 / 0)
I've also heard that being an inspector can be an intimidating and dangerous job when you try to actually enforce anything the plants don't want because the plant's employees kill for a living... not exactly the kind of people you want to upset.

"I can understand someone from Iowa promoting corn and soy, but we are not feeding the world, we are feeding animals and soft drink companies." - Jim Goodman

[ Parent ]
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