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Michael Taylor's Views on Food Safety

by: Jill Richardson

Tue Jul 07, 2009 at 23:17:57 PM PDT

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If you were wondering what Michael Taylor, the new food safety guy at the FDA, thinks we oughta do to make our food safer, look no further than his recent testimony before the House Ag Committee on April 2, 2009. Highlights are below.
Jill Richardson :: Michael Taylor's Views on Food Safety
First, he noted that the two agencies with the most power over food safety - the FDA and the USDA's Food Safety and Inspection Service (FSIS) are not the only two government bodies that deal with food safety:

I would note, of course, that the Environmental Protection Agency (EPA) also plays an important role in food safety as the agency charged by Congress with setting tolerances for pesticide residues in food, and many other agencies within HHS and USDA and across the federal government perform food safety data collection, research and inspection activities.  Moreover, literally thousands of state and local health and agriculture departments and laboratories play critical frontline roles in the nation's food safety system, with primary responsibility lodged at the state and local level for responding to illness outbreaks and regulating the food safety practices of the one million retail food outlets in this country.  

That said, his testimony focuses on the FDA and FSIS. He called today's food safety system "fundamentally flawed," saying:

As the National Academy of Sciences (NAS) and Government Accountability Office (GAO) have found in numerous studies, the federal food safety system is plagued by obsolete laws and food safety strategies, inadequate and often poor use of resources, and fragmented organizational structures. Based on these problems, the GAO has placed the federal government's food safety program on the list of federal programs at high risk of failure, and GAO included food safety among the 13 problems most in need of urgent attention by the new administration and Congress.

I wouldn't disagree.

He goes on to say that food safety reform REQUIRES strong action by Congress - the food safety agencies can't fix the mess alone. Then he outlines his plan for making our food safe. He says his vision is "rooted in" a 1998 NAS report "Ensuring Safe Food from Production to Consumption." He calls for:

1. Taking a farm-to-table approach to preventing food safety problems;

2. Using risk analysis to better understand potential hazards, design interventions, and prioritize prevention efforts;

3. Collecting necessary data to support risk analysis, through monitoring of the food supply, foodborne illness surveillance, and food safety research;

4. Harnessing the primary role of food producers, processors, retailers and consumers in preventing food safety problems;

5. Implementing preventive process control, such as HACCP, throughout the food industry;

6. Establishing science-based food safety performance standards;

7. Carrying out a modern inspection program to support the vigorous enforcement of food safety standards;

8. Integrating food safety efforts among federal, state, and local food safety agencies;

9. Allocating government food safety efforts and resources in relation to risk and opportunities to reduce risk; and

10. Observing sound food safety practices at the final preparation and consumption stage through well-informed commercial food handlers and consumers.

And here's the thing... these are all good ideas, IF they are applied properly. IF you identify that major risks in our system are unhealthy conditions in factory farms and fast line speeds in slaughterhouses and eliminate those risks, you will probably make real progress towards a safe food supply. But is Taylor willing to do that? Is anybody in our government? So far, no.

Furthermore, I question the government's ability (or interest in) applying these principles to small, independent producers. The government tends to craft laws in a way that are most suitable for large corporations, but they apply them to everybody. I'm not saying that small producers cannot cause foodborne illness or that they are inherently safe, but I'm saying that we have a trade-off to consider. We should either regulate the little guys fairly or not regulate them at all (instead of regulating them unfairly, with laws written for big corporations).

Going back to Taylor's testimony, he identifies "Gaps in the Food Safety Tool Kit." He notes that the FDA's food safety laws date back to 1938 and the USDA's date from 1906. Back then the legislators writing those laws could not predict the problems we have today, nor could they predict the scientific advances we've seen in the past century.

He says the FDA lacks:

* A legislative mandate and accountability for reducing foodborne illness;

* Authority to hold the operators of all food facilities accountable for implementing modern preventive controls that reduce the risk of foodborne illness;

* An inspection mandate that ensures an adequate frequency of inspection;

* Authority to routinely examine company records to verify that proper food safety procedures have been followed;

* Authority to administratively detain products that have not been produced under proper conditions;

* Authority to require that companies be able to provide immediate traceback information so that major outbreaks can be more promptly contained;

* Authority to order a recall of unsafe products and enforce rigorous implementation of needed recalls;

* Authority to penalize violations of food safety standards other than through cumbersome and time-consuming court proceedings; and

* Authority to hold importers accountable for ensuring that imported food is produced using modern preventive controls and in a manner that meets U.S. standards.


That's all pretty much true, although much of it will be fixed if the Food Safety Enhancement Act passes.

Here's what he says about FSIS, which will NOT be fixed by any current legislation that I know of:

The core FSIS legislative mandate is to conduct inspection in slaughter houses and in plants that process meat and poultry products.  The original 1906 mandate for carcass-by-carcass slaughter inspection was a response to The Jungle and Upton Sinclair's documentation of diseased animals, gross insanitary conditions and often intentional commingling of bad meat with good.  The visual inspection Congress mandated was effective in addressing those problems, but, as found by the NAS and other expert bodies, this mode of inspection is ineffective in dealing with today's food safety concerns.  Pathogenic bacteria are, of course, invisible.  

Congress also mandates daily FSIS inspection of all plants that process meat and poultry products, without regard to the nature of the operation, which today may range from the relatively high-risk processing of raw ground meat products all the way to the pizza plant that applies pepperoni slices to a pizza that will be cooked to a very high temperature.  In the case of the pepperoni pizza plant, FSIS will already have inspected the slaughter of the animals that provided the meat and the manufacture of the pepperoni at the processing plant.  

Slaughter plants and many meat processing plants are among the most sensitive and risk-prone links in the farm-to-table food safety system and deserve substantial government inspection.  It is very clear, however, that the current inspection mandate and the resulting mode of inspection at FSIS is obsolete and wastes government resources that could be used more effectively in those plants and elsewhere to prevent foodborne illness.  

Despite its obsolete statutory mandate, important changes have occurred in the FSIS program in recent years.  Prior to 1994, the official position of the Department of Agriculture was that slaughter houses and plants processing raw meat were not responsible or accountable for pathogen contamination, on the ground that consumers were expected to properly cook the product.  We changed that when I was Administrator of FSIS by (1) declaring that E. coli O157:H7 is an adulterant in raw ground beef, (2) mandating that all slaughter and processing plants implement a modern preventive control system called HACCP (Hazard Analysis and Critical Control Points), and (3) establishing for the first time microbial test requirements and pathogen reduction performance standards.  

Since the reforms of the mid-'90s, FSIS and the industries it regulates have made progress in reducing pathogens, but progress has been constrained by the agency's obsolete statutes. On the positive side, minimizing pathogen contamination is now seen as a central part of the FSIS mission, and the professional staff at FSIS has been creative in using the tools they have to pursue pathogen reduction.  Reductions in the incidence of contamination have been achieved for some pathogens, such as Listeria in deli meats and Salmonella in poultry, and many companies in the meat and poultry industry have substantially increased their own pathogen testing and pathogen reduction efforts in response to both FSIS initiatives and market incentives.    

On the negative side, an industry legal challenge has put a cloud over the enforceability of the pathogen reduction standards FSIS established in the 1990s, and those standards have not been updated in the way we originally intended.  Thus, FSIS is forced to rely on obsolete benchmarks and indirect means in an attempt to drive pathogen contamination down to levels we know are achievable, when it should be setting and enforcing science-based performance standards to protect consumers.  Moreover, because meeting the obsolete statutory inspection mandate consumes nearly all FSIS resources, it has limited capacity to invest in more modern approaches to enforcing every plant's duty to prevent food safety problems through HACCP and other means.  

There is room for more food safety progress at FSIS within the current statutory framework, but FSIS is unable to fulfill the vision of a modern, science- and risk-based food safety system because it lacks a modern food safety law.  Most importantly, FSIS lacks:

* A legislative mandate and accountability for reducing foodborne illness;

* A mandate and authority to deploy resources efficiently to prevent foodborne illness;

* Authority to address food safety problems at the point of animal production, where many pathogen problems originate;

* A mandate and clear authority to set and enforce science-based pathogen reduction performance standards;

* Authority to order a recall of unsafe products and enforce rigorous implementation of needed recalls; and

* Authority to conduct food safety research.

Next up, he talks about funding. He's totally right on here. As he notes:

FDA regulates 80% of the food supply and the vast majority of food imports with a budget of about $650 million.  FSIS regulates about 20% of the food supply with a budget of about $1 billion.

In other words, the FDA's totally broke. This is also something that will be improved if the Food Safety Enhancement Act passes, although it won't be improved enough just by the $500 user fees stipulated by the bill. Congress will have to kick in some cash as well.

Another good thing he says is:

It is essential to remember, however, that FDA will never have enough resources to be successful on food safety as long as it remains in a primarily reactive mode.  That is why it is so important that Congress give FDA the mandate and authority to change the food safety paradigm to one that holds all food facilities accountable for implementing modern preventive controls and meeting science-based standards and gives FDA the tools to enforce that duty efficiently and effectively.

He goes on to talk about funding at FSIS. It's not a lack of funding there, but an inefficient use of the money. His words here are too vague for me to make a determination whether I agree with him or not. He says that FSIS needs":a strong inspection mandate" and it needs all the money it gets. Terrific. But what kind of inspections? Will the inspectors physically inspect the animals or will they push paper? And will there be microbial testing to determine if meat is tainted or not? How much will the slaughterhouses and processing plants be allowed to "self regulate"?

Marion Nestle has long called for one food safety agency. Right now it seems like Congress isn't interested in making that happen. However, with food safety split up between many agencies, you get a lot of silos. Here's what Taylor says:

That is why the NAS recommended unifying all federal food safety programs under a single, accountable leadership structure.  

I believe the creation of a single food safety agency is a worthy long-term goal, but consideration of that possibility should take a back seat to the immediate need and opportunity we have to improve the food safety programs of FDA and FSIS, where they sit today within HHS and USDA.

So that's what Michael Taylor is going to be up to now that he's officially a part of the Obama administration.

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