By Mike Robach - Vice President, Corporate Food Safety and Regulatory Affairs 

Time to Modernize the U.S. Food Safety System was presented at the U.S. Department of Agriculture - Agricultural Outlook Forum 2010. 

The impetus for reforming U.S. food safety laws and regulatory structures is reaching critical mass, driven predominantly by several recent high-profile food illness outbreaks and recalls. The food processing sector is ready to engage in the modernization chorus and collaborate with other stakeholders to drive change. 

If Congress, too, is serious about moving forward with reform, it must avoid the temptation to patch and fix antiquated laws with band-aid solutions. Changing our food protection laws should draw upon the collective wisdom of all appropriate stakeholders in order to stand the test of time. Some of our most important food laws date to the early and mid 1900s. We don’t reexamine them often, so clearly the time for updating is upon us. 

For years, the food safety debate has been artificially constrained because it has been cast within existing legal framework and government structure. Lawmakers have the ability to aid in the dialogue by temporarily setting aside discussion of the regulatory structure. What is needed most critically is to bring together industry and government public health and food safety experts, food science scholars and consumer interests to help create a “vision” for what an advanced system should accomplish. Without a clear vision, it will be impossible to create a modernized legal and regulatory framework. 

Hopefully, after a productive discussion, the group would conclude that an effective food safety system must be based in science and risk analysis. In turn, science and risk analysis should drive the allocation of government resources. 

Stakeholders would probably agree that zero risk is unattainable, yet minimizing risk is achievable. And most would agree that public health protection should involve collaboration among government, industry and academia. We believe a true, three-way partnership would be the best way to achieve targeted public health goals. 

Another important part of the discussion must be the safety of the global food supply. The United States, through its involvement with multilateral trade groups, the global food industry and various intergovernmental organizations such as the World Organization for Animal Health, better known as the OIE, the World Health Organization, and the UN’s Food and Agriculture Organization and Codex Alimentarius, has significant influence on the global harmonization of food safety standards. 

Risk 

Science tells us every food has a safety risk profile. We can compare the safety of a fresh, organically grown salad mix, a ground turkey burger, a can of soup and bottles of pasteurized and unpasteurized fruit juice. A risk profile involves analysis of things such as viruses, microbes and chemical residues, as well as product uses. Each stage of the supply chain that delivers food from the farm to the dinner table is obligated to improve, or at a minimum not degrade, the food risk profile. 

It is important to note that a tremendous amount of the data required to do this correctly already exists. Ideally, all of this information should be integrated with data from the Centers for Disease Control and state public health agencies so causes of food-borne illnesses can be better understood. 

CDC and the states have the ability to collect the data needed to develop a comprehensive and definitive road map of illness attribution. But a deficiency exists: There is no standardized means of collecting and analyzing data. Addressing the need for better coordination should be a top priority. 

The current legislative structure doesn’t allow this knowledge to influence the flexibility of the system. Today as much as 80 percent of government food safety dollars are allocated to the U.S. Agriculture Department for the inspection of meat and poultry products. And 100 percent of USDA’s share is focused on processing plants rather than throughout the supply chain. The remaining 20-odd percent of federal funding is managed by the U.S. Food and Drug Administration. It looks after foods that have traditionally been thought of as involving less risk. We need to shift resources to where they can be used most effectively to improve the safety of all food. 

Moving forward 

In our view, a modern food regulatory system must give the government the flexibility to move its resources around. Legislation should give, for example, more freedom to operate to food makers that are hitting performance targets, including the incentive and entrepreneurship to try new approaches and develop new innovations. With data, it would be easy to determine if a company or a particular plant is or is not meeting requirements. Depending on the risks involved, government should be able to target its efforts with increasing levels of scrutiny. Both the carrot and the stick could be effective. Consider this - stopping the line in a 4,500 head per day beef processing plant costs as much as $1,800 per minute. Tough new scrutiny, coupled with a greatly increased probability of downtime in the event of infractions, is a stick the size of a tree trunk. 

In conclusion 

Crafting an effective new food safety system is an undertaking worthy of everyone’s best efforts to achieve a common goal for common good. The public would be well served if the Administration were to appoint a senior leader within the White House Domestic Policy Council to work on this challenge. The effort should involve all of the stakeholders appropriately and be transparent to interested parties. If there are differences of opinion, biases or serious conflicts, they should be brought out into the open and resolved through candid discussion and debate. Under the light of day, the best ideas rise to the top. In the end, all ideas should be tested against the following criteria. Would this policy reduce the food risk profile? Would it improve public health in real and meaningful ways? How could the policy give leaders and innovators the freedom to implement changes that increase the safety of food? In essence, all of these questions – and the answers – are aimed at improving the health of Americans. And that’s a noble and worthy goal for all of us to undertake.

For more information on food safety, visit our Food Safety Leadership section.