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School Food Safety System Needs Improvement

Our nation’s school children returned to classrooms in droves last month.  Many underprivileged kids began looking forward to their first day back at school just as last year’s school session was letting out for summer break.  They knew that along with summer vacation came the harsh reality that breakfast and lunch could not consistently be counted on, but the return of school would mean the return of two guaranteed meals, Monday through Friday–no small comfort for millions of kids.

School meal programs are a coordinated effort between Federal agencies, state education agencies, and local food authorities, which operate in school kitchens and cafeterias across the nation.  The collaborative effort that goes into the purchasing, distribution, and preparation of food for our school children is a complex and daunting task when we look at it on a global scale.

I think we can all agree that establishing an effective and efficient food product recall notification system for the general public is a task even more complex and daunting.  But how about a notification process between the federal agencies tasked with food safety oversight and the schools that participate in the federal government’s school meal programs?  It should theoretically be easy to notify a school that it might be serving its students E. coli-contaminated taco meat or peanut butter sandwiches with a dash of Salmonella from foods procured through the federal program.  A report by the United States Government Accountability Office (GAO), also known as the investigative arm of Congress, however, concludes that these federal agencies are making it as difficult and inefficient as possible to get such information to the people who need it – schools.  

Following a series of recent, high-profile foodborne illness outbreaks, the GAO launched an investigation into the federal school meal program as it relates to food recalls.  You can read the full report and final conclusions here (PDF, 46 pages).

If you are at all like me, you will quickly lose count of the number of times you let out an audible, “you’ve got to be kidding me!”  While the GAO’s ultimate conclusions and recommendations for the Secretary of Agriculture are certainly laudable and worthy of implementation, one cannot help but sit in bewilderment that these recommendations were not being carried out already.  

Before I comment on some of the findings and recommendations in the GAO’s report, it is helpful to have a basic understanding of the federal oversight process for foods served throughout the nation’s school systems.  The U.S. Department of Agriculture’s (USDA) Food and Nutrition Service (FNS), is responsible for overseeing federal school meal programs.  These programs provide food products to the schools through the federal commodity program, which accounts for about 15 to 20 percent of the food served in school-provided meals.

The USDA’s Food Safety and Inspection Service (FSIS) is responsible for establishing regulations to ensure the safety of the nation’s supply of meat, poultry, and processed egg products, while the U.S. Department of Health and Human Services’ Food and Drug Administration (FDA) is responsible for nearly all other food items.  It is, quite obviously, a highly fractured and inefficient system that has led many to conclude that a complete overhaul is the only true fix.

But in discussing the current structure, what immediately jumped out at me was the realization that the agencies in possession of nearly all necessary and relevant information about potentially contaminated foods–USDA and FDA–are really awful at sharing that information with the very people they are tasked with protecting.  For example, FSIS has in place procedures that allow it to provide immediate notice to FNS when there is an investigation pertaining to possible contamination of FNS commodity food products.  But despite being USDA’s sister food protection agency, FDA has no such similar procedures in place.  Why does it take a GAO investigation to bring such a glaring deficiency to the FDA’s attention?

Proper notice is the first step in the entire recall process and will ultimately determine whether or not a school is informed that it is serving its students food items under serious investigation for contamination.  Rest assured Joe Public, because FDA is on it now.  FNS and FDA are currently developing a memorandum of understanding on this specific deficiency that will be issued…sometime.  Excuse my cynicism, but this is not some extraneous procedure–this is a central problem that needs immediate action today, not more talk to schedule a meeting to discuss some possible changes to maybe add to a memo at some possible point in the future.  Set a deadline, get it accomplished, and do it now.  It’s your job.

Another frustrating problem lies with a potentially useful and efficient tool at FNS’s disposal.  FNS has the ability to issue administrative product holds, essentially pulling a product from use within FNS’s school meal programs, when it is notified of an initial food recall or upon notice of an investigation by USDA or FDA into possible food product contamination.  This tool would be especially useful because–as both USDA and FDA are well aware–ensuring that food recalls are carried out effectively and efficiently is especially crucial when those foods are going to young children who have a much higher risk of suffering serious health complications due to foodborne illness.  So when does FNS issue these administrative holds?  Great question–it seems no one, including FNS itself, has any idea.  It turns out USDA has given FNS no factors or criteria to consider when attempting to determine whether such an action is advisable.  Instead, FNS relies solely on the recall notices eventually issued once an outbreak is in full effect.  In other words, once people have begun consuming the product and are now infected with a potentially deadly pathogen.  

This isn’t rocket science.  The best time to stop an outbreak is before it occurs, and the only way to effectively do that is to use the tools at your disposal–like administrative holds–that stop products from being distributed or used while still in the investigation phase, not issue recall notices after the contaminated product has made its way into the bellies of our school children.

Speaking of recall notices, this brings me to yet another “duh” revelation in the GAO’s report.  As things currently stand, when a federal school meal programs commodity product is placed under investigation for suspected contamination, USDA or FDA notifies FNS, which in turn notifies individual states, which then notify the schools.  At least this is how the process is supposed to work.  But as the GAO report makes clear, often times FNS will either wait to provide recall information to the states until a recall notice has already been issued, meaning days or weeks can pass before a state is fully informed, or FNS will provide incomplete and inaccurate information to the states, making it needlessly difficult, if not impossible, for the schools to identify the food products potentially in their possession subject to the recalls.   

Even if FNS timely provides information to states, it does not follow through to ensure that information is properly communicated to the schools.  To somewhat address this glaring deficiency, FNS has tried communicating the food recall information directly to the schools via an e-mail notification system.  But as with nearly everything the government does, the process is made so needlessly cumbersome as to be ineffectual.  For example, initially FNS limited the number of characters of text in the notice to 300.  That is only slightly more than the characters allotted for a text message!  Not surprisingly, the notices lacked any product names, or states or schools that received the recalled product.  To its credit, FNS has since increased the number of characters to 1000, but why limit the number in the first place?  Finally, the whole e-mail system requires the end user, presumably the school official designated as the federal school meal program liaison, to register through FNS’s website, and then later confirm the registration.

This voluntary registration process is ridiculous.  FNS should require that each school participating in its federal school meal programs designate at least one primary person and one backup person as an FNS programs liaison.  Those liaisons should be required to provide an e-mail address and telephone number through which FNS would automatically send e-mail and computerized telephonic recall notification.

Once the database is established, FNS must actually use it.  As the GAO report reveals, in the recent Peanut Corporation of America Salmonella outbreak, the FNS e-mail system was not used until a full two days after the FDA had already publicly announced the expanded recall.  Once again, a potentially useful tool went to waste.  As we all know, the simple act of sending an e-mail is, well, simple.  Not to mention that it is also quick and cost-efficient.  Given the rapid transition to instantaneous communication, there is simply no reason or excuse for FNS’s snail-mail approach to providing food recall notices to our nation’s schools.

I’ll just end this rant with a classic contract law axiom that struck me as particularly apropos–time is of the essence.  Each moment wasted in the chain of notice is yet one more opportunity for contaminated food to make it further down the line and onto the lunch tables of our nation’s school children.  The GAO report is full of excellent and worthy recommendations, but there really should not have been a need for the investigation in the first place.  Creating an efficient and effective recall notification system for the foods that are served to our nation’s children should have been accomplished long ago.  A remedy for this problem must be done right, and done right now – before one child’s guaranteed breakfast or lunch leads to a lasting reminder of the failures of our nation’s food safety system.

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