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Building an ‘Integrated Food Safety System’ Will Take All of Us

Opinion

Mike Taylor, the U.S. Food and Drug Administration’s Deputy Commissioner for Foods, stated in his address before the 2015 Food Safety Summit that, “If we were starting from scratch, [America’s food safety system] would look different.”

MilkInspectionMainUnder Taylor’s leadership, FDA’s implementation of the Food Safety Modernization Act (FSMA) envisions an “integrated food safety system” to achieve the ultimate goal of reducing the “risk of illness attributed to food from facilities subject to preventive controls rule under the act.” FSMA is intended to ensure that American consumers are safe by shifting FDA’s focus from responding to problems to preventing them.

The May 25, 2015, report from the Boston Globe (“Widespread violations found at Boston’s food spots” by Matt Rocheleau) exposes how important a preventive approach will be based on the large number of critical violations seen in Boston-area restaurants in 2014. The report also begs the question, “What about the role(s) of state, county, and city food inspectors?”

Whereas FSMA specifically references almost all of the other 14 relevant federal cabinet-level food safety agencies such as the USDA, the Commerce Department, the Departments of Homeland Security and Health and Human Services, and relevant sub-agencies such as CDC, the Act places FDA in a position where the agency must employ an integrated approach that also depends on state, university, tribal, and territorial resources.

FSMA extensively mentions state health and agriculture departments, requiring FDA to coordinate with or consult these agencies on actions it is to take to implement the law, use them as part of its food safety activities, or assist them in upgrading services they perform. In general, FSMA respects federal and state responsibilities but seeks to engage synergies that exist between state and federal entities in an integrated way.

While the roles of other government agencies are not specifically mentioned or identified, FDA has stated that an integrated food safety system will be built for addressing FSMA requirements. The agency has identified and even posted on its webpage that the Partnership for Food Protection (PFP) is the group that will help to build an integrated food safety system.

According to FDA, “The Partnership for Food Protection (PFP) is a group of dedicated professionals from Federal, State, and Local governments (partner agencies) with roles in protecting the food supply and public health. PFP is the structure used to meld and coordinate representatives with expertise in food, feed, epidemiology, laboratory, animal health, environment, and public health to develop and implement an Integrated Food Safety System (IFSS).”

One problem with any integration is that the preventive efforts of every agency must be sustainable. Some states debate FSMA’s reliance on state-level inspections because of resource limits — perhaps one of the biggest challenges for an integrated food safety system.

During FDA’s April 2015 public meeting on FSMA implementation, many top FDA executives stressed that the challenges for implementation included not only the issue of Congress funding the entire needed budget for FSMA implementation, but also the problems inherent in training, communicating, collaborating, and sharing data with a large number of state and federal agencies.

States will need funding to bring their programs up to speed on federal standards and to maintain the level of qualified staff. I imagine that we will soon see the states place a greater emphasis on grants or contract funding as being essential to overcome a lack of resources at the state level.

The 1993 E. coli outbreak served as the “9/11 for the food industry” as it woke up consumers and policymakers to the problems with foodborne pathogens. The problems have spread far from being solely associated with meat. Today, spinach, peanuts, and even ice cream have captured the news for sickening and killing consumers. Even CDC stated recently that some of these foods were never on its radar as foods of concern for pathogens. Thus, the implications for restaurants and for county health inspectors should be that problems with safe food could happen anywhere and at any time.

In the May 28, 2015 Food Safety News article, “Health Code Violations in Boston Not Unusual, Not Acceptable,” Roy Costa, founder and owner of the consulting firm Environ Health Associates, stated that, “Issues persist because many restaurants think they’re fine as long as the health department doesn’t shut them down.” Perhaps a fundamental shift in the food safety culture seen in restaurants is that they, too, play a role in an Integrated Food Safety System, that they should not need to wait until a regulator or a member of the Partnership for Food Protection tells them to do something, and that they should never assume that what they are doing is fine simply because the restaurant has not been shut down.

The March 26, 2015, Food Safety News article, “LA TV Station Reports Health Department’s Failure to Announce Salmonella Outbreak,” exposed how some county health departments “do not typically alert the public when they are in the midst of an investigation.” Unfortunately, Brent’s Deli in Westlake Village, CA, stayed open and customers knew of no health concerns even though the Ventura County Health Department noted that serious violations at that restaurant date back to 2007.

I talk with victims or their families who have seen just how devastating foodborne illnesses can be. They often tell me that they never thought that something like this could happen in America, let alone to them. Their worst fears came about due to violations along the way from the farm to fork. ALL of us, including restaurants and local governments, play a role in making sure that the family meal ordered at a restaurant or served at home does not come with a side of fear or regret.

© Food Safety News
  • John Munsell

    The final paragraph above mentions “…..along the way from the farm to fork”. The article primarily focuses on restaurants and health authorities, artfully dodging responsibilities at THE FORK which includes consumers’ kitchens. The article refers to a truly integrated approach, which must include the Fork, including not only restaurants, but also home owners’ kitchens. Ironic how we delicately avoid stating that consumers likewise share responsibility in the food safety continuum.
    The article places much focus on the duties of local, federal, tribal, territorial, state, county and city food inspectors. Excellent point! But, it runs contrary to true, original HACCP philosophy which deregulated the food industry. Folks who discuss FSIS-style HACCP continue to state “Let HACCP Work”, in other words, allow the industry to self-regulate and unilaterally devise corrective actions to resolve the allegedly “rare” instances of foodborne illnesses, the frequency of which would theoretically be greatly minimized upon HACCP’s advent, as FSIS promised in the 90’s.
    To wit: during pre-HACCP public meetings, FSIS continued to state that its role under HACCP would be (1) “Hands Off”. The article’s focus on increased surveillance by the variety of food inspectors constitutes a “Hands On” presence, which frankly must occur. (2) FSIS stated it would no longer police the industry, but that the industry would police itself. Increasing the presence and duties of the above-mentioned food inspectors runs contrary to the idea of an industry self-policing. (3) FSIS stated that it would disband its previous command-and-control authority under HACCP. Well, Mike Taylor is not suggesting that the phalanx of food inspectors be eviscerated of command-and-control authority. And he is absolutely correct. Lastly, (4) FSIS stated that each establishment could author its own HACCP Plan, unique to each plant.
    History since 1998 continues to prove that FSIS has been aggressively non-compliant with all four promises, by intentional agency design I might add.
    What does FSIS and HACCP theory have to do with outbreaks in FDA-inspected establishments such as spinach, peanuts and ice cream to which the above article refers? FSIS has slyly bastardized HACCP, feigning that raw products qualify for HACCP’s deregulatory advantages for food manufacturers. We don’t observe gov authorities reminding us that Pillsbury’s HACCP protocol was specifically intended for ready-to-eat (RTE) foods which must be treated to a lethality step which kills all pathogens. Raw fruits and vegetables have been identified as the culprits in numerous outbreaks, as have raw meat & poultry products.
    Whenever consumers handle and prepare RAW products, consumers need to handle such products as though they are lethal, because they are. Exactly why Farm to Fork must include proactive involvement on the part of consumers. For this reason, FSIS required the meat industry to label products with Safe Handling Statements because RAW meat is potentially dangerous.
    At the same time, FSIS demands for Zero Tolerance and its issuance of Adulterant designations has created a consumer belief that all USDA-Inspected products are safe as is, even though they are raw and lethal.
    The article above places an erudite emphasis on Prevention, which was a foundational demand of original Pillsbury-style HACCP. FSIS however places primary emphasis on Corrective Actions to Prevent Recurrences, actions which are focused downstream AFTER the products are sent into commerce. FSIS demands that Prevention must occur downstream, rather than at the plant of origin, which is not what Pillsbury visualized. Likewise, Safe Handling Labels at the point of consumption suggest end user responsibility, where FSIS now focuses the need for Prevention and Corrective Actions.
    Bottom line: HACCP was not designed for RAW foods. Pillsbury designed HACCP specifically for RTE products, which do indeed qualify for deregulation. I feel quite comfortable eating Spam, hot dogs, and shelf-stable jerky because they’ve been fully cooked. Conversely, raw ground beef and raw chicken are intrinsically risky, and we treat both with respect, because they can kill us.
    So I ask you “How can we assign more inspectors, with greater surveillance, to segments of the food industry which allegedly fall under the HACCP umbrella which guaranteed us that the gov would embrace a “Hands Off” role, in the absence of Command and Control?” Frankly, USDA for one has successfully carried out a Bait-and-Switch in its HACCP Hoax.
    I agree that we need more surveillance of the food industry by gov food inspectors, armed with meaningful enforcement authority. But, let’s don’t allow the same gov to demand the RAW food industry embrace HACCP, which is valid for RTE products. Admittedly, producers of raw food can benefit by implementing some HACCP ideals, such as Hazard Analyses, Prevention, Control Points, etc. However, and this is where FSIS departs from true HACCP, RAW foods lack a Critical Control Point which is only accomplished via a kill (lethality) step. Any food production system which lacks a valid Critical Control Point is undeniably NOT a HACCP system. FSIS deceitfully claims otherwise.
    I also suggest that all food manufacturers greatly increase their liability insurance, because when their raw products sicken consumers who mishandle and improperly cook the raw products, lawsuits will always find the manufacturer liable, not the final preparer.
    But, let’s not allow FSIS to falsely portray RAW foods as being eligible for HACCP’s deregulatory privileges. Zero Tolerance can only be accomplished in RTE foods, contrary to FSIS’ mandates to the contrary. Time to stop hood-winking consumers.
    John Munsell

    • Thank you for your comments. I do believe that consumers at home play a role in food safety. As a matter of fact, I (the author of this opinion piece) worked directly with the USDA to craft and gain approval for the Food Safe Handling Labels on all packages of raw meat and poultry at the grocery stores. I also helped to gain USDA labels for Mechanically Tenderized Beef in grocery stores.
      My point is that the soon to be implemented FSMA regulations and policies (the authority of which Congress delegated to the FDA – whereas most of your comments pertain to the FSIS which is part of the USDA) depend on enforcement at the local levels. We do not have local government inspectors in our home kitchens, but they are in the restaurants. While this article is critical of that aspect of food safety along the farm to fork spectrum, it was not intended to minimize the need for the actions of all – including consumers.

      • John Munsell

        Thanks Darin. One point I focus on is that FDA continues to refer to HACCP, just like FSIS does. However, neither entity admits that any HACCP Plan without a legitimate CCP is not true HACCP. We will never have consistently safe RAW meat, unless it is subjected to a kill step……in which case, it will no longer be raw. With tight budgets, the prospect of increased funding for additional inspectors at the local and state level is unlikely. John Munsell