Food Safety News, citing the Hagstrom Report newsletter, said on Jan. 14 that the Obama Administration may be considering a plan to merge the functions of food safety as currently performed at the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) and the Department of Health and Human Services Food and Drug Administration (FDA) into one large single food safety agency, located within FDA.


The General Accountability Office (GAO) released a 345-page report to Congress in March, 2011, that proposed changes in efficiencies in federal programs that would save us tax payers $200,000,000,000. I will confess I have not and will not read the entire report. My interests are limited to the 4-5 pages in the report on food safety.

In those few pages, the GAO calls for a single food safety agency at the federal level, but the $200 billion in savings is not impacted by this suggestion. Their proposal for a single food safety system is budget neutral.

And herein lies the rub. Meat and poultry plants must have daily, continuous inspection to operate. It is the law. If a single food safety agency combines employees, duties and dollars, FDA can do nothing more than it is currently doing. Nothing will change.

Food Safety News posted an op-ed by me on Monday, Jan. 16, that was in opposition to a single food safety agency. Since I have publicly professed to detest complainers who bring nothing to the table to solve problems, here are my thoughts on what real change could look like and still be budget neutral: 

The GAO report cites the massive Iowa-based Salmonella egg recall and outbreak as a perfect example of the fragmented food safety inspection system, and it is a great example.

But it does not take a single food safety system to place all eggs under the USDA. Congress “scrambled” the egg inspection system back in 1970 when it passed the Egg Products Inspection Act that gave egg products to the USDA and shell eggs to the FDA. They can unscramble this situation by putting all eggs under the USDA. Simple move, no mess, and it would address a problem that became elevated in the public’s eye in 2010.

They can also put all animals, including bison, fish and seafood, under the USDA and add all products from animals to the USDA list. That would bring all dairy products, eggs and even casings under USDA/FSIS daily continuous inspection.

Currently casings (animal intestines), all fish except catfish, and bison, unless they pay for FSIS inspection, are under FDA’s regulatory authority. Yes, by law FSIS has catfish but not bison. See, we don’t need a massive single food safety agency to correct these silly deficiencies. We just need some common sense.

Congress could also say that any meat or poultry product that has been inspected at least twice and cooked as a final kill step under FSIS inspection does not need to be inspected again when used to make soup, flavorings, baby food, packaged sandwiches, pizzas etc.


There is currently a system called dual jurisdiction at work in many facilities. Let’s look at pizza as just one example.

A company makes frozen vegetarian pizza and gets no inspection by FDA. Add shrimp and still no inspection. The tomatoes may come from Mexico, the peppers from Chile, the onions from Guatemala and the shrimp from Thailand.


Add a little pepperoni from an American plant, pepperoni with the USDA mark of inspection on it, and you add the need for daily, continuous FSIS inspection — but just for the conveyor belt carrying the pepperoni pizza.

Same goes for canned soup, baby food, etc. It is gross overkill to require inspection for chicken noodle soup but not for tomato soup, and it has nothing to do with protecting the public’s health.

The inspection system is totally arbitrary when it comes to corn dogs and bagel dogs, open-face and closed-face sandwiches. Exactly the same product, just different packaging, resulting in either no inspection or daily inspection.

I don’t know for certain, but I believe that if USDA removed all the inspectors at the dual jurisdiction plants and put them to work on fish and seafood, eggs and dairy products inspection, it would not only make those products safer, but would probably not increase the cost of food safety.


Nearly 80 percent of all the fish and seafood we consume is imported. Almost none is inspected as it arrives in this country, and certainly the number of countries exporting these products is not limited in any way.

If under USDA authority, these countries would first have to have an equivalent food safety system, including daily, continuous federal inspection. Then they would be subjected to annual audits, and the products they export to the U.S. would be re-inspected at an FSIS import house. Just like meat and poultry are today. Food safety would be improved, and the cost is covered by not having vegetable beef soup receive a level of inspection that is simply not needed.

Laws mandating daily, continuous inspection for meat and poultry were passed many decades ago, long before PulseNet (the national surveillance system for foodborne outbreaks) and improved epidemiology revealed that many foodborne illnesses are from produce and other sources, and that meat and poultry are not necessarily the most important carriers of pathogens that can kill us.

We need change, with this I agree, but we do not need change that substantially increases cost and does not increase efficiencies and effectiveness in the federal food safety system. 

We should not waste time and effort on a single food safety agency that Congress and many food safety experts simply will not support, but instead we should focus on who should do what and why and, as another Nebraskan is famous for saying,  just “git ‘er done.”

  • cjolley

    I;m not surprised Doc Raymond is no longer in Washington. He keeps coming up with ideas that make sense. Although I’m generally for a single food agency, his suggestion about untangling the ‘spaghetti junction’ of food inspection essentially does the same thing – cleans up the mess created by poorly thought out rules and regs.

  • Dr. Raymond is right on target. As a former FSIS employee, I was amazed and appalled at the arbitrary nature of some of the rules governing meat and poultry inspection. His example of open- vs. closed-faced sandwiches has always made me want to either laugh or cry. I witnessed GS9 and GS10 food inspectors waste hours and mileage inspecting plants that utilized minimal amounts of previously USDA inspected meat and poultry in some of their products. Some of these plants were canneries, where an additional the kill step of heat processing made daily inspection rather ridiculous. In my opinion, combining food safety activities of FDA and FSIS into one monstrous bureaucracy would not serve consumers well. Dr. Raymond’s assertion that USDA should handle animal products and FDA should handle plant-based foods is sound. Also, a practical and science-based decision must be made to limit the number of times a meat/fish/poultry product must be inspected before it is presented for consumption to the public.

  • Chuck Jolley

    I;m not surprised Doc Raymond is no longer in Washington. He keeps coming up with ideas that make sense. Although I’m generally for a single food agency, his suggestion about untangling the ‘spaghetti junction’ of food inspection essentially does the same thing – cleans up the mess created by poorly thought out rules and regs.

  • Of course at the margins the distinctions in jurisdiction between the agencies are silly and arbitrary and it would be a fine thing if they could be cleaned up in a way that makes more sense. But sorting this out is tedious, time-consuming and controversial and the agencies have taken stabs at the task, both during Dr. Raymond’s era and at other times, without ever effectively following through. It’s never been important enough for the necessary commitment to be sustained. There is absolutely no reason to think that things are any different today. (Perhaps even less, given all of today’s “we’re in the public health business” rhetoric). And even if this were not the case, at the end of the day you still wind up drawing an arbitrary line simply highlighting the question of why we should have 100 times more inspection resources devoted to the product just to one (FSIS) side of it than we do for the one just on the (FDA) other.