In 2009 I was asked by the editors of the New York Times to join in a discussion at “Room For Debate” about a single food-safety agency and to post a 300- to 400-word position statement on that issue. After whacking away at it, I finally got it down to size. Now, with renewed discussion about consolidating food-safety regulation, the commentary seems timely again. Here is my original submission:

Perhaps it was Nicholas Kristof who coined it – “Department of Food” in an op-ed column in the New York Times. Certainly, and with some regularity, U.S. Sen. Richard Durbin (D-IL) and Rep. Rosa DeLauro (D-CT) have held press conferences touting the miraculous powers of a “Single Food Safety Agency” – combining USDA’s Food Safety Inspection Services (FSIS), which oversees beef, poultry, pork and lamb, with FDA’s Center for Food Safety and Applied Nutrition (CFSAN), which oversees everything else. I think they split jurisdiction if pepperoni is added to a cheese pizza?

At the mere thought of one department of something, or a single agency of anything, this compulsive trial lawyer begins to fidget with delight. However, as I slowly stop organizing my briefs (no, not those), I also think about the few times that governmental reorganization has consolidated many agencies into one – like Homeland Security. What comes to mind about Homeland Security is “the heck-a-of-a job Brownie” did after FEMA was absorbed, and seeing three-year-olds and grandmas being frisked in airports.

But, I digress. I am not against the idea per se, but the issue of a governmental reorganization may or may not work. Perhaps it is more than “re-arranging the deck chairs on Titanic,” but I am simply not that sure. I worry that reorganization is potentially work without real progress. OK, perhaps it would be more efficient over time, and of course, you would get a new logo on stationery and a new organization acronym.

Perhaps what might make a bit more sense is to put on hold that new stationery, because we are now in the middle of yet another devastating foodborne disease outbreak that has sickened over 600, hospitalized 150 and killed nine. There’s no FDA or CFSAN head, there’s no CDC head, and there’s simply an acting FSIS head. I am presently reminded of the old adage, “if you are in a hole, stop digging.”

The time has come to pay attention and act and not continue simply to react. Consumers, farmers, suppliers, manufacturers, retailers, regulators and politicians need to work together to make our food supply safe, profitable and sustainable. When a quarter of our population is sickened yearly by contaminated food, when thousands die, we do not have the “safest food supply in the world.” We should, must and can do better. So, let’s do something and stop talking about governmental reorganization. Here are some ideas:

1. Improve consumer understanding of the risks of foodborne illness, and create a popular campaign similar to Mothers Against Drunk Driving — the Citizen Food Coalition, which would use consumer power to promote a no-tolerance policy toward growers and companies that produce tainted food.

2. Proper food safety monitoring begins in the local health professional community. By the time an illness cluster has caught the attention of federal authorities, it’s too late — there’s already a large outbreak. The most important thing we can do to stop large outbreaks at the initial cases is to improve surveillance of bacterial and viral diseases. First responders – ER physicians and local doctors – need to be encouraged to routinely test for pathogens and report findings promptly and directly to local and state health departments at the first sign of questionable symptoms — diarrhea, vomiting, fever.

Right now, for every person counted in an outbreak there are 20 to 40 times more people who are sick but never tested. The more we test, the quicker we know we have an outbreak and the quicker it can be stopped. Local, state and federal health agencies need to work together. Turf battles need to take a back seat to stopping an outbreak and tracking it to its source. That means resources need to be provided and coordination encouraged so illnesses can be promptly stopped and the offending producers – not an entire industry – are brought to heel.

3. Provide tax breaks for companies that push food safety interventions and employee training and fund university research to develop better technologies to make food safe and for testing foods for contamination.

4. We need a new emphasis on revamping homeland security, as well as changing the way international terrorism is dealt with. It’s time to start thinking about this issue from a food safety standpoint; imports pose an increasing risk, especially if terrorists were to get into the act. Points of export and entry are a logical place to step up monitoring. We need more inspectors – domestically and abroad – and we need to require that they receive training in how to identify and control hazards.

5. We need all food manufacturing plants to have mandatory HACCP, GMPs and SOPs with risk-based inspections, product testing for bacteria and viruses and complete transparency.

6. Lastly, we can’t overlook the legal issues in food safety. Right now there are too few legal consequences for sickening or killing customers by selling contaminated food. We should impose stiff fines, and even prison sentences, for violators, and even stiffer penalties for repeat violators.

So, let’s make some progress in stopping food poisoning and then later pick out the new stationery.