Food safety is important, but it is not the only consideration when choosing foods.
For example, for people in the U.S., the aversion to dog meat and horse meat is more a cultural matter than a safety issue. For Jews and Muslims, the aversion to pork might have begun as a safety issue historically, but now it is more a religious and cultural matter. Some people shun genetically modified foods because they fear such foods would be unsafe to eat, and some shun them for other reasons, such as their environmental or economic impacts. Some people prefer eggs from free range chickens not because it makes a big difference in the quality of the eggs, but because of their concerns about animal cruelty. Foie gras was banned in California because of concerns about animal cruelty, not food safety. Pink slime may be viewed as disgusting even if it is safe to eat. Some people might wish to avoid certain foods because they are farmed or manufactured in ways that harm the environment. No one has argued that whale meat or turtle meat is unsafe. Shark fin soup is not unsafe. Products might be shunned because they are produced under onerous conditions for workers. Some people think particular foods should be controlled because they increase the likelihood of becoming overweight.
Snack manufacturers argue that there are no bad foods, only bad diets. What should regulatory agencies do about that, especially when many people do have bad diets?
A clear distinction should be drawn between unsafe products and unsafe practices. If infants are fed with tea or cola, perhaps along with breast milk or infant formula, they might not get sick immediately, but they may experience health consequences in the future. What about the case in which, to save money, one grandmother diluted the infant formula by half, because, she said, the baby wouldn’t know the difference? Here it is not the products but the practices that are unsafe. Where does one draw the line between safety concerns in the traditional sense, i.e. pathogen contamination, and other food-related concerns?
Agencies with responsibilities for food regulation should be explicit about what is within the scope of their work, and what is excluded. They should explain how they do their work, and be plain about its limitations. This is important because non-specialists don’t make sharp distinctions between questions such as “is it safe for you?” and “is it good for you?” Many people take approval of a product by an official-sounding agency as an endorsement of that product. The manufacturers take advantage of this. They know that if they claim something has been approved by an agency, many customers will think that means it is good for you, or has other virtues. On close examination we might see that approval is actually based on little more than the manufacturers submitting the proper forms, with the agency making no independent assessment of any kind.
If the national food regulatory agency’s mandate is to look only at safety in the narrow sense of worrying about immediate harm to users, which agencies would attend to other considerations that might be important?
To illustrate, there is good evidence that long chain fatty acids in the diets of pregnant women and infants affect the child’s development, not only physically but also intellectually. Ocean fish and beef from grass-fed cows have good fatty acids in them. However, some industrially produced meats – cultured fish fed mainly with grains and cows fed with grains rather than grass – are not as rich in these crucial fatty acids. How should factors that affect consumers’ long-term intellectual development be addressed? Which government food agencies should look after them?
If infant formula manufacturers make bogus claims that synthetic fatty acids added to infant formula make important contributions to infants’ development, who will call on them to account for these claims? If these are not safety issues, what should we name them?
In India, there is widespread malnutrition among young children mainly because of the widespread poverty, and the fact that many are fed a grain-based diet. Many families are vegetarians, and India’s Public Distribution System emphasizes the provision of highly subsidized grains. Young children can survive on a purely vegetarian diet, but they are likely to be healthier if they eat a balanced diet that includes animal products such as meat, or at least milk or eggs.
Food safety agencies might simply insist that uncontaminated grain is safe to eat, and these issues about the overall diet are beyond their mandates.
Even if it is safe, infant formula might not prepare children for good development in terms of physical size, maturation, intelligence, and visual acuity. The product could be safe by some standards, but still result in important deficiencies in the long term. We can call these questions regarding the product’s nutritional adequacy.
Safety is about ensuring that the product does not cause immediate harm, but that is not enough. There are things infant formula is supposed to do. The quality of infant formula depends not only on its safety, but also on its nutritional adequacy, its functionality.
These issues are of particular concern in a globalized food system. The Codex Alimentarius Commission, the World Trade Organization, the World Health Organization and the Food and Agriculture Organization of the United Nations have roles relating to that system, but in practice there is no global agency that ensures the quality of foods that enter into international trade. Often national standards established for exported products are weaker than the standards for products that are consumed domestically. For many years, horse meat was exported from the U.S. even though it could not be sold in the U.S.. Under some conditions, infant formula produced in the U.S. for export is exempt from rules regarding adulteration and misbranding.
On its page explaining FDA approval, the agency says:
– FDA does not approve infant formulas before they can be marketed. However, manufacturers of infant formula are subject to FDA’s regulatory oversight.
– Manufacturers must ensure that infant formula complies with federal nutrient requirements. Manufacturers are required to register with FDA and provide the agency with a notification before marketing a new formula.
FDA requires that manufacturers adhere to the list of required ingredients for infant formula. If the product meets those requirements and has no serious contamination, it is assumed to be safe. The FDA posts notices about contamination issues, but not about the many other issues that might be raised about the quality of infant formula or any other food.
Apart from that, FDA gives no attention to its nutritional adequacy. Which agencies have responsibility for dealing with considerations other than safety?