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?

  • Reggie

    First you need an agency to evaluate the validity of these “considerations other than safety” of which you speak. An agency that applies good science and good sense then punishes the living bejeezus out of quacks and charlatans who try to convince us GMO foods are unsafe, for example, or eating pork will send you to hell. Leave it up to religions to dictate to their followers how to eat, like halal and kosher. Punish those religious zealots who try to impose their fanatic food beliefs upon all of us. A good old fashioned sentence like stoning or burning at the stake would be appropriate.

  • “For people in the U.S., the aversion to dog meat and horse meat is more a cultural matter than a safety issue.”
    Your statement is true in regard to US horse meat, not because it’s safe but because the litany of banned drugs in it (one of them a human carcinogen) have not been publicized by the media. The public thinks it’s safe and it is the antithesis of such.
    It’s understandable you didn’t know this. I didn’t know it, but then I did some research. I then wrote an article on it, “How Safe Is That Horse Meat?” on
    It’ll disabuse you of any idea that horse meat is safe. Feel free to spread its hazards far and wide. The public needs to know and as one who reports on Food Safety issues, you would be a good candidate to inform them.

  • nancy

    Romantic notions of “quality” are hardly as important as factual concepts of food safety. If you doubt that, spend a weekend perched on the crapper from food poisoning and see how romantic you feel. We do not live in a Barbie & Ken fantasy world no matter how persistently foodies might believe otherwise.

  • Sara

    I appreciate this article! Thanks for putting some thought into something SO often overlooked, particularly (and understandably) in FSN.
    Food quality is at least as important as food safety, if not more so. Food safety concerns aim to prevent immediate illness, while food quality concerns aim to prevent long-term illness and even better, to increase long-term health. Who’s to say which one is more inconvenient? Ask a person struggling with type 2 diabetes about how “romantic” it is to be losing eyesight, to endure the symptoms of high and low blood sugar, to suffer from nerve pain and numbness in the feet or have amputations due to poor circulation, or live with hosts of other lifestyle issues. I know several people who have suffered from these very symptoms so it’s no exaggeration and it’s no more of a picnic then 48 hours of vomited from food poising. In fact I would call it worse. It’s relatively clear that type 2 diabetes is diet-related (if not diet-caused), since obesity is one of the number one factors in developing it. But certainly the strain put on the pancreas to process highly-refined carbohydrates is key as well.
    I bet those now suffering from type 2 diabetes would have appreciated some food quality along with their food safety instead of the slow poisoning they endured with the advent of processed, convenience foods lacking in nutrition and high on the “food safety” scale.

  • Reggie

    See there, that’s exactly what I mean about quacks and charlatans.
    Some fool makes the absurd claim “processed, convenience foods” and “highly-refined carbohydrates” in and of themselves cause type II diabetes. No recognition of genetic predisposition, only passing notice of the role of obesity. This is precisely the sort of hyperbolic fanaticism that should be tempered by a scientific regulating body.
    Evaluate the claim, expose it as malicious nonsense then punish the living bejeezus out of the snake oil salesman pushing the lie. I’ve collected a tidy pile of nicely sized throwing stones here at my feet for the sentencing festivities. Damned false prophets.

  • E. Putnam, Sacramento

    This unusual article, rambling about as it does, nicely illustrates a dangerous confusion surrounding the emerging modern notion of “food quality”. With all due respect to the author, a strict separation of church and state should prevail regarding nutrition science, epidemiology, geriatric medicine and food safety in all its aspects. Otherwise valid science becomes frivolously diluted with the taint of irrational, almost spiritual beliefs injected in random sequence as ambitious foodists battle one another for popularity and political power (witness the bizarre goings on in the “raw milk” circus or the current emotional angst and debate over the farm bill). A separation of proven fact from popular fiction should rightly be overseen by government because even academia is actively caught up in the cyclic advancement of invalid political opinion (witness Marion Nestle at NYU and her unapologetic unscientific pronouncements in many of her commercialized “Food Politics” blurbs).
    Culture and popular opinion have their places but so do rational thought and intelligent respect for fact. Particularly in the business of feeding the world’s population we must not permit quasi-religious zealots to ride roughshod over solid science and good common sense, or risk returning to famines and follies of historic proportions. Simply put, “food quality” and those who force their superficial judgement of it upon all of us must meet with some reasonable checks and balances, for they are motivated less by our collective welfare than they are by the advancement of their own peculiar political agendas.

  • husna

    Nice article that reminds us that we need to do a lot more nutrition education at every level to address not only food safety, but food quality issues as well.
    In response to Reggie’s comment above:
    Nobody imposes their religious dietary restriction on another. It is just a matter of respect as humans to respect the dietary restriction of millions of people around the world and the First Amendment right of every American.

  • husna

    Nice article that reminds us that we need to do a lot more nutrition education at every level to address not only food safety, but food quality issues as well.
    In response to Reggie’s comment above:
    Nobody imposes their religious dietary restriction on another. It is just a matter of respect as humans to respect the dietary restriction of millions of people around the world and the First Amendment right of every American.

  • Jen

    I don’t understand how food quality is anywhere near as important as food safety. If you have a great product, say grass fed organic beef, and it is contaminated during processing by E. coli, does the quality override the fact that the meat could indeed make someone very very ill? Safety should be the one constant people expect from food that is regulated. Obviously, safety is not guaranteed, but it is what governement and food suppliers strive for. Quality, on the other hand, is merely an opinion determined by the consumer. One person’s idea of a quality food may be entirely diferent from someone else’s, and someone on a tight budget may not care if the 50 cent can of low grade canner beef came from CAFO beef eating GMO corn and is not as nutritious as the 3 dollar a can organic, grass fed, high omega 3 beef. And if an impoverished person in Somalia was handed a bushel of half rotten apples, they would likely wash them off in the muddy water they have, and gladly eat them.
    Safety is based on science. Quality is based on consumer perception- perception that is constantly changing and depends on many different factors- lifestyle, income, environment, education, etc. That is not to say that science isn’t continually changing, but it doesn’t sway with political climate, religious beliefs, personal beliefs, diet fads, and the latest crazes.

  • Jen

    I guess my point was that people can make decisions about what type of food they want to eat and go for what they assume is a high or low quality food. They can do their research. But, you can’t tell if a food is safe or not – not by smell, taste, touch or sight. You just kind of expect your food to be safe.

  • Ken

    Jen makes a cogent point here. For people who cannot otherwise accurately evaluate anything, they should rely upon the price to guide them — so the $3 can of yuppie beef is good and the $27 can of snob beef is 9 times better….or at least it contains 9 times more magic fairy gas than the $3 can. If you spend enough money you can ingest enough magic fairy gas to elevate you above the common rabble. Then you will be eligible for induction into the foodie cult. But only for as long as you continue to have more money than brains. And even then, when you run out of money you are out of the club, chump. You will be back to eating by yourself from the 50 cent can and you will be amazed how good it is, in fact there is no discernible difference at all!