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.