— OPINION —
By Bryan Hitchcock
At the request of U.S. Food and Drug Administration Commissioner Dr. Robert Califf, the Reagan-Udall Foundation for the FDA (FDA Foundation) launched an external evaluation of the FDA’s Human Foods Program on September 8, 2022. The goal was simple: examine ways to better secure the nation’s food systems and supply chain. The evaluation examined everything from structure and leadership to resources and culture.
On December 6, 2022, the Foundation shared its recommendations on steps the FDA can take to improve how it executes its regulatory responsibilities and strengthen its relationships with state and local governments. The 51-page report called for sweeping changes throughout the agency, and its impact has been swift.
Media, activists, and the public alike viewed the report as “scathing” and being highly critical of the FDA. Among the issues impacting the FDA, the lack of a single clearly identified person to lead was cited in the report as one of the biggest deterrents to the program’s effectiveness. The report also recommended the FDA be restructured so policy and enforcement are more closely aligned.
Since the release of the report, many have been left to wonder what the future will look like for the agency whose public health mission touches everyone while overseeing 78% of the U.S. human food supply, animal feed as well as good nutrition promotion.
The FDA has played a critical role in ensuring the United States has one of the safest food supplies in the world, but that food supply is evolving, and the FDA must evolve as well. This idea is widely accepted; the only question is what should that evolution look like?
To start, there must be an even greater emphasis on incorporating science and technology to better protect our food supply. The creation and roll-out of the Food Safety Modernization Act and most recently FSMA Sec. 204 Traceability Rule as well as the Agricultural Water Rule are positive steps towards a new era of smarter food safety. The Traceability Rule, for example, will enhance recordkeeping standards for producers, manufacturers, processors, packers, food service operators, retailers, and other supply chain participants with foods identified on the Food Traceability List. It identifies critical tracking events in the supply chain, such as cooling, initial packing, shipping, receiving, and transforming the goods that would require records to be captured containing key data elements. The Agricultural Water Rule focuses on a key risk point for some foods. In short, these regulatory systems focus on addressing foods that have been known to cause foodborne illness outbreaks and recalls.
But that is only one part of the food-safety puzzle the FDA must solve. Realizing FSMA’s food safety prevention goals require a nimble and forward-looking organization. The FDA must evaluate and increase resourcing levels while anticipating increased challenges and complexities to further improve on the delivery of an even safer food supply for U.S. consumers. This means prioritizing food safety risk assessment and increasing its focus on what processes can be employed in identifying areas of concern, such as toxic elements and allergens.
The new version of the FDA must also drive a greater level of resiliency through global harmonization of U.S. regulations on key components in the food supply. Harmonization of regulations ensures that foods can be delivered from other countries when resiliency issues arise.
Inter-agency collaboration must continue to evolve, as well. FDA has worked closely with federal agencies such as the USDA and CDC, as well as other departments at the state and local levels, but there are opportunities to further advance these efforts. These federal, state, and local agencies look to the FDA for its leadership and coordination. One area where further coordination is needed is in food and nutrition research. While FDA has a limited research budget, its expertise is critical in driving food and nutrition research decision-making in other agencies.
Finally, the FDA must continue improving on its consumer awareness and education as it seeks to earn or regain the public’s trust. Updating the Nutrition Facts Label, the 2020 launch of the national consumer education campaign, the pending Healthy claim and front-of-pack labeling research are positive steps, but there’s more work that needs to be done. Increasing the timeliness of decisions on proposed rules and standards aimed at addressing significant public health-related concerns is critical to building trust with the public and building an FDA better prepared for the future of food.
Yesterday’s FDA announcement aligns well with these outlined priorities. Emphasizing clear organizational structure and leadership focused on operational efficiencies will unlock resources as the first step in meeting the future food system challenges. The important role of science and technology, nutrition science and stakeholder partnerships across state, local and non-governmental organizations are clearly highlighted in today’s announcement.
Despite its standing as a global leader in food safety, the FDA is facing big challenges with a food system that is constantly changing. The FDA must evolve to address current and future food safety challenges, as well as deliver on its public health mission. It must also continue to work closely with leading organizations like the Institute of Food Technologists to ensure the global food supply is the safest it can be, especially during this current period of change.
About the author: Bryan Hitchcock is chief science and technology officer at the Institute of Food Technologists (IFT), a nonprofit scientific organization committed to advancing the science of food and its application across the global food system. He joined IFT in 2019 as senior director, food chains, and executive director of the Global Food Traceability Center. Prior to joining IFT, Hitchcock spent nearly two decades at PepsiCo, serving in a variety of process and product development leadership roles.
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