WASHINGTON — The U.S. Department of Agriculture suggests more than 20 years of work from its Economic Research Service may “help identify efficient and effective means of implementing the Food Safety and Modernization Act of 2010” even though primary authority rests with the Food and Drug Administration.
“While the F.S.M.A. directly affects only F.D.A. authority, its implementing regulations and policies are likely to influence food safety practices throughout the federal government and the food and farm sectors,” the U.S.D.A. said in its December issue of Amber Waves.
The U.S. Congress passed the F.S.M.A. in late 2010 after a series of highly visible food borne illness outbreaks. It was signed into law in January 2011 and is considered the most comprehensive reform to federal food safety laws and F.D.A. authority since 1938.
The key elements of the F.S.M.A. include: requirements for food processors to analyze food safety hazards and implement risk-based preventative controls; mandatory F.D.A. recall authority; enhanced traceability systems; improved surveillance and use of science-based risk assessments to target F.D.A. activities; on-farm safety standards for produce; and redesign of F.D.A.’s import safety control system.
“The farm-to-fork, preventative approach embodied in the act reflects an established scientific/managerial consensus on how to improve food safety systems,” the U.S.D.A. said.
The U.S.D.A. indentified four key areas of focus that may help the F.D.A. reach its F.S.M.A. implementation goal of shifting focus from “catching food safety problems after the fact to systematically building in product preventative measures across the food system, from the farm to the table.”
First, the U.S.D.A. suggested “managerial flexibility” was critical to risk-based controls. Prior to the act, which requires “virtually all” food processors, manufacturers and packers to analyze hazards and adopt risk-based preventative controls, such preventative controls were required only for juice, seafood, meat and poultry under Hazard Analysis and Critical Control Points regulations.
“Based on results from a 2002 nationwide survey and (U.S.D.A.) Food Safety and Inspection Service salmonella product testing data, E.R.S. researchers found that conventional proscriptive requirements were responsible for only a third of the decrease in positive pathogen test samples,” the U.S.D.A. said. “Managerial decisions to invest in human and physical capital, food safety technology and changes in firm organizational structure were responsible for the remainder. The study’s results suggest that H.A.C.C.P. is a more effective means of improving food safety than conventional proscriptive requirements.”
Second, the U.S.D.A. said its research shows recalls and public notification prevent illnesses with limited industry impact. E.R.A. research on the sales impact of major food safety incidents over the past 10 years suggests consumers respond to recalls and outbreaks in a measured way that has limited spillover effects, the U.S.D.A. said.
Third, the agriculture department suggested traceability systems need to vary by product. In 2004 the E.R.S. found diverse characteristics in traceability systems for the three major commodity areas of produce, cattle/beef and grains/oilseeds. It concluded that uniform systems across all commodity sectors were more costly and less effective than systems unique to different sectors, that government traceability systems need to allow flexibility to adjust to changing technology and consumer demand, and that private sector systems meet private market needs but not public needs related to food safety.
Fourth, the U.S.D.A. suggested its work may help the F.D.A. focus efforts on pathogens that cause the most harm from food borne illness measured largely by the cost of the illness as it relates to treatment, including lost time from work, and of the impact on quality of life. The E.R.S. and researchers from the University of Florida recently estimated that 14 pathogens account for over 95% of food borne illnesses and impose costs of more than $14 billion annually, and that just five of those pathogens account for 90% of the illness from the 14.
As the result of earlier work, the E.R.S. on-line Food borne Illness Cost Calculator offers a framework for estimating costs related to salmonella and E.coli.
“The F.S.M.A. builds on efforts to modernize the U.S. food safety system that began in the early 1980s,” the U.S.D.A. said. Many of the new F.D.A. policies already are in use, and E.R.S. and other research can inform F.D.A. policy makers as they move forward.