WASHINGTON — Strong views on a wide range of food safety issues were expressed in a June 9 letter from the American Bakers Association to a congressional committee considering actions designed to make the nation’s food supply safer.
While applauding the focus of the House Committee on Energy and Commerce on enhanced food safety, the letter expressed concern about a wide range of measures under consideration, including facility registration fees to cover the cost of extra Food and Drug Administration funding, country-of-origin labeling, so-called pedigree standards for ingredients and increased government access to records. Additionally, the letter expressed support for a "rigorous, reliable and uniform third-party certification system" and a risk-based approach to food safety.
The letter was submitted by Robb MacKie, president and chief executive officer of the A.B.A., and Lee Sanders, senior vice-president of government relations and public affairs for the A.B.A. It was directed to Representative Henry Waxman of California, chairman of the committee, and to Representative Joe Barton of Texas, ranking minority member of the committee.
While wary of the sources under consideration, the bakers said they strongly support increased F.D.A. funding to provide "the most immediate impact on food safety."
"F.D.A. is in need of additional funding if they are to meet current food safety mandates, much less possible new requirements," the A.B.A. said.
Of concern, though, are provisions in the Food Safety Enhancement Act of 2009 that would attempt to address budget shortfalls through new facility registration fees, taxes that the A.B.A. said would "create a costly burden on the domestic food industry for large and particularly small businesses."
Even more worrisome, the letter said, is wording that could apply registration fees not only to manufacturing facilities but also to depots/distribution centers.
"Current estimates show that approximately 10% of bakery registered facilities are used to produce baked goods while approximately 90% of all baking industry facilities registered with the F.D.A. merely store finished food products for 24 hours or less," the A.B.A. said. "These proposed registration fees would disproportionately impact the baking industry over other food producers."
Explaining its concerns about country-of-origin labeling (COOL), the A.B.A. questioned the need for such labeling. The complexity of baking ingredient sourcing would make COOL especially difficult.
"For example, wheat milled in New York may have been grown in the United States, Canada, Australia, Russia, Argentina or many other countries that export to the United States," the A.B.A. said. Such an example may be made with any number of baking ingredients, the bakers added.
"A.B.A. firmly believes that COOL would prove to be unworkable, too complex to implement on processed foods, very expensive and resource intensive for bakers while doing nothing to improve public health," the bakers said.
Even stronger skepticism was expressed toward the potential implementation of pedigree standards for ingredients. While the A.B.A. supports the traceability approach adopted in the Bioterrorism Act of 2002, the group called "unachievable" requirements aimed at creating a food ingredient pedigree.
"Pedigree requirements are not feasible for complex baked products that may contain upward of 50 different ingredients produced from all over the world," the letter said.
Additionally, the bakers said a comprehensive pedigree would provide no public health or food safety benefit and would create confusion, rather than precision, in the event of a food contamination incident, erroneously implicating a range of ingredient sources.
As an alternative to rash action, the A.B.A. noted the baking industry is working with the Institute of Food Technologists and the F.D.A. to "better understand the impacts of traceability practices and requirements on food producers." The A.B.A. said any congressional action should be based upon similar study.
Proposals to increase F.D.A. access to food industry records also drew a wary response.
"F.D.A. should be required to take measures to ensure that effective procedures are in place to prevent the unauthorized disclosure of any trade secrets or confidential information obtained through expanded records access," the A.B.A. said.
Explaining its support of a good third-party certification system, the A.B.A. said reliable certification would eliminate the need for "prescriptive food safety reforms" that potentially are not a good fit for a particular food company or commodity.
"A.B.A. supports a robust third-party certification program, acceptable throughout the U.S. chain of food distribution," the letter said.
Mr. MacKie and Ms. Sanders concluded the letter with words of support for a risk-based approach to food safety legislation.
"Food safety legislation should make clear that the requirements to establish food safety plans is grounded in risk-based hazard analysis and preventive controls is limited to facilities that actually manufacture food," the A.B.A. said. "Facilities that merely hold finished food products in final packaged form are extremely low risk facilities for the baking industry. Resources would be better focused on high risk facilities."