Government Agencies in Food Safety

(Salin 2007 )

Food safety has been an area of intense activity for applied risk analysis in recent years. A succession of highly publicized crises, from mad cow to foot and mouth disease, and most recently avian influenza, have attracted the attention of the public. Fears of deliberate poisoning of the food supply have spurred the US government to establish new requirements for traceability of foods along the supply chain.[1]

The primary rationale for government involvement is to protect public health and safety. Because measures to enhance safety can be costly, the risks of inaction must be balanced against the costs of implementing the regulatory proposals. Risk assessments provide a scientific basis for policy decisions and for refinements of regulatory programs. There have been 6 U.S.-government sponsored risk assessments covering pathogens that potentially are risk factors in food-borne diseases (see for example, Gallagher, Ebel, and Kause 2003). The risk assessments include probabilistic information on the physical processes of food production and distribution, the properties of microbes, and their response to various treatments, among other risk factors.

The US Department of Agriculture’s Food Safety Inspection Service (USDA) and the Food and Drug Administration (FDA) share oversight responsibilities over different aspects of the U.S. food system (Merrill 2005). USDA takes the lead on meat, poultry, and processed egg products and primarily inspects slaughter and processing operations. FDA is the responsible agency for foods sold in interstate commerce, other than meat, poultry, and processed egg products. FDA monitors imported food, although USDA is involved in assuring that slaughter facilities overseas satisfy minimum requirements with respect to their production processes before the output of those foreign plants can be shipped into the USA.

The federal food safety agencies place different emphases on field inspection activities. In 2002, FDA’s food safety regulation budget was $393 million, while USDA’s food safety budget was $704 million (Merrill 2005). FDA has 250 field inspectors to oversee approximately 60,000 food establishments, and allocated 64% of its total food safety budget to field activities. USDA (FSIS) employs 7,600 full-time residential inspectors in approximately 6,000 plants. USDA’s high priority on plant-level inspection is due to statutory mandates (Nelson and Krupnick 2005).

Even if the field inspectors detect contamination, the food safety agencies have weak authority to force companies to recall the product, compared with the product recall powers of other federal agencies involved in consumer safety, such as the Consumer Products Safety Commission and the National Highway Transportation Safety Administration (GAO 2004). Undertaking a product recall is voluntary, and there is no consistent policy among government agencies and firms to define exactly the circumstances that lead to recall.

It is within the federal agencies’ authority to require process control systems in manufacturing plants and to establish standards for reduction of particular pathogens that are of concern. The U.S. food regulatory system has been experiencing a long-term reorientation from its historical roots in visual inspection of meat carcasses toward systems that are based on managerial process control (Hulebak and Schlosser 2002). HACCP, a process control risk management system, was first required by law for the meat and poultry segments of the food industry in 1996 (USDS/FSIS 1996). HACCP was implemented over the next several years according to the size of the facility. Under this regulatory approach, firms bear the responsibility to analyze their production processes, identify potential risks in the processes, establish appropriate controls to reduce those risks, and document the activities for monitoring and accountability (Frey and Patil 2002; Hulebak and Schlosser 2002).

In addition to the federal agencies involved with food, state and local authorities are also involved in inspecting food products and may provide information that leads a firm to recall products. Many foodborne illness outbreaks are identified by medical professionals who report to state and local public health authorities.

References

FDA Food and Drug Administration, Department of Health and Human Services, Risk Assessment of the Public Health Impact of Foodborne Listeria Monocytogenes; Request for Comments and for Scientific Data and Information. [Docket No. 99N-1076] Fed Register 64(88): May 7, 1999, 24661-24663, Federal Register Online via GPO Access [wais.access.gpo.gov] [DOCID:fr07my99-99]

Frey, H.C., and S. R. Patil (2002) “Identification and Review of Sensitivity Analysis Methods,” Risk Analysis, 22:3: 553-578.

Gallagher, D. L., E. D. Ebel, and J. R. Kause. (2003) “FSIS Risk Assessment for Listeria monocytogenes in Deli Meats,” May, s.usda.gov/OPPDE/rdad/FRPubs/97-013F/ListeriaReport.pdf

GAO (U.S. Government Accountability Office). (2004) Food Safety: USDA and FDA Need to Better Ensure Prompt and Complete Recalls of Potentially Unsafe Food, Washington DC, Rpt. No. GAO-05-51, October.

Hulebak, K. L., and W. Schlosser. (2002). “Hazard Analysis and Critical Control Point (HACCP) History and Conceptual Overview.” Risk Analysis, 22:3: 547-552.

Merrill, R, A. (2005) “The Centennial of US Food Safety Law: A Legal and Administrative History.” chapter 2 in Toward Safer Food: Perspectives on Risk and Priority Setting, S.A. Hoffman and M.R. Taylor (eds), RFF Press, Washington, DC.

Nelson, P., and A. J. Krupnick. (2005) “Best Things First: Rethinking Priority Setting for Food Safety Policy.” chapter 9 in Toward Safer Food: Perspectives on Risk and Priority Setting. S.A. Hoffman and M.R. Taylor (eds), RFF Press, Washington, DC.

USDA/FSIS (Food Safety and Inspection Service, USDA). (1996) Pathogen Reduction: Hazard Analysis and Critical Control Point (HACCP) Systems; Final Rule . Available at s.usda.gov/OA/fr/haccp_rule.htm Accessed Jan 3, 2006.

USDA/FSIS (Food Safety and Inspection Service, USDA). (1999) Small Plant HACCP Update, Apr. Available at s.usda.gov/oa/haccp/small8.htm. Accessed Jan 2, 2006.

[1] Public Health Security and Bioterrorism Preparedness Act of 2002, Public Law 107-188, Section 306 Records Maintenance.