4.4 Information, Communications & Integration
Food Recall Management—FDA should have cooperative agreements with state and local food protection programs for the purpose of conducting strategic food safety inspections and surveillance.
Currently, three unfunded cooperative programs exist where states perform independent regulatory control: interstate milk shipments, retail food and food service, and shellfish shipment. The Environmental Protection Agency [EPA] has cooperative agreements with state pesticide programs and utilizes the states activities and results for enforcement and planning purposes. Utilizing cooperative programs and nationally recognized standards will create national uniformity, reduce duplication of efforts, and allow us to address food safety challenges in a more coordinated fashion. States are better positioned, for example, to take on new roles in mandatory food safety regulation beginning at the farm level. Working with imported foods is another burgeoning area to leverage state resources.
A number of states are leading the way in mandatory requirements for vegetable growers and packers. California and Florida have introduced mandatory programs for specific commodities in their states. FDA should model these programs through cooperative agreements so they become nationally accepted. New York and Texas have imported food initiatives with various federal agencies in these states and successfully monitor imported foods that enter into domestic commerce. These programs should be expanded to other states through cooperative agreements.
Federal food safety agencies must be authorized to share food product distribution information with State and Local government during the course of outbreak investigations, recalls and other food emergencies.
Quick response action prevents foodborne illness and saves lives. State and Local agencies are in the best position to respond quickly or to conduct recall effectiveness audits and ensure that contaminated food products are removed from commerce. State Health agencies need distribution information to conduct thorough foodborne illness outbreak investigations and link similarly exposed cases of illness. Currently, distribution information is held as proprietary information and the federal agencies are unable to share this information unless State representatives sign non-disclosure agreements or memorandum of understanding agreements that can not be adhered to or may place States in violation of the federal Freedom of Information Act. Effective response to emergency situations such as Class 1 recalls, which involve contaminated foods cannot be accomplished until this matter is resolved.
For example, North Carolina recently employed an Incident Command System [ICS] utilizing state and local government officials from a multitude of agencies within that state to address a widely marketed chili sauce recall. They performed more recall audit checks in North Carolina than the rest of the country combined and removed from sale approximately 32,000 units of the tainted product from domestic channels in that state. They also found a large number of these botulism-tainted products in children’s camps and other non-traditional food venues ready for sale or service. Federal agencies need to review their response efforts with recalls and establish a formalized strategy with state and local government to significantly improve recall response as was done in North Carolina.
FoodShield– The National Communications Platform for ALL Food Protection Stakeholders
Rapid and accurate communications between federal, state, and local officials and industry is the foundation of a successful response to minimize the public health and economic impact of any food emergency. The need for improved communications between all stakeholders is commonly cited in lessons learned from real events and exercises. The FDA and USDA must require all federal, state, and local food regulators, public health officials, and other agencies with a role in food protection to use a central communications platform.
FoodSHIELD allows the diverse groups of regulators, public health officials, laboratories, industries, academia, and other stakeholders that are responsible for protecting the nation’s food supply to interact and function as one unified network. The result will be enhanced emergency preparedness, identification, response, and recovery efforts to minimize the public health and economic impact of any food emergency. Multiple layers of security exist within FoodSHIELD allowing users to securely share information with a targeted audience. Communication tools including workgroups for sharing documents, polling tools for obtaining situational awareness, 24/7 emergency contact directory, and webinars for training and meetings build the partnerships necessary before, during, and after an emergency.
FoodSHIELD is the premiere national communication, collaboration, education, and training tool among the farm-to-table food and agricultural sectors. However, the lack of investment and promotion by Federal counterparts has limited its adoption. NASDA recommends further promotion, adoption, and funding of FoodSHIELD as the national communications platform for all food protection stakeholders.
Laboratory Issues—NASDA believes that federal agencies should be directed to establish protocols by which they can accept state inspection and food sampling analytical work and use it in enforcement activities including import alerts. The promotion of ISO 17025 accreditation by providing funds to meet and maintain accreditation will exponentially increase the Nation’s laboratory capability and capacity and allow for international acceptability of data.
Failure to accept food safety information developed by the states creates delays in addressing public health risks and increased costs. A 2001 survey of food safety program managers from all 50 States, conducted by AFDO found that, nationally, State Public Health and Agriculture labs analyze more than 300,000 food samples each year. Federal agencies must integrate state and federal inspection and analytical data to guide operational, enforcement, and policy decisions. The U.S. Food & Drug Administration [FDA] does not currently accept State inspection and analytical data and must duplicate analysis before acting to protect consumer health and safety.
In the last 5 years, the New York State Department of Agriculture and Markets has coordinated 1,400 recalls of imported food products from 61 countries based on laboratory analysis of the food products. FDA re-analyzed only 13 of these food samples from the 1,400 and issued an import alert in all 13 instances. FDA did not act on the remainder of these foods that NYS found to be in violation of State and Federal requirements.
The Food Emergency Response Network (FERN) is a nationwide network of federal and state laboratories capable of testing foods for biological, chemical, and radiological contamination. The FERN network builds vital analytic surge capacity for responding to a terrorist attack on food. NASDA supports efforts to expand the FERN system through cooperative agreements and technical support to states.
Food Labeling—More effort needs to be placed on finding effective ways to inform consumers of risk without relying solely on warning statements placed on food products. Criteria need to be established on which to base justification for warning statements or any other disclosure about a food product. Food label claims must be both true and not misleading. Labels are powerful ways to inform, persuade, frighten or misinform consumers and care should be exercised to require only information that represents a material fact. Warning information should only be required when warranted by experimental or clinical evidence.
The United States food supply is rapidly changing as consumers demand diverse and minimally processed foods. At the same time, the number of people at high risk for foodborne illness (pregnant women, individuals with compromised immune systems, the elderly and the very young) has never been higher. Unfortunately, food safety educational efforts have not kept pace.
Consumers frequently can not evaluate microbiological risks when they are purchasing food products. Organisms such as E. coli 0157:H7 can cause severe illness when a susceptible individual consumes even a few organisms. Consumers have no way of knowing when low level contamination is present and they must rely on government agencies and the food industry to ensure that the foods they purchase are safe. Although outbreaks of severe illness are relatively rare, when they do occur, they are often associated with consumer feelings of outrage and broken trust.
Warning and safe handling labels are used to inform consumers of potential foodborne illness risks. Food producers are reluctant to have their products publicly linked with foodborne illness and prefer more general food safety educational approaches, such as the "Fight BAC" campaign. A 1996 consumer survey conducted by the Food Marketing Institute suggested that consumers take action to reduce their risks of foodborne illness in response to information contained in safe handling labels. Sixty five percent of consumers participating in the survey indicated the labels made them more aware of food safety issues. However, only 43% reported changing their behavior based on this information. It was not determined if the behavioral changes were maintained over a long period of time.The most commonly reported changes were:
- Increased cleaning/disinfecting for food contact surfaces ( 41%)
- Cooking foods to proper temperatures (19%)
- Increased handwashing (19%)
- Not thawing meat on kitchen counter (11%).
Disparagement of Ag Products—NASDA supports laws and regulations that requiring factual information be used when making allegations against agricultural products and/or producers will protect the industry and enhance the general public welfare by prohibiting the dissemination of false, disparaging, and economically damaging information.
Apple growers were financially devastated in 1989 by the highly-publicized Alar scare. It was later determined that disseminators of the sensationalized allegations against apples had no recognized,
scientific data to validate their charges. This prompted agricultural interests aggrieved by the apple scare to seek ways to deter such efforts in the future. One option, which several state legislatures have enacted, is to promulgate legislation protecting producers from unfounded scare campaigns. Biotechnology is an emerging tool that will likely become an important part of agriculture’s future, resulting in the development of a host of new food products. This technology and its products are and will continue to be the subject of emotionalized, undocumented, unscientific attacks by certain organizations. To prevent this situation from occurring, the free flow of agricultural products and the financial security of producers must be protected.
Education—Public education should include a general, science-based food safety program directed toward all consumers and target programs for those persons at high risk for foodborne illness. Consumer education should also provide information on technological advances, such as irradiation and agriculture biotechnology that can enhance the safety of the food supply, to promote wider consumer acceptance of such beneficial progress. Federal law should also provide consistent information regarding warning labels and other information statements on food products.
The final control in any system of food safety rests with the consumer. Observations in the United States and other countries have demonstrated that the incidence of foodborne illness can dramatically decline as a result of active public education and effective media coverage. Government and industry must share the responsibility for educating consumers on appropriate food handling and cooking practices.
While it is important to make information available to sensitive populations, statements that are required on some products, but not on other similar products, lead to confusion and misinformation about those products. NASDA would welcome the opportunity to work with federal policymakers on a consistent label and information policy for food products.