Food Protection Trends - November 2010 - 677

At the production stage, FDA has long been active on the farm through our oversight of animal drugs and animal feeds, the egg safety rules we issued last summer, and increasingly in response to the outbreaks that have put produce safety high on the agenda. Produce safety is one of the most challenging food safety tasks FDA has ever faced, due in large part to the diversity of crops, regions, growing and packing practices, scale of operations, and markets. Despite this complexity, the public, industry and Congress have high expectations. They are looking to FDA to provide leadership on produce safety by setting standards that can provide the common, enforceable benchmark for safe growing, harvesting and packing. The only way we will get this right is through intense and sustained interaction with a wide range of participants in the produce sector. We have been doing a lot to foster that interaction long before we issue a proposed rule through listening sessions and by visiting farms, both large and small. We’ve worked with partners at USDA, in state and local governments, and extension; and we’ve sought the perspectives of a range of stakeholders, including groups representing sustainable and organic agriculture. We’ve heard a lot about how our standards should address the key risk vectors of water, soil amendments, worker hygiene, and animal intrusion. They should be risk-based, scale appropriate, reflect current best practices, and be clear enough to be implemented and enforced. They should also include quantifiable performance standards wherever possible to define the standard of care for key risk factors, and they should be flexible enough to take into account emerging science. We’re impressed with the difficulty of getting the rules right, but we think the vastness and diversity of the produce sector means it will be even more challenging to achieve broad compliance with any standards we set. It won’t happen just through business-as-usual inspection and enforcement. It will require a true community effort — including education, training, extension, the work of our state and local partners, and the collaboration of industry groups. The second major point in the farm-to-table spectrum is food processing. Our goal is to assure that all food processing facilities implement preventive controls that are appropriate for their operations. FDA has done this on a selective basis for seafood and for juice. The challenge in implementing preventive controls more comprehensively will be akin to the one posed by produce: How do we discover and express the standard of care regarding preventive controls in the great diversity of food processing settings? How do we assess the adequacy of preventive controls if we don’t know the potential hazards and the feasible interventions for minimizing them? To gain this understanding, we’ll draw on our own expertise and research, but we also will learn from what practices many companies already implement and know work.

Transportation is another part of our focus on prevention throughout the food safety chain. It’s an area that hasn’t received a lot of attention, but food safety breakdowns during transportation can have wide ranging visibility and impact. We need more information, so we issued this spring an advance notice of proposed rulemaking to request information about the food and feed transportation industry. For example, we want to know what proportion of vehicles transport both food and nonfood products? What types of records are currently kept by transporters and what additional records would be useful? We need this input to decide how we can make a difference. In retail, FDA’s work has long been grounded in partnerships, such as the ones embodied in the Food Code and the Conference for Food Protection. FDA works especially closely with state and local governments, which exercise primary regulatory over-sight and conduct inspection at retail. FDA’s role is to promote science-based food safety principles to prevent foodborne illness. One way we do this, of course, is through our work with the Food Code—updating the document and encouraging state and local authorities to adopt the Food Code as the authoritative, science-based model code for preventing foodborne illness at retail. And we promote the Voluntary National Retail Food Regulatory Program Standards for state and local authorities. But together—government and industry must do more. One of the things FDA has done over the years is survey practices in retail establishments and rates of compliance with key elements of the Food Code. In fact, FDA will soon release its 2009 report and a 10-year trend report that show progress in some areas but continued high rates of non-compliance on critical risk factors. We plan to work with our state and local partners and the retail industry to address these issues and promote even wider adoption of, and compliance with, the Food Code. Consumers are the final preparers of food, and the last step before a potential case of foodborne illness. Of course, we don’t regulate consumers, but we have to work with them as part of the solution to preventing foodborne illness. Just like anyone else along the farm-to-table spectrum, consumer behaviors can introduce hazards and minimize hazards. FDA has a long history of work in this area, but we are looking at a new commitment, working through the Partnership for Food Safety Education, to take consumer education to the next level. This includes investing in the research to know what works to improve consumer food safety behaviors, using new communication channels to reach consumers, and measuring progress. So, that’s the end of the whirlwind tour. We have a big agenda, but the “we” is a whole community of people and institutions who share the goal of a stronger food safety system and a safer food supply.

NOVEMBER 2010 | FOOD PROTECTION TRENDS

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Food Protection Trends - November 2010

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