Regulation vs. self-policing has long been a contentious issue in the food industry — with factions of each camp ebbing and flowing with the ever-rising tides of issues related to food safety in our increasingly global food supply chain.
From testing for Salmonella to labeling a food as natural and discerning the finer points of organic, debate arises as to the degree to which the industry can and should police itself vs. the extent to which it should be governed by federal regulation — and the efficacy of the federal bodies regulating the industry.
One point that comes into play is the extent of governance by guidance documents, defined by FDA, itself, to: "represent FDA’s current thinking ... You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations." On the other hand, to successfully self-police, food companies must have a firm commitment — and reason — to prioritize food safety. While consumer health and brand protection are self-evident rationale for most, a lack of proactive prevention, and even questionable ethics, of the few can cause extensive repercussions for all.
The continuance of high-profile recalls is bringing into question both the efficacy of current regulatory practices and the ability of the industry to police itself. It has also served to make food safety a primary focus of consumers and the new administration, with an ever-heightening advocacy for increased and consolidated regulatory oversight.
It is an advocacy which is gaining strength within the industry, as the Congressional testimony of Kellogg Company President and CEO David Mackay shows. Having had products implicated in the PCA peanut-product recall despite its multi-step supplier qualification process, Mackay detailed Kellogg’s recommendations for strengthening food safety, including support of a single food safety authority and single agency accountability; a requirement for food-company FDA-reviewed risk analysis and documentation; annual FDA inspections of high-risk product facilities; a single food safety standard for facility evaluation; and appropriate FDA intervention and enforcement powers.
As the public tide continues to turn toward increased accountability and even the staunchest self-policing advocates face the repercussions of less conscientious producers, we can expect to see further advocacy of increased standards and federal regulation and intervention. However, such a drive should not negate the power of and need for the fundamentally self-policing aspects of prevention and monitoring, without which regulation can’t help but be more reactive than proactive and protective.
Thus, while few would adamantly argue against the call for a reassessment of standards and effective oversight, it is the combination of the two — the merging and cooperation of the regulation and self-policing factions and camps — that is most apt to bring the best results for the future of food safety.
The author is managing editor of QA magazine.
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