A Decade of Food Safety

Research, both public and private, was a constant of the decade, and it continues to drive change. QA’s Cover Profile of May/June 2012 focused on the vast range of research conducted by USDA ARS and the part it plays in the ongoing growth and change of the food industry.

From landmark rulings in food defense to food safety, the decade between 2003 and 2013 has been of vast significance to the industry. Not only have we seen the passage and continued rollout of the Food Safety Modernization Act (FSMA), which has been cited as the most sweeping reform of U.S. food safety laws in more than 70 years, but 2003 saw the issuance of the initial rules of the Bioterrorism Act, which, itself, was landmark legislation in food defense.

What makes the decade even more interesting is the evolution of many of the Bioterrorism Act’s principles and rules from food defense to food safety. Just a few of the key initiatives that have crossed over are:

• Food Facility Registration. Effective December 12, 2003, FDA established regulations requiring that food facilities register with FDA to carry out certain provisions of the Bioterrorism Act. This same registration was then enhanced as a food safety initiative, with the FSMA requirement that food facilities submit additional registration information, including assurance that FDA inspections be permitted; that registration be renewed every other year; and that FDA have the right to suspend the registration of a food facility in certain circumstances. In the same way, the Prior Notice of Imported Food Shipments, Administrative Detention of Foods, and Establishment and Maintenance of Records sections of the Bioterrorism Act all have been picked up, adapted to, or referenced in FSMA.
• One Forward/One Back. Commonly used today as a food safety traceability initiative, the concept of one up/one back actually originated with the recordkeeping provisions of the Bioterrorism Act, which required that all food facilities be able identify and document the previous source of all incoming food—one step back, as well as the next recipient of all produced foods—one step forward. With this traceability as a base, FSMA tasked FDA to enhance tracking and tracing of food and recordkeeping to enable rapid and effective tracing of food products, particularly of high-risk foods. Additionally, many in the industry have taken it upon themselves to extend traceability all the way back to the source and forward to the consumer, for both consumer and brand protection.
• Risk Assessment. A key component of FDA’s food defense initiatives following the events of September 11, 2001, was that of risk assessment. As stated in an October 2003 publication, FDA took steps to improve its ability to prevent, prepare for, and respond to incidents of food sabotage. As part of that, it assessed the risk to, and vulnerability of, the U.S. food supply to an act of terrorism, using scientific evidence on food terrorism. In the same way, FSMA is based primarily on preventive controls which are science- and risk-based. FSMA legislation, in fact, directs FDA to focus on applying science, as well as common sense, to prevent the problems that can make people sick, and provides a congressional mandate for risk-based inspection of food processing facilities.  

A 2003 coloring book published by USDA shows that the industry was dealing with the “unscrambling” of consumer food safety knowledge in much the same way and on the same scrambled topics as it does today.

The more things change …
Along with the advancements and improvements of the last decade in the food safety and the technologies used to ensure it, there also have been a number of areas which reflect the old adage, “The more things change, the more they stay the same.”

• 2003’s “New Food Chain Approach.” Urging prevention as well as cure, the Food and Agriculture Organization of the United Nations (FAO) announced its advocating of a new Food Chain Approach to address the fact that “food safety is a global issue which demands an integrated, global response.” The new approach was in response to the spate of foodborne disease outbreaks which were found to have originated at the beginning of the food chain, rather than during processing, which had previously been the primary target. Although the food chain approach is standard today, the industry is still struggling with methods of traceability, source detection, and accountability at all steps in the chain—from farm through table.
• FDA Funding. FDA’s lack of resources to fully implement FSMA is at issue in 2013. But when one looks back over the decade, it becomes obvious that this, too, is an ongoing issue. In a 2007 report, the Center for Science in the Public Interest (CSPI) called FDA “the neglected stepchild,” stating, “Since 2003, FDA field staff dropped by 12 percent, and between 2003 and 2006 federal inspections dropped by 47 percent … Even as the number of inspectors and inspections declines, the need for more inspectors in critical areas, such as imported foods, has been continuously increasing.” These declines, the report said, can be traced to an ongoing funding shortfall estimated in the hundreds of millions of dollars.
• GM Labeling. Should genetically modified (GM) food products be labeled as such? It is a question that has continued through the decade, with a rift between science and public interest continuing to be at issue and much of the same controversy alive today as in 2003. In 2003, 15 countries were mandating the labeling of any genetically modified food products—stating that while the approved GM foods were as safe as conventional, the labeling was to provide for consumer information and choice. In 2013, the controversy continues. With FDA continuing to determine GM labeling to be voluntary, discussion is now centering on state legislation, with Connecticut currently leading the way. A bill was passed in June that would make Connecticut the first state in the country to require such labeling pending similar passage by four states (including one bordering state) and any combination of northeastern states with a combined population of at least 20 million people.

Although GMs take up much of the spotlight today, a similar controversy continues with cloned animals for food. In 2003 FDA held a public meeting to announce its tentative conclusion that consumption of meat and milk from cloned animals was safe for humans and to get public comment on how or if it should be regulated and labeled. In 2008, with support and agreement from USDA, FDA was continuing to assert the safety of cloned animals, announcing its decision that because it had not identified any food safety concerns or material difference in the meat or milk, there was no science-based reason to label the products as from cloned animals. In 2013, however, the controversy continues; not only in regard to the safety of eating cloned meats, but in relation to the lack of labeling of such.

Through all the innovation, budget cuts, and controversy, the industry continued to make change while continuing to focus on the same. Food defense may have given over the spotlight to food safety, but it has not been forgotten. While FDA continues to struggle to implement the rules of FSMA, this summer also saw its debut of the Food Defense Plan Builder Software. Designed to help food facilities develop individual plans, the tool incorporates FDA guidance and resources into a single application. 

While the decade has seen the key focal points of food safety and defense “stay the same,” it has seen significant change in both areas, driven not only by regulation, but by industry itself and in response to consumer concerns and desires. It has been a noteworthy decade, and perhaps for this industry, the adage would be better stated …

“The more things stay the same, the more they change.”

The author is Editor of QA magazine. She can be reached at llupo@gie.net.