April 21, 2008
Series Editor: Ian Parry
Managing Editor: Felicia Day
Assistant Editors: John Anderson and Adrienne Foerster
Welcome to the RFF Weekly Policy Commentary. The commentary is meant to provide an easy way to learn about important policy issues related to environmental, natural resource, energy, urban, and public health problems.
Each year, an estimated 76 million people become sick and 5,000 die from foodborne illness in the United States. In recent years, foodborne illness incidents have been prominently in the news. Congress has been holding hearings to determine what can be done. This week's commentary by RFF's Sandra Hoffmann identifies how and where U.S. food safety policy needs to change in order to ensure public safety in the face of our rapidly changing food supply system.
Next week's commentary will stay on food issues. Cormac Ó Gráda will provide a historical perspective on famines.
Bringing our Food Safety System into the 21st Century
Sandra A. Hoffmann
Over the past two years, a succession of cases of foodborne illnesses, many serious and some even fatal, has raised questions about the effectiveness of the U.S. food safety system. Our current system is based on procedures that have accumulated over the past century in response to various crises, scandals, and discoveries. Some are now seriously out of date. In other cases, new issues have emerged that the system was never designed to address.
The problem, at its root, is that hazards, foods, food sources, and food marketing are all changing rapidly, while our policies are not. Our meat inspection is governed by a 1906 act that still mandates visual inspection of every carcass processed in the country. Yet today's major hazards are microbial. New problems arise regularly and sometimes unpredictably. E. Coli O157:H7, a potentially lethal bacterium, wasn't even recognized as a foodborne pathogen until 1982.
Changes in products and processes can create unforeseen problems. For example, a major shift has occurred in how ground meat is processed: today, meat from multiple sources is blended in large batches and distributed across the country, creating heightened potential for product contamination and illness. Another significant shift is the growing amount of food we now import. Consumers certainly benefit from flexibility in the food supply through lower prices, greater variety, and better nutrition throughout the year. But those benefits may be coming at the cost of increased risk.
The right response is to start thinking about food safety policy as a problem in modern risk management. In this context, risk management involves the ability to monitor changes in food safety risks system-wide in something like real time and the flexibility to redeploy resources to control these risks as needed. Carrying this out will involve recognizing who has least-cost access to information on how risks are generated and can most efficiently be controlled, and using this knowledge in designing policy. The United States, largely at the initiative of federal agencies and industry, has moved in this direction for the past two decades. But this effort has been seriously hampered by antiquated legislation and severe federal funding cuts.
Better public health information
Information is the foundation for risk management. It is surprisingly difficult to estimate the rate of foodborne illness because often the link to food goes unrecognized. The most widely cited estimates date from 1999. Death estimates are highly uncertain because we do not have a good understanding of the longer term effects of foodborne illness, such as links to heart disease. In the 1990s, significant efforts were made to establish better active surveillance of foodborne illness, but lack of funding has limited the scope of this program to 10 states and a few localities (see CDC FoodNet). Passive surveillance relies both on local doctors reporting foodborne illness to local health authorities and on highly variable state and local public health funding.
Flexible, system-wide, risk-based regulation
Another positive change would be expansion of regulatory approaches that reflect the information constraints and comparative strengths of the public and private sectors. Hazard Analysis and Critical Control Point (HACCP) regulations are a step in that direction. They require firms to identify where foodborne illness hazards are most likely to arise in their operations and to develop processes for controlling these critical points. Government's role is to verify that the firms are actually carrying out this process.
In the past decade and a half, HACCP regulations have been designed for meat, poultry, seafood, and juice. While these regulations make use of firms- informational advantages and provide firms the flexibility to adapt to changing technology and market demands, they do not adequately address the inherent conflicts of interest. Consumer groups have rightly pushed for more effective verification that these systems are not just in operation, but are actually controlling hazards. Court rulings and lack of legislative authority have prevented agencies from using product testing as a full-fledged enforcement mechanism. Third-party certifications systems have also been used successfully by other industrialized countries.
Hoffman received her Ph.D. in Agricultural and Resource Economics from the University of California at Berkeley and her J.D. from the University of Michigan. Her research focuses on improving the role of regulation and tort law in managing health and environmental risks. She is also part of a team of researchers working to develop comparative risk ranking models of the U.S. food system.
Expansion of a HACCP-like approach beyond the processing and packing plant to across the full food supply chain would be helpful. Pathogen testing at retail may soon be technically feasible. Having checks on product contamination at critical junctures - like retail or the end of processing - coupled with product condemnation, recall, public information, and liability could provide powerful incentives for product safety down the supply chain. Trace-back systems are being used by private industry to identify the source of safety failures. These need broader use in public policy.
Risk management of imports
Roughly 45 percent of fresh fruit and 80 percent of seafood consumed in the United States is now imported. Globalization of the U.S. food supply poses three major challenges: volume, rapidly changing sourcing (particularly for food additives), and enforcement. Given the increasing volume of imports, it is clear that border inspection alone will not assure safety. With more and more countries exporting to the United States, it is also unlikely that in-country inspection will fully address the problem. Extension of HACCP-like approaches to supply chain management for vertically integrated firms and use of third-party certification will have to play an increased role. And government needs to police conflicts of interest in these systems and to verify that certification systems are doing their job.
An end to fragmented federal governance
The pizza in your freezer complies with food safety regulations from six different federal agencies. Despite significant effort at coordination through inter-agency agreements, this fragmentation of authority, with the predictable turf battles, competition for budgets, and quarrels over priorities, remains a fundamental problem. But agency unification without legislative reform that authorizes modern approaches to regulation and allows flexible deployment of resources to focus on the most cost-effective opportunities for risk reduction will do little good.
Developing a risk-based food safety system, and pulling together a unified agency to administer it, would require a major reconstruction effort by the White House and Congress. That kind of effort most commonly occurs only after a disaster. The question is whether the political process can achieve a reform of such complexity without first paying the heavy price that a serious breakdown in food safety would exact.
Views expressed are those of the author. RFF does not take institutional positions on legislative or policy questions.
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Hoffmann, Sandra. 2007. "Mending Our Food Safety Net," Resources. 166:11-15.
Hoffmann, Sandra and Michael Taylor (eds.). 2005. Toward Safer Food: Perspectives on Risk and Priority Setting. Resources for the Future Press, Washington, DC.
Golan, Elise, Tanya Roberts, Elisabete Salay, Julie Caswell, Michael Ollinger, and Danna Moore. 2004. Food Safety Innovation in the United States: Evidence from the Meat Industry. Agricultural Economic Report No. (AER-831). April.
Garcia, Marian, Andrew Fearne, Julie A. Caswell, and Spencer Henson. In Press. "Co-regulation as a Possible Model for Food Safety Governance: Opportunities for Public-Private Partnerships." Food Policy
Modern Meat, PBS Frontline
Centers for Disease Control, FoodNet
Food Safety Research Consortium