Food Safety and Environmental Health Blog : Disease Prevention, Public Health, Sanitation Information & Analysis : Environ Health Associates

Food safety has risen to a mainstream issue in the last few years. The reasons behind the rising interest of the public have to do with increasing risks. These risks have resulted in numerous contaminated products, hunderds of large recalls, billions in losses, hunderds of millions in lawsuits and thousands of illness and deaths. How is it possible that our fourth largest state, Florida, would remove public health protection from some of its most vulnerable populations at a time like this? Our public health agencies and the protections they offer to "at risk populations" are without political support and governmental decisions can be easily influenced by money and political power; those are the only logical answers.

Florida has a long history of attacking public health protections. In 1992, the last year health inspectors completed the required inspections in food service operations, the powerful Florida Restaurant Association successfully moved the restaurant inspection program from the then HRS Office of Restaurant Programs to the then Department of Business Regulation, a licensing agency- not a public health agency. This shift also triggered massive realignments of agency responsibilities, transfers of hundreds of positions, and the disorganizing of what was at that time a well run and efficient  inspection operation. The problems continued to plague DBR from thence forth, and the situation was made worse through another reorganization that created the Department of Business and Professional Regulation and yet another reorganization that took place saw Florida's Division of Hotels and Restaurants lose 20 key field positions.

Now we see a similar effort by lobbies to remove public health inspectors from institutions such as childcare centers, hospitals and nursing homes and give the licensing authority the responsibility for public health protection. History is repeating itself and the consequences will come. The situation with foodborne illness outbreaks in Institutions has been remarkably lower than in restaurants. Only about 10% of the food borne illness outbreaks investigated by the health department (yes they would still be responsible for that) are attributed to institutional food service.

Florida holds the number one ranking in foodborne illness reported in the nation. Some of this has to be looked at in terms of the remaining Department of Health DOH environmental epidemiologists in the field and their excellent work uncovering outbreaks, but the fact is the numbers are too high. We do not want to repeat these mistakes, but we here in Florida are all too familiar with Tallahassee's good ol' boy backroom politics and the tactics of industry lobbies.

Its a shame our government lets the people down time and again in favor of special business interests, but this latest attack on public health protection and the safety of food for kids, old folks and those already ill is a new low for Florida.

Please see the following article for more information.

FLORIDA: New law removes health inspectors
25.jul.10
Tampa Bay Online
Carl Orth
www2.tbo.com/content/2010/jul/25/pa-new-law-removes-health-inspectors/

Please see the article from Bites, below, thanks again to Doug Powell at Kansas State.
 
Where are our US public health scientists when food safety/public health regulatory agencies get in a corner? They just do not show up on the scene to take a stand against the political pressure from industry. The US public health science community appears co-opted, fractured, isolated in thier institutions and totally oblivious to these challenges. US Public health scientists when they are interested in food get their grants and quietly do their research in less controversial areas such as diet, nutrition, and security and are basically not heard when it comes to food safety. They rarely provide credibility to the need for public health protection.
 
We saw this in Florida last month when the state legislature abolished public health protection programs for our most vulnerable populations, we saw no support for public health, not the media, the medical community, not the universities and its scientists, and not the consumer. It seems nobody is outraged when Florida nursing homes, childcare centers and hospitals lose public health protection programs. Our agencies over here are sitting ducks for the industry who uses their political fire power through lobbies to shoot them down, because food safety rules require effort and expense and interfere with business. 
 
Here in the UK, amazingly, we have a food industry trade group correcting the Guardian for supporting the de-regulation of the food industry and standing up for food safety! And a respected sceintist speaking out! 
 
Congratulations, at least they are putting up a fight.
 
UK: We will all be losers if the FSA is abolished
14.jul.10
The Guardian
http://www.guardian.co.uk/uk/2010/jul/14/fsa-abolish-food-safety-environment
Melanie Leech, Director general, Food and Drink Federation, writes that contrary to your article (Victory for food firms as safety watchdog axed, 12 July), we understand that no decision has been made about the future of the Food Standards Agency. Your story claimed that food manufacturers had been lobbying to close down the FSA. However, as the voice of UK food and drink manufacturing, the Food and Drink Federation has consistently supported the need for an independent, well-funded food safety regulator. The FSA has been highly effective in this role in the 10 years since its creation, not least in ensuring that consumer confidence in the food we eat has grown significantly. Were its independent role to be abolished, neither the industry nor the consumers would be the winners.

Jon Poole, Chief executive, Institute of Food Science & Technology, writes the demise of the FSA would be regarded by many as a loss – including the food industry itself. The Institute of Food Science & Technology, an independent professional body, has seen the FSA working closely with the industry over the past few years. The adversarial style of relationship suggested in your reports is neither accurate nor helpful. During its existence, the FSA has provided coherent strategy and direction on issues such as reductions in saturated fat and salt and in food-borne diseases such as campylobacter in chicken, as well as regulating food business operators. These are all still live issues and the functions of the FSA, in whatever form, will continue to be needed in the future. Very few in the sector would see its break-up as a positive step.
 

Recent statements by several experts about the legitimacy of third party audits are missing the point. Third party audits are far from Ponzi schemes. They act to protect the buyer when they are realistically representative of the safety of foods and the buyer uses then as a basis for buying decisions. If there is a major shortcoming, it is that buyers do not always adhere to the audit findings, and choose their suppliers on some other basis. Buyers on the other hand are obligated to get the products needed to sell at the retail level. We all need food, and the retail industry cannot stop supplying consumers every time there is a potential problem revealed in an audit. Buyers of food are not police officers empowered to cut off suppliers with questionable sanitation. On the other hand, reputable firms are blind when they purchase unsafe products that would have been very apparent if tested or a visit to the facility made.

As I have argued, apparently in vain, the lack of a foundation of food safety throughout the food supply is the real culprit, not the weaknesses of the third party model. There should be no one, not one firm operating without the oversight of a government agency enforcing minimum standards. As some have written, minimum standards are all we can expect from government, but that is a lot. Without them, its naïve thinking that the industry will “police” itself. That is not what industries do; they expect government to do this. One of the paradigms that must be broken is that getting rid of government inspectors and turning all food safety totally over to industry is the wave of the future. Industry associations have argued this and to an extent have short-circuited the food safety system, but they have been pretty quiet of late and these same associations are now calling for intensive oversight.

I believe very strongly in industry self control, but we need to realize that the way business works, that self-control will be stronger or weaker depending on the entities involved. Therefore I argue that we need both; we need a validated industry self control model and an effective governmental oversight model working in tandem.

What happened at PCA was deplorable but it is not the standard for the third party audit industry. Most auditors understand and report risks, they do not allow relationships that develop on the job to sway them.  Many just go about their business politely and professionally, but still record the errors they see, there is a knack to doing this that we learn. The best auditing firms are very aggressive about not allowing inappropriate relationships to happen, sure, it does, but the best of us discourage it. Auditors are not just vendors that show up at a plant; that is something that industry must also come to realize.

As I have also written, I have faith that this is all working for the best, because basically I have faith in this country and its ability to rise above the obstacles, especially now that we have reached a “Jungle” experience again after 100 years.

Now with consumers, legislatures, media and government appalled by what happened in Plainview and Blakely I predict we will see a real partnership between industry and government. I also believe third party auditing firms will play an important role in bringing order out of the chaos.

In conclusion, once our government enforces basic sanitation throughout the food chain, third parties will be able to do what they do best, and that is separate the Good, from the Excellent from the Superior. It is ridiculous that there is even one firm operating in “Poor” or less capacity such as I observed at PCA. Third parties in reality should never see this. This is lax government oversight. Do not expect third parties to fix the poorest operating facilities, it is not their role, that role belongs to the public health community and fixing that problem will fix most others.

Inspections during Foodborne Illness Outbreaks

When a public health agency becomes aware of an outbreak of foodborne illness, they put into place interventions to stop the transmission. Central to that effort is an environmental assessment referred to as an inspection. Companies may also employ third party inspectors during outbreaks to determine the strength of prevention efforts. Legal firms and private investigators interested in understanding how these outbreaks occur, and why, increasingly conduct inspections during or after foodborne illness outbreaks (See WALB Article on PCA).

www.safefoodsblog.com/uploads/file/WALB Article.pdf 

The Causes of Foodborne Illness

The key principle guiding the inspector is the understanding of the causes of outbreaks. Pathogens cause disease when they are present in sufficient numbers in food to produce an infection or intoxication. How they get into food and survive to the consumer depends on a series of related factors that the inspector must develop as the basis for his inspection techniques.

The Agent, the Host and the Environment

It is fundamental to understand the relationships between the host, the environment and the agent. The characteristics of the host or victim such as age and health status play a role in disease transmission. In addition to the vulnerability of the host, the victim must consume the food so there are logistic considerations about the host and his exposures. The location of the victim, the amount or form of the food consumed, and other facts about consumption and handling relate to whether the person will come in contact with the pathogen. Onset of illnesses and types of symptoms are particular to pathogens and help to provide confirmation of the agent at work.

The Environmental Route of Exposure

The environment plays an essential role in supporting the disease transmission pathway. Disease transmission through the environment occurs when a reservoir of the agent is present and exploits a means of spread. Since the organism in most cases is not motile, it needs a vehicle to get from its reservoir to the food. There it must survive and/or proliferate in the food product. Environmental conditions significantly affect contamination, growth of bacteria, and survival of any pathogen in the food.

Contamination, Growth and Survival

The act of contamination can occur through people, water, vectors such as pests, surfaces, and potentially through the air. Growth of the pathogen occurs when sufficient moisture and temperature are available to the organism for a sufficient time. Facts about the food itself and its ability to support microbial growth include its nutrient content, water content and level of acidity, as well as any processing aids used that influence growth. Survival of the organisms in the food or environment is dependent upon the surface available for colonization, cleaning and sanitary practices, and treatments used on the product such as cooking or pasteurization.

Etiologic Agents

Foodborne agents include over 200 known pathogens; bacterial pathogens that exist in a spore or vegetative cell, viruses, parasites, and toxins. The ability of the organism to survive environmental conditions depends on a number of factors, but Salmonella, Listeria, E coli O157:H7and several other pathogens appear to be hardy enough to survive for long periods, possibly months in ideal conditions. Some spore forming organisms such as Clostridium botulinum need anaerobic conditions to grow, and anaerobic conditions in product and packaging favor other pathogens as well. The reservoir of the pathogen is often difficult to discern. The value of environmental-microbial testing to inspection is that it can identify locations where the organisms have been harboring. Suspicious areas always include moist areas as well as surfaces receiving repeated exposure to dirt and environmental contamination such as floors and drains. There is always a possibility that incoming raw products continually seed the production environment with contamination. It is also possible that multiple reservoirs of the organism in the environment or in people lead to cross contamination throughout the production system.

The Inspection and Analysis

With the understanding of the pathway of infection and the complex relationships between the agent, host and environment, investigators apply an analysis of the food production process. Inspection is a process of observation and the inspector analyzes his observations to determine the likely exposures of the final product to contamination and to identify the process steps that allow proliferation and survival.

Analysis of Production

Food production processes start with the receipt of raw materials but the process at any one step in the food supply are interconnected with all other points right up to consumption. The inspector conducts a visual inspection of the structure, environment, equipment, layout and other factors while focusing on the production process.

Raw materials can contain the pathogen, and include packaging as well as the other ingredients ultimately used in the finished product. While visual observations may reveal potential problems, microbiological and other analysis may be necessary to determine the safety of incoming materials. It is safe to say the opportunity for contamination is significant in raw agricultural commodities grown in the soil and raw meat and other raw, animal foods.

Receiving is usually followed by storage although there may be some immediate use of products as they arrive Stored products may be subjected to hazardous environmental conditions such as pests, dirt, chemicals and foreign of objects Any moisture or signs of vermin where food or packaging is stored increases the risk for contamination.

Foods may be staged into production and be in various forms during processing. Since handling of products occur during production (or preparation), the human element becomes important as does machinery and equipment used, utensils, and the flow of foods through the process itself. Any point can lead to contamination or growth of bacteria if the process is not controlled. Cross contamination can occur when there is poor maintenance of food contact surfaces or under poor storage conditions.

Packaging occurs in food processing while service occurs at the retail level as the final step in the production process. Transportation is an intermediate step in the supply chain and can lead to contamination of finished products. Servers in food service environments can also contaminate foods that were otherwise safe to consume. The key is to analyze the entire food production process and avoid missing hazardous steps.

Evidence Gathering

Photographs, samples and other techniques such as interviewing provide additional evidence in the development of theories of causation and bolster the data obtained through the inspection process. The inspection findings may also benefit from a statistical approach and ranking of factors in terms of their significance and severity. A final report captures the data from all findings and often leads to a conclusion about how foods became contaminated.

Inspection during Foodborne Illness Outbreaks is an Essential Tool

Inspection as a tool in foodborne disease investigation is a critical part of preventing the further spread of pathogens. Inspections also lead to an understanding of the complex associations that influence the probability that a foodborne agent reached a product by a specific pathway. Inspections form a central piece in determining what went wrong and how to prevent similar outbreaks it in the future.

Inspectors should make it clear to operators that they must apply the outbreak inspection findings to the process under study as a matter of urgency and take corrective actions to improve it and other similar processes.

Whether or not an inspection is routine or occurs during or after an outbreak, the ultimate value of inspection in general is to improve the food supply. When applied in a very systematic fashion, inspections during foodborne illness outbreaks can move food safety efforts forward very effectively and dramatically protect the public in the future.

In the absence of food safety regulations in many commodities or the lack of oversight in general, companies have turned to the private regulation of the food supply. On an individual and voluntary basis, dozens of auditing firms and hundreds of private parties are looking closely at the safety of thousands of suppliers. The supplier-food safety scheme is pushing all the way back from the retailer to the primary producer or farmer. As each link in the supply chain tightens standards, there will be a corresponding improvement in the safety of final products.

The third party food safety business model is that buyers ”accredit” or approve the third party food-safety firms they will accept audits from, and suppliers are free to hire whatever firm they wish to satisfy the buyer. The supplier pays the auditing firm directly and the auditing firm sends the audit findings to the buyer. The buyer does not pay for the audit and the findings do not bind his purchasing decision.

Third party audits have the capacity to improve food safety and provide another means of protection in the wake of government inaction or even failure. Third parties use private food safety standards developed either in partnership with prospective buyers or in formal expert groups at the national and international levels. They provide the basis for determining “conformance” whereas regulations provide the basis or scope of the regulatory inspection, which is “compliance”. Third party audits cannot take the place of regulatory inspection in protecting the consumer for the simple fact that only government has the legal power to enforce compliance. Third party audits since they are voluntary often take on a collaborative air. A buyer maintaining good working relationships with his auditing companies makes good business sense and adversarial relationships are not productive. Bias can easily slip in when the audit customer and the auditing firm grow too close. Bias can enter from the supplier side as well. When choosing an auditing firm a supplier may decide to select a firm based on price, personal knowledge of the company and its personnel, as well as the strength of the auditing system and its recognition.

The premise for any company to hire an auditing firm is the needs of the buyer who is more than likely requesting the audit. The consumer benefits from the third party scheme in more consistently safe products but protection is weak when the most hazardous facilities continue to operate. Disqualification of a supplier is the responsibility of the buyer, but the audit findings in no way bind the buyer. Third parties can rate a firm but they cannot dictate to the buyer who to use. In such an unregulated system, unsafe operations continue to operate and distribute unsafe food to consumers who continue to become ill and die. Unsafe operations continue even when audits reveal clear significant problems and more troubling, sometimes auditors do not clearly report unsafe conditions.

Bias can work in another way. Since the auditing firm really wants the suppliers business, relationships between suppliers, auditors and firms may develop. If those personal relationships cloud the findings and discretion of the auditor, the system becomes very weak.

Shifting the weight for protecting the consumer to third parties alone is not a good system and is simply “passing the buck”. There must be at the basis for the model, a comprehensive and competent authority with enforcement powers and consistent presence. We cannot rely upon independent third parties for this. Government authority backing up the system greatly improves the third party model and gives it credibility especially when efforts are coordinated with industry. Government acting in tandem with industry third parties and thus the industry itself brings us full circle in the evolution of food protection efforts. Such an effort would pave the way for a significant improvement in the safety of foods and the protection of consumers.

With both the New York Times and the Atlanta Journal Constitution reporting on inspections and audits, audit company auditors and the third party food safety scheme are coming under fire. There is ample evidence that both the third party audit model and regulatory inspection model have deficiencies, as brought out by the most recent PCA incident and other  food safety crises. There appears to be some confusion however about the root causes of these deficiencies, and we should differentiate third party audits from regulatory inspection. The scopes and purposes of these audits are different in important ways while sharing many similarities.

Third party audits seek to evaluate and examine conformance with a private food safety standard, while of course regulatory audits seek compliance with public health rules and laws. Private companies own and develop the third party audit standards, and although FDA has begun looking at a certification process for such firms, they act independently from regulatory agencies and are not bound to evaluate all laws and rules relative to a firm. 

The scope of the audit limits the third party auditor in determining conformance while the government inspector is bound to determine compliance with the code and seek enforcement. An auditor may find himself narrowly looking at criteria as specified by the standard, and the policies of the auditing company. For example, in a manufacturing environment, the auditor may be interested in one or two lines or one or two processes for a particular labeled good, and find that the scope of the audit does not cover some otherwise important areas of the whole operation and its products.

The strength of the audit from a public health perspective is basically that the audit goes deeper into management systems that support the compliance with laws than most regulatory inspections. The strengthens of the regulatory inspection is that violations of a food safety nature trigger enforcement at some level, re inspection, condemnation and embargo of product and other interventions not available to the third party auditor. Regulatory agencies also have (or should have) the power to compel compliance and the release of vital food safety information such as microbiological tests data, and demand a recall.

The two systems are therefore complimentary and both together have the capacity to bring about public health protection. We can improve the two systems and bring them closer together in a number of ways. The third party auditing company should have the ability to withhold certification based on its own criteria. This means that even a firm who might achieve a Superior Rating could have their certifications withdrawn if they fail to stay in substantial compliance with laws and rules, withhold information about the safety of the product or process, or engage in fraudulent activities. This is currently not the case in many audit schemes, the decision to do business with a supplier is left totally to the buyer who can opt to make a buying decision, based solely on the audit criteria.

We can strengthen the regulatory model in a number of ways. Currently, many food safety agencies are under staffed, poorly funded, and ineffective at regulation. The fragmentation of public health is something the food industry has brought upon itself. Industry must seek to obtain proper funding for food safety agencies or must agree to fee increases to keep these very necessary functions going . Industry must support agencies to expand their jurisdiction.

Third party audits alone will not protect public health, and public health is greatly improved by the independent review of food safety management systems by an outside expert. However, the owners of private standards do not intended to be public health protection agencies and their standards should not take the place of a farm to fork regulatory framework for food safety. The shakiness in this framework is the underlying cause of our food safety dilemma and industry is finding that its third party, buyer driven standards alone will not properly protect their own interests or public health.
 

The food safety net just showed us another huge tear as the result of contaminated peanut butter products. The problem will be felt for years in the peanut industry and will likely change the food safety landscape in many ways.

The government reaction has been harsh and focused in this latest deadly outbreak. More government action means more regulation, and as yet, we have not seen any sweeping changes, but they are likely to come. For the first time we have the highest level of government showing concern, namely the White House. The One Big Agency concept keeps emerging and it is good to examine why proponents believe it is necessary, namely reducing duplication and closing gaps. There is also the idea that policy on food safety could come from one office. We now also have possible criminal behavior on the part of one of the food industry, and the legal consequences of causing an outbreak are becoming clearer and deeper. On the positive side, in this latest crisis there is a real sense of openness for change.

The foodborne outbreaks caused by once thought harmless items such as peanut butter has been the icing on the cake for a very mean period in the history of food safety. It is ironic that at the time the food safety concept is rapidly growing, the hazards keep building against controls.

The question is what we are going to do about it; what do we do before something like this happens again? We have had in the past a vacuum as far as any true leadership to get us out of the problem. Its been a long time since there were any definitive changes in the way we do food safety and there is real room for improvement. So what are we going to do prevent the next outbreak? Do we call for more reforms? Is this the same pattern of business as usual or do we expect something a little bit more decisive from government after peanuts?

Obama joins calls for improving US food safety regime:

http://www.cidrap.umn.edu/cidrap/content/fs/food-disease/news/feb0209fda.html

Peanut butter may get 'high risk' designation as government tightens oversight of food makers

http://www.startribune.com/politics/national/congress/39465507.html?elr=KArks8c7PaP3E77K_3c::D3aDhU6:_0c:QyDiiUiacyKUnciaec8O7EyUr

No one disputes the fact that our food safety net has several gaping holes. Like clockwork, one can seemingly depend on a major foodborne illness outbreak to occur every few weeks. This month it is peanut butter, again, a few months back it was peppers and tomatoes, before that potpies, veggie snacks, canned chili, etc, etc.

Proponents for a massive reorganization of our regulatory agencies continue to make their voices heard. However, few if any of these proponents really appreciate what has caused the dysfunction in our food safety systems. A reorganization of our federal agencies is a dangerous idea that simply will not work and political motives are behind much of the "One Big Food Safety Agency" movement.

While our agencies do seem overwhelmed, actually the solutions are relatively simple; more industry self-control and more oversight by a properly funded and managed government would make a world of difference.

First, industry self-controls should be mandatory, not voluntary! Regardless of the industry, process or commodity, it is the producer that holds the key to food safety. Yet, except for red meat, juice, poultry, seafood and the dairy industry, most of the food industry, including the entire food service industry operates with no formal requirements for a food safety system. Industry self-control does not necessarily mean government should back away from its authority. In fact, mandatory self-regulation would bolster governmental efforts if government were in true partnership with industry and not simply shifting the cost and burdens of public health protection, as seems to be the case.

When operators properly develop and implement food safety systems, they work. Health authorities are no longer reporting juice outbreaks. Statistics show some progress in reducing outbreaks of E. coli O157:H7 in red meat, especially at the retail level and there are very few reports of large-scale outbreaks of salmonella from poultry. This is probably the result of government-mandated self-regulation, although it is somewhat uncertain why we see declines in outbreaks in some pathogens.

The record of the highly regulated seafood industry is remarkably good. We do not have nationwide outbreaks associated with seafood. While groups such as the Centers for Science in the Public interest have misunderstood the statistics related to seafood outbreaks, the seafood industry is undoubtedly one of the safest in spite of the fragility and propensity for bacterial growth of its products.

Government, especially the FDA, is terribly underfinanced, poorly managed and lacks political support. Its counterpart, USDA, seems to fare a little better in its budget, but politics at the highest levels in USDA ensures less effectiveness as a public health agency. These two facts are the major reasons we have a weakened food safety system. Opponents of self-regulation should consider that a mandatory self-imposed food safety system with a strong government oversight is a very different model from voluntary self-regulation where government has no jurisdiction, or abdicates its authority.

An example for how things are improving exists today in the produce industry, probably the most hazardous of all food industries. The California leafy greens industry and the Florida tomato industry have adopted self-regulation, and in the absence of federal oversight, state government has stepped in to provide the needed regulatory oversight. We have an excellent developing model where strict governmental regulations of producers are coupled with demands from buyers for validated self-control systems. We need across the board what is happening in Florida and California, and not just in the produce industry. If we had mandatory industry self-control, coupled with strict government oversight, large-scale foodborne illness outbreaks would stop, and sporadic incidence would dramatically drop.

The panacea of creating One Big Food Safety Agency will not solve our food safety problems. It will however make it much worse. As a government manager who has been through government reorganization, I will tell you it takes years for the agency to recover. Generally, the politics that occur are so damaging to morale and the mission of the agency that any meaningful efforts come to a standstill. It is incredibly naive to think that two massive agencies with 100 years of protocols and independence can be merged into a single agency successfully just by an edict in Washington. While the problem of “who inspects what pizza” makes good fodder for those with an anti-regulatory agenda, this archaic problem can be easily solved by an interagency agreement, or memo of understanding between the two agencies.

If Mr. Obama is smart, he will look to make USDA and FDA efficient and accountable and give them the support they need. These agencies have served us very well up until recently when politics and politicians gutted FDA. USDA is a separate problem. USDA has suffered by being an advocate for industry while simultaneously shouldering a serious public healthy responsibility.

Food safety is a critical public health issue, so what are the leaders in public health concentrating on? Take a look at the American Public Health Association, or the Association of Colleges of Public Health. They are bellwethers for what is on the mind of the public health scientists in this country. Few in these groups are seriously interested in food safety. Colleges of public health do not teach food safety as a public health specialty although there may be a lecture or two in the environmental health track. A long-term solution to strengthening the food safety system is for the public health academic community to attract and train more qualified food safety experts and deploy them into both regulatory and industry food safety positions. It is time for the public health scientists to get out their ivory academic towers and embrace contamination of the food supply as a major public health concern.

We should not waste precious resources in a useless and dangerous reorganization of the federal bureaucracy. It is time for public health scientists, industry leaders and government officials to develop an initiative similar to the “President’s Food Safety Initiative” of 1998. The result of the 1998 effort yielded tremendous progress on many fronts, very cost-effectively.

Providing leadership in Washington, sensible tweaking and funding of our existing regulatory systems, and requiring industry to shoulder more weight to protect the public are what we need. Advocating for “One Big Food Safety Agency” is a colossal mistake in thinking and such an effort will guarantee that we fall further behind the microbes in their incessant attack on people through food. Thankfully, President Obama is probably going to be too busy to make this happen anytime soon.