Environ Health Associated investigated the efficacy of a product known as electrolyzed water on reducing hazards in salad greens in colaboration with ProtonLabs and the University of Washington. The findings have been published in the Journal of Food Science. Our study found that when used on  experimentally contaminated leafy greens an electrolyzed water wash treatment provided a reduction to safe levels in about a minute and complete destruction of all pathogens to undetectable levels after 3 minutes. This technology developed by Protonlabs in Japan has the power to transform the safety of leafy greens. Unfortunately less effective technology developed in Russia has been heavily marketed already in the US, while the Japanese technology is just becoming well known. Environ Health Associates believes this study will open doors for Proton’s Japanese technology that were previously closed to the Russian technology.

What makes the Japanese technology an improvement on the Russian technology is the robust hardware, advanced electronics, and stable chemistry provided by the maunfacture. Environ Health Associates endorses ProtonLabs’ technology. ProtonLabs is the only company offering an effective stabilized electrolyzed water product that can be bottled with shelf life at 2 years under normal storage conditions.

The study showed that an ordinary washing step with electrolyzed water provides an excellent reduction in pathogens and a safe alternative to other treatments. Electrolyzed water resolves to its elemental components with no residue in the environment. The active ingredient, hypochlorous acid (HOCL) is accepted as GRAS by FDA and can be applied to all types of edible foods, including organically grown vegetables.  

Continue Reading Break Through in Produce Safety

Research recently released by the Fresh Express Company has added greatly to our knowledge of the route of transmission of E coli O157:H7 in leafy greens. A research team including Michael T. Osterholm, PhD, MPH  at the University of Minnesota and Dr Michael Doyle of the University of Georgia found that flies can carry E coli to the stomata of the plant (the opening in the plant where gases are exchanged). Once there the E coli find a rich environment and can colonize the site through newly discovered virulence mechanisms. The study also found that the E coli were unable to actually infect the inner vascular structure of leafy greens through roots or leaves.

The research points to a key pathway for disease transmission that needs to be broken. While some filth flies are inevitable in farming operations there are some common sense things that must be considered in reducing fly populations, and those are the presence of decaying matter and fecal material on the farm and proximately to large cattle operations and manure.

The comments of Mr. Jim Prevor the highly respected Perishable Pundit provide an important industry perspective. While Mr. Prevor praises the results of the research, he also points out that applying what is developed in a scientific model to the real world requires something more. Mr Prevor writes "Although this type of quick turnaround can provide important clues for further research and provide the trade and regulators with some notion of how research is progressing, we think demanding instantaneous revolutions in horticultural and processing practices is too much." Mr.Prevor then goes on to praise the research, adding, "For today, however, the industry owes a big hat tip to Fresh Express. We know more and have a clearer path to food safety than we did last week. That is a formidable accomplishment".

I can understand Mr. Prevor’s dilemma, there are obvious implications for agricultural now that we know the dangers of filth, flies and the vulnerability of the stomata. On the other hand, there are simple and practical things that we might attempt. Some questions to explore:

Just how does one control filth and flies in farming operations?

What do we do with knowledge about E coli’s colonization of the stomata?

Is ozone or some other treatment the answer, are there alternatives? 

If more research is needed, what kinds of things should we be looking at?

The produce industry needs to be looking for answers to these questions. Can the industry afford to write off 2 million dollars of their own research money? The produce industry cannot excuse itself citing potential costs or difficulties. Stay tuned as I explore these questions and implications for consumers, industry, regulatory agencies and food safety professionals.

Links to this story:

http://www.PerishablePundit.com
http://www.cidrap.umn.edu/cidrap/content/fs/food-disease/news/sep1708produce.html

http://www.actroninc.com/flash/ifmflash.htm

In another shocking episode of adulteration, Chinese public health officials have announced the recall of infant formula contaminated with melamine. The Chinese obviously have a problem; last year Chinese manufacturers contaminated pet foods with melamine in a fraudulent effort to boost the protein level to make more money. The draw of this additive is apparently irresistible to Chinese food manufacturers. Even after the public execution of officials and others involved in food safety scandals, the Chinese are unable to restrain themselves and have poisoned thousands of their own babies, and may have tried to hide it. Of course, this brings to our attention that unbridled greed is at work in China, with the complicity’s of their international trading partners. The Chinese manufacturers of the contaminated baby formula that has killed a number of children and sickened thousands has ties to international food suppliers, one of whom knew of the contamination for weeks. Accountability and liability should extend to all who have had business dealings with this firm; the final revelation of the deadly threat was delayed according to the story below by official Chinese inaction. If this is true, and history would support that conclusion, Chinese food safety, regulation and public health protection must be questioned for every product produced in China and firms doing business in China need to keep their Chinese partners under close surveillance.

Here is a link to recent infamous Chinese product safety scandals

www.npr.org/templates/story/story.php

Original Article: Chinese hospitals are fighting to save the lives of some of the 1,253 babies who have fallen sick after they were fed milk powder contaminated with an industrial chemical used to make plastic cups and saucers.

Two babies have already died from drinking the formula laced with melamine in a ploy by farmers to boost the apparent protein content of the milk that they sold to one of the best-known milk powder manufacturers in the country. Police have arrested nineteen people, including two brothers who ran a milk collection station.

The brothers are alleged to have added melamine to milk that they sold on from farmers. State media said that their milk had been rejected several times previously by the manufacturer Sanlu Group.

The scandal came to light only because of the intervention of Helen Clark, the New Zealand Prime Minister, who was informed by the New Zealand joint venture partner of the Chinese company of its failure to persuade it to recall the product. Ms Clark said that the food giant Fonterra had been trying for weeks to make Sanlu Group recall the product but “the local authorities in China would not do it”. Fonterra has a 43 per cent stake in Sanlu, but had to follow Chinese rules in handling the incident.

Sanlu halted production last week after investigators found that the melamine in its milk powder caused kidney stones and other complications in infants. It recalled all its products made before August 6.

The children are victims of two of China’s greatest evils: greed and secrecy. Greed has contributed to poor safety: only a few years ago 13 babies died after they were fed a sub-stand-ard fake formula marketed under the Sanlu brand. The determination to stage a perfect Olympic Games may also have delayed revelation of the adulterated milk powder. Twenty-one topics were banned from Chinese media during the Olympics – eighth on the list was food safety scandals.

Li Changjiang, the Minister of the General Administration of Quality Supervision, Inspection and Quarantine, said: “It’s shocking. It’s a crime against the people.”

The eleven-month-old son of a lawyer, who identified himself only as Mr Sun, is in hospital after being fed the milk powder since he was two days old. The child’s nanny had told Mr Sun that he had difficulty urinating. Mr Sun told The Times: “We told her to give him more water. Who would ever think of the milk powder?

“We both regret not paying more attention to our son or we might have identified the problem earlier.”

By yesterday morning illnesses linked to the powder had been diagnosed in 1,253 children, with 340 still in hospital and 53 in serious condition.

Toxic history

— Half of all dangerous goods seized in Europe in 2007 came from China

— Last year China found two companies guilty of intentionally exporting contaminated pet food

— US authorities last year gave warning that monkfish imported from China may be puffer fish, containing a potentially deadly toxin

— In 2005 Sudan 1, a carcinogenic food colouring, was found in Chinese branches of KFC

— In January a survey found almost two thirds of Chinese people were worried about food safety

Sources: European Commission, Times archives

http://www.timesonline.co.uk/tol/news/world/asia/article4758549.ece

Egypt is becoming aware of the importance of food safety to its people, and for its well-being as a nation. However, it is important to note that Egypt is not alone in these concerns. Here in the US we just experienced our worst outbreak of Salmonella through contaminated vegetables, and the end of our food supply contamination problem is not in sight. The global problem of food safety requires a global approach, so it is heartening as an American to see Egypt move forward as a nation to help solve this worldwide problem. Egypt is joining the growing number of nations who are creating, rational, science-based food safety strategies to protect public health. This is the right thing to do for public health. Ensuring food safety is critical for all of us and a healthy populace will enhance all other public health and safety initiatives. The worldwide food safety problem will be solved as each country advances its own reforms. Thank you Dr. Mansour, for beginning this effort in your wonderful and fascinating country. Please read below.

 

Food Safety Project Chief: 500,000 Food Violations

 By  Metwalli Salem, Hisham Yassin and Mohamed Haroun    17/9/2008

The head of the Food Safety Agency Project Hussein Mansour said a workingteam has been formed to prepare a strategic plan of action for the agency once alaw was enacted to establish it.

During a banquet organized by USAID, Mansour said the agency aims at unifyingcontrol over regulations and conditions relating to safe food.

 

He noted that official reports have monitored increasing rates of fraud onmarkets, adding that the number of food violations reached 500,000 casesannually. The number of officially registered factories amounted to 3000‘, producing 20% of food production while the remaining 80% is produced byunregistered factories.

 

Mansour noted that the large number of bodies checking food and thedifference in human and technical capabilities of labs might be the reasonbehind low quality of food.

World organizations concerned with human health advised people who travel toEgypt to be vaccinated against Hepatitis A and Typhoid before traveling for theprobability of taking polluted food or water.

 

Egypt is considered, according to Mansour, one of the countries where ratesof contracting such viruses are high, especially in case of visiting ruralareas.

 

Studies conducted by the National Research Institute proved that 100% ofsamples taken from honey are polluted with chloramphenicol, which causes anemiaand spinal atrophy.

Food pollution negatively affects the national economy, he said, noting thatthe US rejected a food shipment from Egypt because it was polluted withpesticides, as well as low quality of packaging

Moreover, the EU rejected a shipment of soybeans and sunflower seeds becausethey were contaminated with aflatoxin.

 

Mansour warned against the effect of food pollution on general health, whichmight lead to the spread of summer diseases and contracting Hepatitis A andkidney failure.

 

He noted dairy products sold in rural areas and some cities are considered amain reason for contracting several diseases, such as tuberculosis, brucellosis, typhoid, scarlet fever, diphtheria, yellow fever, paratyphoid and dysentery.

 

Mansour revealed that a sound animal produces microbe-free meat, but it ispolluted at slaughtering. Studies proved that the average microbes in the meatafter slaughtering hit 216 microbes in each square centimeter and increase to 10-20 millions and 66 millions after reaching the butcher.

Continue Reading Egypt Tackles Food Safety-an American Perspective

There are those who would debate whether industry should be the leaders or the follower in food safety. Industry has taken a lead over government, going passed the basic food codes. For example, the USFDA Food Code applied at retail does not require food safety systems to be developed, nor does it require certification that employees are training in food safety. The Food Code may infer these tenants of running a safe operation but it does not require it. Thus, industry itself has developed its own food safety protocols for training, food safety systems development and auditing. While this is a very  good thing from a consumer standpoint, letting industry self regulate without oversight is a danger. Industry is motivated by profit as much as it is food safety. While ultimately one could argue that they are both related, food safety requires a serious investment of time, money and workers as well as investments in equipment and the physical plant. Whereas operators do not see a direct economic benefit for these investments, many feel they must protect themselves and most importantly comply with laws. Removing oversight over the efforts of industry in food safety is shortsighted. What is needed is a new approach where government guides industry through the development and application of their own food safety plans and then assesses their own monitoring activities. This is the very approach used by third party auditors. Government efforts would be greatly improved by adopting the industry model and then creating rules, and inducements around them, basically validating and approving the systems in use They would control those operations with clear lines of authority so no unsafe products are released. Self-reporting could be done in a number of ways utilizing technology, allowing constant oversight and rapid intervention.

It is a dangerous thing to allow a vacuum to develop where our sworn public health officials are not involved deeply with food safety protection. The answer is not  a larger role for the government or industry, it is a partnership, but where government maintains its right to protect the public.

To read to differing opinions on this topic, see the links below.

Pro

http://www.csnews.com/csn/news/article_display.jsp?vnu_content_id=1003850433

Con

http://www.cmaj.ca/cgi/rapidpdf/cmaj.081459v2?papetoc

 

 

Abstract: The safety of produce and its production has come under scrutiny as the results of repeated and serious outbreaks of foodborne illness. Environmental health standards for sanitation, personal hygiene, water, and soil quality during farming operations are now recognized as critical for the safety of produce. Public health and rregulatory initiatives targeting produce are underway in Florida, California, and other jurisdictions as a result of numerous outbreaks of E. coli O157:H7 and Salmonella. The California Senate last year approved three bills designed to implement tougher food safety rules for growers and handlers of spinach and other leafy greens. In addition, the California Department of Food and Agriculture (CDFA) is administering a voluntary California Leafy Greens Marketing Agreement (Marketing Agreement) requiring Good Agricultural Practices (GAP). Florida is regulating tomato safety through the Department of Agriculture and Consumer Services (DACS). Environmental health practitioners have many of the skills needed to address the challenge of regulating on-farm food safety. State public health agencies are applying public health protection programs to farms and  the role of the sanitarian/environmental health specialist is essential. 

Environmental Health on the Farm

 

The safety of produce depends on many environmental health factors from the farm to the consumer’s plate. For example, intensive farming of leafy green vegetables occurs in the Salinas Valley on the central coast of California. In this location, farms are subject to flooding from the polluted Salinas River and its tributaries. One major source of pollution in the basin is the surface water run off from the valley’s extensive cattle operations. In addition to polluted water, reservoirs of pathogens include workers, cattle, manure, and wildlife. Once produce is contaminated, pathogens are difficult to remove. Modern distribution and processing systems contribute to the rapid and wide dispersion of contamination if it occurs. There is also a high demand for fresh-cut (processed) produce at the retail level. High demand has increased the amount of processed produce in the marketplace and the numbers of people potentially exposed to farm pathogens. These factors, mostly related to the environment crops are grown in, are causing large and numerous outbreaks of foodborne illness. Experts now recognize the farm as a critical link in the safety of the nation’s food supply and environmental health professionals are now at work in this area.

 

Following environmental health standards in farming is a new concept. Traditionally, environmental health programs have not focused on produce safety on the farm, but legislatures are now  considering laws and rules to stop the spread of disease through produce, as they have done in the past with milk, seafood and meat. Environmental health programs at all levels must expand to confront the risks to public health posed by human health hazards originating in the farming environment.

 

Recent Produce Outbreaks

 

In 2006, produce-borne E coli O157:H7 in spinach and lettuce, and Salmonella in tomatoes, caused several well-publicized and serious outbreaks. In the spinach outbreak, contaminated produce eventually reached 26 states and caused over 200 cases and at least 3 deaths. California leafy greens caused a total of 22 reported outbreaks in the last 12 years, and the Salinas Valley was the source of produce in nine of them. The “Investigation of an Escherichia coli O157:H7 Outbreak Associated with Dole Prepackaged Spinach”, released March 21, 2007, may be the first investigation to link a produce-borne pathogen to a specific US farm[1]. Close on the heels of the spinach outbreak, investigators traced California grown lettuce to 2 outbreaks E coli O157:H7 at two national taco chains. In 2008 the US experienced one of its worst outbreaks of salmonella through contaminated produce with both peppers and tomatoes associated with illnesses.

 

http://findarticles.com/p/articles/mi_m0EIN/is_2008_June_6/ai_n25489057

 

California’s Proposed Regulations and Voluntary Programs

 

California legislatures are seeking to make the California Department of Health the regulator of mandatory on-farm food safety under a series of bills sponsored by state Sen. Dean Florez[2]  A competing industry level program is already in place, and it is questionable whether the bills have strong industry support. The voluntary program is an industry effort supported by the California Department of Food and Agriculture (CDFA). Most of the largest produce growers in California this March signed on to the “California Leafy Greens Marketing Agreement” (Marketing Agreement) allowing the CDFA to conduct GAP (Good Agricultural Practices) inspections on farms, packinghouses and processing plants[3],[4]. With 99% of produce grown in California under the Marketing Agreement, and inspections and audits occurring, farms will more consistently apply Good Agricultural Practices. However, there is skepticism about the sufficiency of voluntary controls alone. If we experience another large outbreak with leafy greens, calls will undoubtedly arise again for public health agencies to intervene.

 

Weakness in the Buyer Driven Food Safety Model

 

FDA first published a “Draft Guidance for Industry; Guide to Minimize Microbial Food Safety Hazards of Fresh-cut Fruits and Vegetables” in 1998, and in March of 2007 issued a “Final Draft” form[5]. The Guide met with general approval by agriculture, but compliance still remains “non-binding”. Industry at some level has adopted the guidance, but compliance is not uniform and we continue to see significant outbreaks involving fruits and vegetables. The FDA also published the “Commodity Specific Food Safety Guidelines for the Lettuce and Leafy Greens Supply Chain.-1st Edition” in 2006[6]and a second edition in February of 2007. This guidance also lacks the force of regulations, and how well the supply chain follows FDA guidance is unknown. For these reasons, many feel there is a need for a specific body of rules that all must follow.

 

Because industry with or without mandatory rules must still supply a safe product, the produce industry has been operating a self-regulating “buyer-driven” food safety system. Although buyers value the safety of products, economic realities may limit the strength of this voluntary approach. There is no requirement for buyers to be so food safety conscious that they  constrict the supply of produce that they rely on, and price must always be a major factor in a buying decision.

 

Strengthening the Buyer Driven Food Safety Model through Regulation

 

In the absence of a regulatory presence, third party auditing firms together with management and the buyers themselves provide the oversight in the buyer-driven model. Third party auditors unlike their regulatory counterparts “inspectors”, do not approve suppliers, enforce standards or decide what products enter commerce. Third party audits provide an assessment of compliance with one of several voluntary food safety standards generally based on FDA guidance documents. While there is much interplay and coordination between the two sectors, third parties act independently of government.

  

The current trend is for  the major wholesale buyers, Albertsons, Wal-Mart, McDonalds, Publix Markets, and other large food retailers to request a third party audit of a produce supplier as a condition of approval. The model needs strengthening because while audits may be thorough and the audit findings comprehensive, as previously explained, buyers make decisions based on factors other than audit results. In the end, the final decision to select or reject a produce supplier rests with the buyer and his needs at the time. Buyers evaluate audit criteria, but also base decisions partly on quality, quantity, and the economics of supply and demand. A complimentary regulatory program would strengthen this model.

 

While it seems logical that the federal government should administer the program, the State Departments of Health or Agriculture are in a better position than federal agencies to regulate produce. FDA reports it cannot move swiftly enough to meet the current challenges in regulating the nation’s produce supply and questions whether its own regulations will work (7). USDA currently does not have any jurisdiction over on-farm food safety, and experts agree that federal laws would take years to put into place.

 

Proposed Mandatory State Rules-“The California Produce Safety Action Plan”

 

In February, 2007, California Senator Dean Florez, introduced “The California Produce Safety Action Plan”, a package of senate bills designed to bring mandatory rules to California produce growing operations for the first time. These bills are in response to the deadly E. coli O157:H7 outbreaks that have hurt the leafy green industry in California. “After 22 E. coli outbreaks associated with leafy greens, we know that market forces have not been strong enough to bring reform to the leafy green industry”, Florez said, during his remarks to the California senate. “For years” he explained, “the federal government through the FDA has been left to writing open letters practically begging the industry to act. None of it has worked” he added, “it’s time that government does its job.”  While these bills met with opposition and are struggling to move forward, the structure of the bills provides valuable insight into how environmental health regulations can be structured.

 

Bills introduced by Sen. Flores in California

SB 200

The first bill, SB 200, allows the California Department of Health Services (DHS) the authority to effectively manage and protect the public safety in the event of an E. coli outbreak. It includes the authority to-

• Quarantine
• Recall, and
• Destroy infected produce

SB 200 also creates the Leafy Green Inspection Program at DHS. Inspectors will inspect farms under this program. DHS inspectors will have the authority to conduct their own investigations and take action to protect public health, including the quarantine of produce.

SB 201

SB 201 mandates the application of GAP. DHS will act as the gatekeeper and create regulations for the industry to follow.

SB 201 also requires DHS to develop Hazard Analysis and Critical Control Point Plans (HACCP) systems for leafy greens and requires growers to develop a plan for each growing location and to keep records.

SB 202

SB 202 requires the creation of a trace-back system. This system will require product coding to identify the source of the product all the way to the specific farm where it was grown.

 

Produce Inspection Duties

 

If such rules come into practice the regulator tasked with seeking compliance must acquire a high level skill specific to farming operations. The regulator must validate the management controls in place, verify the effectiveness of GAP application, and  be able to identify or estimate levels of contamination.

 

The roles of the inspector would include auditing records, making visual inspections, ensuring farmers meet GAP standards, and performing tests. Specific duties might include:

 

·           Testing of water

·           Testing of soil

·           Testing of produce

·           Prohibiting use of raw manure

·           Prohibiting the use of creek water for irrigation

·           Prohibiting the use of portable toilets in the fields themselves

·           Maintaining buffer zones around various hazards

·           Overseeing composting operations

·           Approving grazing land set backs

·           Septic tank installation approval

·           Evaluating Concentrated Animal Feeding Operations (CAFO) set backs

·           Testing water sources (ponds / creeks / lakes / rivers, etc.)

·           Validating recall procedures

·           Verifying trace back and trace forward systems

 

Florida Tomato Initiative

 

In Florida, enforceable standards are required in the tomato industry. Florida tomato growers successfully asked our state legislature for regulation. Under Florida Administrative Rule 5Q-6 these measures and inspections will begin this fall. "We want mandatory inspections to bring everybody that handles tomatoes in the state in the loop to comply with food safety," said Tony DiMare, vice president of Homestead-based DiMare companies, one of the state’s largest tomato growers in a story published recently in the Palm Beach Post[7]. "We wanted to take a proactive approach and stay ahead of the curve". The importance of this initiative is underscored by the fact that although Florida was not shipping tomatoes during the early outbreak of this year, the Florida tomato industry lost millions due to fears of  potential contamination

 

The law takes effect before the fall planting season and is under the auspices of inspectors with the State of Florida Department of Agriculture and Consumer Services.. While the largest tomato operations in the state see the advantage of regulation, many of the small and mid-sized growers will feel a serious impact due to new rules covering mandatory washing and temperature controls for products.

 

https://www.flrules.org/gateway/chapterhome.asp?chapter=5g-6

 

Environmental Professionals and Produce Regulations

 

Environmental health professionals have experience in most key areas important to produce safety. New regulations will require regulators to quickly assimilate knowledge about GAP and apply the principles of GAP to their inspection duties. The FDA guidance documents are a good place to start assimilating knowledge but understanding how the industry applies GAP will take some experience. Determining a grower’s compliance with GAP requires familiarity with Hazard Analysis Critical Control Point (HACCP), especially the process of validating and verifying HACCP systems at all levels of the produce supply chain. The produce industry is actively applying HACCP to growing, harvesting, packing and processing.

 

Regulators will evaluate and interpret microbial data. To assess the effectiveness of on-farm food safety programs regulators need working knowledge of basic microbiological sampling methods and testing procedures for products, water and soil. Sanitarians will also need to stay aware of current research and emerging scientific findings. They will take on the job of assisting in mitigation of microbiological hazards and need an understanding of how pathogens contaminate produce and how to assess risks. To ensure their own efforts are successful, regulators must base regulatory decisions on sound scientific evidence.

 

Throughout the history of public health, sanitarians have played an important part in food protection. With experience in so many key areas, environmental health professionals will undoubtedly make a valuable contribution to on-farm-food-safety through regulation. Public health regulation will enhance what the produce industry is doing now, improve its food safety record, and restore consumer confidence in a healthful and safe produce supply.

 

References

[1] “Investigation of an Escherichia coli O157:H7 Associated with Dole Prepackaged Spinach” California Department of Food and Agriculture. US Food and Drug Administration.

http://www.marlerclark.com/2006_Spinach_Report_Final_01.pdf

[2] “Food Safety Bills Face First Legislative Test“. Dean Florez. California State Senate.

http://dist16.casen.govoffice.com/

[3] “California Leafy Greens Marketing Agreement“. California Department of Food and Agriculture.

http://www.caleafygreens.ca.gov/

[4] “Assessments Begin for Leafy Greens Marketing Agreement“ News Release. California Department of Food and Agriculture.. April 2, 2007.

www.cdfa.ca.gov/exec/pa/pressreleases/PressRelease.asp?PRnum=07-030

[5] “Guidance for Industry; Guide to Minimize Microbial Food Safety Hazards of
Fresh-cut Fruits and Vegetables“: US Food and Drug Administration. Draft Final Guidance. March 2007. http://www.cfsan.fda.gov/~dms/prodgui3.html

[6] “Commodity Specific Food Safety Guidelines for the Lettuce and Leafy Greens Supply Chain.-1st Edition“. Produce Industry Publication. April 26, 2006.

http://www.cfsan.fda.gov/~acrobat/lettsup.pdf

[7] “FDAConsiders Safety Guidelines for Produce” CNBNC report

8-Tomato Growers Push for Regulation“. The Palm Beach Post. April 2, 2007.

http://www.palmbeachpost.com/business/content/business/epaper/2007/04/02/m1a_foodsafety_0402.html

 

Continue Reading Produce Is Ripe for Regulation

Who Owns Public Health Protection?

In an ideal world, the government would have the capacity, resources and determination to ensure public health and safety and government would essentially own food safety as one of its key initiatives, controlling the food industry through laws administered by public health agents of the government. This is the way it was for many years. In the very recent past, when the US food supply seemed “the safest in the world” there was little private sector involvement in food safety and the private practice of food safety served mainly as reinforcement for the strong position held by government. Such industry level efforts did not compete with government for “market share” or a piece of government food safety programs.

Today, our governmental agencies entrusted with public health, FDA and USDA, often lack the authority and political strength needed to address new problems of many types related to the health and safety of the populace. While Americans seem to take their public health protection for granted, when it comes to food safety, our governmental agencies have backed away from their responsibility and have relinquished some of their “ownership” over food safety and public health protection to the private sector. There are consequences , some good and some not that we must understand.

Government Disengagement Creates a Vacuum

There are many reasons for apathy on the part of government, but the fact remains that government’s ineffectiveness to protect the public has created a vacuum, and other stakeholders have come forward to fill in the vacuum. This vacuum is being filled by a variety of food safety stakeholders with a profit motive, including private companies of all types (e.g., Environ Health Associates), academia, and research groups and others. This has given rise to a new sector of the food industry the  “for profit food safety products and services industry”. In this relatively new arena, we have various players competing with government for ownership of some part of food safety. Competitors include many types of food service providers (pest control companies, chemical suppliers, lab services, auditing firms, training agencies and programs), professional associations, certification bodies, consulting firms, law firms, and others. All would  would like to lay claim to a share of the lucrative food safety market.

While the unmet needs of the industry and the demand for food safety are the basis for the demand for products and services, the inevitable market forces inherent in any industry model are shaping the field of food safety in subtle yet significant ways. While government attempts to hang on to a leadership position, there are many who claim ownership of parts of the food safety model reserved in the very recent past to government and who approach food safety from a business standpoint.

Who are the Owners of Food Safety Training?

Currently, there are several groups who claim a market share in food safety training. For example, The National Restaurant Association-NRA is a dominant player in the restaurant, food-safety-training market. As a case in point, the Florida Restaurant and Lodging Association-FRLA has over the last ten years fostered strong political connections to Florida’s regulatory agencies and now enjoys a close relationship with the Florida Department of Business Regulation-DBPR, a state agency. 

Influenced by the FRLA lobby, DBPR chose FRLA as the preferred provider of restaurant, employee-food-safety training materials in the state. This is has been a windfall for FRLA and its sales figures are in the millions every year. FRLA now controls easily 90% of the food-safety training market in Florida where there are at least 50,000 mangers and 500,000 employees needing training.. NRA fosters similar relationships in many states, making NRA’s particular brand of training “ServSafe” virtual law in many locations. Such sales provide a sizeable cash flow to NRA and its state affiliates. NRA ands its affiliates use these funds primarily to lobby legislatures on behalf of the industry, not consumers.

Who Owns Food Safety Training in Seafood? 

We see professional associations such as The Seafood HACCP Alliance, with another approach to food-safety training-market "ownership". The Seafood HACCP Alliance through its relationship with the Association of Food and Drug Officials (AFDO) has influenced the required training of all seafood processors. Now, only those trainers sanctioned by AFDO and taking and approved AFDO accredited course (the only approved one, being owned by the Seafood HACCP Alliance, and rarely offered) are FDA approved to give courses. These required courses provide a significant source of revenue to private, AFDO trainers. It is not clear exactly if or how AFDO benefits, but one can see a potential problem for governmental officials who belong to AFDO advocating AFDO as the sole approved source of training.

Who Owns Food Safety Training in the Meat Industry?

At the level of the manufacturing of meat, food safety training must meet the requirements of the International HACCP Alliance at Texas A&M in order to have validity with USDA. Any training considered “valid” training must now pass through the HACCP Alliance, and is subject to fees and review. We can see a similar sort of problem here for USDA in terms of creating a monopoly for the HACCP Alliance. 

Who Owns Food Safety Auditing?

A similar example exists in auditing for compliance with so-called voluntary standards. The Food Marketing Institute FMI, the self-proclaimed voice of the multi-billion dollar food industry, recently entered the food safety-auditing sector in the US. Through its influence over buyers and the retail distribution chain, FMI’s brand of food safety auditing is trying to become the standard by which the entire food production chain self -regulates its own sanitation programs. While the program may have ultimate benefits for consumers, there is a lucrative monopoly position developing for FMI similar to that owned by NRA in restaurants. While there are many competing standards, FMI’s SQF (Safe Quality Foods) standard was recently endorsed by Wal-Mart, the worlds largest retailer. Suppliers to Wal-Mart are feeling pressure to adopt this standard while FMI is driving significant income to itself. FMI is a powerful political lobbying/marketing group that has the best interests of its members, and not necessarily consumers as its core mission. 

Who Owns International Food Safety?

There are examples of ownership at the international level of food safety, where groups like ISO, the International Standards Organization have put pressure on international regulators to adopt standards based on the work of this group; ISO standards are proprietary and owned by this non-governmental organization. While ISO has a very strong consumer focus, the effort is a business proposition as well as a food safety concept.

Who Owns Food Safety Research? 

In the background are the researchers at the National Institutes of Health and their counterparts; academicians who receive extensive research grants, and who claim ownership to the scientific basis for food safety. The budget for food safety research through NIH grants is in the millions each year. Their ownership of food safety research is ownership over a key segment of the market because it is this body of research that drives legislation and the validity of food safety systems across all segments. While our government spends billions on research, the food industry is very slow to adopt new technology. NIH research has produced a great deal of theoretical knowledge but the public has seen very little added protection from foodborne pathogens from new innovations developed and knowledge gained through research.

Who Really Owns Food Safety?

The reality is that a forgotten group of stakeholders actually owns food safety-and it is we… consumers collectively. The consumer through his buying power and voting power is truly the rightful owner of food safety. Several groups such as the Partnership for Food Safety Education, and Centers for Science in the Public Interest-CSPI have recognized this, yet no consumer level group has been able to unite consumers to affect the changes needed in the current food safety model for the exclusive benefit of consumers. While we as consumers hold the real power in food safety, we are often misinformed and remain mostly disengaged from food safety policies. We do not see the advantage we actually have. There is nothing wrong with educational messages from the Partnership teaching consumers how to safely cook or clean, but ultimately, the real power consumers have to protect themselves is at the voting booth and at the supermarket and not in the kitchen. 

The reality is that there is no “market”, no “profit motive” to motivate stakeholders to organize consumers and properly mobilize them. We have a few creditable grassroots activists and consumer groups whose voices the public hears faintly over the din of industry propaganda and government messages. We can find worlds of information from government agencies on their websites, but our government currently has no plans for any organized consumer education scheme. As in everything governmental these days, there is not enough resources, and a serious lack of leadership preventing government from maintaining an effective consumer protection effort or even attempting a meaningful campaign to educate consumers. 

Law firms are now leaders in the food industry, thanks to the failures of public health protection. The hundreds of millions of dollars in lawsuit settlements and judgments paid to consumers who have been injured provide law firms specializing in this area with leverage to influence industry food safety policies and practices in a positive way. Yet, it is really the consumers the attorneys represent that have the most power for meaningful change, not the law firms themselves. 

If trends hold, eventually we may have a very serious mass foodborne illness outbreak affecting consumer in a way not seen before. Thousands of cases of serious infections have occurred over the last few years, some with life threatening hemorrhagic colitis associated with contaminated produce and meat.  Some far more serious illnesses related to food wait patently in the wings to emerge, or re-emerge as serious threats. 

Eventually, the voting/buying public will awaken to the fact that the industry acting in its own best interest will not provide them the protection they expect. Consumers must demand that their government first does whatever is necessary to protect them as a bottom-line responsibility.

Consumers rightly own food safety because we pay for all the interventions government and industry invoke when we purchase food or pay our taxes. Therefore as owners, consumers need to have an influence in the way industry goes about public health protection. If government elects to essentially delegate some of its public health protection responsibilities to industry, than consumers have a right to know what industry is doing to protect them and to have a much greater say in the matter.

As consumers and owners of food safety we have the power to demand that our government effectively protects our health and welfare, to demand that our elected and appointed officials exert real power over those who produce our food, and to require the food industry to maintain transparency.