The regulations which FDA has proposed to implement the first two of the five components mandated by the Food Modernization Safety Act (FSMA) will dramatically expand federal authority over hundreds of thousands of farms and food handling operations around the world. One can certainly make the case that FDA’s task is both timely and warranted: the standards under revision haven’t fundamentally changed since 1938 and the lethal risks attendant to food borne pathogens are a serious matter.
However, we know from experience, and especially with agriculture, that sweeping, comprehensive federal regulation presents both advantages and disadvantages. For example, the U.S. Department of Agriculture credits its Hazard Analysis and Critical Control Point program with improving the safety of our meat supply, yet innumerable small meat processors have closed up shop rather than assume the extensive compliance requirements it imposes. What is the nature of our current risk from food borne pathogens, how effectively will FDA’s proposal address that risk, and what will be the cost to farmers and consumers? This post and the two to follow will provide basic background for answering these questions and lead into a discussion of the merits of our increasingly centralized and standardized food production and handling systems.
Reports of the fatalities and hospitalizations connected to the latest outbreak of foodborne illness have become a staple of our sound bite, twenty-four hour news culture. Particularly devastating events, such as the 2011 listeriosis outbreak traced to cantaloupes from a Colorado farm which resulted in more than thirty deaths, endure as cautionary lessons for the entire country. Summary data compiled by the Centers for Disease Control conveys a sense that we are almost inevitably destined to be directly affected; it estimates that 48 million Americans suffered a foodborne illness annually with 120,000 requiring hospitalization and 3,000 dying. After years of stalemate between public health, consumer, agricultural and food service interests on Capitol Hill, Congress approved the FSMA’s sweeping expansion of federal oversight in 2010. The FDA is accepting public comment on its current draft regulations through May 16.
The CDC data suggests a genuinely national crisis, and certainly those who have suffered or seen a loved one suffer a debilitating, even fatal illness due to a foodborne illness must see the system as having failed. However, raw data on public health devoid of context can highlight deficiencies within the current safety standards while obscuring successes which we may take for granted. In a vast, culturally diverse and highly mobile society comprised of more than 300 million citizens, how safe can we make our food supply and what are we prepared to sacrifice for incremental gains in doing so? How much government control over how our food is produced and handled are we willing to accept? The ongoing refinement and implementation of FSMA will largely answer these questions.
Next time, we’ll tackle the nuts and bolts of the FSMA’s proposed requirements for fresh fruits and vegetables and food processing facilities.
Mark Keating has worked in the organic, sustainable and local food movements since 1982. His work experience includes commercial food service, farm labor, retail sales and marketing, state and federal civil service, non-profit advocacy, academia, journalism and conducting organic inspections. While working for the USDA National Organic Program between 1999 and 2002 Mark helped draft the national organic standards for crop and livestock production. He spent two more years with the USDA Marketing Services Branch working to develop and promote farmers markets. Mark also worked for the NOP in 2010. An inveterate believer that organically raised and locally distributed food offers the surest path to human health and planetary survival, Mark, his wife and their daughter live alongside the Pequest River in New Jersey, the Garden State.