Introduction
How safe is the food we eat? How safe do we want our food to be? Is the safety of food more important than its price, quality, or convenience? On the surface, these are relatively simple questions with simple answers. Yet, if we examine them closely, we may find that these questions lack definitive answers. Moreover, possible responses could have ethical and political consequences besides food safety implications; so we must weigh these issues in terms of idealism versus realism.
Magnitude of the Problem
Part of the difficulty in dealing with food safety is that the true dimensions of the problem are not known. In the U.S. cases associated with pathogenic microorganisms and their toxins are likely to range from 6.5 million to 33 million annually and deaths from 200 to 9,000 annually. While these numbers reflect only those cases associated with foodborne pathogens, foodborne safety extends to broader categories of concern. FDA's ranking of food safety priorities, in descending order are:
So, how safe is the food we eat? While food safety is a universal issue, most of us buy, prepare, and consume foods without any undue concern. The U.S. food supply is touted as among the world's safest. This statement may be true, but it does not mean that our foods are entirely free of risk. The estimates cited above clearly indicate that a problem exists.
Mixed Messages
The second and third questions; "How safe do we want our food to be?" and "Is the safety of food more important than its price, quality, or convenience?" should be considered together. The reason for this is that we, as consumers, are sending mixed messages. As consumers we want: quality, convenience, variety, minimal processing, no chemical additives or preservatives and safety. Most of our foods, particularly processed convenience foods, are not inherently safe, but rather safety is engineered into the product through processing, packaging, prudent use of additives, storage and handling conditions (temperature), or combinations of these. As we demand products that restrict or minimize these conditions, it is quite possible to reduce the margin of safety (increase risk). I am quite sure that consumers are not aware of this paradox.
HACCP
During the last half-century there have been many technical advances in the manufacturing of food products. A quick perusal of the shelves in a modern supermarket provides ample evidence of successful product innovations resulting from advances in science and engineering. Yet, while product and processing innovations have advanced, it has only been in the past few years that any significant change has been initiated regarding food inspections.
Traditional approaches to food inspection have often focused on "floors, walls, and ceilings". In other words, inspections have traditionally placed more emphasis on the food processing environment than actual processes. The processing environment is important, but control of the actual physical processes associated with the manufacture of foods is equally important. This is where HACCP (Hazard Analysis Critical Control Point) will make a strong contribution to our food safety inspection program. The National Academy of Sciences describes HACCP as a scientifically sound approach to food safety control.
Conceptually, HACCP is simple but elegant. It identifies the food safety hazards associated with specific characteristics and processes associated with a food and establishes controls in the process that prevent the hazards from occurring. Thus HACCP is preventive as contrasted with the traditional system which is reactive. The basis for describing the traditional approach as reactive is the heavy reliance on "end of the line sampling". The product is made and then evaluated to confirm if it was manufactured according to specifications (including safety specifications). It is not difficult to develop a long list of shortcomings with such an approach to food safety control. Conversely, in a HACCP system, the processes are monitored at specified Critical Control Points as the product is manufactured. Periodically, samples of the finished product are analyzed, but this serves only to verify that the in line preventive measures are controlling the hazards.
The National Advisory Committee on Microbiological Criteria in Foods has recommended that the elements of a HACCP system should include the following seven principles:
Currently, FDA has proposed rules that would require seafood processors to develop HACCP plans to control food safety hazards. Also, as you probably already know, USDA's Food Safety and Inspection Service is actively pursuing incorporation of a HACCP-based system for products under their jurisdiction.
In my opinion HACCP has the potential to significantly improve a processor's ability to control the food safety hazards. I am concerned, however, that HACCP (as defined in the seven principles above) will be diluted by the "political process" to such an extent that it may not be effective. As a prime example of this, FDA's proposed HACCP rules do not include principles five and seven. The Office of Management and Budget could not find any justification for the inclusion of these two principles and made FDA remove them from the requirements.
I also believe that HACCP-based concepts must be applied at other points in the food continuum from production to consumption. While the processing sector is important, the phrase "a chain is no stronger than its weakest link" is quite applicable to the food chain.
Single Food Agency
Politically, I do not know if it could ever happen, but it makes sense to incorporate our entire food inspection system under one agency's umbrella. Currently, there are two big players, USDA and FDA. There are, however, several other agencies with significant responsibilities: National Marine Fisheries Service, Department of Defense, Environmental Protection Agency, and Customs. While there are any number of Memorandums of Agreement between these agencies, in which they pledge mutual support and cooperation, communication and coordination do not always exist. Additionally, there traditionally has been a difference in regulatory philosophy between agencies, particularly USDA and FDA.
Communication
We need to do a better job in communicating with consumers. Instead of talking about zero risk, associated with food safety concerns, we need to be communicating the concept of risk minimization. As veterinarians I am sure you are cautious in making absolute guarantees although you may have a high degree of confidence in your treatment. The same applies in the area of food safety. We recognize that certain risk factors are small, even very small, but it is unwise and unethical to lead consumers to believe that all foods are free of food safety risks.
