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5. Where Current US Food Safety Activities Fall Short
Pages 79-90

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From page 79...
... The increasing complexity of food production and delivery and the exploding internationalization of the US food supply impose added pressure on the federal regulatory apparatus which was constructed in simpler times. Given the challenges, the US food safety system has several strengths.
From page 80...
... However, in spite of growing national concern about foodborne illnesses, both research and its scientific base for the regulatory programs in the FDA were slowly eroding prior to the Food Safety from Farm to Table: A National FoodSafely Initiative (Appendix C) ; this trend appears to be changing with the current actual and proposed increased funding for food safety research (Appendix E)
From page 81...
... . President Clinton's fiscal year 1999 budget proposes increased funding for food safety research as part of the National Food Safety Initiative.
From page 82...
... While these actions are significant steps toward improving food safety research, there remain major shortfalls in the application of science in the current system, which include: · There is no nationally coordinated scientific research agenda among all agencies involved in food safety-that stems from a unified mission or centrally focused leadership. · There is a lack of adequate integration of research efforts among agencies.
From page 83...
... The major shortfall with regard to the use of risk assessment in the current system includes: · Under the current statutory and budgetary constraints, it is not possible to fully realize the benefits of the valuable and critical tool of risk assessment and its resulting positive impacts on food safety. INSUFFICIENT INFORMATION A glaring weakness of the current US food safety system is a lack of information.
From page 84...
... Current resources are not adequate to meet statutory requirements and to train and hire the federal regulatory personnel required to implement HACCP programs fully throughout the food safety system. Implementation of HACCP systems throughout the food continuum is a major step toward enhancing food safety, but HACCP systems should not be thought of as preventing all human illnesses resulting from consumption of potentially hazardous foods.
From page 85...
... There is a lack of a unified mission among the various agencies with regard to food safety. STATUTORY LIMITATIONS There is no "food safety" counterpart of such modern federal regulatory laws as the Clean Air Act or the Occupational Safety and Health Act, and there is no comparable legal framework for federal food safety activities.
From page 86...
... The law obligates FDA or EPA to entertain and rule promptly on applications for new food additives. Although the agencies rarely meet statutory deadlines, their legal obligations to rule on new chemicals have led them and Congress to allocate major resources to this function and to neglect activities directed toward food sanitation.
From page 87...
... It is a matter of debate whether federal law potentially applies to these activities, but it is clear that federal officials leave regulation of them to the states and localities, where monitoring and enforcement are vulnerable to budgetary pressures, jurisdictional disputes, and diverse legal standards. The major statutory shortfall of the current system is that: · There are inconsistent, uneven, and at times archaic food statutes that inhibit use of science-based decision-making in activities related to food safety, and these statutes can be inconsistently interpreted and enforced among agencies.
From page 88...
... Lack of public and private coordination. As described by the United Food and Commercial Workers Union, implementation of HACCP programs in meat packing plants is often required and attempted without allowing time to perform proper cleaning or to conduct effective employee training (Jackie Nowell, United Food and Commercial Workers Union, personal communication to committee, April 1998; Appendix D)
From page 89...
... FSIS statutory authority requires meat and poultry food safety systems of exporting countries to be equivalent to the US system (GAO, 1998~. FDA lacks the authority to require that imported foods be produced under a system equivalent to the one that it administers domestically; instead, FDA relies primarily on sampling at ports-of-entry to determine whether food imports meet domestic requirements (GAO, 1998~.
From page 90...
... SUMMARY FINDINGS: Where the US Food Safety System Falls Short Inconsistent, uneven and at times archaic food statutes that inhibit use of science-based decision-making in activities related to food safety, including imported foods; a lack of adequate integration among the 12 primary federal agencies that are involved in implementing the 35 primary statutes that regulate food safety; inadequate integration of federal programs and activities with state and local activities; absence of focused leadership: no single federal entity is both responsible for the government's efforts and given the authority to implement policy and designate resources toward food safety activities; lack of similar missions with regard to food safety of the various .


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