The Center for Science in the Public Interest (CSPI) and the Consumer Federation of America (CFA) held a press conference issuing a statement headlined as Emergency Regs Needed for Tracking Produce, Food Groups Say.
The gist of their proposal is two-fold:
First, they issued an “urgent plea to Dr. Andrew von Eschenbach” who is the commissioner of the FDA, to issue an “emergency regulation” requiring “traceability for produce.”
Second, the groups also urged the agency to require growers and packers to have written food safety plans.
Caroline Smith DeWaal is the food safety director for the CSPI and she is an earnest, intelligent woman. She is knowledgeable and does a great press conference.
The problem here is that you have groups such as CSPI having goals that were established long before this outbreak and they attempt to use the news to buttress the case for things they want anyway.
We think Caroline wants to make food safer, so we would encourage her to look hard at this specific outbreak and see what can be learned.
The first and most obvious thing is that whatever the problems may be with traceback, this outbreak indicates a problem with our public health system’s epidemiological efforts — not a problem with traceback.
At the very beginning of this outbreak, we published a piece by Jim Gorny, PhD, Executive Director, Postharvest Technology Research & Information Center, University of California, Davis, entitled Tomato/Salmonella Situation Cries For Improved Epidemiology, and he warned us that what slows these things down is epidemiology, not trace back.
Later we published an interview with Michael T. Osterholm, PhD, MPH, Director, Center for Infectious Disease Research and Policy, University of Minnesota, entitled Dr. Michael Osterholm, Esteemed Authority On Public Health, Speaks Frankly About The FDA, The CDC And The Incompetent Management Of The Salmonella Saintpaul Tomato Outbreak Investigation. In this article, Dr. Osterholm very clearly said that the CDC efforts on this matter have been inept and that they were unlikely to find the source BECAUSE OF THEIR INEPTNESS, specifically their failure to trace back the control group.
Traceback only comes into play after epidemiology is done identifying the items implicated. If epidemiology doesn’t tell us whether it is cilantro, tomatoes, jalapenos, Serrano peppers, tortillas or premade salsa — a direct video hookup to the farmer installed on every produce item won’t help solve the outbreak.
As far as having a written food safety plan, we don’t know any large, mainstream operators who do not. Somehow we suspect that CSPI’s earnestness on all these issues will falter when they learn that the practical effect of demanding all these things will drive small organic growers, Amish farmers, etc., out of business.
Be that as it may, we don’t see requiring a food safety plan as an issue, but find the call to be begging the question: What should be in such a plan, who should write it? Must it be certified? By what party? Where do they want the plans held?
Once again, it is basically impossible to be a mainstream grower selling to McDonald’s, Costco, Wal-Mart, Sysco, etc., without being audited numerous times both by third-party auditors and by customers — and you can’t be audited without written plans to audit against.
So this call by the CSPI is odd. The only practical consequence would be to smother tiny growers with expenses they couldn’t handle. It is highly predictable that should such a regulation ever be considered, the organic groups and others will call for an exemption based on small size and get it. So the practical effect of this regulation would be to say that everyone who already has a written food safety plan would have to spend money on “certifying” it in some way.
Net, net, net — there would be no increase in food safety, just another lawyer’s cash cow.
It is very hard to make progress on food safety if the players don’t really look at each outbreak to see what we can learn from it. This one teaches us that changes are needed at CDC and FDA, and that should have been the focus of the CSPI and CFA statement.
