One wonders if the FDA is aware of how much its rhetoric has diverged from its practice. On a recent press call, Dr. David Acheson, M.D., FDA’s Associate Commissioner for Foods, said all the right things about food safety. When he was asked if the FDA was going to do more inspections, he said that although FDA would be adding inspectors, you can’t inspect safety into fresh produce at the end.
The key, he correctly stated, was to “build prevention and safety up-front.” In other words, you can’t see pathogens, so mere visual inspection won’t help very much. You can test, but it is expensive, takes time and we are unlikely to be able to test enough product to statistically guarantee safety. That is why farmers in implicated areas can’t just test a load and then send it over with a certificate.
So the only option is a system to ensure that during the entire lifecycle of the product, it is always treated in accordance with best practices — that is, building prevention and safety up front.
Yet… and here is the rub: Despite saying this and seeming to recognize its importance, the FDA has made NO ALLOWANCE for firms that have done this. In fact, the FDA treats the most negligent farmer in a region EXACTLY THE SAME as the most progressive and safety-conscious.
Although FDA has a mechanism for whole states or regions to prove they were not in production or marketing at the time of the outbreak so that they can be added to the “not implicated” list, it has no mechanism to provide relief for a farm that made the effort to do what Dr. Acheson wanted it to do: Build prevention and safety up front.
Show at FDA’s door with a raft of Primus and Davis certifications? It doesn’t help. Perhaps you are certified under Tesco’s Nature’s Choice scheme or Marks & Spencer’s Field-to-Fork program? No difference. McDonald’s, Darden, Denny’s, Jack-in-the-Box, Sysco, all trust you? Unimportant to the FDA.
All in all, each time there is an outbreak on fresh produce FDA is damaging public health by micro-focusing on the one known outbreak as if it is the only food safety risk in the world.
In the short term, bans on complete regions lead buyers to purchase produce from strangers. In other words, carefully vetted companies get tossed aside and their produce is replaced by the production of far less vetted farms and companies.
So because less prevention and safety was built in up front — because the FDA compelled the buyer to drop its supplier with whom it worked to build in prevention and safety — the risk to consumers actually is increased due to FDA’s actions, not decreased.
Want to know what would have made a big difference in future food safety expenditures and thus, long-term, in food safety? If FDA had announced that while it searches for a source, it is going to block imports except from those farms that are third-party audited to conform to Good Agricultural Practices, then FDA would be sending a message that it pays to invest in food safety. Now FDA just sends this message: Don’t listen to what we say, watch what we do and we will treat the most safety-conscious grower precisely the same as the most negligent grower.
There is no upside from the FDA in any individual farm investing in food safety.
