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Pundit’s Mailbag — Are Attacks
On FDA Flawed?

We consider ourselves blessed to receive some very generous fan mail at the Pundit, but sometimes it goes the other way. So our comprehensive coverage on the Salmonella Saintpaul/Tomato crisis brought this brief, but pointed, critique:

Your repeated attacks on the FDA are not logic nor science-based and put industry protection ahead of consumer protection.

— Bill Gerlach
Research and Development Director
Melissa’s World Variety Produce
Los Angeles, California

Although we enjoy it when people say nice things about our work, we also value those who bring different points of view and are willing to engage in rigorous debate to benefit the industry, the country and the world as a whole.

We have no problem with criticism and recognize that we have no monopoly on truth, so we encourage withering intellectual scrutiny of our ideas. It is exciting, stimulating and helps the whole industry advance.

Unfortunately, this kind of letter doesn’t advance much of anything. We’ve met Bill, he seems like a nice guy; we even published a letter from him once before.

Today’s letter, though, strikes us more as name-calling than anything that will help us grow as an industry.

You want to say that we are illogical? Fair game. But in what way are we illogical? Which article was illogical? Which sentence or claim?

We have a lot of very important readers. If our logic is flawed, we want to correct it, to make a better Pundit — and a better industry.

Yet Bill’s letter doesn’t give us a clue as to what he is talking about.

The same goes for Bill’s assertion that we are not “science-based” — what is he talking about? What scientific fact did we have wrong? In which article? Which day’s issue?

Once again, we are open to critique and acknowledge the possibility, indeed the probability of error — but find this type of critique worthless. We urge people who disagree to engage with us because that is what will make for better decisions, but this is just name-calling.

We will try to address the also unsupported allegation that we “…put industry protection ahead of consumer protection.”

Once again, without a specific example, it is difficult to know why Bill says this but, as a principle, we would say this about our work in this area:

All of us want safe food, and as the father of two young children and the son of a man who had his immune system destroyed by chemotherapy in order to fight a deadly leukemia, we bow to few others in our demand for a safe food supply.

Within the industry, we push and prod for an emphasis on sustainability and sustainability for this industry requires a happy — and healthy and living — customer base. So we can think of few things more important to the industry than producing safe food.

Yet, this all being said, we recognize that consumers of food are not SOLELY consumers of food, and so there are trade-offs in food as there are in most segments of life.

When they purchase a car, very few people think SOLELY of auto safety. They trade off different values — perhaps a larger car is safer, but it costs more to operate.

In society, we recognize the legitimacy of these types of trade-offs. If there is an auto accident and a person dies, we do not declare that model car “flawed” and stop everyone from driving it until we ascertain the “problem” and ensure it has been “fixed.”

In fact we understand fully that we could make the car safer by, say, requiring bigger and stronger bumpers, but we don’t do so because that would raise the weight and the price of the car.

So when we look at food safety, we think about safe food, of course, but we also see trade-offs.

The food supply is exceptionally safe. Just the other day, we ran a piece which analyzed the risk to consumers of this Salmonella outbreak:

As of the latest update, there are 167 people who are known to have gotten sick from Salmonella Saintpaul, with the same genetic fingerprint as is implicated in this outbreak.

If we assume all of these people did, in fact, get it from tomatoes and that for each known sick person there are 99 unknown people who also were sickened by this outbreak but were not sick enough to require treatment, we wind up with a total of 16,700 people sickened as a result of this outbreak.

Now the CDC tells us that this outbreak has had people reporting an onset of illness starting on April 16 and going to May 27, 2008, or a total of 40 days. It is always possible people ate for a day or two before they got sick but let us, for this thought experiment, assume 40 days of consumption.

USDA Economic Research Service reported that in 2006 per capita tomato consumption was 19.9 pounds of tomatoes per person.

Forty days is 11% of a 365-day year, and 11% of 19.9 lbs is 2.19 lbs. A serving of fresh tomatoes is typically represented as ½ cup or 90g or 3.17 ounces.

If you do the math, you find out that during this 40-day period, the average American consumed 11.05 servings of fresh tomatoes.

The current US population is about 305 million people. So during this 40-day period, people ate around 3,370,250,000 servings of fresh tomatoes.

If we go back to our assumption that 99 people got sick for every one we know about, then the odds during this 40-day period that an average person would eat a serving of tomatoes with sufficient salmonella to cause illness was 16,700/3,370,250,000 or 0.000005%.

In announcing its warnings, if an FDA spokesperson prefaced these warnings by saying, “We calculate that during the last 40 days, Americans have been running a .000005% risk of consuming a serving of tomatoes with sufficient salmonella to cause illness as a result of this outbreak, so we are warning against consumption of…” we doubt we would see many of these New York Post-type headlines. In fact, we are not sure anyone would listen to the FDA and its warnings.

Because fresh produce is so safe, it is not clear that consumers would actually choose to pay more to make it safer… or that they should.

Maybe instead of investing in safer food, we should invest in safer cars.

It can’t be an issue of the industry vs. consumers. The industry always must serve consumers.

The question is: What do consumers actually want?

Many thanks to Bill for his letter.

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