On June 3, the U.S. House of
Representatives Committee on Energy and Commerce held hearings on the
proposed Food Safety Enhancement Act of 2009 (http://tinyurl.com/pzwfec ).
Most of the provisions are well-meaning and the bill would give FDA
additional resources and authorities it needs to monitor the food
industry. Margaret A. Hamburg, the new FDA commissioner, called the
legislation ďa major step in the right direction,Ē but stated that her
agency will need more money to carry it out (http://tinyurl.com/r237lg ).
The purpose of the proposed
legislation is to help FDA better ensure the safety of the nationís food
supply. Some of the provisions include required registration of all
domestic and import food processing facilities and a $1,000 annual fee to
help offset the costs of FDA inspections and recalls. It also provides
for preventative food safety plans for imported foods and fresh produce,
increased microbiological testing and improved traceability for all food
The question is, will the
passage of this bill make food safer for consumers?
The problem with inspection and
testing is that neither necessarily results in safer food. In the end,
what makes foods safe are validated safe food processes. Of course, that
is what HACCP is supposed to provide. Inspection and testing are useful
tools to verify safe food processes, but by themselves they do little to
make food safe.
Whether the food safety problem
is E. coli in fresh spinach, Salmonella
in peanut butter or melamine in milk, properly designed and validated
HACCP plans should successfully control food safety hazards and provide
for safe food products.
The challenge is to assure that
all food processing plants operate under validated HACCP plans and have
the necessary technologies to control food safety hazards. When that is
accomplished, USDA and FDA will actually require fewer inspection
resources and less money.† Testing
will be done only to verify the effectiveness of the food safety systems.
For too many years, we have
operated under the assumption that inspection makes food safe. Recently
that premise also has included the assumption that increased testing
makes food safe. It is impossible to inspect and test all food. It is,
however, possible and even cost-effective to produce all food under
validated safe food processes, apply continuous monitoring to assure
process control and then verify through inspection, testing and record
keeping. This approach definitely makes food safer for consumers and
eliminates most or all recalls in the process.