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Michael R. Taylor, J.D., Grocery Manufacturers Association Science Forum

How the Food System Will Make Food Safer 
And the Role of Science in a Prevention-Based Paradigm

Remarks prepared for delivery by 
Michael R. Taylor
Deputy Commissioner for Foods
U.S. Food and Drug Administration

Grocery Manufacturers Association (GMA) Science Forum
Washington, D.C.
March 16, 2010

I want to thank GMA for inviting me to speak. It’s a great opportunity to share some thoughts about the distinct but complementary roles FDA and the food industry play in meeting consumer expectations for a safe and nutritious food supply.  And it’s the right forum to focus on the role science must play in everything we do.   

When GMA asked, I wasn’t told I’d be following the First Lady.  But I’m glad I am, because I want to underscore how committed FDA and HHS are to the First Lady’s obesity initiative.

Front-of-Pack Labeling

We’ve been working closely with the Department’s leaders and the White House on the information element of the initiative, focusing on front-of-pack (FOP) nutrition labeling.  And we’ve had very productive conversations with GMA’s leaders about the goals of FOP labeling and the collaborative, research-based approach we want to take to finding an FOP solution that works for consumers.   

Our goal is FOP nutrition labeling that provides clear, consistent information in a format that enables consumers to readily notice, understand, and use the information to compare products and choose healthier diets for themselves and their families.   

We hope this is a goal on which we can agree and on which we can work together. And that includes working together on the consumer research that must underlie an effective FOP solution.  We expect to be sitting down with experts from GMA member companies, as well as from the retail sector. And we will be reaching out to other agencies, academic experts and the consumer community and working with a new Institute of Medicine committee on FOP labeling.  In the end, the choice of a FOP labeling solution will require a judgment about what works in the real world, but we want it to be a research-based judgment driven by what will help consumers.

Food Safety

We’re at an historic juncture on food safety, with broad consensus on the need to modernize how the government’s food safety system and on the broad principles that should guide the system.  

These principles are familiar to most of us.  We need a system that:

  • Is prevention oriented – the key to public health and public confidence;
  • Science- and risk-based – which is essential to being effective and efficient in reducing foodborne illness;
  • Addresses food safety comprehensively, from farm-to-table; and
  • Holds imports to the same standards we set for domestic facilities.

The pending legislation embraces these principles, and we appreciate GMA’s support for its prompt passage.  The hard part is not the principles – or even passing the legislation – but putting them into action, and I’d like to touch on three topics that will be critical to implementation of the vision I think we all share.   

First is being clear about the respective roles of government and industry and how they work together to make food safer.  Food safety is a food system challenge, and it will take a food system effort to meet the challenge; government and industry both play essential, distinct and complementary roles.

The second topic, and the most appropriate for this forum, is the role science must play in a prevention-oriented food safety system.  With the science-based prevention paradigm fully embraced by the Obama administration and about to be adopted as national policy by Congress, it is more critical than ever that government and industry have the science needed to understand and prudently minimize food safety hazards.

And third, I will reflect on the respective roles of FDA and the industry in generating the data, the scientific understanding and the technological innovation that will be needed to meet today’s dynamic food safety challenges.  
For our part at FDA, we know that we have a duty to provide scientific leadership on food safety, but we also know that many of the companies represented here have a deep reservoir of expertise and that technological innovation to improve food safety has historically come primarily from the food industry – and this must continue.    

Government and Industry Food Safety Roles

One way to think about government and industry roles on food safety is to ask the question:  How will food get safer? The starting point for me in answering this question is to say emphatically that there is little government can do acting alone to make food safer, but there is a lot government can do acting in parallel and often in concert with others, including the companies represented here. And the reason for this lies in the very nature of the food safety problem: it’s not a government problem or a food processor problem, it’s a food system problem.

You know this very well:  food safety outcomes – whether and to what extent people get sick – can be affected at every step along the supply chain and by every participant in the system, from agricultural producers and the fishing industry, to food processors, transporters, retailers and consumers.

This also means that opportunities to prevent problems lie at every step along the way and that food safety solutions ultimately have got to be food system solutions.  And just to be clear, FDA, as a part of the food system, has to be part of the solution. Put simply, everyone shares responsibility for food safety – we’re all in it together.

And so, food gets safer – the food safety system works – when everyone in the system does their part to prevent hazards from entering the food supply and reaching the consumer. This is not a new or complicated idea, but it is hard to execute, in large part because there are so many moving parts, so many actors in the system, and thus so many points at which something can go wrong to cause a food safety problem.

It is thus a striking achievement that the food system does the remarkable job it does in providing the public with an abundant, low cost food supply that is, by global and historical standards, fundamentally sound and as safe as any.

But we also know our food supply it is not as safe as it can be.  Many participants in the system perform well consistently, but many don’t. We know there are interventions and practices that can make food safer, but we don’t always adopt them.  And we know that every significant outbreak or contamination incident can be tracked back to some preventable action or event.  

So what are the respective roles of government and industry in making food safer?

The starting point must be the role of industry – those who produce, process and market food. I’ve often said that the government doesn’t make food and can’t by itself, acting directly, make it safe.  That’s the food industry’s job: the food industry has the primary responsibility for the safety of the food it produces and sells.

For the food companies gathered here, that means such basics as verifying that suppliers are providing safe ingredients, understanding hazards that may be inherent in their own operations, applying modern controls and interventions to minimize them, verifying that these controls are working consistently, and rapidly detecting and containing problems when they do occur.

Conceptually, this is just “Preventive Process Control 101.” But, again, the ideas are easy; the execution can be a challenge. It requires management commitment, capital investment, scientific understanding of the hazards and controls, innovation to address new food safety issues, and technical expertise and staffing to implement. All of this incurs cost, and the challenge only gets greater as supply chains and operations spread globally.

Many of the companies in this room are among the world’s leaders in food safety; you have made the commitment and the investment; and you have developed systems and innovations that work well to minimize hazards. You are doing this for your customers and your businesses, not to please FDA, but we at FDA applaud you for what you are doing to make food safe.

So, where does FDA come in?  What is FDA’s food safety role?  I’ll say again, FDA doesn’t make food and can’t by itself, in any direct way, make it safe. But FDA plays a critical role in the food safety system to address three persistent realities. First, some companies don’t make the needed commitment to food safety or fail to fulfill it consistently.  Second, some of the data and scientific understanding needed to support a risk-based, preventive food safety system can only or at least best be produced by government.  Third, because we depend on millions of human beings to produce and process food, problems will occur that require government intervention to solve, working in concert with the food industry.

So I see FDA contributing to making food safe in at least three important ways, none of which involve FDA making food safe directly,  but all of which involve influencing or supporting the actions of those who do make food safe.

First, FDA’s core food safety role, as a public health regulatory agency, is standard setting and compliance.  In particular, FDA’s role is to set and ensure high rates of compliance with prevention-oriented, science-based food safety standards that provide the level of protection that consumers expect and deserve, and that provide the food industry a level playing field.  This is not a new role for FDA, but it will become even more important in the future as we broaden implementation of preventive controls.

The basic elements of preventive controls are well known, but what do they mean in practice in a wide variety of operations? The details of how a company implements preventive controls should be determined by the company itself.  But the level of protection and verification that is adequate is an issue FDA will have to address, with input from industry, consumers and food safety experts, so that the public can have confidence that the system is working effectively to prevent food safety problems.  And, of course, through inspection and enforcement, FDA helps ensure high rates of compliance with food safety standards.

Second, FDA plays a critical scientific and technical role in the food safety system.  For example, it serves as a source of scientific expertise in key fields like food science and microbiology, analytical methods development, toxicology, and risk assessment.  FDA also conducts and helps set the agenda for food safety research.  And FDA provides information to industry on hazards and on interventions and practices that can prevent food safety problems.  I’ll say more about FDA’s scientific role and how it relates to industry’s role in a minute.

But, third, FDA plays a critical role in detecting and responding to food safety problems, especially contamination incidents and foodborne outbreaks.  This is a large topic that deserves its own discussion.  But I want to assure you that FDA takes very seriously its responsibility to act swiftly and effectively when problems occur, both to protect consumers and to help companies discover the source of the problem and contain it. 

We’re doing a lot to improve our performance, which I would be happy to come back and discuss, including how we can improve our collaboration with the food industry in emergency response situations. 

The Role of Science in the New Prevention Paradigm

I think I need to speak only briefly to this audience about the role of science in implementing the risk-based, prevention-oriented food safety paradigm.  Science must underlie everything we do, and everything you do, to ensure food safety.

For FDA’s part, we need to collect the data, do the research, and perform the analysis required for:

  • identifying and understanding the most significant problems to be sure we use our resources well to reduce foodborne illness – in this respect epidemiology needs to play an enhanced role priorities;
  • setting standards that reflect our science-based understanding of the risks;
  • developing analytical method and other food safety tools;
  • evaluating the effectiveness of specific food safety procedures and interventions;
  • detecting and containing food safety problems; and
  • evaluating the overall effectiveness of our program.   

The food industry has many of the same scientific needs to understand and prevent problems at the plant and system level, having to do with understanding hazards and controls, creating and validating innovative food safety procedures and interventions to prevent problems, and having better methods for detecting and containing potentially harmful contamination. 

The government and industry need for high quality scientific research and data to achieve success on food safety is only going to grow. So, this is a good time to open a dialogue about how we are together going to meet those needs.

Like food safety in general, I believe the discussion needs to begin with the industry’s role and primary responsibility to know what it needs to know and to have the tools it needs to have to produce safe food. But I also think that FDA, along with other agencies, has a duty to contribute in a very significant way to building the science base required for an effective, prevention-oriented food safety system.  Some of the needed work is really only done feasibly by government, such as the epidemiology of foodborne illness, baseline surveys, and basic toxicological research and methods development.  But other work, perhaps most notably analytical methods development, is done – and needs to be done – by both government and industry.

In all of the work that is done, the question has to be how can we do it better?   For FDA, this means asking some hard questions:

  • How can we be sure government food safety research is focused on the highest priority mission needs?
  • How can we take advantage of the scientific resources across the entire Foods Program, at headquarters and the field?
  • How can we link our research and methods development program to work going on in other government labs?
  • How can we link what we do with work going on in the food industry?   

I pose these questions from the vantage point of an agency that has a proud and strong tradition of food safety leadership, including scientific leadership—and with full recognition of the strong base of scientists and programs on which FDA’s scientific reputation is based.   But the challenges to FDA’s science and science capacity have never been greater, so we are very focused on building our capacity and being sure we make the most of it.

This focus is seen in:

  • the investments we are making in people and facilities;
  • the research planning efforts the Center for Food Safety and Applied Nutrition, Center for Veterinary Medicine, and Office of Regulatory Affairs are undertaking;
  • the consideration we are now giving to how we can more fully integrated the foods-related research programs of all three operating units plus the National Center for Toxicological Research; and
  • the links we have built with researchers and other scientists from industry and academia through the Joint Institute for Food Safety and Applied Nutrition, the National Center for Food Safety and Technology, and other channels.   

There’s more we need to do internally to meet today’s scientific challenges.  But there is also more we need to do in collaboration with others, including the food industry, to prioritize hazards and interventions, develop methods, and share data.  I see FDA and industry collaborating on concrete problem solving as new problems emerge and solutions are needed.  I also see FDA stimulating research in academia and the private sector through dialogue on research priorities and technology development needs.

FDA will meet its responsibility to provide scientific leadership on food safety by doing the things only we can do, but also by working with the food industry and its scientists – tapping into your expertise and your responsibility for developing and applying the best science to improve food safety.   

In closing, there are no silver bullets or magic wands for food safety.  It’s a long-term system building and system change process that will require all of us working together.  We look forward to working with all of you.