Milan EXPO: World Food Safety and Security Forum
September 22, 2015
Michael R. Taylor
Deputy Commissioner for Foods and Veterinary Medicine
U.S. Food and Administration
I am very pleased to participate in this forum addressing the vital intersection of food safety and food security.
There is no more important challenge for the long-term well being of the world’s population than the success of the global food system in meeting the basic human need for food security, of which food safety is an integral part.
We at the U.S. Food and Drug Administration are part of the food system. We are focused on our central mission to protect the health of American consumers, and we are concentrating much of our effort now on implementing the FDA Food Safety Modernization Act. But for me and many of my colleagues, the experience of implementing our new food safety law has only driven home the importance of FDA thinking and acting as part of a world-wide food system whose goal is food security – ensuring that all people at all times have physical and economic access to sufficient, safe, nutritious food.
FDA is a public health agency, and nothing is more important to public health than food security, when understood in its broadest sense. Too little food or food of poor nutritional quality stunts growth and development, both physically and mentally, with dire consequences for the ability of people to thrive in all aspects of life. People who are food insecure are also vulnerable to obesity and to chronic diseases, like heart disease and diabetes, because they are forced to choose poor quality, calorie-dense foods. Food security is thus a key element in combating the global epidemic of chronic disease.
FSMA is first a food safety law, but if you step back and look at the origins of FSMA and all of the mandates it gives FDA, it becomes clear that our Congress sees food safety in the context of food security and the overall success of the food system. And so, as we do our public health and food safety job, we believe we have a responsibility to be mindful of how that job affects and is affected by the broader realities of today’s global food system, and how we can work well within that system.
Food Safety and FDA’s Role in the Food System
Food System Goals
The story begins with the origins and goals of FSMA. Congress passed FSMA in response to the demands of a broad coalition of stakeholders – produce growers, food processors, retailers and consumers – who were disturbed by a series of illness outbreaks and contamination incidents. These events, which involved both domestic and imported food, harmed consumers, undermined consumer confidence, and imposed costly disruptions on food producers and marketers. And they were largely preventable.
This stakeholder coalition saw the progress that the food industry had made in developing best practices for preventing food safety problems and asked Congress to make these practices the norm for all of those supplying the U.S. market. That is what FSMA does.
While protecting consumer health was FSMA’s central goal – and vitally important in its own right – Congress and FSMA’s supporters also wanted to protect the food system from the loss of consumer confidence and the market disruptions and high costs to industry resulting from foodborne illness.
These goals all relate directly to food security in both its food safety and nutrition dimensions. This is so even among people who generally enjoy food security. To use just one example, when American consumers lose confidence in the safety of fresh produce, or access is diminished due to outbreaks or recalls, they have less food security.
FSMA pursues its broad goals by fundamentally changing FDA’s food safety role and its relationship with other participants in the food system.
FDA-Industry Collaboration on Food Safety
First, FSMA explicitly embraces the food safety role of the food industry. It rests on the core principle that those who produce food for the commercial market have the responsibility and capability to make it safe in accordance with recognized best practices for preventing harmful contamination. FDA has the job of establishing the framework of standards that help define such practices and then overseeing their implementation to achieve high rates of compliance with the standards.
In the past, FDA worked on food safety largely at arm’s length from the industry, as the agency inspected and investigated problems after they had occurred. Under FSMA, and FDA’s implementation strategy, FDA will be working in direct collaboration with industry to prevent problems by actively fostering voluntary compliance with food safety standards. This means providing guidance, education, training and technical assistance so that producers know what’s expected and are supported in doing it. It also means carrying out inspections in a way that focuses less on possible regulatory violations and more on whether food producers are meeting their responsibility to achieve good food safety outcomes.
In this way, FDA will be functioning more as an integral part of the food system, rather than standing apart from the system as primarily an enforcer of rules. FDA will of course take swift enforcement action when needed to protect consumers, using new tools provided by FSMA, but our goal under FSMA is food safety, not enforcement for the sake of enforcement.
Embracing the Diversity of the Food System
Another key feature of FSMA is its recognition of the great diversity of today’s food system, as it operates both globally and locally. With its new import safety mandate, Congress recognized the need to address food safety at a global scale to address the wide range of commodities the U.S. imports from over 200 countries and territories and to assure food is safe regardless of its source. Much of this trade is conducted on a large scale by some of the world’s largest companies.
Congress also recognized the prevalence and value to the food system of tens of thousands of small-scale growers and processors and the emergence in recent years of a vibrant local food movement in response to consumer interest in buying food grown closer to home. In some U.S. communities, local food systems are central features of the social fabric and important contributors to economic sustainability and development.
I believe that diversity is a real strength of the food system – for many economic, social, and consumer preference reasons – and FDA is committed to implementing FSMA in a way that respects this diversity. It is important that the FSMA regulatory mandates for produce safety, preventive controls in food facilities, and import safety are risk-based and inherently adaptable to the diversity of commodities, as well as types and scales of operations, in today’s food system. The final rules we began issuing this month are fully in line with and facilitate that adaptability to diversity.
Collaborating Locally and Globally with Food System Partners
Finally, in enacting FSMA, Congress recognized that FDA cannot succeed on its own but rather must work collaboratively with a wide range of food system partners – both public and private – to achieve our food safety goals. And we fully agree.
The food industry collaboration I’ve outlined is part of the partnership picture, but FDA has also embraced enthusiastically the FSMA mandate to partner with our government counterparts, in both the United States and other countries. At home, we are continuing to build a national integrated food safety system that includes expanded collaboration with our federal government partners but also a true operational partnership with the 50 states. This builds on a long history of FDA food safety work with the states and is aimed at making best use of all available public resources to implement FSMA effectively and ensure consistent, high quality oversight nationwide.
We see international collaboration and partnership on food safety as equally important, and potentially even more transformational. A major political factor in the enactment of FSMA was the rapid expansion of food imports to the United States, recurring outbreaks and contamination incidents, and a resulting loss of consumer confidence in imported food. Congress thus directed FDA to build a new import safety program. This program is to include new accountability for importers to verify the food safety practices of their foreign suppliers, as well as expanded FDA presence overseas to conduct inspections and collaborate on food safety with other governments.
This new mandate for FDA must be seen in the context of similar efforts to strengthen food safety systems all over the world. In fact, one of the reasons this is such an historic time for food safety is the great degree of alignment that exists across the food system on the need to build modern preventive measures into food production operations and, equally important, verify that those measures are in place and working. That is what FSMA is about.
As we implement this new imports system, we will do so in a way that is consistent with our international trade obligations and recognizes the flexibility needed to accommodate different sizes and types of foreign suppliers while achieving our food safety goals.
Role of International Collaboration in Implementing FSMA
One of the biggest food safety challenges we all face, however, is how to provide the level of verification that is needed for food safety and consumer confidence in a world of expanding scale and diversity of international trade in food, coupled with always finite and often scarce resources available for food safety.
That is the reason why one of our central FSMA themes is working closely with foreign governments that share our food safety goals and whose own food safety efforts can contribute to the assurances we seek regarding the safety of imported food. We are motivated by our need to make the best use of the resources we have, which means risk-based targeting of what we do and avoiding duplication of effort when we can.
The overarching goal of our international collaboration is mutual reliance, which entails the ability of FDA and its foreign food safety partners to rely on what each other are doing in a range of possible ways. Let me give you a few examples, beginning with systems recognition.
Systems recognition is based on a rigorous assessment by FDA that another country has a food safety system that is comparable to ours in its capacity and effectiveness in assuring good food safety outcomes. We believe this regulatory cooperation program will assist us as we implement FSMA and deploy our food safety resources. Over the last five years, FDA has developed a well-defined process for assessing the comparability of other national food control systems, and we are finalizing systems recognition agreements with several countries. It’s a two-way street since the goal is mutual recognition and mutual reliance.
It’s important to be clear that systems recognition is a tool for food safety cooperation, rather than being a market access tool in the trade sense. With a systems recognition agreement in place, we can better target our foreign inspection and border surveillance resources where there is a greater risk of non-compliance with U.S. requirements. We also plan to allow U.S. importers, in meeting their new food safety responsibilities under FSMA, to take into account whether their foreign supplier is in good standing in a country whose system we have recognized as comparable.
So far we have entered into a systems recognition agreement with New Zealand, which collaborated with us on our initial pilot test of the assessment process. We are in late stages of assessments and development of mutual recognition agreements with Australia and Canada, and we have begun the assessment dialogue with our counterparts at the European Commission. We are eager to build collaboration with Europe in all aspects of food safety.
In addition to system-wide mutual recognition, we see great opportunity for commodity-specific collaboration with foreign partners.
A prominent example is the Produce Safety Partnership we launched in 2014 with our Mexican regulatory counterparts. This partnership is based on our common interest in the safety of Mexican produce and our shared commitment to make FSMA’s prevention strategy a success. We are exchanging information and expertise and working with Mexican authorities as they engage their growers and packers in preparation for FSMA’s forthcoming produce safety rule. We consider Mexico a full partner on produce safety and indispensable to achieving our shared food safety goals.
Another example is our several years of work with China’s AQSIQ to improve compliance with U.S. limits on the use of animal drugs in aquaculture. We have invested much effort and made significant progress through education and technical assistance for Chinese producers and regulators and joint inspections to build our confidence in Chinese government oversight in this arena. We are doing this work under a broad memorandum of agreement with China to pursue mutual reliance on food safety, and it shows that working together on food safety pays off.
Food safety capacity building – involving education, training and laboratory harmonization – is part of our collaboration with Mexico and China and has been a part of FDA’s engagement with the international community for many years. Under FSMA, however, we have a new mandate to foster improved food safety capacity in countries that export food to the U.S. Congress directed us “to develop a comprehensive plan to increase the technical, scientific, and regulatory food safety capacity” of governments and food industries in these countries, which we completed in 2013.
Our plan makes clear that the capacity building challenges are enormous, but so too are the opportunities to improve food safety by strengthening capacity across the global food system. The plan emphasizes the limits on what FDA can do unilaterally in this arena, given funding and other realities, but outlines ways we can make a difference by working with other governments and the private sector.
I see the FSMA mandate on capacity building as another example of how Congress takes seriously the role of the United States and FDA as part of a global food system that has to work together to be successful. FDA totally embraces that idea.
That’s why we have supported enthusiastically the establishment at the World Bank of the Global Food Safety Partnership . The Partnership is a public-private initiative aimed at providing food safety training and technical support so developing countries can improve their food safety systems and benefit from better compliance with food safety standards. FDA has provided seed money to help get the Partnership started and supports developing it into an important part of the capacity-building landscape.
Food Safety, Food Security and Development
I’d like to close by coming back to the link between food safety and food security, especially as it occurs in the developing countries that are important sources of food for the U.S. and Europe. In these countries, agriculture and the food system – all that goes into producing and distributing food – are often the dominant economic activity and widely seen as a key driver of economic development. At the same time, food security – as affected by inadequate supply, poor distribution, and lack of safety – is too often an acute concern.
That’s why all of us – whether focused mainly on public health, agriculture, or broader economic development and poverty reduction – have a common interest in the overall success of the food system, including its role in making food safe. By investing in a developing country’s food safety capacity, we make food safer for U.S. and European markets, and we also foster food security and economic development in less well-off countries.
FDA is thus very pleased that the Global Food Safety Partnership is lodged at the World Bank, as a reflection of this synergy between food safety and development, and we hope the Partnership will be a vehicle for mobilizing trade- and development-oriented resources to work at the nexus of food safety and food security. The World Trade Organization’s Standards and Trade Development Facility is another international vehicle for pooling resources to support food safety capacity building, in recognition of its link with food security, development and trade.
FDA’s food safety capacity building strategy is based on partnering with entities like these. We want to contribute our expertise to making food safer, and food systems more successful, for consumers wherever they live.
Thank you for inviting FDA to participate in this World Food Safety and Security Forum. We applaud the conveners for the broad framing of our food system challenges. And we look forward to sustaining the dialogue and collaboration started here.