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Michael R. Taylor, J.D., Global Food Safety Summit

Remarks presented by Michael Taylor, Deputy Commissioner for Foods, Food and Drug Administration, before the Global Food Safety Summit, February 4, 2010, Washington, D.C.

I really do appreciate the chance to be here today and join so many people who are colleagues and partners in food safety.  Today, I want to talk about how we – and I do mean all of us – are going to make food safer.  And I have one very simple message, which is that I really do believe we are all in it together and that together, we can succeed in making food safer. 

I’m going to talk about FDA’s role in making food safer.  But I really think it’s critical to put FDA’s role in a much broader food system context because the bottom line is that food safety is a food system challenge. 

I don’t need to review what the challenges are for this audience.  You know the dynamic nature of the food system and the challenges we face.  We do have a persistent burden of food-borne illness in this country.  And recently, in particular, we’ve had some very visible, very large-scale outbreaks that have resulted in declining consumer confidence in the food safety system itself and big economic impacts for the industry. 

And we at FDA encounter this situation in a time where it has been a very long time since our laws have been modernized.  We do operate under obsolete food safety laws and it has been a struggle to create the capacity to keep up with new scientific developments and the incredibly dynamic nature of the food system. 

But the opportunity for progress has also never really been greater.  And I think all of us who have been watching the political alignment around food safety in the United States are keenly aware of this.  We really do have an opportunity to make some interesting changes.  The White House has made food safety a priority.  Congress is working on bipartisan food safety legislation that really would overhaul FDA’s food safety laws.  Within the Department of Health and Human Services, Secretary Sebelius, and FDA Commissioner Hamburg have a really deep, personal commitment to building a stronger program at FDA.

And what’s striking to me is that in addition to this sort of political-level alignment, we have alignment on the direction that change should take.  We should take pride in this achievement because a lot of us in this room have worked on food safety issues for a long time.

It’s clear that we need a system that is prevention-oriented.  That’s really the fundamental principle of public health.  We also need a system that’s science- and risk-based.  Don Zink, who spoke before me, and his colleagues are certainly leaders in that enterprise.  This is really essential if we’re going to have a system that’s both effective and efficient in reducing food-borne illness and preventing food safety problems and a system in which the public can have confidence.  Also important is a system that addresses food safety comprehensively from farm to table – again, a very familiar principle to the people in this room.  And we also need a system here in the United States – and I know this goal is shared by countries around the world – a system that holds imported foods to the same standards that we set for domestic facilities. 

So we know, conceptually, where we’re going.  But how will we actually make a difference?  How will food actually be made safer in a system that is operating under these principles?

The first thing I want to emphasize is that, in fact, it won’t be just because of what government does.  As I said at the outset, food safety is a food-system problem.  We know that food safety outcomes are affected by what happens all up and down the supply chain.  It starts with agricultural producers and the fishing industry, food processors, transporters, retailers, and consumers.  The whole system engages in behaviors that can create hazards but also creates opportunities to minimize the hazards.  And so again, the core principle that I really want to emphasize is that everyone shares responsibility for food safety. 

This is kind of an obvious observation.  I think most of us who’ve been around food safety would say that there are elements or concepts or practices that contribute to prevention that aren’t rocket science.  But achieving this goal and fulfilling this vision of everybody doing their part to improve food safety is a very difficult thing.  And it’s because we just can’t lose sight of the complexity of the system, but also, the fundamental human aspect of the food system.  It is about millions of people doing billions of things every day that affect the safety of the food supply. 

And so I think one thing we have to acknowledge is that the current food system and food supply that we’ve got today is a striking achievement.  It is fundamentally sound.  It feeds millions and billions of people every day and it’s a remarkable achievement that we’ve achieved the level of safety that we have today. 

But what we also know is that the food supply is not as safe as it can be.  We know that while many participants in the system have performed very well and very consistently, many don’t.  We know that there are interventions and practices that can make food safer, but we also know they aren’t always adopted or adopted properly.  And we also know that every significant outbreak or contamination incident can be tracked back to some preventable action or event.

So again, food gets safer by systematically building prevention throughout the food system by every participant in the system doing everything they reasonably can to make food safe.  And so we’re not talking about zero risk; we’re talking about everybody doing their best.  Zero risk is not a realistic goal—we’ve got a system that is too complex, too human.  Consumers do not expect a sterile food supply but they do rightly expect that everybody in the system has done their best.

The legislation that’s pending in Congress is going to, in a very important way, equip FDA with the tools – the legal tools– to do its best to implement this science-based prevention paradigm for food safety.  This would become national policy in the United States.  And we welcome the new mandate and the new authority to bring our laws up to date.  The statutes will really empower FDA to play, effectively, what I believe is a central role in food safety.

And I think it’s really important, coming from FDA, to clarify exactly what that role is.  Certainly, FDA has a role in the farm-to-table food safety system.  We don’t make food, and we can’t make it safe.  We contribute by influencing behaviors of others.  We influence food safety indirectly through our core role as a public health regulatory agency.  And that role is to set standards that are prevention-oriented and science-based and to ensure high rates of compliance with these standards.  These standards must provide consumers with the protection they deserve, establish the standard of care that’s appropriate, and provide a level playing field for the food industry.

We do other things as well.  FDA contributes, along with the scientific community, to bring the best science to bear and to share that with the industry.  We provide guidance to industry on interventions and practices that can prevent food safety problems.  Responding to outbreaks is a critical part of what we do.  We think that’s also very much part of prevention because lessons learned from outbreaks can be used to prevent future outbreaks from happening. 

Communicating with consumers in various ways is another FDA role, and we do other things of course.  But for us to be successful, we’ve got to fulfill the central task that society looks to us for, which is setting and implementing a science-based, prevention-oriented regulatory scheme that influences behaviors across the food system, which in turn help to reduce food-borne illness.

In order to play this role, we’re really focusing FDA, today, on three themes that we think are essential for us to do in this new prevention-oriented system.  The first is partnering with parties throughout the system.  The second is the operational integration of FDA’s role with the states, with our partners in state and local government, as well as at the federal level.  And finally, we need to bring about fundamental change within FDA to unify and elevate our program to meet today’s challenges.

And let me just touch briefly on each of these three themes that I think you’re going to see very strongly playing out as we move into the future on food safety.  Partnership throughout the system couldn’t be more fundamentally important.  And it’s both with government partners and the private sector.  I’m going to talk, before I close, specifically about opportunities we see to collaborate with the food industry and with organizations like yours. 

But we can’t do our work in the government without close partnerships with other federal agencies such as the Centers for Disease Control and Prevention, the U.S. Department of Agriculture and the Environmental Protection Agency.  These partnerships have been around for a long time, but we’re building stronger ones, more productive ones.   Obviously, we intersect in numerous ways, such as with overlapping jurisdictions, and we are seeing an incredibly high degree of collaboration and partnership among these agencies in this administration. 

It’s partly a function of the people and the goodwill that exists among these agencies.  It’s also because the President has established a White House-level food safety working group to be sure that we are, in fact, engaged constructively together.

We also have to engage actively with foreign governments to help ensure the safety of imports.  We’ve got to collaborate with the scientific community.  And of course, we have to work with the consumer community – consumers are FDA’s ultimate customer.  We interact with consumers in multiple ways.  Consumers are also actors in the food safety system—what individuals do influences food safety as well, and we have that opportunity for partnership.

The second theme that I want to emphasize is our integration with state and local governments.  And this may not be of core interest in a global perspective, but I assure you that we will not succeed at FDA if we don’t fully leverage the resources, the activities of state and local governments. 

They are closest to where things happen on food safety.  They do most of the inspections, most of the sampling that goes on in this country for food safety.  They have historically, and today, continue to have the lead on retail food safety in terms of actually conducting inspections and adopting standards.  Outbreak response cannot happen without state and local agencies. 

And we’ve got to figure out how to increasingly make progress in being better at investigating and containing outbreaks, as well as learning from outbreaks.  And this is going to be a critical part of how we make progress on food safety.  We have to learn from every outbreak that comes along, and learn for prevention purposes.  And the states will continue to be a key part of that.

So again, we are going to invest resources.  We’re investing effort in really building a truly national, integrated food safety system.  This is the policy of the Obama administration.  We expect to see the legislation contain, for the first time, a real mandate for FDA to look to building state capacity, to look to leveraging state resources.  It’s going to be an important part of the future. 

The third theme, I’ll just touch on very briefly.  It may be true inside baseball, but we can’t do our job in the world unless we have done some work at home within FDA to strengthen the way in which we carry out our responsibilities, and in particular to unify the program. 

We have three organizations within FDA that are very strong, with very long traditions that we’re looking to unify and elevate within FDA to provide a really effective food safety program:  the Center for Food Safety and Applied Nutrition, the Center for Veterinary Medicine, and of course, our Office of Regulatory Affairs, which runs the field function, the inspection program and actually manages the majority of the food safety resources. 

We’re really working to unify them and pursue a one-mission, one-program philosophy within the agency.  And we’ve enlisted more than a hundred experts from all over the agency and aligned them in 10 groups that are addressing these very fundamental, crosscutting issues that will be key to the future of the program, ranging from how we implement preventive controls and oversee imports to how we integrate and build our science capacity. 

Looking fundamentally at how we manage our resources, we’ve got to figure out how to make the best possible use of every dollar that we have to do this public health job.  And I just want to assure people that, as Congress is about to give us legislative tools that will affect the way we affect you, we also know that we have to do work at home to be able to do that job well, in keeping with the science-based and public health-oriented mandate that we’re about to get. 

I want to close by talking about the Global Food Safety Initiative (GFSI)  and what we see as real opportunities – given the challenges that we face—for us to work on this common goal of improving food safety. 

Private certification programs are such a huge part of the landscape already on food safety.  In fact, one of the first things you hear when you travel around and visit companies is how many audit and certification programs there are.  And I think that this is a really positive development in safety.  Done well, these programs really do show the industry doing its part, doing everything it reasonably can, meeting its responsibility for ensuring the safety of food. 

Done well, this really does benefit consumers.  To the extent that we can increase the likelihood that modern preventive controls have been implemented effectively and are targeted at the most significant risks and minimizing those hazards as much as they reasonably can, consumers benefit in a tangible way. 

Now, doing it well is easier said than done.  And again, this is where I see GFSI playing a critical role in helping ensure that it’s done well.  We’ve got to have good standards, and we’ve got to have qualified auditors to conduct good audits against these good food safety standards. 

Again, I think GFSI brings an enormous contribution to this with its role in benchmarking standards.  And from FDA’s vantage point, this is a role that we want to encourage and we want to take advantage of, because it is of value to FDA as well. 

To the extent that we can have confidence in certification systems and we can rely on them in allocating our own resources, it can affect, certainly, the flow of goods in international commerce, and it can affect the way in which we target that oversight. 

For us to do that, though, we’ve got to have transparency.  We’ve got to ensure that the standards are what they ought to be.  We need to embark on a dialogue and partnership with you so that we can complement one another and take advantage of our respective roles in the system.  So we want to work with you on certification. 

But we really see opportunities to work with the industry, including many of the companies that are represented here, on a broader front.  Because we’re going to get a mandate to implement preventive controls comprehensively, across all food facilities in the country, we need to address the issue of standards.  We know how to set standards at a broad level, to implement preventative controls.  We’ve done it for seafood, for juice, and at USDA for meat and poultry. 

It’s one thing to create the broad framework—it’s another fill in the details of what is the actual standard of care that we expect to be met in a preventive control system that’s operated under generally accepted principles.  What’s the standard of care at a level of detail that we can then inspect against to ensure that the standard of care that’s expected is being met?

In filling in those blanks, we need to learn from the leaders in the food industry.  What is the standard of care?  What are the best practices?  How can we make best practices increasingly common practices across the food system?  I see GFSI contributing to that already.  I see FDA needing to engage the industry broadly through whatever channels work and are available to us to really benefit from that industry expertise and experience.  You have primary knowledge about what works to improve food safety and what doesn’t work. 

So we really look forward to working with all of you here at GFSI.  We look forward to working with the food industry more broadly.  I was delighted to accept the invitation to speak here because this really is a great place for me to be, early in my tenure, as I express my desire to open up a dialogue. 

You know, we’re really clear at FDA that there are no silver bullets, there are no magic wands for food safety.  We’re in a long-term, system-building mode at FDA.  And I think it’s the same in the private sector. 

But FDA is certainly in it for the long haul.  We have more than a 100-year history.  We’ll have another 100-year history.  We want to get on with building a program and a food safety system we can all be proud of.  And so we look forward to working with all of you and to future opportunities to get together.