Risk gains momentum over reaction in worldwide food-safety efforts
By George Miller
To some consumers, it’s becoming a rock-vs.-hard-place choice in food safety: Risk Salmonella and other types of microorganism contamination or choose irradiation as a means to protect against it.
But for food producers, importers, shippers, and regulators, another option involves the use of more sophisticated risk-based techniques to identify problem areas in the food supply chain, monitor them closely, and eliminate the problems at their source. Successful risk-based systems should eliminate the need for lengthy, complicated, and expensive trace-back efforts when contaminated food begins making people sick.
“At the food processor level, we believe in risk-based programs,” says Tom Chestnut, vice president for supply chain, food safety, and quality programs at NSF International (Ann Arbor, MI). NSF is a not-for-profit organization that writes standards for food, water, and consumer goods protection.
“For example, the import system for seafood safety inspections in the U.S. looks at about 2 percent of imports,” he says. “But they use risk-based systems to determine where to look.”
Reactive efforts involve testing at the port of entry or further down the chain, according to Chestnut. However, in the approach developed by NSF and the Global Food Safety Initiative (GFSI), “We’re trying to be proactive, to work with suppliers to ensure safety before the product is shipped.”
GFSI is a retail-led network coordinated by CIES???The Food Business Forum, comprising international food-safety experts and trade associations.
Chestnut says that infrastructure is an issue in some countries???sometimes even at the level of getting the product from its source to where it is shipped. Nonetheless, he counters, “the countries that want to sell to the U.S. are very responsive when we visit, and they want to do better.”
Now is a good time to take advantage of their willingness: Chestnut says that via audit tracking, he sees a tripling of food suppliers in Southeast Asia who want to sell to the United States, as well as increases in other parts of the world.
Food production systems in developing countries are facing some challenges, according to the Food and Agriculture Organization (FAO) of the United Nations (New York, NY) and the World Health Organization (WHO; Geneva, Switzerland): Among these are population growth and urbanization, changing dietary patterns, and industrialization of food and agricultural production.
In addition, food safety legislation in many developed and developing countries is often incomplete or obsolete or not in line with international requirements, according to the organizations. Laboratories lack essential equipment and supplies.
FAO and WHO currently support national governments in improving food monitoring, disease surveillance, and emergency preparedness. They also provide scientific advice on issues such as food additives, chemical and microbiological contaminants, and agro-chemical residues.
A policy issue
Many national governments are addressing the issue of food safety in high-level policy. At an international forum held late last year in Beijing???just months after contaminated Chinese food exports forced the Chinese government to make public commitments to reform???officials from more than 50 countries adopted the Beijing Declaration on Food Safety. The declaration is a commitment to resolve food safety problems through positive collaboration rather than trade barriers.
Such policy-level support is necessary because food safety is no easy task, regardless of how well a country’s risk-based and trace-back systems are developed. The United States Salmonella Saintpaul outbreak that began last April, stemming from contaminated peppers grown in Mexico (see “Contaminated Pepper Trail Reveals Complexity of Trace-back Effort,” CleanRooms, September 2008, p. 8), culminated in sickness for more than 1,400 people and was linked to the deaths of two. But these numbers are dwarfed by the worldwide figures for children alone???1.8 million???who die of diarrheal disease related to contaminated food and water, according to FAO.
The beleaguered FDA???criticized through much of the Salmonella Saintpaul investigation for its handling of the difficult international tracing of single-item produce products???announced separately and coincidentally as the outbreak was winding down in late August that it had approved the use of irradiation on lettuce and spinach as a means of preventing such outbreaks.
That announcement garnered far greater general press coverage than the policy- and industry-level efforts underway to protect the food supply via risk-based methods.
For example, FAO, in conjunction with WHO, began urging all countries to be “far more vigilant” about food safety following scares in 2007. Perhaps more importantly, the joint efforts of the two organizations have also established the Codex Alimentarius Commission, which develops science- and risk-based food safety standards as a reference for international trade and for use by countries developing their own food safety legislation.
The commission in July 2007 adopted 44 new and amended food standards and organized a set of risk analysis principles to help governments establish their own standards. Additional efforts are ongoing.
More recently, in testimony before the U.S. Congress in late July, the Grocery Manufacturers Association (Washington, DC) advocated prevention (risk-based measures) over reactive trace-back measures.
GMA’s chief science officer Robert Brackett outlined reforms, some already included in the proposed FDA food-safety modernization legislation, to address current safety gaps from risk evaluation to identification of contamination sources.
The proposed risk analysis framework combines science (risk assessment) and policy (risk management) to provide improved exchange of information and opinions regarding potential food safety threats (risk communication).
For the food industry and consumers alike, these proactive risk-based initiatives are a step forward in ensuring food safety for the future. But longstanding risk initiatives still prove effective today and will likely have a role in the future, like a wise friend or mentor. The FDA’s Hazard Analysis and Critical Control Point (HACCP) system is just such a tool.
“When you use HACCP, your testing becomes validation,” says Chestnut of NSF.
HACCP is built on seven proactive principles, including some that resemble elements in the newer risk-based proposals being considered today. HACCP has been an FDA workhorse for a decade, covering each food-safety aspect for any member of the supply chain. Principles of HACCP include:
- Analysis of hazards.
- Identification of critical control points.
- Establishment of preventive measures with critical limits for each control point.
- Establishment of procedures to monitor critical control points.
- Establishment of corrective actions to be taken when monitoring shows that a critical limit has not been met.
- Establishment of procedures to verify that the system is working properly.
- Establishment of effective recordkeeping to document the HACCP system.
Before Congress GMA’s Brackett emphasized that “it is critically important that Congress modernize our food-safety system by making risk and the prevention of contamination the focus of our food-safety strategies.”