Ensuring The Safety Of Imported Food Ingredients

A flattening world, consumer price resistance and overtaxed regulators require new approaches to ensure the safety of imported food ingredients.

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“If the supplier can prove they operate under the proper guidelines, if they use the [appropriate] processes to insure product and employee safety, including facility security, and if they can prove they will meet the customers’ needs with every shipment, they deserve to be considered a reliable, safe source of supply. But there’s a cost associated with doing that,” he notes.

“When dealing with imported foods or ingredients you must think outside of the traditional quality control box and include in your considerations the production practices, ecological and social conditions in the exporting country,” says Prince. “History has shown the need to give additional attention to chemical contaminants, but attention must also be given to authenticity testing of imported products and certificates of analyses.

“You must constantly review international food safety intelligence and apply the elements learned in the design of your food safety program to make sure your products meet consumer expectations.”

Because the cost of product recalls in the past year has affected corporate earnings, “Food safety not only should be on the agenda of the food firm’s top executives but also on the oversight agenda of their board of directors,” adds Prince. “Unfortunately, most corporate food company board membership is made up of expertise in financial and legal [segments] and has not included representation with expertise in food safety. But food safety is a key component to a food firm’s core business.”

Our Achilles’ heel

“Imports are our Achilles’ heel,” says Ken Lee, professor and director of Ohio State Food Safety Center, Ohio State University. “There is no global food regulator. If the Chinese want to put an adulterant into food, they can do it until they get caught. I’ll wager it will happen again, because it’s driven by the profit motive.”

The real dilemma is no technology can totally ensure safe imports. Irradiating every container entering the U.S. has been suggested, but the cost is prohibitive, would delay delivery and consumers are still wary about the technology. And while irradiation kills pathogens, it won’t solve the problem of adulterated ingredients or poisons.

Inspections of all containers would require vast increases in the FDA and USDA budgets. Meanwhile, FDA is inspecting products from China and other countries with less stringent internal food safety controls than ours, and relaxing inspections from countries such as Britain and Canada, which have stronger standards. And, FDA might require importers and U.S. processors using imported ingredients to provide far more detailed information about the production processes in place at foreign suppliers.

For years, some members of Congress have called for a streamlining of the system. The large number of recalls last year (or better reporting methods) and melamine contamination has spurred delegates to action.

Pressure is on from both industry and consumers. According to a recent Consumer Reports study, 92 percent of Americans want to know which country produced the food they buy. And a 2007 survey by The Food Marketing Institute found consumer confidence in food safety has plummeted to 66 percent, down from 82 percent the year before.

In July 2007, President Bush issued an executive order creating a cabinet-level Interagency Working Group on Import Safety to conduct a review of the U.S. import system, regulations, procedures and practices and identify ways to increase the safety of imports. Chaired by HHS Sec. Mike Leavitt and comprised of 12 federal departments and agencies, working group members visited more than two dozen cities across the country, covering ports, railroads, airports, freight hubs, border crossings, wholesalers, retailers, fruit stands and meat and seafood processing facilities. Its initial findings contained 14 broad recommendations and 50 action steps -- a road map for enhancing the safety of the increasing volume of imports entering the U.S.

Last Nov. 6, Secretary Leavitt presented the Import Safety Action Plan with recommendations and specific short- and long-term steps, categorized under the principles of prevention, intervention and response. The report concluded the U.S. must transition from an outdated “snapshot” approach to import safety, in which decisions are made at the border, to a prevention-focused model that targets critical points in the import life cycle where the risk of the product is greatest, and then verifies the safety of products at those important phases.

Simultaneously, FDA developed a comprehensive Food Protection Plan, unveiled in November 2007, to address the changes in food sources, production and consumption. The new plan presents a strategy to protect the food supply from both unintentional contamination and deliberate attack. It builds in prevention first, then intervention, and finally response.

But is there money to do all this?

A subcommittee of the FDA’s Science Board released a report detailing how underfunding of the agency is jeopardizing FDA’s ability to protect the food supply (see www.fda.gov/ohrms/dockets/ac/oc07.htm).

Funding for the FDA should be doubled over the next two years and manpower increased by 50 percent, says Peter Barton Hutt, former chief counsel of the FDA, internationally recognized partner in Washington law firm Covington & Burling and adjunct food and drug law professor at Harvard Law School. Hutt also implores the food industry to lobby Congress to increase funding.

The FDA’s FY 2007 budget was $453 million for food alone (for the Center for Food Safety and Applied Nutrition and for related field activities in the Office of Regulatory Affairs), according to the Appropriations Bill. FDA food programs cover food safety, food defense, dietary supplements, nutrition and cosmetics. In the current fiscal year, ending Sept. 30, appropriations were increased to $513.5 million.

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