— opinion —
by Frank Iannas and Mindy Brashears
We have both dedicated our careers to improving food safety and protecting the public. We have both done so at the height of our federal service, in academia, and even in the private sector. That’s why we believe we are qualified to offer our perspective on this issue.
Few topics are more important to a nation than its ability to provide its citizens with access to safe, nutritious, and accessible food. And in order to do that efficiently and effectively while properly managing taxpayers’ taxes, things need to change. The time has come for our country to unify on a single, forward-looking food safety strategy.
Having both led teams and worked in large organizations with thousands or even millions of employees, we understand that strategy should take precedence over organizational structure. I am. Therefore, if we agree that a single, unified food safety strategy is in the best interest of all of our citizens, we must by default support the idea of a single, unified food safety authority. In other words, you need the right structure to achieve a unified strategy and vision.
Sadly, this is not a new or unique idea. And just to be clear, this is not a political or partisan issue either.
In 2017, the Trump administration proposed reorganizing oversight of food safety regulatory activities into a single agency, the Federal Food Safety Administration, to be housed within USDA. Similarly, the Obama administration proposed a single food safety agency, but suggested it be located within the FDA. In fact, since 1949, efforts have been made to consolidate food safety activities into one agency. Over the past decade, Rep. Rosa DeLauro and Sen. Richard Durbin have repeatedly introduced similar bills calling for a single food safety agency, without success. The U.S. Government Accountability Organization has made similar recommendations. GAO states that “creating a single food safety agency to administer a unified, risk-based inspection system would help the federal government solve long-standing problems, address new food safety issues, and improve food safety.” This is the most effective way to ensure that National food supply. ”
Recently, we (Mindy Brashears and Frank Yiannas) joined former Acting FDA Commissioner Stephen Ostroff on a podcast hosted by the Federalist Society.
The purpose of the podcast was to discuss reorganization within the FDA following the results of a report conducted by the Reagan Udall Foundation titled “Operational Evaluation of the FDA Human Food Program.” This report was written at the direction of current FDA Commissioner Dr. Robert Califf. Following a barrage of complaints from stakeholders leading up to the infant formula crisis, Khalifa called for an independent review. The agency was hit with three separate lawsuits alleging it failed to issue food safety regulations within the required deadlines set by Congress when it passed the Food Safety Modernization Act in 2011. (10 years ago), government agencies also failed to address toxic heavy metals in baby food, among other issues.
The Regan-Udall report discusses several problems with the current FDA human food program. First and foremost, we were concerned that the program lacked a clear leader within its organizational structure. There was no appointed leader responsible for overseeing the food program, and each office leader reported individually to the FDA Commissioner. The result was a lack of a clear vision or mission for the human food program apart from the FDA as a whole. The report also points out that the FDA focuses on “consensus building” rather than decision-making, reducing the organization to the “lowest common denominator” in order to get everyone’s buy-in. Consensus models are necessary in some situations, but this process slows down decision-making and leads to a lack of ability to implement the latest scientific advances. There were also concerns about a lack of funding from Congress and low salaries that limited the ability to compete with industry for employees.
In summary, while there was agreement in the podcast that changes need to be made at the FDA, further strengthening food safety requires a single food safety agency with a broader perspective beyond just the FDA. There was also agreement that this was necessary. This could have a major impact on food supplies and public health.
There hasn’t been enough time to discuss where a new single food safety agency (USDA, FDA, or HHS as a new independent agency) would be located, but based on experience, we all believe that It was clear that the current system was fragmented, in some cases redundant, and inefficient.
To illustrate this point, think of it this way. Frozen pizzas containing cheese and pepperoni are subject to ongoing inspection by the USDA, while frozen pizzas with only cheese (no meat) are inspected by the FDA once every five years as not high risk. . These differences are not based on science or risk.
But it’s not just about who inspects which foods. More importantly, how do we adopt a more modern, risk-based, data-driven approach to how we regulate the safety of our food supply? Why is pepperoni pizza continually tested, but something as important as baby formula is tested at most once a year?
For those who don’t know, the FDA operates a different inspection system than the USDA. USDA operates on a continuous system where each animal is inspected before and after harvest under the supervision of the DVM. At the processing facility, an inspector will be present at least once a day. FDA’s food inspection oversight model requires that high-risk food facilities be inspected once every three years and non-high-risk facilities once every five years. Additionally, most of FDA’s food inspections are performed by state officials on behalf of FDA under contract with FDA.
Modern times require a more modern approach. Now is the time to move to a more risk-based, data-driven compliance approach and further monitor products that pose the greatest risk to consumers.
We have been leaders at FSIS and FDA, which oversee food safety during a very difficult time for this nation, and our long-standing professional relationship has led us to make high-level, impactful decisions on a typically weekly basis. , we worked very closely together, sometimes on a daily basis. Because we needed to work together to make decisions, and because we knew that was what the American people expected of us. However, there were no standards or defined “requirements” for these interactions. In many cases, we have moved forward to break them down, only to find ourselves experiencing biases, turf wars, and silos that exist between the two organizations. In our hearts, it is important that the country is better served if we work together, whether it is addressing the impact of the pandemic on food supply chains or investigating foodborne illness outbreaks. That’s what I was thinking. This often includes collaboration with another important partner, the CDC. In fact, a joint committee was set up between the three agencies to review the outbreak investigation. However, in certain cases and during specific periods of crisis, distance, structure, and unclear roles and responsibilities made coordination of activities and communication difficult.
As we all know, change within government takes time, and moving to a single food safety authority is difficult and requires a “decision of parliament,” but it is not impossible. Sometimes political leaders need the strength and courage to do difficult things.
We are in no way saying that FDA and USDA staff are not doing a good job. Indeed, we commend the staff of both institutions for their service to the nation. But we both believe that we can strengthen the system to help them do their jobs more efficiently.
Finally, for those who think this will lead to bigger government, we don’t support that at all. We believe that if properly executed and implemented, it will lead to more effective government by establishing clear roles, responsibilities, and lines of authority. Eliminate inefficiencies by enabling a more data-driven, risk-based approach to inspection oversight that will enable a more integrated approach to national food safety efforts and benefit consumers and food producers. Reduce duplication of effort. No other developed country operates with such a fragmented system. It is time for the United States to make difficult decisions, put aside turf and political differences, and prioritize public health by beginning a plan to transition to a single food safety agency. Consumers, taxpayers, and regulated industries across the country deserve this.
About the Author: Mindy Brashears served as USDA’s Under Secretary for Food Safety from 2019 to 2020, and Frank Yiannas served as FDA’s Deputy Commissioner for Food Policy and Response from 2018 to 2022.