Food Safety: Continued Vigilance Needed to Ensure Safety of	 
School Meals (30-APR-02, GAO-02-669T).				 
                                                                 
The national school lunch and breakfast programs provide	 
inexpensive or free meals to more than 27 million children each  
day. During the 1990s, nearly 300 outbreaks of foodborne illness 
at the nation's schools sickened 16,000 students. The rise in the
number of school outbreaks mirrors a rise in the number of	 
outbreaks in the overall population, according to the Centers for
Disease Control and Prevention (CDC). Because the CDC data	 
include outbreaks attributable to food brought from home or other
sources, GAO could not determine the extent to which food served 
in the school meal programs caused reported outbreaks. Data from 
1998 and 1999 do show, however, that most of the outbreaks during
those years were caused by foods served through the school meal  
program. Foods contaminated with salmonella and Norwalk-like	 
viruses were the most common causes of outbreaks. GAO found that 
the Department of Agriculture has not developed security measures
to protect foods served at schools from deliberate contamination.
The existing food safety system is a patchwork of protections	 
that fall short in addressing existing and emerging food safety  
threats.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-669T					        
    ACCNO:   A03206						        
  TITLE:     Food Safety: Continued Vigilance Needed to Ensure Safety 
of School Meals 						 
     DATE:   04/30/2002 
  SUBJECT:   Children						 
	     Contaminated foods 				 
	     Food inspection					 
	     Food programs for children 			 
	     Food services					 
	     Health hazards					 
	     Public schools					 
	     Safety regulation					 
	     National School Breakfast Program			 
	     National School Lunch Program			 
	     USDA Food Distribution Program			 

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GAO-02-669T
     
Testimony Before the Subcommittee on Oversight of Government Management,
Restructuring and the District of Columbia, Committee on Governmental
Affairs, U. S. Senate, and the Subcommittee on Government Efficiency,
Financial Management, and Intergovernmental Relations, Committee on
Government Reform, U. S. House of Representatives

United States General Accounting Office

GAO For Release on Delivery Expected at 2: 30 p. m. EDT Tuesday, April 30,
2002 FOOD SAFETY

Continued Vigilance Needed to Ensure Safety of School Meals

Statement of Lawrence J. Dyckman, Director, Natural Resources and
Environment

GAO- 02- 669T

Page 1 GAO- 02- 669T School Meals Safety

Mr. Chairmen and Members of the Subcommittees: I appreciate this opportunity
to come before you today to discuss the safety of the foods served in our
schools. As you know, more than 27 million children are provided low- cost
or free meals daily through two federally assisted programs administered by
the U. S. Department of Agriculture?s (USDA) Food and Nutrition Service
(FNS)- the National School Lunch and School Breakfast programs. In fiscal
year 2001, these programs were funded at about $8 billion dollars. According
to the Centers for Disease Control and Prevention (CDC), between 1990 and
1999, nearly 300 outbreaks of foodborne illness occurred in schools
affecting approximately 16,000 children. Outbreaks of foodborne illness in
our schools are of particular concern because of children?s vulnerability to
harmful pathogens. According to CDC, only a fraction of foodborne illnesses
are routinely reported, and since most foodborne illnesses are sporadic,
only a small number are identified as being part of an outbreak. 1

In February 2000, we reported that USDA should take actions to better ensure
the safety of foods served in federal school meal programs. 2 In response to
your request, Mr. Chairmen, our testimony today (1) provides information on
the frequency of outbreaks of foodborne illness in schools between 1990 and
1999, (2) discusses the status of our February 2000 recommendations to
better safeguard the food served in our schools, (3) offers additional
observations on how the safety of the school meal programs could be further
enhanced, (4) discusses the status of efforts to minimize the risk of
deliberate contamination of school meals, an issue of heightened importance
in the wake of recent events, and (5) because the safety of the school meals
hinges on the effectiveness of the nation?s overall food safety system, our
testimony summarizes several endemic problems that we have found in the
federal food safety system as a whole.

Our current analysis of CDC?s outbreak data shows an increase in the number
of school- related outbreaks reported to CDC between 1990 and 1999 (the last
year for which complete outbreak data is available). Overall, our analysis
of these data indicates that the rise in the number of

1 CDC defines an outbreak as an incident in which two or more persons
experience a similar illness after ingestion of a common food. 2 U. S.
General Accounting Office, School Meal Programs: Few Outbreaks of Foodborne
Illness Reported, GAO/ RCED- 00- 53 (Washington, D. C.: Feb. 22, 2000).
Results in Brief

Page 2 GAO- 02- 669T School Meals Safety

outbreaks reported in schools since 1990 mirrors the rise in the number of
outbreaks reported in the general population. We cannot determine the extent
to which foods served in the school meal programs are the cause of reported
outbreaks because CDC?s data also includes outbreaks that are attributable
to foods brought from home or other sources. Our examination of 20 large
school outbreaks in 1998 and 1999 does show, however, that the majority of
the outbreaks in those years were caused by foods served through the school
meal programs. CDC attributes much of the increases in reported outbreaks to
the improved data collection procedures initiated in 1998, when it began
encouraging states to report foodborne outbreaks and to verify the data they
submitted. CDC also suggests that increased resources for outbreak
investigations and greater pubic awareness regarding foodborne disease might
also account for the increased number of reported outbreaks. However, after
accounting for CDC?s more active surveillance approach, our analysis
revealed an increase in reported outbreaks in schools, generally averaging
10 percent per year. Our analysis also shows that, of those outbreaks with a
known cause, the most commonly identified cause of the illnesses were foods
contaminated with salmonella and Norwalk- like viruses. 3

USDA has been, for the most part, responsive to the two recommendations we
made in our February 2000 report. Our first recommendation entailed USDA
establishing a database to track all of the actions it takes to hold or
recall USDA- donated foods that could potentially cause foodborne illness in
schools. We made this recommendation so that USDA could document its
responsiveness to food safety concerns and potentially identify problematic
vendors or foods. USDA agreed with our recommendation and established a
database that currently contains records of 11 food safety actions. We also
recommended that USDA revise its school food service manual to include
guidance for state and local school authorities on enhanced safety
provisions that are normally included in USDA?s procurement contracts for
donated foods. USDA plans to address our recommendation by revising its
school procurement guidance to include an example that addresses safety
concerns. However, we believe USDA should include more information that
would be useful to schools. We made this recommendation because state and
local school food authorities

3 Food contaminated with salmonella may cause nausea, vomiting, diarrhea,
and headaches. Nausea, vomiting, diarrhea, and abdominal pain also
characterize Norwalk- like viral infections. Headache and low- grade fever
may also occur.

Page 3 GAO- 02- 669T School Meals Safety

purchase 83 percent of the dollar value of foods for the school lunch
program.

Based on the limited work we conducted in preparing for this testimony, we
have identified two other issues that may warrant additional study and could
contribute to improving the safety of school meals. First, as we reported in
February 2000, USDA?s procurement officials have routine access to the
federal inspection and compliance records of potential suppliers, and they
take these records into account when considering bids before contracting for
donated foods. However, our recent interviews with USDA officials suggest
that there is currently no mechanism for state and local authorities to
easily and routinely access such information. Because state and local school
authorities purchase the majority of foods for school meals, they may
benefit from having ready access to the inspection and compliance
information that the U. S. Department of Health and Human Services? Food and
Drug Administration (FDA) and USDA collect. Such data sharing could enable
them to make more informed purchasing decisions. USDA officials stated that
this idea would have to be explored further to address potential legal
impediments to such information sharing. FDA officials said that the idea
might have merit. Second, in the course of preparing for this testimony, we
observed that FNS has an established process for holding and recalling USDA-
donated foods when safety concerns arise. As the single common point of
contact for all schools participating in the school meal programs, FNS may
want to study the possibility of extending its hold and recall procedures to
include school- purchased foods. In this manner, FNS would coordinate and
track safety actions pertaining to all foods served in the school meal
programs rather than just those pertaining to USDA- donated foods. USDA
officials agreed with this concept and indicated that they intend to share
the hold and recall procedures with schools in fiscal year 2003.

USDA and FDA have not developed specific security provisions to protect food
served in the school meal programs from potential deliberate contamination.
But, according to USDA and FDA officials, actions designed to enhance the
security of the federal food safety system as a whole would also enhance the
security of school meals. As we testified in October 2001, recent events
have raised the specter of bioterrorism as an emerging risk factor for our
food supply. Moreover, under the current structure, there are questions
about the food safety system?s ability to detect and quickly respond to any
such event. Since our October 2001 testimony, FDA and USDA officials stated
that they are better prepared to detect and respond to such an event. The
agencies are in the process of conducting risk assessments to determine
where in the farm- to- table food

Page 4 GAO- 02- 669T School Meals Safety

continuum the food supply may be most vulnerable. In addition, FDA has
issued voluntary guidelines to the sectors of the food industry that it
regulates to enhance, among other things, the physical security of
processing and storage facilities. USDA is also working on a similar set of
guidelines. Finally, agency officials told us that they have asked their
field personnel to be on heightened alert for potential security concerns.

Finally, Mr. Chairmen, as we have frequently reported in the past, a series
of structural weaknesses in our federal food safety system can affect all
consumers, including children who eat school meals. As we reported in
February 2000, while no federal agency specifically monitors the safety of
school meals, USDA and FDA are responsible for enforcing regulations that
ensure the safety of the nation?s food supply. As we testified in October
2001 the existing food safety system is a patchwork structure that hampers
efforts to adequately address existing and emerging food safety risks
whether those risks involve inadvertent or deliberate contamination. 4 The
food safety system is affected by a series of overarching problems that
impede efforts to address public health concerns associated with existing
and emerging safety risks. For example, when unsafe foods are detected,
neither USDA nor FDA has the authority to recall them from distributors,
although the appropriate agency can request manufacturers to do so
voluntarily. Therefore, today we re- emphasize the need for the creation of
a single food safety agency with new legislative authority. Such an action
would go a long way toward improving overall food safety.

The extent of foodborne illness in the United States and its associated
costs are significant. CDC estimates that unsafe foods cause as many as 76
million illnesses, 325,000 hospitalizations, and 5,000 deaths annually. 5 In
terms of medical costs and productivity losses, foodborne illnesses
associated with seven major pathogens cost the nation between $7 billion and
$37 billion annually, according to USDA?s estimates.

4 U. S. General Accounting Office, Food Safety and Security: Fundamental
Changes Needed to Ensure Safe Food, GAO- 02- 47T (Washington, D. C.: Oct.
10, 2001). 5 On Apr. 19, 2002, CDC reported that there has been a decrease
in several major bacterial foodborne illnesses, including infections due to
salmonella, campylobacter, and listeria. However, CDC has not revised its
estimates of the overall incidence of foodborne illness in the United
States. Background

Page 5 GAO- 02- 669T School Meals Safety

The National School Lunch Program and the School Breakfast Program share the
goals of improving children?s nutrition, increasing lower- income children?s
access to nutritious meals, and supporting the agricultural economy. The
school lunch program is available in almost all public schools and in many
private schools. About 70 percent of those schools also participate in the
breakfast program. Schools participating in the school lunch or breakfast
programs receive a per- meal federal cash reimbursement for all meals they
serve to children, as long as the meals meet federal nutrition standards. In
fiscal year 2001, school meal programs provided lunch, breakfast, and snacks
to over 27 million school children daily.

At the federal level, FNS administers the school meal programs. At the state
level, the program is usually administered by state education agencies,
which operate them through agreements with local school food authorities.
Overall, USDA donates about 17 percent of the dollar value of food that goes
on the table in school lunch programs through its Food Distribution Program.
USDA purchases and distributes commodities to remove surpluses from the
marketplace and to provide nutritious foods to the nation?s children.
Schools purchase the remaining 83 percent of the dollar value of food served
using USDA?s cash reimbursement and their own funds. In fiscal year 2001,
the total cost of the school meal programs- including cash reimbursements to
schools, USDA purchases of donated foods, and program administration- was
nearly $8 billion. By far the largest component of the school meal programs
is the school lunch program. In fiscal year 2001, the school lunch program
cost about $5.7 billion.

The procurement process for foods served in school lunch program differs
depending on whether federal or state/ local food authorities procure the
foods (see figure 1).

Page 6 GAO- 02- 669T School Meals Safety

Figure 1: School Lunch Program Procurement Process

USDA?s Agricultural Marketing Service (AMS) and Farm Service Agency (FSA)
are responsible for procuring USDA- donated foods. The Agricultural
Marketing Service purchases meat, poultry, fish, and fruits and vegetables
for donation; the Farm Service Agency purchases grains, oils, peanut
products, dairy products, and other foods. USDA contracts for the purchase
of these products with manufacturers that are selected through a formally
advertised competitive bidding process. FNS, through its Food Distribution
Division, provides the donated foods to state agencies for

Page 7 GAO- 02- 669T School Meals Safety

distribution to schools. Schools then purchase the remainder of food for
school meals independently using their own procurement practices, either
purchasing foods directly from manufacturers or distributors, or contracting
with food service management companies that procure the foods for them.

USDA provides little guidance to promote safety in school food procurements.
FNS? guidance to schools emphasizes safe food handling because, according to
USDA officials, most cases of foodborne illness at schools are due to poor
food storage, handling, and serving practices. Therefore, the priority is on
guidance to ensure food safety through proper handling and preparation of
foods at schools. For example, manuals are provided that address appropriate
temperatures for reheating ready- to- eat foods and for hot- holding
potentially hazardous foods. Similarly, FNS provides information on employee
personal hygiene and how it relates to cross- contamination of foods.

CDC?s outbreak data shows an increase in the number of school- related
outbreaks since 1990. Between 1990 and 1999 (the most recent year for which
complete outbreak data is available from CDC), 292 school- related outbreaks
were reported to CDC, averaging 17 outbreaks in the first 4 years of the
decade, 28 in the next 4 years, and 57 in the final 2 years (see table 1).
In total, approximately 16,000 individuals, mostly children, were affected.
6 For those outbreaks with a known cause, the most commonly identified cause
of the illnesses were foods contaminated with salmonella or Norwalk- like
viruses.

6 According to CDC, foodborne illnesses are underreported because (1) milder
cases are often undetected; (2) pathogens that are transmitted through food
may also be spread through water or from person to person, obscuring the
role of foodborne transmission; and (3) some proportion of foodborne illness
is caused by pathogens or agents that have not yet been identified and thus
cannot be diagnosed. Furthermore, CDC relies on states to voluntarily report
outbreak information. Data Show an

Increase in School Outbreaks

Page 8 GAO- 02- 669T School Meals Safety

Table 1: Outbreaks and Illnesses in Schools and Non- School Settings, 1990-
1999 Year School

Outbreaks Other Outbreaks School

Illnesses Other Illnesses

1990 25 508 1212 18,019 1991 14 517 486 14,566 1992 14 397 991 10,092 1993
15 499 676 13,404 1994 31 659 1,807 15,188 1995 9 636 436 13,061 1996 32 570
1,772 13,649 1997 39 767 2,026 16,776 1998 63 1,251 3,944 22,775 1999 50
1,294 2,882 22,404

Total 292 7,098 16,232 159,934

Note: As explained later, this outbreak data includes outbreaks caused by
foods in the school meal programs as well as foods brought from home.

Source: Centers for Disease Control and Prevention data.

According to CDC officials, some unknown portion of the increase in reported
outbreaks extends from CDC?s transition from a completely passive
surveillance data collection method to a more active surveillance
methodology in early 1998. In effect, CDC went from accepting data from the
states to actively soliciting states for more comprehensive information and
having the states verify the information that they submit. As a result,
states began to report more of all types of foodborne outbreaks, including
school outbreaks, to CDC beginning in 1998. Moreover, CDC suggests that
increased resources for outbreak investigations and greater awareness among
the general public about foodborne disease might also account for the
increased number of reported outbreaks.

To evaluate the trend in the number of school outbreaks, and in their number
relative to non- school outbreaks, we compared the observed numbers to the
estimated numbers of school and non- school outbreaks. 7 This analysis shows
that there is an upward trend in foodborne illness outbreaks reported in
schools between 1990 and 1999 and that not all of this increasing trend is
attributable to changes that took place when CDC began a more active data
collection effort. Outbreaks in the general

7 We used traditional statistical tests to determine how well the different
models fit the observed data and which models were preferable to distinguish
the pattern in the observed data from random fluctuations.

Page 9 GAO- 02- 669T School Meals Safety

population have increased by a comparable amount over the same period;
therefore, there is no statistically significant difference between
increased outbreaks in schools and increased outbreaks in general. As figure
2 shows, our analysis of CDC?s data indicates that, even after adjusting for
CDC?s improved data collection, the number of school- related foodborne
outbreaks increased, on average, about 10 percent per year between 1990 and
1999.

Figure 2: Trends in School- Related Foodborne Outbreaks (1990- 1999)

Source: GAO?s analysis of CDC data.

We also analyzed trends in participation in the school meal programs over
this same time period and found that the changes in school outbreaks
reported did not simply mirror changes in the number of students
participating in the school meal programs. While the number of reported
school outbreaks doubled over the decade, and generally increased by an
average of about 10 percent from one year to the next, the number of school
lunch participants increased by only 12 percent over the entire decade, or
by just over 1 percent per year. Thus, the increase in school outbreaks
reported is not explained by the increase in children?s participation in the
school meal programs.

Page 10 GAO- 02- 669T School Meals Safety

One should exercise caution, however, when analyzing school outbreak data.
CDC?s data must be supplemented with more detailed state or local
information to determine the extent of foodborne illness outbreaks actually
associated with the school meal programs in any given year. We gathered
additional state and local health department information for the 20 largest
school outbreaks in CDC?s database for 1998 and 1999, each of which resulted
in 100 or more illnesses. We determined that 13 of the 20 outbreaks (65
percent) were associated with foods served in the school meal programs.
Three of the 13 outbreaks were linked to tainted burritos that were
distributed to schools nationwide and are thought to have caused
approximately 1, 700 illnesses. The other 7 outbreaks were not linked to
foods served in the school meal programs, but with foods brought to schools
from home or other sources. Therefore, data limitations make it difficult to
assert with complete certainty to what extent the foods served in the school
meal programs are the cause of the reported outbreaks from 1990 to 1999.

USDA has, for the most part, been responsive to the two recommendations we
made in our February 2000 report. First, we recommended that USDA develop a
database to track the actions it takes to hold or recall donated foods when
safety concerns arise regarding foods donated to the school meal programs.
Second, we recommended that the agency revise its school food service manual
to include guidance regarding food safety procurement contract provisions,
which could be used by state and local school authorities.

We made our first recommendation because, without comprehensive records of
such safety actions, USDA had no reliable basis for identifying problematic
foods or suppliers, or for documenting the agency?s responsiveness to
concerns over the safety of USDA- donated foods. In response to our February
2000 recommendation, USDA implemented its food safety action database in
April 2000. The database identifies and tracks key hold and recall
information starting in October 1998. As of April 2002, the database lists
11 food safety actions, including, for example, the recall of 114,000 pounds
of chicken that was contaminated with listeria in February 2000. 8 Because
of the limited number of actions recorded thus

8 Listeria is a foodborne contaminant that can cause meningitis, septicemia,
and perinatal disease. USDA Has Been

Largely Responsive to Our February 2000 Recommendations

Page 11 GAO- 02- 669T School Meals Safety

far, USDA has not conducted any analysis of the information contained in the
database, but plans to continue maintaining it for future use.

We made our second recommendation because, although USDA has established
procurement policies and procedures to ensure the safety of foods donated to
schools, these policies and procedures do not apply to foods purchased
independently by schools. For example, contracts for donated foods may
specify pathogen testing for every lot of certain products that are highly
susceptible to contamination, or may contain contract provisions that
establish specific temperature requirements for chilled and frozen products
during processing and storage at the plant, transportation between
processing plants, upon shipment from the plant, and upon arrival at final
destination. However, there is no requirement that state and local
authorities include similar food safety provisions in their procurement
contracts. According to USDA?s regulations for schools participating in the
school meal programs, the responsible school food authority may use its own
procurement procedures, which reflect applicable state and local laws and
regulations. Therefore, the extent to which schools address safety in their
food procurement contracts may vary depending on state and local laws and
procurement guidance that is available to them. To assist state and local
authorities, we recommended that USDA provide them guidance on food safety
provisions that could be included in their procurement contracts.

USDA officials told us that they plan to address our recommendation by
revising the school procurement guidance to include an example that
addresses safety concerns. We believe, however, that USDA should include
more information that would be useful to schools. Specifically, providing a
list of the specific food safety provisions found in USDAdonated food
contracts would help schools in preparing their own food procurement
contracts. While USDA officials contend that local school districts have
little negotiating power to require safety provisions because their
purchases are mainly low- volume from commercial sources, USDA?s own data
indicates that in the 1996- 1997 school year, the latest year for which this
data was available, 37 percent of school food authorities participated in
cooperative arrangements that purchase in larger volume. Therefore, we
believe that more detailed information on contract safety provisions could
enhance the safety of foods purchased directly by schools. In particular,
since local school authorities purchase 83 percent of the dollar value of
school meals, it is important that they receive guidance from FNS on how
best to achieve a comparable level of safety precautions through their
procurement process.

Page 12 GAO- 02- 669T School Meals Safety

Based on limited work conducted in preparation for this testimony, we offer
two additional observations that, if validated by further study, may
contribute to greater safety for school children at minimal cost. First,
USDA?s procurement officials told us that they have routine access to
federal inspection and compliance records of potential suppliers and that
they consider this information when they review bids before contracting.
However, there is currently no established mechanism for state and local
authorities in charge of purchasing food for schools to easily and routinely
access such information. It may be desirable for USDA to consider whether it
should provide state and local school officials with access to information
collected through FDA?s and USDA?s inspections of school lunch food
suppliers, potentially enabling them to make more informed purchasing
decisions. USDA officials stated that this idea would have to be explored
further to address potential legal impediments to such information sharing.
FDA officials commented that this idea is worth considering.

Second, FNS has developed a process for holding foods suspected of
contamination that applies exclusively to food commodities that USDA
purchases for donation to schools. The hold allows time for additional
testing and inspection prior to asking for a recall of donated foods when
safety concerns arise. Because FNS is the single common point of contact for
all schools participating in the school meal programs, and because it does
provide guidance to the schools on food nutrition and quality, an extension
of FNS? hold and recall procedures to include non- donated (school-
purchased) foods would seem logical. USDA officials agreed with this concept
and indicated that they intend to share the hold and recall procedures with
schools in fiscal year 2003.

USDA and FDA have not developed any specific security provisions to help
protect food served through the school meal programs from potential
deliberate contamination. But, according to USDA and FDA officials, actions
designed to enhance the security of the federal food safety system as a
whole would also enhance the security of meals served at schools. As we
testified in October 2001, however, recent events have raised the specter of
bioterrorism as an emerging risk factor for our food safety system.. We
further stated that under the current structure, there are questions about
the system?s ability to detect and quickly respond to any such event. Since
our October 2001 testimony, both FDA and USDA have stated that they are
better prepared to detect and respond to such an event. Both agencies are in
the process of conducting risk assessments to determine where in the farm-
to- table food continuum there is a critical Potential Opportunity

to Further Enhance the Safety of School Meals

There Are No Special Security Provisions for the School Meal Programs

Page 13 GAO- 02- 669T School Meals Safety

need to provide additional resources. In addition, FDA staffing has already
increased inspections of imported foods, added more inspections of domestic
producers, and more laboratory testing of food products. Further, FDA has
issued voluntary security guidelines to the sector of the food industry that
it regulates on the need to (1) ensure physical security of processing and
storage facilities, (2) ensure that chemical and biological agents that may
be kept in their facilities or at in- house laboratories are under
appropriate controls, and (3) verify the background of plant employees.
Currently, the agency is receiving public comments and expects to revise the
guidelines. USDA is also working on a similar set of guidelines that meat,
poultry, and egg products processors could voluntarily adopt. Finally,
agency officials told us that they have generally asked their field
personnel to be on heightened alert for potential security concerns. We are
initiating a review to determine how these guidelines are being implemented
and how federal agencies plan to monitor their implementation.

As we reported in February 2000, while no federal agency monitors the safety
of school meals, USDA?s Food Safety and Inspection Service (FSIS) and FDA
are responsible for enforcing regulations that ensure the safety of the
nation?s food supply. FSIS is responsible for the safety of meat, poultry,
and some eggs and egg products, while the FDA is responsible for all other
foods, including fish, fruit, vegetables, milk, and grain products. However,
as we stated most recently in our October 2001 testimony, the existing food
safety system is a patchwork structure that hampers efforts to adequately
address existing and emerging food safety risks whether those risks involve
inadvertent or deliberate contamination. The food safety system is also
affected by other overarching problems, such as the challenge of effectively
coordinating the food safety activities of multiple agencies including
coordinating multi- state outbreaks. For example, the current organizational
and legal structure of our federal food safety system has given
responsibility for specific food commodities to different agencies and
provided them with significantly different regulatory authorities and
responsibilities. As a result, we have inefficient use of resources and
inconsistencies in oversight and enforcement.

USDA and FDA oversee recalls when the foods they regulate are contaminated
or adulterated. If a USDA- regulated company does not voluntarily conduct
the recall, USDA can detain the product for up to 20 days. On the other
hand, FDA, which currently does not have administrative detention authority
for food under the Federal Food, Drug, and Cosmetic Act, must seek a court
order to seize the food. Moreover, as Overarching Problems

in the National Food Safety System Also Affect the Safety of School Meals

Page 14 GAO- 02- 669T School Meals Safety

we reported in August 2000, 9 neither USDA nor FDA had provided guidance to
industry on how to quickly initiate and carry out food recalls that involve
potentially serious adverse health risk. We recommended that such guidelines
instruct companies on time frames for quickly initiating and carrying out
recalls, including procedures that expeditiously notify distribution chains
and alert the public. USDA has revised its guidelines, and FDA is in the
process of revising its guidance and expects to reissue the guidance in
September 2002.

Finally, Mr. Chairmen, in working on food safety issues over the past
decade, we have reviewed USDA?s and FDA?s inspection systems and identified
weaknesses in both. The agencies agreed with most of our recommendations and
have either taken steps or are taking steps to improve inspections. We have
also focused on specific products, many of which are included in school
meals. For example, because of concerns about the risk of salmonella in
eggs, we reviewed the adequacy of the federal system for ensuring egg
safety. Our work shows that the current regulatory and organizational
framework for egg safety makes it difficult to ensure that resources are
directed to areas of highest risk. Similarly, we evaluated the seafood and
shellfish safety program and determined that theses programs do not
sufficiently protect consumers because of weaknesses in FDA?s implementation
of the new science- based inspection system. FDA agreed with most of our
recommendations. We also reviewed USDA?s oversight of meat and poultry
products and concluded that, in order to better ensure safety, USDA needed
to ensure that inspectors are properly trained on the new science- based
system. USDA agreed with our recommendation and is providing enhanced
training. In January 2002, 10 our report on mad cow disease concluded that,
although bovine spongiform encephalopathy (BSE) has not been found in the
United States, federal actions do not sufficiently ensure that all BSE-
infected animals or products are kept out of the country or that if BSE were
found, it would be detected promptly and not spread. FDA, USDA, and Customs
generally agreed with the report?s recommendations.

9 U. S. General Accounting Office, Food Safety: Actions Needed by USDA and
FDA to Ensure that Companies Promptly Carry Out Recalls, GAO/ RCED- 00- 195
(Washington, D. C.: Aug. 17, 2000).

10 U. S. General Accounting Office, Mad Cow Disease: Improvements in the
Animal Feed Ban and Other Regulatory Areas Would Strengthen U. S. Prevention
Efforts, GAO- 02- 183 (Washington, D. C.: Jan. 25, 2002).

Page 15 GAO- 02- 669T School Meals Safety

Mr. Chairmen, in conclusion, schools face the difficult task of providing
healthy, nutritious meals to millions of children daily. As the data
indicate, the number of school- related foodborne illness outbreaks reported
between 1990 and 1999 has generally increased despite the efforts of these
schools, as well as the federal regulatory agencies, to prevent tainted food
from reaching cafeteria plates. We believe that to make substantial
improvements in the safety of school meals will require, in part, addressing
the overarching problems that affect the nation?s federal food safety system
as a whole. Nevertheless, as we have discussed today, there are steps that
USDA could take within the existing safety system to better ensure the
safety of school meals, such as providing state and local school authorities
with specific food safety provisions that could be included in their
procurement contracts. Additionally, continued vigilance is necessary to
determine the true extent and cause of the problems, to ensure that schools
obtain the safest food possible for our children, and also to ensure that
unsafe foods are promptly and effectively withdrawn from schools when
illnesses occur.

Mr. Chairmen, this completes my prepared statement. I would be happy to
respond to any questions you or other members of the Subcommittees may have.

Contacts and Acknowledgments

For future contacts regarding this testimony, please contact Lawrence J.
Dyckman at 202- 512- 3841. Individuals making key contributions to this
testimony included Maria Cristina Gobin, Brad Dobbins, John M. Nicholson,
Jr., John C. Johnson, Doug Sloane, Stuart Ryba, and Maria- Alaina I. Rambus.
Conclusions

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