Food Safety: Opportunities to Redirect Federal Resources and Funds Can
Enhance Effectiveness (Letter Report, 08/06/98, GAO/RCED-98-224).

Pursuant to a congressional request, GAO (1) analyzed the federal food
safety agencies' budgets for fiscal year 1999 to determine whether the
appropriated funds of more than $1 billion can be spent more
effectively; and (2) provided its views on whether the food safety
initiatives for fiscal years 1998-1999 will address underlying problems
in the federal food safety system.

GAO noted that: (1) more than one-fourth of the over $1-billion federal
budget for food safety--about $271 million--could be used more
effectively if most of these funds were congressionally redirected from
the Food Safety and Inspection Service's organoleptic carcass-by-carcass
slaughter inspections to a number of the other food safety activities
that need attention; (2) funds currently used for organoleptic,
carcass-by-carcass slaughter inspections do not optimize federal
resources because these inspections do not detect the most serious
public health threat associated with meat and poultry--microbial
contamination; (3) instead, these inspections mostly assure the quality
of food and therefore benefit the industry more than they ensure food
safety for consumers; (4) the $271 million could be used, for example,
by the Food Safety and Inspection Service to help the smallest slaughter
and processing plants with the cost of installing new science- and
risk-based inspection systems; (5) since industry will bear most of the
installation cost and the smallest plants operate at a smaller volume
over which to spread this cost, these plants will be disproportionately
affected by the cost of the new inspection systems; (6) in addition to
the funds that could be made available from the revisions to the
carcass-by-carcass slaughter inspections, some funds used for daily
inspections of meat- and poultry-processing plants could be
congressionally redirected to other needs; (7) for example, inspections
could be based on the risks at other food plants, such as cereal
manufacturers; (8) if the frequency of these inspections were based on
the health risk posed rather than on the Food Safety and Inspection
Service's practice of conducting processing plant inspections on a daily
basis, these inspections would be more effective; (9) the food safety
initiatives have made some improvements to the federal food safety
system, but they have not comprehensively addressed the underlying
problem of the fragmented nature of this system; (10) in fact, while the
initiatives provided funding for specific food safety efforts, the
initiatives' effective implementation may be impeded by the system's
fragmentation; and (11) for example, progress in carrying out the
initiative's objective of consolidating seafood inspection activities
under one agency has been impeded by the slow progress of the Food and
Drug Administration and the Department of Commerce in developing
legislation for congressional consideration.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-98-224
     TITLE:  Food Safety: Opportunities to Redirect Federal Resources 
             and Funds Can Enhance Effectiveness
      DATE:  08/06/98
   SUBJECT:  Cost effectiveness analysis
             Meat inspection
             Poultry inspection
             Consumer protection
             Contaminated foods
             Safety regulation
             Food industry
             Product safety
             Health hazards
             Infectious diseases
IDENTIFIER:  FSIS Hazard Analysis and Critical Control Point System
             CDC FoodNet
             
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Cover
================================================================ COVER


Report to the Chairman, Committee on the Budget, House of
Representatives

August 1998

FOOD SAFETY - OPPORTUNITIES TO
REDIRECT FEDERAL RESOURCES AND
FUNDS CAN ENHANCE EFFECTIVENESS

GAO/RCED-98-224

Food Safety

(150649)


Abbreviations
=============================================================== ABBREV

  AMS - Agricultural Marketing Service
  APHIS - Animal and Plant Health Inspection Service
  ARS - Agricultural Research Service
  ATF - Bureau of Alcohol, Tobacco, and Firearms
  CDC - Centers for Disease Control and Prevention
  EPA - Environmental Protection Agency
  FDA - Food and Drug Administration
  FSIS - Food Safety and Inspection Service
  FTC - Federal Trade Commission
  GAO - General Accounting Office
  GIPSA - Grain Inspection, Packers and Stockyards Administration
  HACCP - Hazard Analysis and Critical Control Point
  HHS - Department of Health and Human Services
  NMFS - National Marine Fisheries Service
  USDA - U.S.  Department of Agriculture

Letter
=============================================================== LETTER


B-280252

August 6, 1998

The Honorable John R.  Kasich
Chairman, Committee on the Budget
House of Representatives

Dear Mr.  Chairman: 

The increasing incidence of foodborne illness has heightened concerns
about the federal system's effectiveness in ensuring the safety of
the nation's food supply.  These concerns have focused in part on the
multiple federal agencies that carry out their responsibilities under
35 different laws and spend over $1 billion annually.\1 The primary
agencies responsible for food safety are the U.S.  Department of
Agriculture's (USDA) Food Safety and Inspection Service (FSIS), which
is responsible for meat, poultry, and some egg products, and the Food
and Drug Administration (FDA), within the Department of Health and
Human Services (HHS), which is responsible for all other food
products.  In addition to the more than $1 billion that all the
agencies get for their food safety activities, they received $43
million for fiscal year 1998 and requested $101 million for fiscal
year 1999 under the national food safety initiatives announced by the
President.  These initiatives are intended to address areas of
concern in the current food safety system and support a broad range
of activities, including the monitoring of incidences of foodborne
illnesses and the development of educational messages on food safety. 

You asked us to (1) analyze the federal food safety agencies' budgets
for fiscal year 1999 to determine whether the appropriated funds of
more than $1 billion can be spent more effectively and (2) provide
our views on whether the food safety initiatives for fiscal years
1998-99 will address underlying problems in the federal food safety
system. 

To respond to your request, we analyzed 10 federal food safety
agencies' budgets and the appropriation requests for the two food
safety initiatives and made observations based on our previous
reports' findings.  (Prior GAO products relevant to this report are
listed at the end of this report.) Furthermore, we asked federal
program and budget officials to explain selected programs and
activities in more detail for their agencies' fiscal year 1999 budget
and for the initiatives. 


--------------------
\1 See Food Safety and Quality:  Who Does What in the Federal
Government (GAO/RCED-91-19B, Dec.  21, 1990).  See also Food Safety: 
New Initiatives Would Fundamentally Alter the Existing System
(GAO/RCED-96-81, Mar.  27, 1996). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

More than one-fourth of the over $1 billion federal budget for food
safety--about $271 million--could be used more effectively if most of
these funds were congressionally redirected from the Food Safety and
Inspection Service's organoleptic (seeing, smelling, and touching),
carcass-by-carcass slaughter inspections to a number of the other
food safety activities that need attention.  Funds currently used for
organoleptic, carcass-by-carcass slaughter inspections do not
optimize federal resources because these inspections do not detect
the most serious public health threat associated with meat and
poultry--microbial contamination.  Instead, these inspections mostly
ensure the quality of food and therefore benefit the industry more
than they ensure food safety for consumers.  The $271 million could
be used, for example, by the Food Safety and Inspection Service to
help the smallest slaughter and processing plants with the cost of
installing new science- and risk-based inspection systems.  Since
industry will bear most of the installation cost and the smallest
plants operate at a smaller volume over which to spread this cost,
these plants will be disproportionately affected by the cost of the
new inspection systems.  In addition to the funds that could be made
available from the revisions to the carcass-by-carcass slaughter
inspections, some funds used for daily inspections of meat- and
poultry-processing plants could be congressionally redirected to
other needs.  For example, inspections could be based on the risks at
other food plants, such as cereal manufacturers.  If the frequency of
these inspections were based on the health risk posed rather than on
the Food Safety and Inspection Service's practice of conducting
processing plant inspections on a daily basis, these inspections
would be more effective. 

The food safety initiatives have made some improvements to the
federal food safety system, but they have not comprehensively
addressed the underlying problem of the fragmented nature of this
system.  In fact, while the initiatives provided funding for specific
food safety efforts, the initiatives' effective implementation may be
impeded by the system's fragmentation.  For example, progress in
carrying out the initiative's objective of consolidating seafood
inspection activities under one agency has been impeded by the slow
progress of the Food and Drug Administration and the Department of
Commerce in developing legislation for congressional consideration. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Foodborne illness in the United States is extensive and expensive. 
The incidence of foodborne illness is estimated to range from 6.5
million to 81 million cases each year and result in as few as 500 to
as many as 9,100 related deaths annually.\2 In terms of medical costs
and productivity losses, foodborne illness costs the nation between
$7 billion and $37 billion annually, according to USDA's estimates. 

Public health officials believe that the risk of foodborne illness
has been increasing over the last 20 years.  Trends in the incidence
of foodborne illness in the United States are linked, at least in
part, to changes in Americans' eating habits.  For example, Americans
today consume more raw fruits and vegetables than they did in the
past and in some cases may mishandle them by not washing them.  While
this change in diet has many health benefits, the mishandling of
these foods and other foods, such as undercooking and/or improperly
refrigerating meat and poultry, may also contribute to the spread of
foodborne illnesses. 

The scientific community has recognized that preventing contamination
is the key to reducing the risk of foodborne illness.  However, FSIS
conducts organoleptic meat and poultry inspections of each and every
meat and poultry carcass in order to fulfill current program
requirements for carcass-by-carcass inspections in slaughtering
plants.  While these inspections fulfill the requirements, they
primarily identify defects in quality but do not detect microbial
contamination. 

However, as the threat of microbial contamination has increased, a
Hazard Analysis and Critical Control Point (HACCP) system has come to
be considered the best approach currently available for ensuring safe
food because it focuses on preventing contamination rather than on
detecting it once it has occurred.  The HACCP system (1) identifies
hazards and assesses the risks associated with each phase of food
production,\3 (2) determines the critical points where the identified
hazards can be controlled, and (3) establishes procedures to monitor
these critical control points. 

In January 1998, FSIS began to require meat and poultry plants to
implement HACCP systems.  Implementation is expected to take 3 years,
starting with the nation's 300 largest slaughtering plants, which
account for 75 percent of all meat and poultry slaughter production. 
In 2000, this system will be fully implemented and will have reached
very small plants--those with fewer than 10 employees.  The HACCP
system requires FSIS' verification that a plant's overall system--not
just the individual control points--is working.  This verification
relies on, among other things, microbial and other types of testing
of product samples taken at various times throughout production. 
These tests contribute to verifying whether the plants meet food
safety standards and alert the plants to deficiencies in the
slaughtering process. 

In addition to carcass-by-carcass slaughter inspections, FSIS
inspects meat- and poultry-processing plants at least once per day
during each operating shift.  Its current inspection program practice
for processing plants is labor-intensive and is not based on the
health risk that a plant poses.  Processing plants' operations can
include the simple cutting and packaging of meat and poultry,
grinding, complex canning procedures, or the preparation of
ready-to-eat products. 

Multiple agencies share the responsibility for ensuring the safety of
the nation's food supply.  In fact, 12 different federal agencies
located within six federal entities are involved:  HHS' Food and Drug
Administration and Centers for Disease Control and Prevention (CDC);
USDA's FSIS, Agricultural Marketing Service (AMS), Animal and Plant
Health Inspection Service (APHIS), Agricultural Research Service
(ARS), and Grain Inspection, Packers, and Stockyards Administration;
the Department of Commerce's National Marine Fisheries Service
(NMFS); the Department of the Treasury's U.S.  Customs Service and
Bureau of Alcohol, Tobacco, and Firearms; the Environmental
Protection Agency (EPA); and the Federal Trade Commission.  Appendix
I describes these 12 agencies' roles and responsibilities in food
safety, and table I.1 shows the food safety funding for and staffing
levels of the agencies for selected years.  This structure
necessitates extensive coordination to minimize duplication of
effort, prevent gaps in regulatory coverage, and avoid conflicting
actions.  Our past reviews have shown inconsistencies and differences
between agencies' approaches and enforcement authorities that
undercut overall efforts to ensure a safe food supply.\4 In the past,
we have recommended a single food safety agency to correct the
problems created by this fragmented system. 

In addition to the more than $1 billion provided for routine food
safety activities, the administration's food safety initiatives
increased funding for federal food safety efforts by $43 million in
fiscal year 1998 and requested $101 million for fiscal 1999.  These
funds went to various agencies--some of which previously did not have
any food safety activities--to target efforts for collaborating on
food safety priorities in six areas:  (1) enhance surveillance of
foodborne illnesses and build an early warning system; (2) improve
the assessment of the risks associated with exposure to foodborne
pathogens;\5

(3) improve coordination among local, state, and federal health
authorities; (4) improve the efficiency and effectiveness of seafood,
fruits and vegetables, and other FDA inspections; (5) develop
educational messages for a variety of audiences, such as consumers
and schoolchildren, on the hazards associated with handling food; and
(6) research methodologies for, among other things, more rapid and
accurate identification and characterization of foodborne hazards. 
These areas represent important and specific food safety activities
that, in many cases, existed prior to the initiatives but had
difficulty obtaining funding through their agencies' processes for
setting budget priorities.  Appendix II shows, by agency, the fiscal
year 1998 funding and fiscal 1999 request for these initiatives. 


--------------------
\2 See Food Safety:  Information on Foodborne Illnesses
(GAO/RCED-96-96, May 8, 1996). 

\3 Hazards include any biological, chemical, or physical property
that may cause an unacceptable risk to consumers' health. 

\4 Food Safety and Quality:  Uniform, Risk-Based Inspection System
Needed to Ensure Safe Food Supply (GAO/RCED-92-152, June 26, 1992),
Food Safety:  A Unified, Risk-Based System Needed to Enhance Food
Safety (GAO/T-RCED-94-71, Nov.  4, 1993), Food Safety:  A Unified,
Risk-Based Food Safety System Needed (GAO/T-RCED-94-223, May 25,
1994), and Food Safety:  Fundamental Changes Needed to Improve Food
Safety (GAO/RCED-97-249R, Sept.  9, 1997). 

\5 Pathogens are harmful bacteria, viruses, and parasites that are
known to be transmitted by foods and foodborne outbreaks. 


   FUNDS FOR FOOD SAFETY
   INSPECTION RESOURCES COULD BE
   SPENT MORE EFFECTIVELY
------------------------------------------------------------ Letter :3

A significant area in which food safety funds could be spent more
effectively is inspection resources.  Most of the $271 million--over
one-fourth of the food safety budget--spent annually on FSIS'
organoleptic, carcass-by-carcass slaughter inspections could be spent
more effectively on other food safety activities that better address
food safety risks.  Once HACCP is fully implemented, the funds could
become available through the Congress's (1) authorizing FSIS to
impose user fees on meat and poultry plants for carcass-by-carcass
slaughter inspections, (2) eliminating the legislatively mandated
requirement for these federal inspections and allowing slaughter
plants to hire their own inspectors, or (3) combining the above
options--permitting the slaughter plants to either pay the user fees
for federal inspections or hire their own inspectors.  In addition,
if daily inspections of the processing plants--at an annual cost of
about $109 million--were replaced by inspections based on health
risk, an undetermined amount of funds could be made available.  All
or part of the funds made available through the implementation of
revisions to food safety inspections could be redirected to other
food safety priorities. 


      RESOURCES FROM
      CARCASS-BY-CARCASS SLAUGHTER
      INSPECTIONS COULD BE SPENT
      MORE EFFECTIVELY
---------------------------------------------------------- Letter :3.1

Currently, FSIS spends about $271 million annually on inspectors who
are present at each slaughter plant nationwide every day that it is
in operation.  These inspectors, under current FSIS rules and
regulations, inspect each carcass--over 8 billion birds and livestock
annually--for visible defects, such as lesions and diseases.  Under
the traditional organoleptic inspection system, an inspector has
about 2 seconds per bird, at the fastest line speeds, to determine
whether the carcass meets federal standards for wholesomeness. 

We previously reported that with the introduction of the HACCP
system, the traditional system of organoleptic meat and poultry
inspections of each meat and poultry carcass will become obsolete for
improving the safety of meat and poultry because it does not prevent
microbial contamination.\6 Moreover, experts have recognized that
post-mortem organoleptic inspections on every carcass must be changed
because (1) they waste resources and cannot detect microbial
pathogens, (2) the animal diseases for which they were originally
designed have been eradicated in many countries, and (3) they result
in unnecessary cross-contamination because the hands-on inspection
techniques used virtually ensure that contamination spreads from one
carcass to another.  However, this type of inspection may be useful
to slaughter plants, since it primarily provides an assurance of
quality, such as ensuring that feathers are removed and that tumors
and blood clots are not present.  While these conditions do not
generally threaten human health, they affect the quality of the
product. 

Because the organoleptic inspections of slaughtered animals primarily
help to ensure quality rather than food safety, these inspections are
foremost in the slaughter plants' interest.  Therefore, as we
previously reported, it may be appropriate to charge user fees to
cover the cost of these activities.\7 Historically, FSIS has sought
but never received the authority to charge user fees for all of its
inspection activities.  FSIS is requesting user fees again in its
fiscal year 1999 budget for all inspection activities.  Although the
Congress has decided in the past that it is not appropriate to impose
user fees for all food safety inspections, the Congress, as a first
option, may consider it appropriate to authorize user fees for the
federal organoleptic, carcass-by-carcass inspection of slaughtered
animals after FSIS has fully implemented the new science- and
risk-based HACCP inspection system.  If this authority were granted
and used, most of the $271 million that FSIS currently spends on
these inspections could be recovered. 

As a second option, the Congress could amend the mandated requirement
for federal carcass-by-carcass inspections by stipulating that after
a slaughter plant has operated under a HACCP system for a period of
time, the plant could conduct its own carcass-by-carcass slaughter
inspections, with appropriate FSIS oversight.  Alternatively, as we
previously recommended, the Congress could revise the meat and
poultry acts to provide FSIS with the flexibility and discretion to
target its inspection resources to meet the most serious food safety
risks.\8

Finally, the Congress could provide for a combination of the first
two options.  That is, a plant could (1) pay a user fee to FSIS,
adjusted periodically to reflect FSIS' increased costs, and use FSIS
inspectors for carcass-by-carcass slaughter inspections or (2) hire
its own employees to do these inspection activities with the
appropriate FSIS oversight. 


--------------------
\6 See Food Safety:  Risk-Based Inspections and Microbial Monitoring
Needed for Meat and Poultry (GAO/RCED-94-110, May 19, 1994). 

\7 See Food-Related Services:  Opportunities Exist to Recover Costs
by Charging Beneficiaries (GAO/RCED-97-57, Mar.  20, 1997). 

\8 See Food Safety:  Risk-Based Inspections and Microbial Monitoring
Needed for Meat and Poultry (GAO/RCED-94-110, May 19, 1994). 


      RESOURCES FROM DAILY
      PROCESSING PLANT INSPECTIONS
      COULD BE SPENT MORE
      EFFECTIVELY
---------------------------------------------------------- Letter :3.2

In prior work, we reported on the opportunity to more effectively use
federal food safety resources by adopting a risk-based approach
rather than the approach currently used by FSIS, which requires daily
inspections at all processing plants.  This inflexible,
labor-intensive approach costs an estimated $109 million annually. 
Under FSIS' current approach, an inspector must visit each meat and
poultry processing plant every 8-hour operating shift to perform a
number of tasks, such as monitoring the cleanliness of the workers'
bathrooms and ensuring that the canning process operates under the
right temperatures and pressures.  An undetermined amount of funds
could be made available by adopting a risk-based approach to
determine the appropriate frequency for these inspections and to
allow for more substantial inspections, if needed, when they do
occur.  Funds made available from this new approach could then be
redirected to other food safety priorities. 

Developing a risk-based system to determine the frequency of daily
inspections would result in fewer inspections but also in inspections
that are more closely tied to risk.  Our past work pointed out the
inefficiencies of FSIS' daily inspection of all 5,900 meat- and
poultry-processing plants (or once per shift if a plant operates more
than one 8-hour shift) with the same frequency and intensity of
inspection regardless of the processing plant's public health risk
and compliance history.  In fiscal year 1997, the annual cost
associated with inspectors traveling between processing plants on
daily "patrol assignments," which averaged three to six plants per
day, was $6 million.  Under a risk-based approach, some of these
inspections would occur less frequently because they would be based
on the risk that specific food products pose to public health and the
plants' past inspection histories. 


      OPPORTUNITIES EXIST TO
      REDIRECT BUDGET RESOURCES TO
      MORE EFFECTIVE USES
---------------------------------------------------------- Letter :3.3

If FSIS changes its current approach to carcass-by-carcass slaughter
inspections, all or part of the $271 million annually spent on these
inspections could be redirected to other federal food safety
activities that better reduce the threat of foodborne illness.  In
prior work, we identified a number of food safety concerns that could
be addressed, such as the following: 

  -- FSIS could help to install HACCP inspection systems at the
     smallest meat and poultry slaughter and processing plants. 
     Since industry will bear most of the installation cost for these
     new systems and the smallest plants have a smaller volume over
     which to spread this cost, these plants will be
     disproportionately affected by the cost of the new inspection
     systems. 

  -- FDA could increase the frequency of its inspections of other
     U.S.  food-processing plants, such as nonmeat soup plants,
     cereal manufacturers, and canned fruit and vegetable processors. 
     Currently, FDA inspects such plants under its jurisdiction only
     once in 10 years, on average.  These inspections are not based
     on the health risks that these plants pose, but rather on
     available resources.  FDA officials informed us that if they had
     increased resources, FDA could increase the frequency of
     inspections of high-, moderate-, and low-risk firms, in that
     order.  In general, the inspections of lower-risk firms would be
     based on the availability of resources. 

  -- FDA could improve its oversight of imported foods by assisting
     foreign countries in developing equivalent food safety systems
     or it could use the funds to improve its oversight of imported
     foods at ports of entry. 

In addition to these actions, the food safety agencies may have other
priorities for the use of the funds that are made available from
organoleptic slaughter inspections of meat and poultry plants or by
basing the frequency of meat- and poultry-processing plant
inspections on risk.  For example, an ARS official stated that FDA
could use additional funding to support an ongoing surveillance
system of food animals.  This system samples tissue from food animals
that have been treated with antibiotics.  The system monitors (1) the
buildup of antibiotic tolerances in animals and (2) the mutation of
pathogens due to antibiotic treatment.  The health concern is
antibiotic resistance to pathogens in humans as a result of consuming
these food animals. 


   NATIONAL FOOD SAFETY
   INITIATIVES IDENTIFIED
   WEAKNESSES, BUT THE FRAGMENTED
   STRUCTURE PERSISTS
------------------------------------------------------------ Letter :4

The national food safety initiatives were announced by the President
for fiscal years 1998-99 and provided additional funds for identified
weaknesses.  These initiatives have improved some food safety
activities.  However, the initiatives do not address the fundamental
problem of the system--its fragmented structure.  In fact, for
certain food safety activities, the initiatives intensified the need
for coordination among the loosely networked group of federal food
safety agencies. 


      INITIATIVES IDENTIFIED
      WEAKNESSES AND PROVIDED
      ADDITIONAL FUNDS
---------------------------------------------------------- Letter :4.1

For fiscal year 1998, the administration's initiative received $43
million for specific food safety activities to improve the nation's
food safety system.  Prior to the initiative, these activities had
competed with other agency priorities for funding.  The $43 million
in funding was aimed at, among other things, (1) improving a
nationwide early-warning system for foodborne illnesses, (2)
increasing seafood safety inspections, and (3) expanding research,
training, and education in food safety.  Under the initiative for
fiscal year 1999, the administration has requested $101 million to
build upon the food safety efforts in the 1998 initiative and to
enhance the safety of imported and domestic fruits and vegetables,
among other things. 

CDC used initiatives funding to improve its monitoring of foodborne
illnesses and will expand its surveillance locations throughout the
country to eight.  This program, now known as FoodNet, provides
national data to better identify illnesses associated with foods;
these data allow for more informed decisions about dealing with
microbial contamination.  Prior to FoodNet, CDC had very limited
information on the extent of foodborne illnesses.  Since this
surveillance effort was undertaken, for example, CDC has learned that
the incidence of one pathogen, Campylobacter, is far more frequent
than previously known.\9 Policymakers can now use this information to
direct research and other activities to reduce illnesses from this
pathogen. 


--------------------
\9 Campylobacter is a pathogen that causes such foodborne illnesses
as chronic diarrhea, meningitis, and blood poisoning.  It is the most
common precipitating factor for Guillain-Barre syndrome, which is now
one of the leading causes of paralysis from disease in the United
States.  Campylobacter can occur from contact with such foods as raw
poultry and raw milk. 


      INITIATIVES DO NOT ADDRESS
      FRAGMENTED STRUCTURE OF THE
      FOOD SAFETY SYSTEM
---------------------------------------------------------- Letter :4.2

While these food safety initiatives have addressed, and intend to
address, some targeted problems, they do not effectively deal with
the underlying fragmentation in the federal food safety system.  As
we have reported, past efforts to correct deficiencies in the federal
inspection system for food safety have fallen short, in part because
they did not address the fundamental problems in the system.\10
Agencies operate under different regulatory approaches, have widely
disparate budgets and staffs, and lack the flexibility needed to
respond to changing consumption patterns and emerging food safety
issues.  These agencies' efforts are hampered by laws that were
designed to address safety concerns in specific foods in a piecemeal
fashion, typically in response to particular health threats or
economic crises. 

In addition, this fragmentation may have impeded the effective
implementation of some of the activities funded through the food
safety initiatives.  For example, the initiatives for fiscal years
1998-99 included about $15.7 million to FSIS, FDA, and the
Cooperative State Research, Education, and Extension Service, among
other agencies, to jointly develop a national campaign to educate the
public about the safe handling of fruits and vegetables.  However,
this effort excluded EPA, which is spending about $230,000 in fiscal
year 1998 and about $400,000 in fiscal 1999 to develop and distribute
its own brochure to educate the public about pesticides and foods. 
While EPA attempted to coordinate its educational brochure with the
other agencies, significant differences over the message still
occurred.  According to USDA and FDA officials and consumer groups,
EPA's message implied that there are risks associated with eating
fruits and vegetables treated with pesticides.  These groups said
that EPA's message contradicted USDA's advice to eat more fruits and
vegetables.  At the same time, the other agencies' effort developed a
message that discussed the safe handling of fruits and vegetables and
encouraged their consumption.  In March 1998, after receiving
comments from other agencies and the public on its draft brochure as
published in the Federal Register, EPA began revising its brochure to
reflect the concerns of the other agencies and advised us that it is
still in that process. 

Even when an activity under the initiatives has been designed to
address a fragmentation problem, there is no assurance that it will
be successful.  For example, in January 1997, the President's Food
Safety Initiative (Food Safety From Farm to Table:  A National Food
Safety Initiative) proposed improving seafood inspection activities
by consolidating seafood inspections under one agency by October
1998.  Under the proposal, NMFS' voluntary fee-for-service seafood
inspection program would be moved to FDA.  Progress on this
consolidation has been slow because some of the necessary legislative
changes are still being drafted.  As of May 1998, NMFS officials told
us that they have drafted legislation, in conjunction with FDA, to
transfer the program to FDA but budget issues have delayed the
legislation from being sent to the Office of Management and Budget
for its review and approval.  Consequently, the Congress has not had
the opportunity to decide on the proposed legislation.  Commerce's
fiscal year 1999 budget request does not show NMFS' program as part
of Commerce's fiscal 1999 budget, because Commerce assumed that
legislation to transfer the program would be enacted during fiscal
1998.  In addition, neither FDA's fiscal year 1999 budget nor its
initiative funds provide for transferring NMFS' program to FDA, which
has primary responsibility for seafood inspections.  FDA officials
told us that they did not include the transfer in their fiscal year
1999 budget request because they had not received the legislative
authority to charge the user fees that are associated with NMFS'
inspection program. 


--------------------
\10 See Food Safety:  Fundamental Changes Needed to Improve Food
Safety (GAO/RCED-97-249R, Sept.  9, 1997). 


   AGENCY COMMENTS AND OUR
   RESPONSE
------------------------------------------------------------ Letter :5

We provided the Department of Commerce, the CDC, EPA, FDA, and USDA
with a draft of this report for their review and comment.  The
following summarizes their comments, which are shown in their
entirety with our point-by-point responses, in appendixes III through
VII. 

USDA disagreed with the draft report and had concerns with (1) the
draft's description of the Department's food safety inspection
operations as well as the laws supporting these operations and (2)
any implication that food safety resources should be transferred out
of the Department.  Concerning the former, USDA stated that we
mischaracterized the statutory authorities for FSIS' programs that
ensure the safety of the meat and poultry supply and inaccurately
described FSIS' current inspection practices.  For example, USDA
noted that, in contrast to statements in the draft report, the
statutes do not mandate how carcass-by-carcass inspections are to be
carried out nor do they state the frequency of processing
inspections.  We used the Department's comments, where appropriate,
to clarify certain aspects of the report.  These clarifications are
described in more detail in appendix VII.  However, none of these
revisions changed the fundamental description of the Department's
inspection operations.  Furthermore, they do not change our principal
observation that USDA's current carcass-by-carcass inspection process
as well as its daily processing plant inspection process are not
risk-based and, therefore, in our view, may not be an efficient use
of federal food safety resources. 

USDA's second concern stemmed from a misinterpretation of the draft. 
USDA officials incorrectly inferred that the report implied that any
resources made available by revising the Department's current
carcass-by-carcass inspection and daily plant inspection processes
should be redirected outside FSIS.  The report does not say this;
rather, it presents several food safety activities that these
resources could be redirected toward, both within and outside of
FSIS. 

EPA and FDA each had one primary concern about the draft report. 
This concern related to one of several examples used to illustrate
our observation that the food safety initiatives did not address the
underlying problems of fragmentation in food safety regulation.  More
specifically, the draft report noted that under the food safety
initiative for fiscal year 1999, USDA and FDA had planned to
consolidate efforts for monitoring microbial contamination in fruits
and vegetables but had missed an opportunity to take a similar
approach to monitor for pesticide residues in these foods.  In
commenting on the draft, both FDA and EPA stated that the objectives
of USDA's and FDA's pesticide- monitoring efforts differed
significantly enough that it would be difficult to develop a single
monitoring program that would satisfy both agencies' monitoring
objectives.  On the basis of their concerns, we eliminated this
particular example.  However, our overall observation concerning
fragmentation and the problems it creates for ensuring food safety
remains unchanged. 

The Department of Commerce and CDC generally agreed with our report
and provided several technical corrections, which we incorporated as
appropriate. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :6

You asked us to (1) analyze the federal food safety agencies' budgets
for fiscal year 1999 to determine whether the appropriated funds of
more than $1 billion can be spent more effectively and (2) provide
our views on whether the food safety initiatives for fiscal years
1998-99 will address underlying problems in the federal food safety
system. 

To address the first question, we reviewed the two food safety
agencies with the largest budgets and another seven agencies with
budgetary increases in their fiscal year 1999 budget requests for
selected food safety programs and projects.  In total, we examined 10
agencies' budgets:  FDA and CDC, within HHS; FSIS, AMS, APHIS, ARS,
the Grain Inspection, Packers, and Stockyards Administration, and the
Cooperative State Research, Education, and Extension Service, within
USDA; NMFS, within the Department of Commerce; and EPA.  In addition,
we asked the agencies' program and budget officials to explain budget
justifications in more detail for selected programs and projects to
ascertain if these various agencies' budgets represented the best way
to spend $1 billion on federal food safety activities through
appropriations and user fees.  In order to provide our views on
whether the food safety initiatives for fiscal years 1998-99 will
address the underlying problems in the federal food safety system, we
reviewed the administration's initiatives on food safety, examined
four of the six priority areas identified within the initiatives
because these areas had the largest budgets, and interviewed
knowledgeable food safety agencies' program and budget officials on
selected projects within those four areas. 

In addition, to address both issues, we used information from our
prior reports and reports from the Congressional Research Service. 
We conducted our review from February through May 1998 in accordance
with generally accepted government auditing standards. 


---------------------------------------------------------- Letter :6.1

We are sending this report to various congressional committees
because of their role in overseeing the activities and funding of the
issues discussed.  We are also sending copies of this report to the
Secretaries of Agriculture, Commerce, and HHS; Administrator, EPA;
and Director, Office of Management and Budget.  In addition, we will
make copies available to others on request.  See appendix VIII for
major contributors to this report.  Please contact me at (202)
512-5138 if you or your staff have any questions. 

Sincerely yours,

Lawrence J.  Dyckman
Director, Food and
 Agriculture Issues


RESPONSIBILITIES OF FEDERAL
AGENCIES INVOLVED WITH FOOD SAFETY
=========================================================== Appendix I

Food and Drug Administration (FDA), within the Department of Health
and Human Services (HHS), is responsible for ensuring that domestic
and imported food products (except meat, poultry, and processed egg
products) are safe, wholesome, and properly labeled.  The Federal
Food, Drug, and Cosmetic Act, as amended, is the major law governing
FDA's activities to ensure food safety and quality.  The act also
authorizes FDA to maintain a surveillance of all animal drugs, feeds,
and veterinary devices to ensure that drugs and feeds used in animals
are safe and properly labeled, and produce no human health hazards
when used in food-producing animals. 

Centers for Disease Control and Prevention (CDC), within HHS, is
charged with protecting the nation's public health by providing
leadership and direction in preventing and controlling diseases and
responding to public health emergencies.  CDC conducts surveillance
for foodborne diseases; develops new epidemiologic and laboratory
tools to enhance the surveillance and detection of outbreaks; and
performs other activities to strengthen local, state, and national
capacity to identify, characterize, and control foodborne hazards. 
CDC engages in public health activities related to food safety under
the general authority of the Public Health Service Act, as amended. 

Food Safety and Inspection Service (FSIS), within the U.S. 
Department of Agriculture (USDA), is responsible for ensuring that
meat, poultry, and processed egg products moving in interstate and
foreign commerce are safe, wholesome, and correctly marked, labeled,
and packaged.  FSIS carries out its meat and poultry inspection
responsibilities under the Federal Meat Inspection Act, as amended,
and the Poultry Products Inspection Act, as amended.  Amendments to
these acts require that meat inspected by state inspection programs
as well as imported meat are to meet inspection standards "at least
equal to" those of the federal program.  Furthermore, the Department
of Agriculture Reorganization Act of 1994 transferred to FSIS some
food safety inspections previously performed by other organizations
within USDA. 

Animal and Plant Health Inspection Service (APHIS), within USDA, is
responsible for ensuring the health and care of animals and plants. 
APHIS has no statutory authority for public health issues unless the
concern to public health is also a concern to the health of animals
or plants.  APHIS identifies research and data needs and coordinates
research programs designed to protect the animal industry against
pathogens or diseases that are a risk to humans to improve food
safety. 

Grain Inspection, Packers and Stockyards Administration (GIPSA),
within USDA, is responsible for establishing quality standards and
providing for a national inspection system to facilitate the
marketing of grain and other related products.  Certain inspection
services, such as testing corn for the presence of aflatoxin, enable
the market to assess the value of a product on the basis of its
compliance with contractual specifications and FDA requirements. 
Those requesting inspection services, typically the owner of the
grain, are responsible for complying with FDA regulations.  GIPSA has
no regulatory responsibility regarding food safety.  Under a
memorandum of understanding with FDA, GIPSA reports to FDA certain
lots of grain, rice, pulses, or food products (which were officially
inspected as part of GIPSA's service functions) that are considered
objectionable under the Federal Food, Drug, and Cosmetic Act.  GIPSA
carries out its responsibilities under the U.S.  Grain Standards Act,
as amended, and the Agricultural Marketing Act of 1946, as amended. 

Agricultural Marketing Service (AMS), within USDA, is primarily
responsible for establishing the standards of quality and condition
and for grading the quality of dairy, egg, fruit, meat, poultry,
seafood, and vegetable products.  As part of this grading process,
AMS considers safety factors, such as the cleanliness of the product. 
AMS carries out its wide array of programs to facilitate marketing
under more than 30 statutes--for example, the Agricultural Marketing
Agreement Act of 1937, as amended; the Agricultural Marketing Act of
1946, as amended; the Egg Products Inspection Act, as amended; the
Export Apple and Pear Act, as amended; and the Export Grape and Plum
Act, as amended.  AMS is largely funded with user fees. 

Agricultural Research Service (ARS), within USDA, is responsible for
conducting a wide range of research relating to the Department's
mission, including food safety research.  ARS carries out its
programs under the Department of Agriculture Organic Act of 1862; the
Research and Marketing Act of 1946, as amended; and the National
Agricultural Research, Extension, and Teaching Policy Act of 1977, as
amended. 

National Marine Fisheries Service (NMFS), within the Department of
Commerce, conducts its voluntary seafood safety and quality
inspection programs under the Agricultural Marketing Act of 1946, as
amended, and the Fish and Wildlife Act of 1956, as amended.  In
addition to the inspection and certification services provided for
fishery products for human consumption, NMFS provides inspection and
certification services for animal feeds and pet foods containing a
fish base. 

Environmental Protection Agency (EPA) is responsible for regulating
all pesticide products sold or distributed in the United States and
setting maximum allowed residue levels--tolerances--for pesticides on
food commodities and animal feed.  EPA's activities are conducted
under the Federal Insecticide, Fungicide, and Rodenticide Act, as
amended, and the Federal Food, Drug, and Cosmetic Act, as amended. 

Federal Trade Commission (FTC) enforces the Federal Trade Commission
Act, which prohibits unfair or deceptive acts or practices.  FTC's
food safety objective is to prevent consumer deception through the
misrepresentation of food. 

U.S.  Customs Service, within the Department of the Treasury, is
responsible for collecting revenues and enforcing various customs and
related laws.  Customs assists FDA and FSIS in carrying out their
regulatory roles in food safety. 

Bureau of Alcohol, Tobacco, and Firearms (ATF), within the Department
of the Treasury, is responsible for administering and enforcing laws
covering the production (including safety), use, and distribution of
alcoholic beverages under the Federal Alcohol Administration Act and
the Internal Revenue Code. 



                                    Table I.1
                     
                      Changes in Funding and Staffing Levels
                      for Food Safety at 12 Federal Agencies

                              (Dollars in millions)

                       Funding                             Staffing
          ----------------------------------  ----------------------------------
                                      Fiscal
              Fiscal      Fiscal        year      Fiscal      Fiscal      Fiscal
Agency     year 1989   year 1994      1998\a   year 1989   year 1994   year 1998
--------  ----------  ----------  ----------  ----------  ----------  ----------
FDA\b           $158        $239        $254       2,648       2,999       2,796
FSIS             457         606         676      10,399      10,109       9,702
APHIS\c           \c          \c          \c          \c          \c          \c
GIPSA\d           42          44           0         860         685           0
AMS\e              9          14          10         183          33          42
ARS               25          38          55         168         134         167
NMFS\d            12          16          13         265         285         174
EPA\f             90          95         127         624         786         970
CDC                3           4          15          25          34          50
FTC                2           2          \g          29          23          \g
Customs\          \c          \c          \g          \c          \c          \g
 c
ATF\c             \c          \c          \g          \c          \c          \g
Total           $798      $1,058      $1,150      15,201      15,088      13,901
--------------------------------------------------------------------------------
\a Appropriated funds for fiscal year 1998. 

\b FDA's data include funding and staffing for various programs
across FDA that are involved with food safety activities, including
the Center for Food Safety and Applied Nutrition, the Center for
Veterinary Medicine, the field components for these centers, and
overall agencywide support. 

\c The agency did not specify its food safety resources. 

\d Agencies' funding and staffing levels are for both safety and
quality inspection activities. 

\e AMS' funding and staffing totals for fiscal year 1989 reflect egg
inspection activities, which were transferred to FSIS in 1994. 
Totals for fiscal years 1994 and 1998 include data for the Pesticide
Data Program, which began in 1991. 

\f Numbers for EPA are from the following sources:  Fiscal Year 1991
President's Budget, 1989 Actuals; Fiscal Year 1996 President's
Budget, 1994 Actuals; and Fiscal Year 1999 President's Budget, 1998
Enacted, and includes the total Office of Pesticides Programs. 

\g We did not review these agencies' food safety budgets because of
the small amount of funds for these activities in previous years. 

Source:  GAO's analysis of federal agencies' data. 


FOOD SAFETY INITIATIVES BY
CATEGORY AND DOLLAR AMOUNT
========================================================== Appendix II

                              (Dollars in thousands)

            Fiscal year
                1997           Fiscal year 1998            Fiscal year 1999
            ------------  --------------------------  --------------------------
Six               Actual        Budget
Initiative  expenditure\  appropriatio   Change from        Budget   Change from
categories             a             n       FY 1997       request       FY 1998
----------  ------------  ------------  ------------  ------------  ------------
Surveillance
--------------------------------------------------------------------------------
Food              $1,000        $1,500          $500        $1,500             0
 Safety
 and
 Inspectio
 n Service
Economic              32            32             0           285           253
 Research
 Service
Food and             678         3,838         3,160         6,038         2,200
 Drug
 Administr
 ation
Centers            4,500        14,500        10,000        19,000         4,500
 for
 Disease
 Control
 and
 Preventio
 n
================================================================================
Subtotal           6,210        19,870        13,660        26,823         6,953

Coordination
--------------------------------------------------------------------------------
Food and           6,598         7,148           550         7,348           200
 Drug
 Administr
 ation
================================================================================
Subtotal           6,598         7,148           550         7,348           200

Inspections
--------------------------------------------------------------------------------
Food                   0           565           565         8,412         7,847
 Safety
 and
 Inspectio
 n Service
Food and          67,376        75,246         7,870       102,846        27,600
 Drug
 Administr
 ation
================================================================================
Subtotal          67,376        75,811         8,435       111,258        35,447

Risk Assessment
--------------------------------------------------------------------------------
Agricultur         5,461         4,498          -963         4,818           320
 al
 Research
 Service
Cooperativ           145           150             5         1,962         1,812
 e State
 Research,
 Education
 , and
 Extension
 Service
Food                   0             0             0         1,000         1,000
 Safety
 and
 Inspectio
 n Service
Economic              33            33             0           686           653
 Research
 Service
Office of             62            60            -2           158            98
 the Chief
 Economist
Food and           2,382         6,332         3,950        13,532         7,200
 Drug
 Administr
 ation
================================================================================
Subtotal           8,083        11,073         2,990        22,156        11,083

Education
--------------------------------------------------------------------------------
Cooperativ         2,365         2,365             0         7,365         5,000
 e State
 Research,
 Education
 , and
 Extension
 Service
Food                   0             0             0         2,500         2,500
 Safety
 and
 Inspectio
 n Service
Food and               0             0             0         2,000         2,000
 Consumer
 Service
Office of             27            38            11            38             0
 the Chief
 Economist
Economic             420           420             0           420             0
 Research
 Service
Food and           4,415         6,485         2,070        10,085         3,600
 Drug
 Administr
 ation
Centers                0             0             0           500           500
 for
 Disease
 Control
 and
 Preventio
 n
================================================================================
Subtotal           7,227         9,308         2,081        22,908        13,600

Research
--------------------------------------------------------------------------------
Agricultur        44,186        50,351         6,165        64,001        13,650
 al
 Research
 Service
Cooperativ         3,724         6,250         2,526        10,438         4,188
 e State
 Research,
 Education
 , and
 Extension
 Service
Agricultur             0             0             0         6,257         6,257
 al
 Marketing
 Service
Food and          19,127        25,527         6,400        34,727         9,200
 Drug
 Administr
 ation
================================================================================
Subtotal          67,037        82,128        15,091       115,423        33,295
================================================================================
Total                                        $42,807                    $100,578
--------------------------------------------------------------------------------
Legend

FY = fiscal year. 

\a The first initiative started in fiscal year 1998; data for fiscal
year 1997 are provided as a baseline.  The resources reflected above
are for the Food Safety Initiatives only and do not include funding
for the agencies' other food safety activities. 




(See figure in printed edition.)Appendix III
COMMENTS FROM THE DEPARTMENT OF
COMMERCE
========================================================== Appendix II



(See figure in printed edition.)


The following are GAO's comments on the Department of Commerce's
letter dated June 24, 1998. 

GAO'S COMMENTS

1.  We revised the report to reflect the Department of Commerce's
language changes.  However, we did not delete the "January 1997" date
because we wanted to clearly demonstrate the time frame involved with
the activity. 

2.  We revised the report to reflect the language requested by the
Department. 




(See figure in printed edition.)Appendix IV
COMMENTS FROM THE CENTERS FOR
DISEASE CONTROL AND PREVENTION
========================================================== Appendix II


The following are GAO's comments on CDC's letter dated June 25, 1998. 

GAO'S COMMENTS

1.  We revised the report to reflect the language requested by CDC. 




(See figure in printed edition.)Appendix V
COMMENTS FROM THE ENVIRONMENTAL
PROTECTION AGENCY
========================================================== Appendix II



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on EPA's letter dated July 6, 1998. 

GAO'S COMMENTS

1.  The report now reflects the $230,000 that EPA expects to spend on
the effort for fiscal year 1998.  In addition, the $1 million
estimate for fiscal year 1999, which EPA's budget officials had
previously provided us with, has been revised to reflect EPA's
current estimate of $400,000. 

2.  This section of the report was deleted.  Originally, this section
discussed a specific example of how the food safety initiative did
not address underlying problems associated with the fragmentation of
food safety responsibilities.  In particular, the example noted
efficiencies that could be gained by combining FDA's and USDA's
pesticide-residue-monitoring programs for fruits and vegetables. 
This action would have been consistent with FDA's and USDA's plans
under the 1999 food safety initiative to combine their systems for
monitoring the microbial contamination of fruits and vegetables. 
However, FDA's letter expressed concerns about whether the proposed
combined microbial- contamination-monitoring program would satisfy
its monitoring needs and has similar concerns about combined
pesticide residue monitoring.  (See app.  VI.) In view of these
concerns, as well as similar concerns expressed in EPA's letter, we
eliminated the discussion of this particular example.  However, we
did not change the report's overall observation concerning the food
safety initiative's failure to address fundamental fragmentation
problems. 

3.  We revised the draft report to reflect EPA's most recent funding
and staffing estimates. 




(See figure in printed edition.)Appendix VI
COMMENTS FROM THE FOOD AND DRUG
ADMINISTRATION
========================================================== Appendix II



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on FDA's letter dated July 7, 1998. 

GAO'S COMMENTS

1.  This section of the report was deleted.  Originally, this section
discussed a specific example of how the food safety initiative did
not address underlying problems associated with the fragmentation of
food safety responsibilities.  In particular, the example noted
efficiencies that could be gained by combining FDA's and USDA's
pesticide-residue-monitoring programs for fruits and vegetables. 
This action would have been consistent with FDA's and USDA's plans
under the 1999 food safety initiative to combine their systems for
monitoring the microbial contamination of fruits and vegetables. 
However, FDA's letter expressed concerns about whether the proposed
combined microbial contamination monitoring program would satisfy its
monitoring needs and has similar concerns about combined pesticide
residue monitoring.  In view of these concerns, as well as similar
concerns expressed in EPA's letter (see app.  V), we eliminated the
discussion of this particular example.  However, we did not change
the report's overall observation concerning the food safety
initiative's failure to address fundamental fragmentation problems. 




(See figure in printed edition.)Appendix VII
COMMENTS FROM THE U.S.  DEPARTMENT
OF AGRICULTURE
========================================================== Appendix II



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on USDA's letter dated July 7, 1998. 

GAO'S COMMENTS

1.  We do not believe that we have seriously mischaracterized
descriptions of the Food Safety and Inspection Service's programs and
activities.  USDA's specific comments in this regard and our
responses are addressed below.  (See comments 2, 3, 4, and 5.)

2.  We revised the language to more clearly explain that the law
requires carcass-by-carcass inspections but does not specify who
should conduct the inspections nor how the inspection should be
performed.  However, USDA has historically fulfilled this mandate
through organoleptic inspections, which are accurately described in
this report.  Our point remains that the inspections are not risk
based and, therefore, resources used for them could be used more
effectively in other areas of the federal food safety system. 

3.  We agree that organoleptic inspections do not solely ensure
product quality.  In fact, in the draft report, we noted that these
inspections provide some measure of safety.  However, we continue to
believe that they primarily are meant to ensure product quality
rather than detect the most serious food safety risk--microbial
contamination.  Furthermore, experts have increasingly questioned the
public health benefits of these inspections.  For example, an October
1993 conference of the World Congress on Meat and Poultry Inspection,
an international association of government regulators from
meat-trading countries, concluded that post-mortem carcass-by-carcass
organoleptic inspection must be changed because (1) it wastes
resources and cannot detect microbial pathogens, (2) the animal
diseases for which it was originally designed have been eradicated in
many countries, and (3) it results in unnecessary cross-contamination
because the hands-on inspection techniques used virtually ensure that
contamination spreads from one carcass to another. 

4.  We recognize that a statute mandating the frequency of processing
plant inspections does not exist and have clarified the report
language accordingly.  However, the fact remains that FSIS continues
to conduct these inspections on a daily basis.  The frequency of
these inspections is not risk based and therefore, in our view, may
not be an efficient use of federal food safety resources. 

5.  Our use of the word simple was to illustrate the range of
processing operations from simple cutting and packing operations
through grinding to more complex operations, such as canning and the
preparation of ready-to-eat products.  We were not describing risks
associated with any particular aspect of meat-processing operations. 
We revised the language of the report to avoid any misinterpretation. 

6.  The report does not assert that resources should be transferred
from FSIS.  Instead, the report identifies examples of food safety
resources that could be used more effectively if they were redirected
to other food safety activities.  As we point out in the report,
these activities may be within or outside of FSIS' area of
responsibility.  Furthermore, as USDA correctly points out, we did
not conduct comparative risk assessments for prioritizing which other
food safety activities could be carried out if the resources were
redirected.  Instead, we present a list of possible activities where
food safety resources could be more effectively used, recognizing
that food safety officials may have other priorities. 

7.  The report does not claim that funds appropriated to FSIS could
be more effectively used if redirected from the agency.  (See comment
6.)

8.  While APHIS, AMS, and GIPSA have no regulatory responsibilities
for food safety, they do perform food safety activities and provide
the food safety regulatory agencies with information.  For example,
AMS conducts sanitation inspections when doing grading activities. 
When AMS identifies problems, it notifies the appropriate food safety
regulatory agencies. 

9.  We included this more detailed description of GIPSA's food safety
activities in appendix I. 


MAJOR CONTRIBUTORS TO THIS REPORT
======================================================== Appendix VIII

Keith Oleson, Assistant Director
John M.  Nicholson, Jr., Project Leader
Patricia A.  Yorkman
Nancy Bowser
Carol Herrnstadt Shulman

RELATED GAO PRODUCTS

GAO REPORTS

Food Safety:  Federal Efforts to Ensure the Safety of Imported Foods
Are Inconsistent and Unreliable (GAO/RCED-98-103, Apr.  30, 1998). 

Food Safety:  Fundamental Changes Needed to Improve Food Safety
(GAO/RCED-97-249R, Sept.  9, 1997). 

Food-Related Services:  Opportunities Exist to Recover Costs by
Charging Beneficiaries (GAO/RCED-97-57, Mar.  20, 1997). 

Food Safety:  Information on Foodborne Illnesses (GAO/RCED-96-96, May
8, 1996). 

Food Safety:  New Initiatives Would Fundamentally Alter the Existing
System (GAO/RCED-96-81, Mar.  27, 1996). 

Meat and Poultry Inspection:  Impact of USDA's Food Safety Proposal
on State Agencies and Small Plants (GAO/RCED-95-228, June 30, 1995). 

Food Safety:  Risk-Based Inspections and Microbial Monitoring Needed
for Meat and Poultry (GAO/RCED-94-110, May 19, 1994). 

Food Safety and Quality:  Uniform, Risk-Based Inspection System
Needed to Ensure Safe Food Supply (GAO/RCED-92-152, June 26, 1992). 

Food Safety and Quality:  Who Does What in the Federal Government
(GAO/RCED-91-19B, Dec.  21, 1990). 

Food Safety and Quality:  Who Does What in the Federal Government
(GAO/RCED-91-19A, Dec.  21, 1990). 

GAO TESTIMONIES

Food Safety:  Reducing the Threat of Foodborne Illnesses
(GAO/T-RCED-96-185, May 23, 1996). 

Food Safety:  A Unified, Risk-Based Food Safety System Needed
(GAO/T-RCED-94-223, May 25, 1994). 

Food Safety:  A Unified, Risk-Based System Needed to Enhance Food
Safety (GAO/T-RCED-94-71, Nov.  4, 1993). 

*** End of document. ***