Food Safety: Fundamental Changes Needed to Improve the Nation's Food
Safety System (Stmnt. for the Rec., 10/08/97, GAO/T-RCED-98-24).

Pursuant to a congressional request, GAO discussed the fundamental
weaknesses that need correcting in order to achieve a fully effective
food safety system, and the Department of Agriculture's (USDA)
associated regulatory authority.

GAO noted: (1) the existing federal system to ensure a safe food supply
is fragmented, characterized by a maze of often inconsistent legal and
regulatory requirements implemented by 12 different federal agencies;
(2) of the 12 agencies, 6 have major roles in carrying out food safety
and quality activities; (3) this structure necessitates extensive
coordination to minimize duplication of effort, prevent gaps in
regulatory coverage, and avoid conflicting actions; (4) coordination has
sometimes broken down, allowing unsanitary and other unsafe conditions
to persist in some food processing plants; (5) inconsistencies and
illogical differences between the agencies' approaches and enforcement
authorities undercut the system's effectiveness; (6) how frequently a
food processing plant is inspected and what actions are taken to enforce
food safety standards are determined not by a unified, comprehensive
assessment of the risk that specific food products pose to public
health, but rather by the legislation that governs the responsible
agency; (7) past efforts to correct deficiencies in the federal food
safety inspection system have fallen short, in part, because they did
not address the fundamental problems in the system; (8) agencies
continue to operate under different regulatory approaches, have widely
disparate budgets and staffs, lack the flexibility needed to respond to
changing consumption patterns and emerging food safety issues, and are
hampered by laws designed to address the food safety concerns that
existed at the turn of the century, not those that the United States
faces today; (9) a new structure for food safety inspection and
enforcement, based on uniform enforcement authorities and an assessment
of the risk that food products pose, is needed; (10) federal regulations
issued in July 1996 require meat and poultry plants to use a scientific
system called Hazard Analysis and Critical Control Point (HACCP) to
ensure the safety of their products; (11) the system will be phased in
over an 18- to 42-month period, depending on the plant's size; (12) the
new regulations also require that meat and poultry slaughterhouses
conduct microbial tests for E.coli (a general indicator of sanitary
conditions) but do not require meat and poultry processing plants to
conduct similar testing; and (13) requiring HACCP and microbial testing
is important in moving towards a more scientific approach, but it does
not address the fundamental problem of multiple jurisdictions nor the
inefficiencies caused by mandating the frequency of inspections for some
products and requiring little or no inspection or testing of other
products.

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

 REPORTNUM:  T-RCED-98-24
     TITLE:  Food Safety: Fundamental Changes Needed to Improve the 
             Nation's Food Safety System
      DATE:  10/08/97
   SUBJECT:  Food inspection
             Food and drug legislation
             Product safety
             Contaminated foods
             Safety regulation
             Interagency relations
             Consumer protection
             Safety standards
             Health hazards
             Regulatory agencies
IDENTIFIER:  FSIS Hazard Analysis and Critical Control Point System
             
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Cover
================================================================ COVER


Before the Committee on Agriculture,
Nutrition, and Forestry,
U.S.  Senate

For Release on Delivery
Expected at
9:00 a.m.  EDT
Wednesday
October 8, 1997

FOOD SAFETY - FUNDAMENTAL CHANGES
NEEDED TO IMPROVE THE NATION'S
FOOD SAFETY SYSTEM

Statement for the Record by
Robert A.  Robinson, Director,
Food and Agriculture Issues,
Resources, Community, and Economic
Development Division

GAO/T-RCED-98-24

GAO/RCED-98-24T


(150648)


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

  USDA -
  HACCP -

============================================================ Chapter 0

Mr.  Chairman and Members of the Committee: 

Thank you for the opportunity to contribute this statement to your
hearing on the federal food safety system and the Department of
Agriculture's (USDA) associated regulatory authority.  As the
Committee considers options relative to USDA's authority to recall
contaminated food, we would like to draw your attention to the
fundamental weaknesses that, in our view, need correcting in order to
achieve a fully effective food safety system:  namely, regulatory
fragmentation and inconsistency.  We believe the existing federal
food safety structure needs to be replaced with a uniform, risk-based
inspection system under a single food safety agency.  While some
administrative actions can be taken to improve the system, the
fundamental changes that are needed will require legislative action. 

Recent outbreaks of foodborne illness have once again raised
questions about the safety of the U.S.  food supply.  In August of
this year, a number of illnesses caused by hamburger contaminated
with E.coli 0157:H7 resulted in the recall of 25 million pounds of
ground beef patties and the closing of a major meat processing plant. 
In 1996, and again in 1997, outbreaks of foodborne illness were
traced to raspberries imported from Guatemala that were contaminated
with cyclospora, a parasite.  Moreover, in April of this year, a
hepatitis A outbreak was traced to contaminated strawberries that
were served as part of the federal school lunch program.  The recent
outbreaks are not a new phenomenon, simply well-publicized examples
of a much more widespread and ongoing problem.  In May 1996, we
reported that between 6.5 million and 81 million cases of foodborne
illness and as many as 9,100 related deaths occur each year. 
(GAO/RCED-96-96.)

In this context, we want to bring to your attention the findings and
recommendations expressed in a number of GAO reports on the food
safety issue.  Our work has pointed time and again to the need to
address this issue at a fundamental level.  The natural inclination
to react to each event with a patch here and a band-aid there has not
proven to be an effective long-term solution.  As summarized below
and discussed more fully in the reports listed in the Related GAO
Products section, our work demonstrates that more basic actions are
needed. 

The existing federal system to ensure a safe food supply is
fragmented, characterized by a maze of often inconsistent legal and
regulatory requirements implemented by 12 different federal agencies. 
Of the 12 agencies, 6 have major roles in carrying out food safety
and quality activities.  This structure necessitates extensive
coordination to minimize duplication of effort, prevent gaps in
regulatory coverage, and avoid conflicting actions.  However, as
might be expected, coordination has sometimes broken down, allowing
unsanitary and other unsafe conditions to persist in some food
processing plants.  (GAO/RCED-91-19A, GAO/RCED-91-19B, and
GAO/RCED-92-152.)

Our work has also shown that inconsistencies and illogical
differences between the agencies' approaches and enforcement
authorities undercut the system's effectiveness.  How frequently a
food processing plant is inspected and what actions are taken to
enforce food safety standards are determined not by a unified,
comprehensive assessment of the risk that specific food products pose
to public health, but rather by the legislation that governs the
responsible agency.  For example, under current federal law, federal
inspectors must examine each meat and poultry carcass
slaughtered--about 7 billion annually--and visit each of the
approximately 5,900 meat and poultry processing plants at least once
during each operating shift.  For most other foods, however, the
frequency of inspections is not mandated; thus, the inspection rate
for foods other than meat and poultry has slipped from an average of
once every 3 to 5 years in 1992 to once every 8 years in 1994, to
once every 10 years, according to current estimates. 
(GAO/RCED-94-110.)

Past efforts to correct deficiencies in the federal food safety
inspection system have fallen short, in part, because they did not
address the fundamental problems in the system.  Agencies continue to
operate under different regulatory approaches, have widely disparate
budgets and staffs, lack the flexibility needed to respond to
changing consumption patterns and emerging food safety issues, and
are hampered by laws designed to address the food safety concerns
that existed at the turn of the century, not those that our nation
faces today.  As we have previously reported, a new structure for
food safety inspection and enforcement, based on uniform enforcement
authorities and an assessment of the risk that food products pose, is
needed.  (GAO/RCED-92-152, GAO/RCED-94-192, and GAO/T-RCED-94-223.)

Federal regulations issued in July 1996 require meat and poultry
plants to use a scientific system called Hazard Analysis and Critical
Control Point (HACCP) to ensure the safety of their products.  The
system will be phased in over an 18- to 42-month period, depending on
the plant's size.  The new regulations also require that meat and
poultry slaughterhouses conduct microbial tests for E.coli (a general
indicator of sanitary conditions) but do not require meat and poultry
processing plants to conduct similar testing.  Requiring HACCP and
microbial testing is, without question, important in moving towards a
more scientific approach, but it does not address the fundamental
problem of multiple jurisdictions nor the inefficiencies caused by
mandating the frequency of inspections for some products and
requiring little or no inspection or testing of other products.  No
system will be foolproof but a scientific, risk-based approach would
allow for more effective use of resources and ensure a safer food
supply. 

While our statement today is based on previous work, GAO is
continuing to analyze issues affecting the food safety system.  In
particular, we currently are conducting a study of imported food
safety for the Senate Committee on Governmental Affairs, Permanent
Subcommittee on Investigations.  Likewise, we would be happy to work
with the Senate Agriculture Committee as it continues its efforts to
maximize the effectiveness of the nation's food safety system in
protecting the public's health. 

Again, thank you for the opportunity to submit this statement for the
record. 

RELATED GAO PRODUCTS

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

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

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

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

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

Food Safety:  Changes Needed to Minimize Unsafe Chemicals in Food
(GAO/RCED-94-192, Sept.  26, 1994). 

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


*** End of document. ***