Assuring a Healthy Food Supply: A Case for Fundamental Reform of Regulatory Programs

Abstract

Recent months have brought a steady procession of well publicized food scares-some more perceived than real—that have alarmed consumers and drawn attention to the surveillance and inspection activities of various regulatory programs. Investigations by Congressional committees, the General Accounting Office and others have revealed significant shortcomings in program design and execution. Many problems are deeply rooted in a history of food regulation too often characterized by hasty, piecemeal solutions to health threats that have arisen in one food sector or another. Less attention has been paid to examining potential hazards in the food supply as a whole and directing limited federal resources toward areas where risks to health are greatest.

The result is a system replete with inconsistencies, conflicts and gaps. Nor have regulatory programs kept pace with science. In some instances, regulators continue to use analytical tools that are decades out of date. State governments increasingly are moving into what they perceive as a regulatory vacuum with the best of intentions but the very real prospect of adding to regulatory conflicts and contradictions, without any corresponding benefit to public health.

There is a pressing need to harmonize and modernizing the food regulatory system as a whole. A growing number of policymakers, consumer groups and industry leaders believe that this can be accomplished through the implementation of a science-based set of regulatory principles known as Hazard Analysis, Critical Control Points (HACCP). These principles, applicable to every link in the food production, processing and distribution chain, focus on the process rather than the product, and seek to control potential hazards at critical points on the farm, in the plant, in the market and elsewhere. However, the introduction of science based systems of food safety assurance will pose numerous challenges to the federal, state and local agencies charged with food regulation. Moreover, since HACCP transfers much of the burden of safety assurance onto the industry itself, its success ultimately depends on the good faith commitment of the food industry.

The lively dialogue now taking place in the food regulatory arena has widespread implications for other sectors of the economy where government safety assurance activities may also require harmonization and modernization.