tion to be adopted by state legislatures. FDA also works with groups such as the Association of Food and Drug Officials of the United States and the Association of Official Analytical Chemists.¹⁷ FDA, in conjunction with the states, regulates animal feed ingredients and feeds as part of the American Association of Feed Control Officials.¹⁸

Critics charge that part of the "food safety problem" is that U.S. food safety laws and regulations are fragmentary and inconsistent and are not comprehensive. Critics also claim that too many agencies are responsible for food safety activities. Foods posing similar health risks may be inspected by different agencies at different frequencies. The roles that these agencies play depend for the most part on their statutory authority and their resources. One former official who served in both USDA and FDA said that the fragmentation and diversity of the agencies' authority undercuts the government's accountability for food safety, and he added:

Other examples abound. USDA daily inspects meat and poultry for contamination of various pathogens, including Listeria monocytogenes and E. coli 01 57:H7. At the same time, FDA may inspect once every ten years soft cheeses or apple juice in which those same pathogens have been found. Some believe that it is inappropriate for separate agencies using different risk and inspection criteria to regulate the nation's food supply. These critics also think that the same or similar risk criteria should be used by all federal agencies to prevent microbial contamination on all foods.²⁰

Others charge that safety cannot be properly regulated when food safety responsibility is placed in the hands of the same agency in charge also of promoting

Front Matter (R1-R14)

Executive Summary (1-16)

1. Introduction and Background (17-24)

2. The Current US Food Safety System (25-50)

3. The Changing Nature of Food Hazards: Cause for Increasing Concern (51-62)

4. What Constitutes an Effective Food Safety System? (63-78)

5. Where Current US Food Safety Activities Fall Short (79-90)

6. Conclusions and Recommendations (91-100)

References (101-104)

Appendix A Glossary and Organizational Framework for the Current Food Safety System (105-114)

Appendix B CRS Report for Congress, Food Safety: Recommendations for Changes in the Organization of Federal Food Safety Responsibilities, 1949-1997 (115-160)

Appendix C Executive Summary: Food Safety from Farm to Table: A National Food-Safety Initiative (161-168)

Appendix D Summary of Comments and Testimony from Workshop (April 29-30,1998) and Agenda (169-180)

Appendix E Federal Food Safety Budget Information (181-184)

Appendix F Acknowledgments (185-188)

Appendix G Committee Biographical Sketches (189-194)