A FORTIFIED STRUCTURE OF FOOD SAFETY REGULATION

There are many opportunities for reorganization within HHS—and indeed across federal departments—that would bring more coherence, reduce overlaps and redundancy, and create more efficiency. Changes of this sort can be extremely difficult, time consuming, and highly controversial. They involve obtaining new authorizing legislation, the reassignment of large budgets and significant numbers of people, the opposition of powerful special interest groups, both expected and unexpected disruptions in work, and other implementation difficulties. Creation of the new Department of Homeland Security was a case in point: Only at a time when Congress and the nation felt a sense of severe crisis could such a massive reorganization have occurred so swiftly, but even with that utmost sense of urgency, the transition was far from smooth.

For these reasons, the IOM committee so far has avoided suggesting the reorganization of agencies within HHS or across departments. However, the seriousness of the food safety issue prompted the committee to use it as an example of a public health issue that HHS cannot address adequately within its current structure, which is the reason some reorganization would be both logical and advantageous, despite the difficulties. Proposed consolidation of the food safety activities of FDA and the USDA’s Food Safety and Inspection Service (FSIS) is not merely illustrative, however, since its potential to benefit the health of the American public is so great that it is included among the committee’s recommendations.7

Nowhere is the weakness of HHS’s science base more apparent or potentially harmful than in FDA’s food safety regulatory activities. A candid report recently prepared for the FDA Science Board found (FDA Subcommittee on Science and Technology, 2007):

The nation’s food supply is at risk. Crisis management in FDA’s two food safety centers, Center for Food Safety and Applied Nutrition and Center for Veterinary Medi-

7

Food safety issues have garnered a great deal of attention in Congress. A search for bills in the 110th Congress related to “food safety” returns over 100, with some calling for improved coordination and unification of the food safety inspection activities (e.g., H.R. 2297 and H.R. 7143), which the Senate Committee on Governmental Affairs concluded was necessary over 30 years ago when it called for a single food safety agency (Senate Committee on Governmental Affairs, 1977).



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