to the overall mission of the department. For example, within HHS, food inspection functions would be closer to the surveillance functions carried out by the CDC.

  1. The Committee recognizes the strengths of the FSIS program and the scientific expertise it provides (currently, FDA relies on USDA for much of the science base of food safety regulation). A thoughtful and careful transfer of FSIS functions to HHS and its multiple science-based resources could enhance the capability to more effectively coordinate the use of science to enhance food safety.

  2. HHS has full regulatory authority over drugs, and the distinction between foods and drugs is diminishing. We have the advent of “nutriceuticals” and greater acceptance of “health foods” and supplements, and foods are increasingly exposed to antibiotics, irradiation, pesticides, and other chemical interventions, as well as genetic modification.

  3. Recognizing the need to strengthen its food safety regulatory operations, FDA recently developed a Food Protection Plan, an integrated strategy to protect the food supply through prevention, intervention, and response (FDA, 2007b).

The IOM committee understands that transferring FSIS functions to the department is likely to be difficult and that similar proposals in the past have been met with resistance:

  • It would be a large move, in both budgetary and personnel terms.

  • Major revisions to authorizing legislation for FSIS would be needed.

  • It would weaken the voice of public health within USDA—obviating the need for the position of USDA undersecretary for food safety, who is currently required by law to have food safety or public health credentials.

  • Without additional action, it would sever the food regulatory responsibility from its research base.

For the unification to be effective, it therefore would have to include 5provisions for (1) ongoing collaboration or relocation of USDA food safety research programs to HHS, and (2) maintaining relationships with USDA programs that work to prevent food contaminations on farms.

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