4
What Constitutes an Effective Food Safety System?

Earlier chapters have addressed the definition, historical significance, and current status of food safety in the United States as well as recent trends in and reasons for concern about foodborne hazards. This chapter turns to the features of an ideal food safety system and to a somewhat detailed description of its attributes. Constructing a model system establishes a benchmark that provides both a point of reference for judging actual systems and a goal to be achieved.

The Mission of the System

There is universal agreement on the need for safe food, but no consensus on the means by which safe food is secured. The effectiveness of a food safety system begins with a clear, unified mission that focuses and integrates the varied needs and responsibilities of all stakeholders, gives the stakeholders a basis for achieving the goals of the system, and is broadly accepted.

The committee defines safe food as food that is wholesome, that does not exceed an acceptable level of risk associated with pathogenic organisms or chemical and physical hazards, and whose supply is the result of the combined activities of Congress, regulatory agencies, multiple industries, universities, private organizations, and consumers. The mission of a food safety system should be stated as an operational charge that uses and reflects that definition. The committee defines the mission as follows:



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4 What Constitutes an Effective Food Safety System? Earlier chapters have addressed the definition, historical significance, and current status of food safety in the United States as well as recent trends in and reasons for concern about foodborne hazards. This chapter turns to the features of an ideal food safety system and to a somewhat detailed description of its attributes. Constructing a model system establishes a benchmark that provides both a point of reference for judging actual systems and a goal to be achieved. The Mission of the System There is universal agreement on the need for safe food, but no consensus on the means by which safe food is secured. The effectiveness of a food safety system begins with a clear, unified mission that focuses and integrates the varied needs and responsibilities of all stakeholders, gives the stakeholders a basis for achieving the goals of the system, and is broadly accepted. The committee defines safe food as food that is wholesome, that does not exceed an acceptable level of risk associated with pathogenic organisms or chemical and physical hazards, and whose supply is the result of the combined activities of Congress, regulatory agencies, multiple industries, universities, private organizations, and consumers. The mission of a food safety system should be stated as an operational charge that uses and reflects that definition. The committee defines the mission as follows:

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The mission of an effective food safety system is to protect and improve the public health by ensuring that foods meet science-based safety standards through the integrated activities of the public and private sectors. The remainder of this chapter focuses on these matters. Activities that are implied in the definition and are incorporated in achieving the mission to ensure safe food include: adequate monitoring and surveillance; science-based research and development; incorporation of the tenets of risk analysis, including risk assessment, risk management, and risk communication; good practices in food production, processing, manufacturing, retail sale, transportation, preparation, and handling; and appropriate technical assistance and education. Box 4-1 provides a definition of science-based and related examples. BOX 4-1. What is the Meaning of Science-Based? A science base for ensuring safe food encompasses many elements. When utilized, these elements improve the ability to identify, reduce, and manage risks; minimize occurrence of foodborne hazards; gather and utilize information; enhance knowledge; and improve overall food safety. Several examples of science-based actions that have been implemented in the US food safety system that are readily recognized as positive elements of the system include: ·   Implementation of low-acid canned food processing technology, which reduces the risk of botulism; ·   implementation of HACCP systems and risk assessment in decision-making; ·   approval of irradiation technology for use in spices, pork, beef, poultry, fruits and vegetables; ·   prohibition of the use of lead-based paints on utensils that come in contact with food; ·   estimation of maximum allowable exposure levels to pesticides; ·   development of standards for allowable practices associated with transport of foods following transport of pesticides in the same containers; ·   use of labeling as a device to warn consumers who are sensitive to potential food allergens of the content of the allergen; and ·   requirements that meat and poultry products at the retail level carry consumer information related to safe food handling practices. While the approaches above are important successful science-based tools in food production and processing, these are only examples of implementation of the scientific basis for food safety. An effective food safety system also integrates science and risk analysis at all levels of the system, including food safety research, information and technology transfer, and consumer education.

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Ensuring a system to provide safe food within the United States is a common goal, and legislative mandates should direct the components of that system. The mission should be focused on using public health resources and management to perform risk analysis and research and at the same time on optimizing coordination and planning of prevention, intervention, control, response, and communication mechanisms. General Attributes of the System An effective food safety system is an interdependent system composed of government agencies at all levels, businesses and other private organizations, consumers, and supporting players. The system is dynamic and aligned to the unified mission of improving food safety so as to maintain and improve the public's health and well-being. Figure 4-1 depicts the interrelationships of an effective food safety system. Although the players have key, independent functions, they must implement many of their actions through strong partnerships. The system is built on the flexibility and adaptability of the players and on the nature and course of their FIGURE 4-1. Attributes of an Effective Food Safety System: A Dynamic Interdependence. Partners in the system include government, private industry, and consumers. Supportive players, who are critical to the integration of the attributes of research, education, and information, include universities and colleges, the news media, and focused special interest organizations, among others.

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relationships, and these affect their ability to prevent, identify, and resolve food safety issues in the most efficient, effective, and cost-beneficial manner. The system is responsive to the expedient issues of today but also evolves strategically to meet future challenges. It must be effective in both the domestic environment and the new global food environment, with increasing international trade. The system is science-based with strong emphasis on risk analysis and the use of data. It is attentive to learning through the use of feedback loops and continuous improvement. Although responsiveness to and coordination of food safety crises are critical attributes, the system is designed to stress prevention and detection of emerging problems. The system has adequate funding, is supported by strong research and education components, uses technology adequate to the task, and is integrated to achieve its mission. Statutory and regulatory authority promote the system's horizontal and vertical integration. Because integration is such a critical attribute, the system requires strong, centralized leadership. The system champions a culture of capacity building. With the transition toward a new scientific and risk-based foundation, agencies will encourage and fund retraining and further development of their employees, and they will initiate plans for the recruitment and retention of high-quality staff with the skills and knowledge to enhance the new system and its changing operations and focus. Capacity must also include consumer knowledge and practices, taking into account cultural sensitivities and practices. An effective system is commensurate with today's driving forces, trends, and societal expectations. Partnerships will expand with the growing recognition that government cannot abandon our food safety problems to private industry and consumers. The effective system stresses the inclusion of its players in their roles but also acknowledges the need for effective regulation, compliance, and enforcement. Although some of the roles will need to change, the system functions in an environment of trust and respect. The globalization of the food system and other factors that can increase the risk of foodborne incidents mandate urgency in adopting the system. The effective food safety system is focused on public health, and its many actions are aligned to achieve a safer food supply, improve public health, and instill consumers' confidence in both the system and their role in improving it. Finally, the dynamic interconnectiveness also promotes the attainment by all of the players of both responsibility and accountability for making the food safety system perform optimally. The following sections describe in more detail the attributes of an effective food safety system.

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The Importance of Partnering Food safety is the responsibility of numerous and diverse stakeholders, and partnerships provide the links that are necessary to build a coordinated and cohesive framework for action. Partnerships can improve efficiency and provide a mechanism for information and technology transfer. Interaction and communication through partnerships lead to cooperation and collaboration among public and private interests. Partnerships can also help to integrate regulated activities with important non-regulatory components of the system. Incentives can greatly influence and facilitate the building of effective partnerships. ''Positive" incentives are often financial. "Negative" incentives can include the desire to avoid legal or regulatory action or media attention. Another incentive for partnerships can be the generation of new and useful information that improves production and processing capabilities simultaneously with improved control of risk. The market is an important incentive for private industry. As global markets and domestic consumers expect safer food, safety itself can become a factor in differentiating products. Retailers can help to leverage this concept as brand names become associated with reduced risks. Some factors, such as intellectual property issues, pose challenges to the establishment and maintenance of partnerships. These issues might become increasingly difficult in the future, as such sciences as the microbiology of food continue to advance rapidly. Despite the challenges posed by the diversity of the players and changing priorities within the system, the potential realm of strong partnerships is large and includes all partners: government, the private sector, consumers, and support players, as shown in Figure 4-1. Partnerships should be formed and function in an open process that is independent and protected from political, economic, and social pressures. Partners must have clear delineations of responsibility and the authority to make decisions to meet responsibilities. They must have the resources to work together effectively. Successful partnerships are based on close, detailed, and accurate communication and collaboration. The Roles of Government Partners In the public sector, the federal government is in the best position to influence how the other components of the food safety system work together. Its actions, which often take the form of regulation, originate in federal food law. The federal government must guide the system with national food law that is clear, rational, and based on scientifically determined risk. A few principles form the basis for ideal food law, which can be conceptualized by the philosophical structure of food safety. This structure includes a process that is fair and open to participation by all without political, economic, or social pressures and that provides for adequate authority and budgetary considerations.

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Legislation must be flexible and enforceable, and it must comprehensively address all aspects of the entire system from production to consumption. The authority and responsibility of the federal government and its interface with private and other partners must be well-articulated. Definition of a broad federal role is promoted by the similarities of food safety issues across states and demographic groups. Other levels of government have a role in shaping federal activities if they are to be effective in implementing national standards and in dealing separately with local issues. With a sound food law in place, partnerships between the federal government and others in the system can establish a framework to provide several important functions. For instance, partnerships of federal, state, and local governments with industry, universities, private organizations, and consumers can ensure that the system is science-based and risk-focused, that surveillance and monitoring efforts provide sufficient information to maintain and improve effectiveness, that research and education efforts are properly focused, that regulation and enforcement are effective and consistent, that the system is responsive to new technologies and changing consumer needs, that a continuous process of evaluation can respond to the queries and problems of all stakeholders, and that resources are adequate and appropriately allocated throughout the system. A Science-Based Foundation Using Risk Analysis The scientific foundation for decision-making within a food safety system is risk analysis. The role of risk analysis in an effective food safety system is threefold: it provides a basis for identifying where resources should be allocated in the short term; it constitutes a mechanism for determining where public and private efforts should be directed in the long term, especially with respect to research and preventive measures; and it yields important information for estimating and analyzing the costs and benefits of policy alternatives. The components of risk analysis-risk assessment, risk management, and risk communication-use interdependent approaches, methods, and models; none can function well in the absence of the others. Good risk communication is required for effective risk assessment and risk management. All components of risk analysis-scientific, economic, legal, behavioral, or other-require an environment that is independent of the derivation of policy and must be subject to agency leadership. Focused risk assessment identifies risks that have the most important consequences for human health and (not always the same) shows where the most progress can be made with available resources. Scientific risk assessment should identify the risks associated with one or more possible actions, or risks associated with taking no action. Risk assessment is fairly well-developed for chemical hazards, such as pesticides, but not for foodborne pathogens.

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Development of risk assessment for the complexity of such pathogens must be given high priority. A pivotal component of risk analysis is risk assessment. Scientific risk assessment is the process of determining the relation between exposure to a hazard at a specific magnitude and the likelihood of an adverse event or disease (IOM, 1997). The science should characterize the nature and magnitude of risks to human health associated with food related hazards. On the basis of the scientific assessment, regulators can make informed decisions about where and how to allocate resources to prevent and control hazards. The same scientific technique can sometimes be used for a range of problems throughout the entire system. Uniformity in the process of risk measurement can reduce uncertainty about how specific foods or processes will be addressed, and thus benefit non-regulatory components of the system as well. Adequate Surveillance and Monitoring Strong surveillance and technical support provide an infrastructure to set priorities for research, education, and response. Food safety, perhaps more than any other health-related activity of government, demands a continuing and dynamic "moving picture" of the system, rather than periodic "snapshots." For successful leadership, the federal system requires the ability to identify and set priorities among potential food safety hazards and emerging issues. Surveillance and monitoring, education and research, and enforcement and regulation are all used to identify, set priorities among, and address concerns. Surveillance is the first step toward building the capacity to detect and respond to sporadic instances and outbreaks of foodborne illness. Surveillance and monitoring are also essential for evaluating the system, identifying emerging issues and new trends, and assessing risk from the farm or sea to the table. Monitoring foodborne disease and related hazards can allow early and rapid detection of hazards and illnesses. Thorough investigation of outbreaks to determine their sources and causes can identify crucial weaknesses in the system. Focused Education and Research Part of the role of the federal government in ensuring safe food is to promote education and research. Continuous, high-quality research is needed to keep capabilities of regulators up-to-date and to ensure rational and maximally effective evaluation and decision-making as well as optimal preventive measures. Effective education, the strongest and most important form of information transfer, requires partnerships at the federal, state, regional, and local levels. The federal government should lead efforts to educate and inform the general public on such issues as labeling (including health and nutrition information), standards

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and specifications, changing technologies, and advertising. All stakeholders in the food system should be fully informed of risks and of food-handling practices that reduce those risks. Both the responsibilities and the needs for setting education and outreach priorities are shared among many stakeholders. Integration and collaboration can help to focus efforts where the needs are greatest. Priorities for education are closely tied to communication capabilities and should be based on need. General academic and land-grant institutions in partnership with private industry and a variety of organizations play critical roles in the transfer of information. Producers, processors, and consumers have needs for both general and specialized education. Carefully planned education programs to communicate fundamental issues are important, with additional opportunities for education in times of crisis. Both should be used during major or highly publicized foodborne illness events. Education about the critical role of consumers in the food safety system might be especially effective. Research priorities should be focused on the prevention of foodborne illness; this requires research on measures of current problems to determine how the problems can best be brought under control. Specifically, research priorities should be related closely to needs as determined by effective surveillance. Some research priorities in an effective food safety system must be responsive to emerging problems, but others must have a long-term perspective, and effective research management requires a capability to shift resources and emphasis. In the past, research priorities have often been based on opportunities or pressing issues of the moment. Typically, research funding has been event-driven, rather than evenly sustained in support of longer-term objectives. The press of current problems is an ever-present threat to the needed long-range research, and an effective food safety system will support and protect both. Research must always be relevant to societal concerns and to the complex problems of ensuring a safe food supply. Research priorities should be established internally and externally in partnership with private industry, academe, consumers, and other stakeholders. The priorities must be widely known and accepted; it can be difficult for any agency to maintain an appropriate long-term balance when the news media, the public, legislators, and others, direct issues to be set aside when a crises of the moment arises. The research budget, especially for long-term projects, should be protected from rapid swings and decreases. Perhaps more than most other activities, the development of effective research teams requires development over time, with significant effort, patience, and resources. A single lean budget can destroy the benefits of effective team-building efforts over a period of many years. Not every research need can be met, but a force of the best scientific research investigators are needed to solve the long-term, difficult, and highly complex issues of food safety. These experts must be dedicated to the mission of protecting public health by ensuring a safe food supply and they must not be

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distracted by needs for research in other fields, such as improved methods of food production or processing, or treatment of food related illnesses. Effective and Consistent Regulation and Enforcement Mechanisms for the prevention of foodborne illness can span the spectrum from voluntary to regulatory and from outright bans to warning labels and education. Regulation is often intended to be a preventive and protective measure. A prerequisite for any regulatory action should be the assurance of adequate, consistent, and effective enforcement. The ability to protect requires the authority and resources to take action. The food safety system must contain adequate provisions for enforcement of regulations and must clearly link responsibilities with accountabilities. Many challenges posed by the current food safety structure, as described in Chapter five of this report, result from an inability to take action, respond to needs, or protect. Consistency is important in all aspects of ensuring safe food. Similar risks require similar planning, actions, and response. For instance, the intensity, nature, and frequency of inspection should be consistent for foods associated with like risks. Response and Adaptation to New Technology and Changing Consumer Needs The food supply and food production, processing, distribution and consumption practices in the United States have changed dramatically during the past 70 years. Further major changes will certainly occur, though it cannot be predicted when or what they will be. The fundamental shifts from a few, largely local items to today's variety, from small neighborhood stores to supermarkets, from familiar individual ingredients to prepared foods, from home to outside preparation or consumption, and from traditional to "ethnic" cuisine were not widely predicted before they were well in progress. As these shifts continue to occur, the technologies associated with production, processing, manufacturing, and delivery of food also continue to change. Hazards associated with food consumption also are continually changing. In recent years, the risks associated with fresh fruits and vegetables have grown because of increased consumption, variety, and importation of produce from developing countries (GAO, 1998). Importation of different types and amounts of foods from outside the United States expands the federal responsibilities and expertise needed in the US food safety system. The system must include primary prevention of new food hazards through research and other activities and be flexible to respond to new and potential hazards. The food revolutions of this century have proceeded irregularly and often simultaneously, but few have been adequately anticipated. It is certain that

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revolution will continue, and an effective food safety system will prepare for the known as well as for future hazards that cannot be clearly seen. The changing attitudes, concerns, desires, needs, and roles of consumers dictate the characteristics of the food supply and its associated risks. The United States has become home to people of many origins and cultures. With those cultures has come the desire for particular foods. A great challenge to a food safety system is to meet the changing demands while securing safety of a rapidly expanding and diversifying food supply. Human and Financial Resources The immense responsibility of an effective food safety system is coupled with the need for adequate human and financial support. If federal and other programs are to prevent, identify, track, control, and respond to food related illness and reduce risks of future outbreaks or hazards, they will require commensurate funding. Insufficient funding and lack of incentives can diminish an ability to inspect and control foodborne illness; curtail needed research; prevent sustainable, aggressive, and innovative education efforts; and create instability in the system. For instance, the role of states as a public partner in the food safety system has traditionally been important. State and local regulators can help to ensure the safety of food in commerce, and they can assume responsibility for monitoring and enforcing safe food-handling practices; but adequate state and federal funding is needed to carry out these tasks. The economic costs and benefits of reducing the risk of foodborne illness are difficult to determine accurately and consistently. Regulations that govern the production, processing, distribution, and marketing of food can create benefits by improving food safety, but they can also increase producers' costs and potentially raise food prices. The economic costs of inaction are difficult to assess because the data typically reflect only reported incidents and deaths; unreported events generally elude economic assessment. Net benefits of increasing food safety can be maximized by equating the marginal benefits of safer food with the marginal costs of achieving food safety goals. Market-oriented approaches to food safety include economic incentives. In addition, personnel must be trained, developed, and kept up-to-date with advances and innovations elsewhere. Scientific and managerial competence must be ensured to build the human capacity necessary to support the system. Provision of adequate funding and staffing are not sufficient; the system must also be efficient and cost-effective. One cost-effective measure is early detection and early warning of outbreaks before they spread. Federal coordination with regard to research and education efforts can ensure rapid and efficient response. Every system should be practical. The mission must be practical, the goals must be attainable, and the work must be feasible. Primary food hazard prevention approaches and research (both long-term and short-term) efforts

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must focus on practical applications. Inspection, surveillance and monitoring, and education programs should be practical in their gathering and conveying of information. The federal government plays a prominent role in ensuring that vital elements are in place and that the unifying mission of food safety is sufficiently addressed. The coordinated application of scientific, technical, and regulatory measures to prevent foodborne illness and promote public health and safety is critical to the federal government's mission, with its core responsibility to ensure an effective food safety system. There are also occasions where regulatory activity can encourage or require the use of new technologies, which causes movement toward higher standards in the system. The Roles of Private Sector Partners Private partners working in an effective food safety system include producers and importers, processors, marketers (retail and wholesale), food services, trade organizations, professional societies, and private organizations. The primary and common roles of the various private-sector partners include bringing food to the tables of consumers and bringing sound scientific information to others in the partnership. Within the food production system, the private sector has the primary responsibility for ensuring food safety. To be most effective in this task, the private sector must maintain close interaction with the public sector, which sets standards and provides oversight, and with the consuming public, which expresses its food needs and choices. Many of the important attributes of an effective food safety system are included in a recent report, Guiding Principles for Optimum Food Safety Oversight and Regulation in the United States, endorsed by 13 professional, scientific societies (IFT, 1998). The roles and contributions of specific private partners are varied and distinctive, and each can make unique contributions to the overall functioning of an effective system. Several examples of successful partnerships that highlight private roles in the framework of an effective food safety system are provided below. Producers Production in some areas may represent the least controlled point in the food supply system. However, there are valuable opportunities for effective partnerships between producers and governments in the food safety system. An example of a combination of regulatory and non-regulatory partnership between producers and federal and state governments is the National Poultry Improvement Plan (NPIP), in which state authorities cooperate with the US

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Department of Agriculture to administer regulations for the improvement of poultry, poultry products, and hatcheries. In this example, industry participants follow both the general provisions of the plan and specific provisions that are related to their industry category hatcheries, dealers, and breeders. Food animal industries use and understand on-farm quality assurance or control programs; these could be expanded to include food safety provisions if they are cost-effective and serve as an incentive to market products. The industries are to follow all sanitary provisions and undergo testing and inspection. The industries pay most costs of the plan and seek to achieve and maintain a free or "clean" status. The plan has been useful, especially in breeding flocks, and has helped to eliminate several poultry diseases and prevent the spread of disease from breeders to commercial flocks. More recently, the NPIP adapted an on-farm sanitation program to prevent and control the serious human pathogen Salmonella enteritidis in hatching eggs and chicks. The NPIP provides a working model that involves federal-state-industry partnership. Industry members use the findings to inform the public that they have met the highest standards and have free, or "clean," status, a designation that adds value to their products and is a "preharvest" animal-production model that might be used in an expanded version for other food animal species. Federal and state agencies benefit from reduced requirements for inspection and oversight of "clean" facilities. Processors, Marketers, and Distributors The dairy processing industry recognized the need for effective control of foodborne pathogens by promoting the enactment of effective controls of milkborne disease, including pasteurization. To assist states and municipalities in their efforts to prevent milkborne disease, the US Public Health Service developed model regulations for voluntary adoption by state and local milk control agencies in 1924. A model milk regulation, the Grade A Pasteurized Milk Ordinance, was developed and implemented through partnerships between the dairy industry and federal, state, and local regulatory agencies. Private industry can contribute to the shaping of the scientific basis of the future food safety system. For example, the Flavor and Extract Manufacturers Association (FEMA) and the Food and Drug Administration (FDA) developed the FEMA Generally Recognized as Safe review program to ensure the safety of food flavors and extracts. In another example of industry-FDA cooperation, the development of low-acid, canned food regulations was a major step toward the safety of canned foods by reducing risks of botulism. Those examples illustrate how a progressive, scientific partnership can contribute to a food safety system. Education and information transfer can also be important contributions of private industry and its associated trade organizations. For instance, the Food Distributors International and its retail partners have engaged in a cooperative

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food safety initiative, implemented through the Food Marketing Institute. This project assists the allied food industries to share information, to keep up to date on regulatory developments and technical resources in food safety, and to develop and maintain procedures for the industry. The egg industry has integrated government efforts, academic research, and other industries to address food safety concerns. The industry has implemented new technologies developed by government and academe to reduce foodborne illness, has developed model partnerships, and has educated and informed consumers about the safety and nutritional composition of egg products. The Role of the Consumer Consumers have a large and critical role in an effective food safety system. First, the food system revolves around the purchasing power and decisions of consumers. Annual expenditures for food are enormous—over $700 billion in the United States (Putnam and Allshouse, 1997). More important, the health, well-being, and longevity of the nation's population ultimately depend on individual consumer decisions. As discussed earlier, it is the role of the private (industrial) sector to deliver to consumers food that is wholesome and safe and food that can be rendered or maintained safe by appropriate handling and preparation by the consumer. After food leaves the production and distribution systems, a different set of risks affects food that is prepared and consumed at home, for which only consumers can be responsible for safety, and food that is prepared by commercial establishments away from home (restaurants, takeout shops, grocery store delicatessens), for which vendors retain major responsibilities for safety, although consumers must still follow good safety practices. As has been noted before, the food system and the food safety system have constantly changed in many ways to meet consumers' perceived needs. This evolution has depended on close interactions between government and the private sector, but the role of government is often unseen except during crisis situations. Continuing activities of the government and the private sector provide the foundation of a safe food supply, but they must also provide the information and education that consumers need if they are to meet their own responsibilities. Although consumers' desires, needs, and cultures have changed, the basic standards of food hygiene in the home have changed very little and probably will not change much in the foreseeable future (See Box 4-2). The food safety system should continue to include fundamental information about frequent and effective washing, prompt refrigeration, and proper cooling. Consumer knowledge on good practices is essential to consumer action, including handling, storage, and preparation of food in ways that improve food safety. Consumers should have reason for confidence that food and food components

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are safe when received, and they should know how to protect their food as it moves through preparation and consumption. The size and importance of the consumer interactions with the food system have contributed to the growth of consumer organizations. These play an important role, particularly in advocacy about food safety matters. In addition, they help greatly by providing education and information. They should be involved in the development of protocols and studies to fill the vital information needs of the food safety system. Their leadership role requires them to ensure that their positions on food safety issues are science-based, and that they fairly represent the concerns of consumers in their advocacy role. BOX 4-2 The Consumer's Role in Food Safety In the early 1900s, pasteurization of milk was becoming common. It was the consumer's responsibility to preserve the quality of milk after it was delivered to the home. The consumer was instructed that "as soon as possible after the milk is set on the doorstep, it should be taken in and put in a cold part of the ice box. If some time must elapse between delivery and care by the consumer, an insulated box should be provided to protect the milk from heat and/or freezing. Milk should be placed only in clean pitchers or receptacles. Milk that has stood at room temperature during a meal should not be poured back into cold, fresh milk, but kept in its own container." Keep clean and cold was the rule that was followed to preserve the quality and flavor of milk. Today, the rule of almost a century ago still applies to consumer responsibility, as is demonstrated by the Fight BAC campaign's educational message. New mechanisms for production, processing, and delivery have evolved, but consumers remain responsible for ensuring that milk and other products are kept clean and cold. (USDA, 1939; Partnership for Food Safety Education, 1997b). The Role of Other Partners Government, the private sector, and consumers are not the only recognized organizations that are vitally involved in the food safety system. Scientists, educators, and food specialists are also key partners who are placed throughout the system and in academic institutions. For example, the Institute of Food Technologists represents food scientists, and the American Veterinary Medical Association represents veterinarians in industry, academe, and government agencies. Both professional organizations have subgroups that interact with the government agencies. The news media cannot be considered an active partner in a food safety system, but are important players. Objective, accurate reporting about food hazards and timely transfer of information to the general public are essential.

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The news media also engage in efforts to educate the public about basic food hygiene. In an effective food safety system these groups are recognized for their distinct and important roles and are encouraged to participate by membership on advisory groups, by providing direct input to the regulatory process, or by other actions. A Dynamic Interdependence Ensuring safe food is an appropriate role for government, but that role is not exclusive, nor is it a contract between government and the American public to guarantee absolute safety. A strong government presence may be necessary for a strong food safety system but is not necessarily sufficient to create a stronger and better food safety system. An effective food safety system is based on a particular set of attributes and relationships and a focus on improving the public's health and well-being, and the roles of federal, state, and local governments must be well defined, coordinated, and consistent in achieving a single mission. The public often turns its attention to what government should do rather than what government can do. But what can government at its various levels actually do to promote food safety, and what conditions must exist to optimize its performance? The answers to those questions are based on defining the functions of the food safety system that can best be performed by each of the actors and on the ability to fill in system gaps in light of the inherent limitations of public service today. What can others or other systems do just as well or better, and should they? An effective food safety system is built on fusing the strengths of multiple players, by linking roles and authorities to responsibilities, and by aligning shareholders' efforts toward a single overarching mission of public health. An effective system emphasizes partnerships new and old, integration, and the need for accountability of all participants. The food safety system in the twenty-first century should be based on a framework of common goals, measures, rewards, teams, and networks that focus on outcomes. Once the framework is developed and operating to address desired outcomes, and once the attributes of a successful system have been integrated, optimum features of a final organizational design will be more apparent. There is a critical need to connect the food system strategically with an effective food safety component; this cannot be an afterthought but rather must be a planned and purposeful activity. It is clear that the food safety system must function as a integrated enterprise. That is, it must be agile, fluid, connected, integrated, and transparent. Integration is the antithesis of a system with components in isolation, barriers, and disconnected functions, rules, and policies. One of the most important aspects of an effective food safety system is the ability to assume an active, preventive role, as opposed to a reactive mode, to deal with problems already

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present. Focusing on prevention of foodborne illness rather than on response to failures is key to identifying and controlling outbreaks of foodborne illness. The system must be built to resolve today's problems but also with a special contemplation and flexibility to address future needs that are not yet foreseeable in detail. Most important, systems for continuous improvement must be based on information and science. Feedback processes are critical to learning, improvement, and change. The food system requires good data at numerous points to measure results and adapt processes. A unified food safety mission implies that goals are adopted to protect the public health, reduce risks of foodborne illness, and maintain, build, or rebuild consumer confidence. Means for evaluation and feedback are needed to determine whether the food safety system is meeting its goals. The criteria for assessment of the system outcomes include verifiable measures of progress, such as reduced numbers of foodborne illness outbreaks, decreased incidence of chemical residues in food, and a better understanding of foodborne risks that improves public policy and promotes improved consumer practices. Summary Findings: An Effective Food Safety System Should be science-based with a strong emphasis on risk analysis and prevention, thus allowing the greatest priority in terms of resources and activity to be placed on the risks deemed to have the greatest potential impact; is based on a national food law that is clear, rational, and scientifically based on risk; includes comprehensive surveillance and monitoring activities which serve as a basis for risk analysis; has one central voice at the federal level which is responsible for food safety and has the authority and resources to implement science-based policy in all federal activities related to food safety; recognizes the responsibilities and central role played by the nonfederal partners (state, local, industry, consumers) in the food safety system; and receives adequate funding to carry out major functions required.