IFT Commentary to The Interagency Working Group on Import Safety

October 1, 2007

IFT Commentary to
The Interagency Working Group on Import Safety
Public Meeting on Import Safety
October 1, 2007
Jefferson Auditorium, U.S. Department of Agriculture
Washington, D.C.

Good afternoon and thank you for the opportunity to address the Interagency Working Group on Import Safety at this public meeting. My name is Dr. Rosetta Newsome, and I am a food scientist on the staff of the Institute of Food Technologists. The IFT, which was founded in 1939, is a not-for-profit international scientific and educational society of food scientists and technologists working in the government, academia, and the food industry. IFT is a diverse organization comprised of 22,000 individual members, 17% of which live and work outside the United States--in 106 countries including China. Our organization includes members from a variety of food science and technology disciplines, and we stand committed to advancing the growth of the food science and technology profession. In addition, we all share a long-range vision of assuring a safe and abundant food supply that contributes to healthier people around the world.

IFT has a common commitment with the Working Group on Import Safety. And, we believe that food scientists and technologists play an essential role in protecting the consuming public. As demonstrated by our collaborative work with the Food and Drug Administration, IFT seeks to foster the proliferation new science-based programs, both here and abroad, to ultimately achieve our vision.

IFT agrees with the Working Group that U.S. citizens would benefit from the continued availability of a variety of food products regardless of the country in which they were produced. However, food safety must not be compromised in providing this benefit and food scientists and technologists stand ready to play a vital role in helping protect the public.

Managing food safety is a very complex task, for several reasons. First, hazards have become truly mobile, because of widespread global sourcing, food distribution, and human travel. Further, we generally have less knowledge about food production, manufacturing, and distribution in countries exporting to the United States than we do for U.S. firms. And, as pointed out by the Working Group, exporting countries often have less-developed regulatory systems than the United States.

Nevertheless, we have had considerable success in enhancing food safety; but, current systems cannot ensure a risk-free food supply. We still do not have the scientific knowledge, technology, and equipment to eliminate all hazards from all foods. The causes of the majority of foodborne illness are still unknown. Moreover, as described in an IFT Expert Report-Emerging Microbiological Food Safety Issues: Implications for Control in the 21st Century-microbial hazards have the inherent capability of evolving. Bacteria can exchange genetic material among themselves, and they have highly sophisticated systems that allow them to respond at a genetic level to stressors. Such circumstances can lead to the development of a new pathogen, even from a commensal, or harmless microorganism.

IFT is very supportive of the Working Group's recognition that focusing on areas of greatest risk over the life cycle of a product is an effective means for minimizing risks and maximizing quality. We agree that a cost-effective, collaborative, risk-based system that enables overseas manufacturers and the importing community to identify and mitigate risks at the most appropriate points of manufacture and distribution, rather than addressing issues at the border, is essential. We also agree that safety cannot be inspected into the system; food manufacturers, distributors, and others in the private sector have the responsibility to build safety into products and maintain control.

A key conclusion of IFT's Expert Report focuses on the value of Food Safety Objectives. A Food Safety Objective is a statement of the maximum frequency and/or concentration of a microbiological hazard in a food at the time of consumption that provides the appropriate level of protection. Food Safety Objectives enable food manufacturers to design, in a science-based, flexible manner, processes that provide the appropriate level of control, and which can be monitored to verify effectiveness. IFT's Expert Report recommends that regulatory agencies work with other public health officials, industry, and other interested parties to establish FSOs.

Another challenge is the fact that public health-related surveillance systems are too limited and disparate to enable control of pathogens to the extent desired. We agree with the Working Group that a forward-looking approach to import safety requires new ways to gather, integrate, analyze, communicate, and act upon information about imports from across the import life cycle. Expansion and integration of surveillance systems would provide a broader vision of the flow of microorganisms throughout the food chain, and would fill in data gaps pertinent to risk assessment.

IFT agrees with the Working Group that technological innovation and new science need to be promoted. We agree that research into the causes of risk, such as the conditions that lead to food contamination, can help identify vulnerable points in the life cycle of specific products and allow regulatory agencies and food manufacturers to take steps to control hazards at those points.

Recognizing the importance of the Codex Alimentarius Commission to international harmonization of food standards, IFT actively participates, as a non-government organization, in Codex work. For example, IFT contributed to the development of Codex guidelines on risk assessment and HACCP.

More recently, IFT is developing a three-part industry training program on quality control and assurance concepts, incorporating Codex approaches to food safety management, which we anticipate delivering to food industry and government audiences in China. This is one of a number of activities stemming from our strategic focus on collaborative, capacity-building efforts in China and Latin America.

In conclusion, IFT is supportive of the risk-based, prevention-focused model described by the Presidential Interagency Working Group on Import Safety. As more resources become available, IFT recommends allocation of additional funding for food safety research and for industry training programs on risk-based food safety management systems. Additional resources are also needed in regulatory agencies for oversight and regulation of the food system.

On behalf of IFT and our 22,000 members, I thank you for this opportunity to provide input to the Interagency Working Group.

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