IFT Provides Oral Comments to CDC/FDA/USDA on Measuring Food Safety

July 21, 2010

Good afternoon. My name is Sarah Ohlhorst and I am a Staff Scientist with the Institute of Food Technologists, which exists to advance the science of food. IFT’s long-range vision is to ensure a safe and abundant food supply contributing to healthier people everywhere. Founded in 1939, IFT is a nonprofit scientific society with individual members working in food science, food technology, and related professions in industry, academia, and government. IFT champions the use of science across the food value chain through knowledge sharing, education, and advocacy, encouraging the exchange of information, providing educational opportunities, and furthering the advancement of the profession. We thank you for the opportunity to provide comment on Measuring Progress on Food Safety: Current Status and Future Directions.

Since the 2002 release of IFT’s Expert Reporton Emerging Microbiological Food Safety Issues, IFT has advocated for the use of Food Safety Objectives or FSOs which place specific values on public health goals. FSOs, which can be applied throughout the food chain, specify the maximum level of hazard that would be appropriate to avoid foodborne illness at the time a food is consumed. FSOs would enable food manufacturers to design processes that provide the appropriate level of control and that could be monitored to verify effectiveness. Microbiological testing of finished food products and fresh fruits and vegetables can be misleading due to statistical limitations based on the amount of product sampled, the percentage of product contaminated, and the heterogeneity of contamination throughout a food.

FoodNET data provide critical information regarding foodborne illness trends. However, we know that foodborne illness is severely underreported. IFT strongly encourages the Agencies to support outreach to the public and to physicians to increase the reporting and detection of foodborne illness. Without knowing the true incidence of foodborne illness, it is extremely difficult to measure progress in preventing these illnesses.

IFT recognizes the immense effort required to generate the 1999 Mead et al study. The number found by the study more than a decade ago—an estimated 76 million cases of foodborne illness per year—continues to be cited but is based on outbreak data from as much as 30 years ago and surveillance data that are approaching 15 years old. For years we have heard that an update to the “Mead et al” study is in the works, and we anxiously await its release. We also urge CDC to release reports more frequently since more accurate figures of the estimated cases of foodborne illness each year can be vital to determining where to focus valuable prevention resources.  

IFT also seeks clarification on the definition of “priority pathogens” and would like insight into how the agencies weigh frequency of occurrence versus severity of impact. We would like to know how the information obtained from metrics will be used to inform regulatory action and federal funding. As an example, the recently released USDA NIFA AFRI funding priority in food safety is for Shiga toxin producing E. coli. However, FoodNet data from 2009 show that the incidence of E. coli O157:H7 met the Healthy People 2010 goals while rates of salmonellosis, campylobacteriosis and listeriosis exceeded the targets. We are furthest from the Salmonella target, but funding for research on the organism will not be available until 2011, and at that time, it appears that it will be limited to Salmonella in poultry. IFT would appreciate increased transparency with regard to how the agencies determine which pathogens should receive priority research funding, recognizing that E. coli infections are more severe, while salmonellosis is more frequent. Having appropriate metrics is clearly critical, but how these metrics will be used to inform future decision making is just as important. 

In conclusion, having metrics provide the opportunity for meaningful data to be collected, shared amongst stakeholders, and used to determine future actions. For example these data may  populate risk assessment and risk ranking models. Models that rank risks and hazards will allow the agencies to make more informed decisions on how to allocate resources to achieve maximum public health benefit

IFT commends the Agencies for working collaboratively to explore metrics, and offers our assistance as these are identified and implemented.

Thank you.

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