IFT Comments on Import Safety

During a public meeting at the United States Dept. of Agriculture on Oct. 1, IFT was among more than 40 presenters delivering verbal comments to The Interagency Working Group on Import Safety. This was an opportunity for IFT to be recognized as a global citizen and partner, and to speak to key points in our Expert Report on Emerging Microbiological Food Safety Issues as well as supporting the Working Group’s vision for a risk-based, prevention-focused model in which the private sector strengthens import safety by building safety into food products. Some of IFT’s verbal commentary, excluding introductory remarks, follows:

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 of 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 of origin. 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 due to 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.-based firms. And exporting countries often have less-developed regulatory systems than the U.S.

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 sophisticated systems that allow them to respond at a genetic level to stressors. Such circumstances can lead to the development of a new pathogen.

IFT supports 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 importers to identify and mitigate risks at appropriate points of manufacture and distribution, rather than addressing issues at the border, is essential. Safety cannot be inspected into the system; food manufacturers, distributors, and others in the private sector have the duty to build safety into products and maintain control.

A key conclusion of IFT’s Expert Report focuses on the value of Food Safety Objectives, which 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. The report recommends that regulatory agencies work with other public health officials, industry, and other 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 that technological innovation and new science need to be promoted. 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.

In conclusion, IFT supports the risk-based, prevention-focused model described by the Working Group. As more resources become available, IFT advocates 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.

by Rosetta Newsome,
Ph.D., Professional Member of IFT,is Director,
Dept. of Science & Communications,
Institute of Food Technologists,
525 W. Van Buren St.,
Chicago, IL 60607
([email protected]).