The Food and Drug Administration (FDA), the United States Department of Agriculture (USDA), and the Centers for Disease Control and Prevention (CDC) have developed several strategies to address the foodborne disease problem.
FDA's current inspectional strategy emphasizes periodic visual inspection of food facilities, supplemented with end product testing. It was designed to control the problems that were known to exist when the Federal Food, Drug and Cosmetic Act was modernized in 1938. This approach was effective for its time but it is relatively resource intensive and has been criticized as being "inefficient." Although inspections can determine the adequacy of conditions in a food plant at the time of the inspection, they cannot determine whether the company is operating reliably and consistently, over the long term, to produce safe food. Furthermore, the current system of regulatory controls is reactive, not preventive. That is, the system generally relies on detecting and correcting problems after they occur, rather than preventing them in the first place. Only in certain limited areas and products, such as low-acid canned foods, are mandated preventive controls currently in place.
Between 1973 and 1988, bacteria not previously recognized as important causes of foodborne illness, such as E. coli O157:H7, L. monocytogenes, and Salmonella enteritidis, became very significant. These emerging and re-emerging food pathogens, along with the challenge of the increased use of ready-to- eat food products in the United States, have prompted FDA to consider adopting a new strategy to reduce foodborne illness. This strategy is generally referred to as the Hazard Analysis Critical Control Point (HACCP) approach to food safety.
The HACCP approach calls for a science-based analysis of potential hazards, determination of where problems can occur, and institution of measures to prevent them and corrective actions to take if they do occur. Detailed HACCP record-keeping then allows a firm and government regulators to monitor closely how well that firm is performing on a continuing basis.
HACCP offers a number of advantages over the current system. Most importantly, HACCP does the following:
More than 85 state and territorial agencies and 3,000 local regulatory departments license and inspect the more than 1 million establishments in the United States that offer food directly to consumers. Given the size and diversity of this segment of the food industry and the limitations of agency resources, FDA directs its activities toward achievement of an effective system of state and local regulatory programs nationwide.
The strategy is threefold:
The first model code was published in 1924. Over the years FDA published three model codes directed at the retail segment. The Food Service Sanitation Code (last published in 1976) has been adopted by 40 states and territories and by 160 local jurisdictions. The Vending of Food and Beverages (last published in 1978) has been adopted by 7 states and 3 local jurisdictions. (Earlier editions of these two codes are used by the other states.) The Retail Food Store Code (last published in 1982) has been adopted by 22 states and 9 local jurisdictions. Other states regulate their retail food stores under their food laws based on FDA's food service model.
In the late 1980s, FDA started a process for updating and combining the three model food codes. Combining the codes was necessary because the lines of distinction have blurred between the types of services offered by retail food operations. For example, some restaurants now sell featured ingredients from their own entrees, such as barbecue sauces and bakery items, as groceries. Grocery stores have self- service salad bars and ready-to-eat entrees in their delicatessens.
The new document, FDA's Food Code 1993, is an amalgamation of the best scientific thinking of public health professionals from all segments of the food safety community and includes the most up-to-date advice to the states on how to ensure food safety in the retail setting. FDA's strategy is to work with the States and representative organizations, such as the Conference for Food Protection (CFP) and the Association of Food and Drug Officials (AFDO) implementing all phases of the Code. First, FDA orients and trains state and local officials on the new provisions of the Code. Then, FDA provides support when the state or local jurisdictions start the administrative procedures to adopt the Code. Finally, FDA assists state and local jurisdictions in their implementation of the Code. The USDA Food Safety and Inspection Service (FSIS) supports this strategy and is working with FDA and the CFP to encourage states to update their food laws.
FDA's strategy is to work more closely with, and to provide better services to, the federal agencies that develop and provide the overall regulatory policy under which institutions are inspected at the state and local level. With better information exchange and joint participation in each others' policy development and training mechanisms, federal agencies will be better able to speak with one voice on food safety matters. FDA expects that, as guidelines and regulations are revised and updated, reference to FDA model food code provisions for foodborne illness prevention will be incorporated.
More than 7,400 USDA FSIS inspectors are continuously present in 6,200 slaughter and processing plants to ensure that diseased animals do not enter the food supply and that sanitation and other requirements are met. Inspectors also monitor the meat and poultry supply for violative levels of chemical residues.
Despite its successes, however, the current program does not fully protect public health. The current system largely focuses on organoleptic (sensory) inspection, which was appropriate when the first major meat inspection law was passed in 1906. At that time, animal diseases were the major concern, and invisible hazards, such as pathogenic microorganisms and drug residues, had not yet attracted the attention of regulatory agencies. Since that time, changes have been made in the inspection program to reflect changes in the production of meat and poultry and to increase the efficiency of inspection. However, the current program is still inadequate to detect invisible hazards that can cause foodborne illness. In short, it does not integrate systematic control into the production process to make meat and poultry as safe as possible.
To address the deficiencies of the current system, FSIS is pursuing a broad, long-term, science-based strategy to improve the safety of meat and poultry products and protect public health. The strategy addresses food safety issues from the farm to the table, including proposed requirements that all federally inspected meat and poultry plants reduce pathogenic microorganisms that can cause foodborne illness. The strategy is based on the philosophy of prevention embodied in HACCP.
FDA and FSIS are closely collaborating on implementation of the HACCP approach to food safety.
CDC has developed a strategic plan entitled "Addressing Emerging Infectious Disease Threats: A Prevention Strategy for the United States." The plan was developed in partnership with representatives from state health departments, other federal agencies, medical and public health professional associations, and international organizations.
The strategic plan emphasizes surveillance, applied research, prevention and control, and public health infrastructure. Some of the high priority implementation goals of the plan are the following:
The CDC prevention strategy is based upon the premise that it is far less costly, both in terms of human suffering and economics, to anticipate problems by preventing foodborne infectious diseases than to react to unanticipated public health crises with expensive treatment or containment measures. Investments in surveillance, laboratory research and training, epidemiologic investigations, and integration with prevention and control efforts will prepare CDC to respond to emerging infectious disease threats and thereby lessen their impact.
Each year, in collaboration with state health departments, CDC performs numerous field investigations of selected foodborne disease outbreaks through the Epi-Aid mechanism. Recent investigations have included a large multistate outbreak of S. enteritidis infections resulting from contaminated ice cream, a restaurant- associated outbreak of botulism caused by improper handling of an aluminum foil-wrapped baked potato, and a multistate outbreak of S. stanley infections resulting from contaminated alfalfa sprouts. Outbreak investigations continue to provide invaluable information about foodborne diseases and frequently lead to further studies, intervention by regulatory agencies, and education efforts.
CDC also maintains national reporting systems for laboratory-confirmed or clinically diagnosed cases of cholera, typhoid fever, and diseases caused by C. jejuni, E. coli O157, Salmonella spp., and Shigella spp. Laboratory-confirmed cases are reported to CDC by the State Public Health Laboratories through the Public Health Laboratory Information System (PHLIS).
As needs arise, CDC also conducts special studies which have recently included a national antimicrobial resistance survey of Salmonella and Shigella spp. isolates and a national survey of clinical laboratories to determine their laboratory techniques for detecting E. coli O157:H7.
Education programs are a critical part of the strategy to reduce the incidence of foodborne illness. It is difficult, however, for the government to inform adequately all food service workers and consumers about the best ways to prevent foodborne disease. For that reason, the agencies are increasing their efforts to work with other public and private sector organizations. The strategy adopted by the three agencies to educate the public about foodborne disease consists of six components.