A pound of prevention

by Keith Nunes
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WASHINGTON — Michael R. Taylor is the first deputy commissioner for food at the Food and Drug Administration and heads the Office of Foods, which was created in August 2009 to coordinate and manage all of the F.D.A.’s food programs. Among Mr. Taylor’s principal charges are guiding the agency’s food program as it works with industry to inaugurate new prevention-based systems to address foodborne illness and improving how nutrition information is conveyed to consumers.

Mr. Taylor began his career in food safety with the F.D.A. in the 1970s and served in several high-level positions both at the F.D.A. and the U.S. Department of Agriculture’s Food Safety and Inspection Service. His service at the U.S.D.A. included a stint as F.S.I.S. administrator and acting under secretary for food safety.

Food Safety Monitor asked Mr. Taylor what has changed at F.D.A. in terms of structure or priorities in the past several months of the Obama administration.

“I think the important news is that we’re building a system aimed at preventing foodborne illness,” Mr. Taylor said. “We’re building that system on a foundation of a lot of F.D.A. work conducted over the years, but also recognizing that by harnessing modern tools of preventive process control, we can do a better job of reducing foodborne illness. So, we’re organizing much of our efforts around being able to do that, with our role being to set standards for what’s the appropriate approach to preventive controls and then developing the regulatory framework and ability to ensure those standards are met. It’s a simple approach, but it’s at the heart of what we do.”

Mr. Taylor said it was important for government to understand current best practices employed by many in the food industry that have proved effective in preventing food contamination, and to ensure such practices are adopted broadly.
“We want to be sure that preventive controls, modern and effective preventive controls, are in service throughout the system,” he said.

Much hinges on food safety legislation before Congress, Mr. Taylor acknowledged.

“Fundamentally, the legislation would give us a mandate to pursue this prevention strategy and would create a requirement that preventive controls be adopted in all food facilities in ways appropriate for each facility,” he said. “It would give us additional tools to set standards, but also additional tools to verify that those standards are being observed. The legislation basically codifies the modern approach to preventive controls that many in the food industry have been pursuing for a long time and that we all agree would contribute to reducing foodborne illness.”

Mr. Taylor said while he could not predict the Senate calendar, “We’re optimistic, quite confident, that when the bill comes to the floor, it will pass in the Senate, and then they’ll have to work out the differences with the House. The process is going forward, and we hope Congress acts soon.”

In the interim, an F.D.A. team is working on developing regulations with respect to preventive controls, both in anticipation of the legislation and to pursue preventive controls under current law to the extent possible, Mr. Taylor said.

F.D.A. also has undertaken several initiatives to enhance food safety under its current authorities, Mr. Taylor pointed out.

“For example, last summer, we issued regulations for egg safety (shell eggs), where we set standards for preventive controls on the farm in laying houses so the risk of contamination of eggs by Salmonella enteritidis would be reduced,” he noted. “Those regulations go into effect this summer, and we’re going to be doing direct inspections and verification to ensure the controls work to reduce risk.

“We’re also working hard on developing standards for produce safety. We’ve had a lot of requests, demands from industry and consumers, that we establish standards for safe growing practices on the farm to reduce the risk of harmful contamination. We think we can do that under current law, although we’d be strengthened in our program if Congress acts. Both the House and Senate food safety bills would direct us to establish these produce safety standards. That’s an area where we can make progress.”

In recent years, the F.D.A., long starved for resources, has begun to receive additional funding. Asked how the agency is employing the resources, Mr. Taylor said, “In the last three budget years, we have received increases. We’re still, frankly, catching up from a resource deficit that accumulated over a number of years, over a couple decades, really. Until recently, there had been an erosion in our buying power, so there has been a very positive gain in the last three years. But we’re still playing catch-up.

“We’re using those additional resources to make important investments in the scientific capabilities to do the preventive control approach to food safety,” Mr. Taylor said. “We’re investing in laboratory infrastructure to improve our scientific tools for testing food for pathogens. We’re working closely with the states to leverage their resources in building some of the infrastructure needed to do that as well. We want to work with the states on inspections, but we want to be certain that they’re working under the same standards and criteria that we work under, and that requires investment in building soft infrastructure, if you will, of developing standards and training in collaboration with the states. So we’re laying a foundation for the modern prevention-oriented program of the future, to which we’re all committed.”

The additional resources also have assisted the F.D.A. in strengthening inspections of imported food, but the food safety legislation before Congress would be of great importance to these critical activities as well, Mr. Taylor said.

“Ensuring the safety of imported foods is one of our biggest challenges because of the large volume of imports coming into the United States from all over the world,” Mr. Taylor said. “The legislation pending in Congress is particularly important and would be helpful on this.

“We currently are able to have inspectors at the border, at the ports of entry, checking product as it comes in, and if we can catch a problem, if we can detect a problem, we can stop the product. But I think everyone knows that the way we ensure the safety of food coming into the United States from overseas, just as we ensure the safety of food from domestic facilities, is prevention at the point of production.

“The new legislation would enable us to have much clearer standards making importers accountable for knowing where the food comes from, the conditions under which it was produced, and require they be able to assure us that those foods were produced in accordance with our standards, including the new prevention-oriented standards that we’ll be developing.”

The legislation also directs the F.D.A. to work with foreign governments more actively to ensure they’re providing proper oversight and allows for the employment of independent and accredited certifiers or auditors to inspect foreign facilities and provide assurance the facilities meet U.S. standards.

Meanwhile, under its current authority, the F.D.A. is better targeting for inspection imports that pose the highest risk, making the best use of its limited port-of-entry inspection resources, Mr. Taylor said. The F.D.A. also is increasing its inspections of overseas food production facilities.

“A year or two ago, we did, maybe, 200 of those inspections a year,” he said. “We’re shooting for 600 this year, and 1,000 next year, which is a small number in relation to the number of facilities, but it shows an overseas presence and lets some major foreign suppliers know that we are paying attention to what they do.”
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