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Yesterday, USDA announced its new Food Safe Families campaign to get you to pay attention to food safety procedures in your kitchen.  These, as always, are:

1. Clean: Clean kitchen surfaces, utensils, and hands with soap and water while preparing food.
2. Separate: Separate raw meats from other foods by using different cutting boards.
3. Cook: Cook foods to the right temperature by using a food thermometer.
4. Chill: Chill raw and prepared foods promptly.

The media campaign, which reportedly cost $2 million, comes with a graphic that can’t be all that expensive:

So what is the $2 million for?  According to Food Chemical News (June 28):

The campaign, which will feature public service announcements in English and Spanish, centers on “humorous over-the-top depictions of the four key safe food handling behaviors”….The campaign will include ads on television, radio, print and websites, along with an integrated social media program.

As it happens, a reader sent me the preliminary “concept” version of this campaign (thank you kind reader).   Trust me, this campaign is worth a look, and Food Safety News has some of the videos.

Here’s my favorite concept:

Yes, this is a baby pig in a sauna.  Humorous maybe, but how will it convince anyone to clean up the kitchen?

Two other points:

• None of the concepts seem to have anything to do with food.
• All of them are about your responsibility for food safety.

But the big national outbreaks we’ve been experiencing lately are from foods that are already contaminated by the time they get to you.  Following food safety procedures makes good sense, but that’s not where the problem lies.  They would not help you much with contaminated raw sprouts, for example, unless you cook them (not a bad idea these days).

To stop food safety problems at their source, we need a functional food safety system.  This means rules that require all producers to follow food safety procedures and a government with the authority and resources to make sure they do.

Will we ever get a food safety system like this?  And how bad will things have to get before we do?

In an action highly unusual for the FDA, the agency has released a new “special report” on what it is up against as it tries to get a handle on the safety of imported foods.

Pathway to Global Product Safety and Quality points out that imported foods account for:

• Between 10% and 15% of all food consumed by all U.S. households
• Nearly two-thirds of all fruits and vegetables
• 80% of seafood

And imported foods have increased by at least 10% during each of the last seven years and are expected to increase by 15% per year for the next several years.

The New York Times notes that in 2008 the FDA would have needed “1,900 years to check every foreign food plant at its rate of inspections at the time.”

That’s not all.  According to FDA:

Manufacturers and producers…face intense pressure to lower costs and improve productivity, fueling a cycle in which the quest for efficiency leads to increased production abroad and higher volumes of imported products to regulate.

Goods entering the U.S. will come from new and different markets, flowing through long, multistep processes to convert globally-sourced materials into finished goods.

The shift in global product flows will make it difficult to identify the “source” of a product and to ensure that all players along the supply chain meet their safety and quality responsibilities.

And it is not just legal activity that poses challenges for the FDA. Increasingly, the agency must contend with ever more sophisticated threats of fraud, product adulteration, and even terrorism.

The FDA illustrated its report with terrific graphics.  My favorite is the supply chain for canned tuna:

What will the FDA do about this problem?  It says it will:

1) Assemble global coalitions of regulators dedicated to building and strengthening the product safety net around the world.

2) With these coalitions, develop a global data information system and network.

3) Expand capabilities in intelligence gathering and use.

4) Allocate agency resources based on risk, leveraging the combined efforts of government, industry, and public- and private-sector third parties.

The FDA released its report on practically the same day that the Health and Human Services Inspector General’s office released a report highly critical of the FDA’s ability to monitor the safety of imported foods.

Because FDA’s food recall guidance is nonbinding on the industry, FDA cannot compel firms to follow it and therefore FDA cannot ensure the safety of the Nation’s food supply.

FDA did not always follow its own procedures to ensure that the recall process operated efficiently and effectively.

This kind of criticism is not new.  Just last month, the GAO issued a critical report on the FDA’s problems regulating the safety of imported seafood.  The FDA’s difficulty with recalls is that until Congress passed the food safety act last year, FDA did not have the authority to order recalls.  It had to “pretty please” ask companies to recall unsafe foods.  Now it has the authority, but Congress did not grant new resources to carry out that authority.

The New York TImes explains the reason for the FDA’s lack of oversight:

Audits of the F.D.A.’s oversight of the nation’s food system routinely find the agency’s efforts wanting, in part, the agency says, because its budget for such activities has long been inadequate. And although the new food safety law gave the agency extra supervisory powers, it is not clear how much it will be able to do, given that House Republicans have proposed cutting its budget for protective measures.

The FDA official in charge of food safety, Michael Taylor, has been discussing the vexing resource question in recent speeches.  He points out that the FDA:

Has a a huge workload. And even though public health officials are working hard, the agency will likely not meet all of its deadlines. On top of the backlog, FDA has no idea what its budget will be for fiscal year 2012.

An agriculture appropriations bill that cleared the House last week would cut food safety programs $87 million below fiscal year 2011.

The current budget situation does paint a challenging picture…a patchwork of continuing resolutions to keep the government funded — as we saw in 2011 — makes it nearly impossible to plan ahead.

When Congress gives us our budget over half way through the fiscal year it’s very difficult to use that money in as orderly a way as possible. You can’t use that money to hire the experts you need because the hiring process is such that you won’t get them hired until the end of the fiscal year

When it comes to food safety, we only have one food supply, and it is global.  That was the whole point of my book Pet Food Politics: The Chihuahua in the Coal Mine—a case study of how melamine in China got into American, Canadian, and South African pet foods.  If it could happen to pet food, it could happen to ours.

To monitor the safety of imported foods, the FDA neeeds to be stronger, not weaker.

German authorities now say that  sprouts grown on an organic farm in Lower Saxony are the source of their E. coli O104:H4 outbreak, now responsible for more than 30 deaths and 3,000 illnesses, 750 of them severe kidney disease.

The epidemiological studies point to sprouts after all.

Sprouts, as I mentioned in an earlier post, are a prime suspect in microbial outbreaks.   They have been implicated in many outbreaks in the United States.  This is because sprouts are sprouted from minute seeds that are hard to clean, as shown in this microscopic view:

As Food Safety News explains in a long discussion of this problem, the seeds need to be dumped in bleach to kill bacteria.  It’s also a really good idea to test the wash water to make sure it is free of pathogens.

The seeds are sprouted in water at room temperature, “a warm, moist climate — just perfect for a bacteria’s social life and subsequent reproduction.”

The FDA has been aware of this problem for a long time, as shown by this brief chronology:

• 1999: The FDA issued “nonbinding guidance” on growing sprouts.  This caused the ever-vigilant Center for Science in the Public Interest (CSPI) to file a petition arguing that guidance rules for sprouts needed to be mandatory.
• 2004: The FDA wrote a “note” to producers and shippers of sprouts stating that it was aware of 27 outbreaks of microbial illness due to sprouts and urging producers to follow the voluntary guidance procedures.
• 2004: The FDA followed up by issuing safety guidance for growing sprouts in retail establishments.  These were voluntary, of course.
• 2004: California health officials produced a slide presentation on the hazards of sprout production, urging producers to follow safety guidelines.
• 2005: The FDA announced public meeting to discuss the science of safe production of sprouts as a basis for beginning a rulemaking process for mandatory safety procedures.
• 2009: The FDA issued a warning about consuming alfalfa sprouts.

The Food Safety Modernization act passed last year finally gives FDA the authority to require food safety controls for sprouts.

The German outbreak ought to be a wakeup call for this industry in the United States.  Sellers of bean sprouts market them as health foods but say little about how unsafe they are if eaten raw.

It also ought to be a wakeup call for consumers.  If you aren’t absolutely sure the seeds come from a clean source, cook your sprouts.

I haven’t said anything about the E. coli 0104 crisis in Germany up to now because I’ve been waiting for the evidence.  Without evidence, the source of the outbreak remains uncertain.

Yesterday, the German minister of agriculture announced that sprouts are the cause.  But are they?

What  is known without question is that the outbreak is deadly serious.  Bill Marler reports these shocking numbers as of June 5:

Deaths = 22 (21 in Germany, 1 in Sweden)

Illnesses = 2,243 (2,153 in Germany, and 90 more in 10 other European nations and the U.S.)

Cases of Hemolytic Uremia Syndrome (HUS) = 627

Why shocking?  This is a devastating disease, excruciatingly painful, with a high probability of causing lifelong complications.  And the disease is almost entirely preventable by following standard food safety procedures.

The idea that the cause is sprouts, and German sprouts at that, comes as a surprise.  Why?  First, sprouts are a frequent cause of foodborne illness and should have been high on the list of suspected foods.  Second, sprouts did not turn up in the case-control studies.

Instead, investigators examined cucumbers, lettuce, and tomatoes (and, in the process, put Spanish cucumber producers out of business).  As Marler explains, the German authorities didn’t want to take a chance, given the results of their investigation.

The case-control investigation was conducted by the Robert Koch Institute, the German equivalent of our CDC.

• The cases: From May 29 to June 2, investigators interviewed 46 affected patients from Bremen, Hamburg and Lübeck about the foods they had eaten.
• The controls: They interviewed 2,100 people who were not sick but were of similar age group, sex and region of residence.
• The results:

Food Reported Eaten         % By Cases     % By Controls

Lettuce                                        84                           47

Cucumbers                                 75                           50

Tomatoes                                   80                            63

95% of the Cases had eaten at least one of the three vegetables.

This evidence strongly implicates these vegetables.  But did they not look for sprouts?

In another related study of people from a Frankfurt business company who had become ill, those who had eaten from the salad bar in the company cafeteria had a 7-fold increased risk of developing bloody diarrhea than those who had not.  No such association was seen for other foods investigated, such as dessert, fruit and asparagus.  Sprouts are not mentioned.  How come?

In trying to figure out what’s going on here, a BBC World News report raises even more questions (my emphasis):

The agriculture minister for Lower Saxony, Gert Lindemann, said there was a clear trail of evidence pointing to a plant nursery south of Hamburg [as the source of the contaminated sprouts].

The nursery has been closed, though officials say the outbreak’s source cannot yet be definitively confirmed.

…Mr Lindemann said epidemiological studies all seemed to point to the plant nursery in Uelzen in the state of Lower Saxony, about 100km (62m) south of Hamburg – though official tests had not yet shown the presence of the bacteria there.

“Further evidence has emerged which points to a plant nursery in Uelzen as the source of the EHEC cases, or at least one of the sources,” he said.  [What evidence?]

…Gert Hahne, a spokesman for the Lower Saxony agriculture ministry, earlier told the Associated Press news agency that many restaurants in which people ate before becoming ill had recently taken delivery of the sprouts. [Guilt by association]

He said authorities would still maintain a warning against eating tomatoes, cucumbers or lettuce.

The health ministry in Berlin said it was still waiting for results from tests on the beansprouts, Germany’s DPA news agency reported.

And the head of the Robert Koch Institute (RKI), Germany’s national disease centre, was also reported as saying that the cause of the outbreak could not yet be confirmed.

So: are sprouts the cause?

By this time, the outbreak is slowing down as the contaminated foods make their way through the food supply.

Could this happen here?  You bet.

If ever there was a time to give the FDA more resources, now is it.  The FDA now has the authority to impose standard food safety procedures on food producers and to require safety measures for the foods we import.   But Congress wants to cut the agency’s budget, and badly.

Now would be a good time to let congressional representatives know that we need a stronger FDA.   And while you are at it, let the USDA know that you think it would be a good idea to regulate other forms of toxic E. coli as adulterants in the same way they regulate E. coli 0157:H7. There is plenty government could do right now to protect us from outbreaks like this one.

A word about sprouts:

How come sprouts are such frequent sources of food safety problems?

Sprouts are grown from tiny seeds that are impossible to wash thoroughly enough to ensure that they are free of harmful bacteria.  The seeds are sprouted in water that must be changed several times a day.  This water is an excellent growth medium for bacteria.  That is why FDA guidance says sprout producers ought to test the wash water for harmful bacteria.

Under the new legislation, the FDA has the authority to enforce this guidance.  But does it have adequate personnel?  Unlikely, given the current stance in Congress.

This just in:  No, it’s not sprouts, according to this bulletin from Food Chemical News:

The latest news, reported this morning by both the Associated Press and BBC, is that 23 of 40 samples of organic sprouts taken from the Gaetnerhof farm in the Lower Saxony region of Germany have tested negative for the bacteria. Tests on the other samples have yet to be returned.

Michael Taylor, FDA’s associate commissioner for foods, gave a major speech yesterday at the George Washington University School of Public Health.

In it, he talked about the origin and effectiveness of HACCP (Hazard Analysis and Critical Control Point) controls for preventing food safety problems.  HACCP, he explained, works just like other aspects of public health practice.  It requires:

• understanding the specific food safety hazards that could affect a particular food production operation,

• devising and implementing scientifically validated controls to minimize the hazards,

• monitoring the implementation of preventive controls to verify effectiveness, and

• making corrections and adjustments as needed, based on experience.

He then went on to say how FDA plans to put the Food Safety Modernization Act into action:

We are well on our way to developing a proposed produce safety rule that addresses areas such as employee hygiene, water quality, soil amendments, and animals in the growing area, as FSMA mandates.

In food facilities, such as processing and packaging plants, we will be proposing rules that are grounded in the widely embraced principles of preventive process control for food safety, similar to HACCP.

The law requires each facility to… (1) evaluate the hazards that could affect food safety, (2) specify what preventive steps, or controls, to put in place to minimize or prevent these hazards, (3) specify how the facility will monitor these controls to ensure they are working, (4) maintain routine records of monitoring, and (5) specify what actions the facility will take to correct problems that arise.

For example, in a facility that produces peanut butter, factors such as  ingredient safety, sanitation, and cross contamination would have to be considered. After the outbreak of Salmonella typhimurium in peanut butter in 2008 and 2009, which caused 714 cases of illness, the company had to reevaluate the hazards in its facilities so this wouldn’t happen again.

Such review and correction – and a sharp focus on specific hazards – will become the norm under a system of preventive controls.

Taylor outlined FDA’s vision for preventive controls from farm to table.  Now, if Congress will just give it the resources to do all this, we might actually have a food safety system that functions.

FDA’s program is generally limited to enforcing the Hazard Analysis and Critical Control Point—the internationally recognized food safety management system—by conducting inspections of foreign seafood processors and importers each year.

These inspections involve FDA inspectors reviewing records to ensure the processors and importers considered significant hazards, including those resulting from drug residues if the seafood they receive are from fish farms.

The inspectors generally do not visit the farms to evaluate drug use or the capabilities, competence, and quality control of laboratories that analyze the seafood.

• Aquaculture assessments have been limited by FDA’s lack of procedures, criteria, and standards. In contrast, the EU reviews foreign government structures, food safety legislation, the foreign country’s fish farm inspection program, and visits farms to ensure that imported seafood products come from countries with seafood safety systems equivalent to that of the EU.
• FDA’s sampling program does not generally test for drugs that some countries and the EU have approved for use in aquaculture. Consequently, seafood containing residues of drugs not approved for use in the United States may be entering U.S. commerce.
• FDA’s sampling program is ineffectively implemented. For example, for fiscal years 2006 through 2009, FDA missed its assignment plan goal for collecting import samples by about 30 percent.
• In fiscal year 2009, FDA tested about 0.1 percent of all imported seafood products for drug residues.
• FDA’s reliance on 7 of its 13 laboratories to conduct all its aquaculture drug residue testing raises questions about the agency’s use of resources.
• FDA has inspected 1.5 percent of Chinese seafood processing facilities in the last 6 years.

And Congress wants to cut FDA’s resources.  I have no doubt that the FDA could be more efficient but the scope of what it is expected to do with limited resources is beyond absurd.

From where I sit, the entire food safety system needs an overhaul and the problems with food imports are a good reason for doing that.

By this time, you must have heard about the study in Clinical Infectious Diseases sponsored by the Pew Charitable Trusts.  The study found nearly half of supermarket meat and poultry samples to be contaminated with Staphylococcus aureus. Half of the contaminated samples were resistant to multiple antibiotics.

Staph causes awful infections.  When I was a child, my mother had a Staph infection that kept her out of commission for what seemed like months in that pre-antibiotic era.  Antibiotics can keep Staph under control, but not if the Staph are antibiotic-resistant.   Staph resistant to multiple drugs are a clear-and-present danger.  No wonder this study got so much attention.

The study provides strong support for the idea that we ought to be reducing use of antibiotics as growth promoters in farm animals, an idea strongly supported by the CDC.

Even though 80% of U.S. antibiotic use is for farm animals, the meat industry strong opposes any proposal to change its practices.

The National Cattleman’s Beef Association responds by attacking the science:

Calling into question the safety of U.S. beef without conclusive scientific evidence is careless and misleads consumers. Pew Charitable Trusts, an agenda-driven organization on this issue, funded this study, which concludes that its extremely small sample size was ‘insufficient to accurately estimate prevalence rates’ and that ‘public health relevance of this finding is unclear.’ The study’s authors clearly call into question the validity of their own study. The bottom-line is U.S. beef is safe and is part of a healthy, well-balanced diet.

The American Meat Institute reassures the public that meat is safe.  After all, you are going to cook your meat, aren’t you?  In any case, the responsibility rests with you.

While the study claims that the many of the bacteria found were antibiotic resistant, it does note that they are not heat resistant.  These bacteria are destroyed through normal cooking procedures, which may account for the small percentage of foodborne illnesses linked to these bacteria.

As with any raw agricultural product, it is important to follow federal safe handling recommendations included on every meat and poultry package that urge consumers to wash hands and surfaces when handling raw meat and poultry and to separate raw from cooked foods to ensure that food is safe when served.

These sound like the arguments that the meat industry has made for years for Salmonella and E. coli O157:H7.

I see this study as another reason why we need better food safety regulation, and the sooner the better.

Postscript: Bill Marler reports that he had 100 samples of chicken tested from Seattle markets:

IEH Labs found S. aurea [sic], or staph, in 42 percent of the samples overall and Campylobacter in 65 percent. The supermarket chicken was contaminated with other pathogens as well: 19 percent of the samples tested positive for Salmonella, one tested positive for Listeria, and 10 percent showed the presence of the methicillin-resistant S. aureus (MRSA). In an unusual finding, one of the chicken samples tested positive for E. coli 0126, Shiga-toxin producing E. coli (STEC) bacteria more likely to be a contaminant of beef than poultry. Organic Chicken proved to be slightly less contaminated than nonorganic with 7 of the 13 (54%) testing positive for harmful bacteria.

As I said….

My monthly Food Matters column for the San Francisco Chronicle:

Food is cheap at market, but costs a lot elsewhere

Q: I pay a lot for food, and more each day, but then people like you say our food is cheap because its real costs are “externalized.” Huh? What’s that supposed to mean?

A: Food prices are indeed going up, and I can hardly keep track of the possible causes: natural disasters, crop failures, commodity speculation, corn used for biofuels, lack of research in agriculture, the declining value of the U.S. dollar and just plain greed.

But we Americans still pay relatively less for food than anywhere else because so many of the costs of industrialized food production are “externalized.” We pay for them, but not at the grocery store.

Human costs

I was reminded of externalized food costs when reading about the remarkable efforts of a Salinas teacher to educate children of itinerant farmworkers. The kids are trying to learn under disrupted, impoverished, crowded living conditions. If their parents were paid and housed better, we would pay more for food.

Last summer I visited fish canneries at the far end of the Alaskan peninsula. The fish packers were women from the Philippines, working round the clock for months to send money home to their children and families.

The canneries used to hire Alaskan high school students at wages high enough to put them through college. But to keep prices competitive, the companies reduced wages and imported labor. That money disappeared from the community.

The CEO of a large U.S. meat company told me that if he raised wages by $3, he could hire locals and not have to deal with immigrant labor. But then he would have to raise the price of his meat by 3 cents per pound (I’m not kidding). That amount, he claimed, would price him out of competitiveness.

Environmental costs

Twenty billion dollars of our tax money goes to subsidies for industrial food production every year. Additional tax money is required to clean up the mess created by that system – polluted drinking water, infertile soil, ocean dead zones and overall misery in the surrounding areas.

While driving to give a talk at a college in rural Minnesota last year, I passed within a mile or so of an industrial pig farm. The overpowering smell – an externalized cost – was still on my clothes hours later.

Safety costs

Food safety is one casualty of a food system devoted to low cost. Companies save money by cutting corners on oversight and overlooking safety violations. The Centers for Disease Control and Prevention (CDC) says food pathogens cause 48 million illnesses, 128,000 hospitalizations and 3,000 deaths each year.

Some experts say unsafe food costs Americans $152 billion annually – $1,850 for each case in health care and lost wages. Severe illnesses from E. coli O157:H7 can generate more than $1 million in health care costs alone, and ruin lives forever.

To these amounts must be added the costs to food producers of product recalls, continued loss of sales, lawsuits and ruined reputations. Sales of spinach, for example, are only now returning to levels reported before the huge E. coli outbreak in 2006.

Here again, the cost of prevention is minimal for large companies producing large volumes of food. Officials of one vegetable-packing company told me that the impressively comprehensive food safety system they instituted in the wake of recalls raised the cost of their products by only one penny a case (I’m not kidding about this, either).

Despite ample evidence from surveys that consumers are willing to pay more to guarantee safe food, large food producers perceive those few pennies as competitive barriers.

Health care costs

Let’s count obesity as another externalized result of a cheap food system. The cheapest foods are high in calories and low in nutritional value – “junk” foods. When food is cheap, people eat more of it.

Abundant cheap food leads companies to aggressively market their products to be eaten any time, any place and in very large amounts – all of which promote biologically irresistible overeating.

Current estimates of the costs of obesity and its consequent illnesses in health care and lost productivity approach $147 billion annually, almost the same as the cost of unsafe food.

Accurate or not, such numbers provide ample evidence for the need to bring agricultural policy in line with health policy.

To pick just one example: Dietary guidelines say to eat more fruits and vegetables, and cut down on sodas. But the indexed cost of fruits and vegetables has increased by about 40 percent since the early 1980s, whereas that of sodas has decreased by about 20 percent.

The high externalized cost of our present food system is a good reason to reconsider current policies when the Farm Bill comes up for renewal in 2012. Now is the time to start working toward food system policies that will better promote health, safety and human welfare.

Marion Nestle is the author of “Food Politics,” “Safe Food,” “What to Eat” and “Pet Food Politics,” and is a professor in the nutrition, food studies and public health department at New York University. E-mail her at food@sfchronicle.com, and read her previous columns at www.sfgate.com/food.

This article appeared on page H – 4 of the San Francisco Chronicle