One item in the consumer news wrap-up published by the Salt Lake Tribune yesterday caught our eye. It was this:
We found the Produce Safety Project’s (PSP) website here and noted its key findings:
More from the report’s summary follows here.
Preventive Safety Standards for Fresh Produce
FDA officials consistently pointed to this outbreak as further proof of the need for preventive safety controls for produce but said they need Congress to act. In fact, FDA, under its existing statutory authorities, has established similar preventive control systems through its Hazard Analysis and Critical Control Point (HACCP) regulations for seafood and juice, and has proposed on-farm safety measures for shell eggs. Moreover, in early 2007, FDA officials cited those same existing statutory authorities when they unsuccessfully sought approval from the Department of Health and Human Services (HHS) to move forward on produce-safety standards. The recent Salmonella Saintpaul outbreak shows the immediate need to establish preventive safety measures using existing legal authority.
Organization and Capacity
Questions about the food-safety system’s lack of organization, capacity and coordination and their resulting impact on the effectiveness of the public-health response are raised by comparing the CDC’s Mortality and Morbidity Weekly Report article on the outbreak (hereafter, "CDC Outbreak Report") with the public statements of FDA and CDC officials during the outbreak. For instance, the epidemic curve (or "epi curve") published in the CDC outbreak report shows that some 50 percent of the confirmed cases began before the FDA nationwide consumer advisory on June 7 recommending that consumers avoid eating certain tomatoes. While there was a drop in cases after that announcement, it appears that the most sustained drop began around June 24. Maybe this drop was a factor of the incubation period for the illness, or maybe it points to an off-target intervention. A post-mortem analysis should examine this question. In addition, the discussion in the CDC outbreak report of cluster investigations in mid- to late-June raises questions about why FDA and CDC officials continued to maintain so steadfastly and for so long that tomatoes were the leading suspect for being the vector for Salmonella Saintpaul.
From the beginning of the outbreak, public-health communication to the media and the public was disjointed and confusing. Five different agencies – two federal and three state — "announced" the outbreak over the course of four days with significant variations in facts and messages. Then, three weeks into the public-communications effort, the CDC significantly changed – with no explanation — the manner in which it presented outbreak data, from raw number of cases in a state, to cases per million in a state, to a range of cases per state. While the change in presentation of data by CDC may have been worthwhile, it begs the question of why established procedures were not in place before this outbreak began. These failures in communication may well have contributed to the public’s decision to stop buying and eating tomatoes altogether in June and July.
To date, much of the analysis of the outbreak has focused on the "traceback," FDA’s attempt to locate the source of contamination. As important as that discussion is, if the post-mortem analyses are limited to that aspect, deeper and even more fundamental structural and organizational shortcomings risk being neglected. Indeed, these shortcomings in the nation’s food-safety system are not new, having been documented repeatedly during the past decade by many expert bodies, including the National Academies of Science, the Government Accountability Office, and the FDA’s Science Board. The key question here is whether the nation’s food-safety policymakers will learn the lessons of this outbreak and fix the system. To learn those lessons, they need to undertake a thorough, in-depth and transparent review of what went right this past summer, what went wrong, what could be done better, and what should never happen again.