On Reducing Bullshit in Food Safety Science and Regulation

SUPERBUGS, MAD COWS, MAD SCIENCE AND
REGULATORY-SCIENTIFIC MISADVENTURES:
IT’S A TIME TO BE HUMBLE; IT’S A TIME TO APOLOGIZE!

<< "Seeing reality is the first step towards changing it." >>

New mission statement for public health agencies:

To play nicely TOGETHER in the sand box and find ways to tolerate and resolve differing minority regulatory science opinions (the approach of the supreme court should be considered);
TO BE HUMBLE by remembering the many regulatory-scientific misadventures in our past, e.g., the blood crises, the Vioxx paradox, SARS farce, the ongoing superbug crisis (add any number of other examples) and to reflect that mad cow disease is perhaps the greatest regulatory-scientific misadventure, amounting to the ultimate doctors’ dilemma and vegetarians’ worst nightmare because of the potential broad impact on foods, drugs, medical devices, cosmetics and other bovine sourced consumer products ......
To work cooperatively and transparently with all fellow Canadian citizens to maximize the health impact of the public health resources being spent;
To resist creating false expectations by making promises we know we can’t keep;
To resist wasting precious public health resources by working in redundancy or reinventing the wheel (mapleleafing) and by fostering progress by adopting or importing innovations that exist elsewhere;
To accept full responsibility for the regulatory-scientific misadventures the same way we celebrate regulatory-scientific successes;
To recognize that spin doctoring, bullshit and "lience" have no place in public health science;
To minimize secrecy because we recognize that secrecy is the ally of corruption, the hiding place of incompetence and the birthplace of bullshit and überbullshit;
To admit that we may not have all the answers all of the time and that our answers are not the only possible answers; and to never again pronounce that "The review process is sound, rigorous and based on the best available scientific information and we can be confident in our conclusions." ..... IT’S A TIME TO BE HUMBLE!

The Ottawa Citizen 2004) Re: Drug test results should not be hidden, AUG. 12.

Recent news coverage, including letters to the editor, regarding the termination of Health Canada scientists, has raised questions regarding Health Canada's scientific processes and decision-making. Health Canada's fundamental priority remains the health and safety of Canadians. Whether reviewing a drug or providing nutrition advice, our activities are carried out with the goal of improving Canadians' health. Health Canada did not take the decision to terminate the employment of these three individuals lightly. Our reasons for dismissal must by law respect the confidentiality of the individuals. Health Canada's actions were based on fundamental management principles, in accordance with the law and with our obligations as public-service managers. Health Canada recognizes the need to have the best possible science to support its decision-making. As with other drugs reviewed and approved by Health Canada, veterinary drugs are approved only after a stringent and comprehensive evaluation. Teams of scientists with a broad range of scientific expertise review drug submissions. It is this breadth of scientific evidence, not the personal opinions of individuals, that is critical to scientific decision- making. Our processes include internal and external peer reviews, discussions at directorate and branch levels, international consultation as well as the use of expert advisory committees. The review process is sound, rigorous and based on the best available scientific information and we can be confident in our conclusions.
Health Canada's Veterinary Drug Directorate (VDD) has an excellent and committed multidisciplinary team of scientists, drug evaluators and support staff. Well regarded internationally, Health Canada and VDD serve the needs of Canadians with integrity and professionalism.

Acting assistant deputy minister, Health Products and Food Branch, Health Canada

References on bullshit

As you can see, Canadians have not been slouches when it comes to publishing on bullshit. I think McLuhan is out and Frankfurt (On Bullshit) is in. Or to put it another way, while we were focusing on the medium, the message turned into bullshit. At any rate, bullshit studies have become respectable and popular.

References: On Canadian Excellence on Bullshit.

1. McCallum, John S. 2005 Viewpoint - On Bullshit is not bullshit, Ivey Business Journal, Sept/Oct, 2005, 1-3. (on the Internet)

2. Penny, Laura 2005 Your Call is Important to Us: the Truth About Bullshit, Crown, New York

3. Richardson, Alan Performing bullshit and the post-sincere condition, pp 83- 97 in Bullshit and Philosophy - guaranteed to get perfect results every time, edited by Hardcastle, G.L. and G.A. Reisch 2006, Open Court, Chicago & Lasalle, Illionois

Überbullshit or Ueberbullshit

Ueberbullshit is bullshit produced by individuals or groups of experts (often scientists) who should know better. My favorite example is the following:

On bullpoop/bullshit and food microbiology.

The most frightening thing I ever read was the following statement: "There is a good reason why the foods we eat in Canada are safe" This quote is the opening in Food Safety and You - Her Majesty in the Right of Canada 2000, Cat. No. A62-52/2000, ISBN 0-662-64805-6. I think it is reasonable to assume that members of the production team included knowledgeable microbiologists who knew that the official numbers for foodborne microbial disease in Canada at the time were 30 deaths and 2 million cases annually. Based on the scholarly definition of bullshit in the 2005 nonfiction US best selling book by Princeton University professor emeritus Harry Frankfurt - On Bullshit (see http://press.princeton.edu/titles/7929.html ; http://www.slate.com/id/2114268/ ), it is difficult to decide whether this statement is a lie or bullshit. With 76 million cases reported annually in the US, North America has as many as 89 million cases of foodborne disease annually or 243,835 cases daily - a funny definition of safe!
Nor is the contamination of vegetables a new phenomenon. Let me provide some evidence: "Melick mentioned a number of instances where vegetables have caused disease" (1917. J. Infect. Dis., 21, 28). "Another outbreak occurred in Philadelphia where 18 out of 19 persons who ate water cress sandwiches became ill with typhoid fever" (1917). There are many other examples in chapter 15, Microbiology of vegetables and vegetable products, The Microbiology of Foods, F.W. Tanner, 1944, Gerrard Press, Champaign, Ill., USA. My motto has always been that one can't discover what is already recorded in text books. My first act when a food microbiological problem is "newly discovered" is to look at what, if anything was known before 1944. It may surprise some folks that the possibility of Salmonella being transmitted by chocolate, a recent problem that has resulted in chocolate recalls in U.K. and Canada, was studied as long ago as 1915.
It is obvious that bullpoop has been spread for too long by public health/regulatory officials as well as some academics and industry and NGO spokesthingies when it comes to microbiological safety of foods - we must stop telling consumers that the food supply is safe - it is no true, has not been true and probably won't be true in the future! It seems to me that telling consumers that the food supply is safe gives a false sense of security to consumers. It seems to me that those who do are also giving an implied warranty which could/should make them liable under certain conditions or could/should be used to question their credibility.