Tuesday, June 2, 2009

CONSUMERS "R" US. - GOLDEN RULE OF FOOD SAFETY

CONSUMERS “R” US.

Prepared and submitted to:
Subcommittee on Food Safety of the Standing Committee on Agriculture and Agri-Food
Sixth Floor, 131 Queen Street
House of Commons
Ottawa ON K1A 0A6
Canada
May 29, 2009

Ladies and gentlemen I would like to thank you for allowing me to address this Committee on foodborne listeria and food safety in general.
I would like to start over by addressing you as: Fellow Canadian consumers of the Canadian food supply because all of us eat up to 6 times a day (this includes snacks) – all of us are exposed to essentially the same risks. It is my opinion that food safety is not an area for politics because we know from past experience that bugs don’t care which party is in government. I also feel that food safety is not an area for Frankfurtian spin or rhetoric (see Frankfurt, Harry G. 2005 – On Bullshit, Princeton U. Press, Princeton), yet there is often far more of both then is good for all of us.
I have experienced the food business from starvation to regulation and I have worked in Canada in the food business from the manure pile to the sewage treatment plant; but one thing I have always kept in mind and that is: The food that resulted from these activities must be suitable for consumption by me and my family. Whether I was working for industry, academia or as a regulator I was always a consumer of food like everyone around this table. I often was disturbed by coworkers who appeared to forget that they are consumers by asserting that they represented industry, academia or regulatory – even professional consumer advocates seem to forget that all of us eat. Too often things are done for/to Canadians, for/to Consumers as in: “Protecting and promoting the health and safety of Canadians, their families and communities is of paramount importance to Health Canada.” How condescending!

THE GOLDEN RULE OF FOOD SAFETY:
Do onto others what you would want them to do onto you
if they were preparing food for you!


For the remainder of my 10 minutes I would like to give a few examples of failure related to the food safety system:
On the one hand the official body counters inform us that there are up to 13 million cases of microbial foodborne disease and up to 500 deaths in Canada each year (those are the current statistics which have changed from those used for many years – 30 deaths and 2 million cases). On the other hand every time there is an outbreak we pretend that we never heard of foodborne disease before! Between 2000 and 2005 our food regulatory system send out 12 million copies of a brochure entitled "Food Safety and You" which starts as follows: "There's a good reason why the foods we eat in Canada are safe." (This publication was also posted on the Internet). As a result of an ATIP request I found out that this publication was in response to: "public opinion research done in September 1999 indicated that 'confidence in the food safety system may be eroding slightly'." Therefore $2,600,000 was spent to distribute 12 million copies which also noted : “there are thousands of Canadians working every day so that you and your family can be confident that the foods you eat are safe.” As a consumer and food microbiologist I see two major problems associated with this careless use of the term "safe." First, it shows callous disrespect for those Canadian individuals who died from these risks and essentially denies their life, and it appears unkind to their surviving Canadian relatives. Second, it is clearly credibility-destroying behavior by the regulatory and scientific community. Is it any surprise that our credibility as scientists is being eroded? While we like to blame the media I believe that we, members of the regulatory/scientific community, are entirely to blame! Let me further add that the food supply has not been safe in the past, is not safe today and probably won’t be safe in the future. Recalls do not prove that the food safety system is working to provide a safe food supply; they are rather proof that the system is operating continuously in failure mode or as a former Health Canada colleague published – safe, virginity and sterility are absolutes and can not be qualified. The excessive use of “safe” results in a false sense of security by Canadians and in my opinion should/could result in liability under some circumstances as it appears to provide an implied warranty.
Let me conclude this section by referencing two recent papers that try to come to grips with the current food safety crisis:
1. Maki, Dennis G. 2009 – Coming to Grips with Foodborne Infection --- Peanut Butter, Peppers, and Nationwide Salmonella Outbreaks, The New England Journal of Medicine, vol. 360, No. 10:940-953.
2. Moss, Michael 2009 Food Companies Are Placing the Onus for Safety on Consumers, The New York Times, May 15, 2009.
Maki describes recent large scale recalls of foods in the USA because of microbial contamination which are national and/or international in scale like the ready-to-eat luncheon meat listeria recall in Canada. What all these recalls seem to have in common is “reckless consolidation” without appropriate compensation to mitigate increased risk visibility, meaning that once product contamination occurs, distribution is wide. For example the Maple Leaf Class Action claims that “over 243 products were identified as potentially contaminated with the bacteria species Listeria monocytogenes, which may have caused persons to become sick or die.” Moss on the other hand describes a globalized food production system that no longer knows where ingredients come from and which has placed the onus for safety on consumers.

Doing more of the same things that have gotten us here and expecting different outcomes!

In spite of what some people would like you to believe, food microbiology is not a new science!
I have here my copy of Tanner, Fred W. 1944 (2nd edition) The Microbiology of Foods, Garrard Press, Champaign, Illinois. Reading this book one is overcome by the realization that many of the food safety issues have been around and documented for at least 100 years.
I also brought along a copy of COMMITTEE ON SALMONELLA 1969 An Evaluation of the Salmonella Problem, National Academy of Sciences, Washington, D.C. Once again the salmonella problems we are seeing now are not new.
My final exhibit in this little show-and-tell is a copy of Health and Welfare Canada, 1981, CODE OF PRACTICE GENERAL PRINCIPLES OF FOOD HYGIENE FOR USE BY THE FOOD INDUSTRY IN CANADA. It may interest you that roughly 65,000 copies of this document were provided in Canada. Yet here we are many years later and rather than having seen an improvement in the microbial foodborne infections, they have officially gone from about 30 to 500 deaths and cases have gone from 2 million to as many as 13 million annually. It should be noted that the Canadian plant involved in the listeria recall appears to have been considered HACCP compliant (as listed on the CFIA website); however, it should be noted that HACCP by now is also a fairly old food safety system that has failed like GMP; perhaps because too many companies get on the band wagon and pay lip service to these systems.

Efficient redundancy or Mapleleafing:

One of the things that has frustrated me while working in food microbiology in Canada is the amount of hubris we have and which results in wasting our limited scientific resources blissfully reinventing technologies in use in other countries. I would like to finish my presentation with the example of phage therapy as applicable to both food technology and medicine.
Phage therapy was discovered by the French-Canadian microbiologist, Felix d'Herelle in 1917. Phage therapy uses highly specific viruses, bacteriophages, which are harmless for humans, to treat bacterial infections and can also be used to reduce or eliminate bacteria in food processing applications. Phage therapy is not currently approved or practiced in Canada. However, according to a letter signed by a former federal health minister it can be made available legally to Canadians under the Special Access Program of our Food & Drugs Act! A discussion of phage therapy is currently very timely because of the release of the Canadian film: Killer Cure: The Amazing Adventures of Bacteriophage and the book by Thomas Haeusler entitled, Viruses vs. Superbugs, a solution to the antibiotics crisis? ( see http://www.bacteriophagetherapy.info ). Both references are available at Ottawa libraries.This file has dramatically changed because the US Food and Drug Administration has amended the US food additive regulations to provide for the safe use of a bacteriophages on ready-to-eat meat against Listeria monocytogenes (see http://www.fda.gov/OHRMS/DOCKETS/98fr/02f-0316-nfr0001.pdf ). Also http://www.cfsan.fda.gov/~dms/opabacqa.html . The idea that ready-to-eat meat can be treated if contaminated with Listeria bacteria while a doctor could not get a pharmaceutical grade phage therapy product when faced with a patient suffering listeriosis strikes this author as absurd especially considering the recent massive recall of ready-to-eat meat in Canada due to contamination with listeria. Additionally, in the USA two other agencies, EPA and the USDA have approved the use of bacteriophages for various food processing applications. According to information from a Health Canada science manager to date there has not been a submission seeking approval of phages to mitigate microbial contamination of food products; however, should there be applications then we would treat these products as new and a complete review would be carried out. This clearly would be costly and cause significant delay in making this technology available in Canada giving USA food processors technological advantages. What is needed is a Canadian agency that has as it’s express responsibility to look at technologies available in other countries and if judged important there must be legal means of bringing them to Canada.
{Information is available on phage therapy treatment of human infections in Georgia , Europe ( http://www.phagetherapycenter.com ), or Poland - ( http://www.aite.wroclaw.pl/phages/phages.html ) or more recently at the Wound Care Center, Lubbock, Texas ( http://www.woundcarecenter.net/ ) .}

Getting Beyond Bullsh*t:

While it is easy to criticize the current failures of the food safety system, especially when I am no longer working in it, I feel fully justified to do so since it is my food supply that is being jeopardized. I would like to close with the message from a recent management book: Culbert, Samuel, A. 2008 Beyond Bullsh*t – Straight-Talk at Work, Stanford U. Press, Stanford, California. Canadians deserve honest, spin and rhetoric free communication when it comes to food safety and it is my opinion that that was not always the case in the past! Additionally we need to be more proactive in adopting technology and scientific evidence from other countries because larger populations may result in increased risk visibility.
Prepared by:
G.W. (Bill) Riedel, PhD Food Science/Microbiology

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