Zero Tolerance is a Bad Strategy to Protect Food Safety
When promulgating regulations, government agencies tend to be unwilling to directly accept negative outcomes, including illness, as an acceptable possibility for the citizenry. This aversion reflects political reality. However, avoidance of risk thresholds can be counterproductive to public health. Of paramount importance is the development of acceptable risk levels against which to establish and scientifically evaluate quantitative food safety criteria and, thereby, to appropriately protect public health. Quantitative targets allow application of the best available technologies for modeling and monitoring hazards to effectively enhance food safety. The proposed Produce Safety Rule (PSR) under the U.S. Food and Drug Administration (FDA) Food Safety Modernization Act (FSMA) is intended to assure food safety through science-based minimum standards, or regulatory criteria. The fact that the PSR borrowed the science-based criteria for recreational water quality and applied them to irrigation water is a case example of the need for quantitative risk criteria. Without quantitative risk criteria, it is impossible to evaluate whether PSR water quality criteria are overly protective or not protective enough. Furthermore, it is impossible to test alternatives to the proposed criteria for equivalent levels of public health protection. In the broader sense of food safety, beyond irrigation water quality, risk models and other tools can be effectively used to guide policy. A short list of application examples includes the establishment of irrigation water quality targets, detection probability targets for pathogens or toxins on imported foods, and efficacy evaluation for new technologies, such as utilization of gene sequence information in the detection pipeline. Once established, the risk modeling structure allows effective communication of the scientific basis for policy decisions designed to enhance food safety, and the protective value of food safety criteria and regulations.
This paper was debated at the ISGP conference Food Safety, Security, and Defense: Focus on Food and the Environment, convened in partnership with Cornell University in October 2014.
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