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In a perfect world.... (commentary)

Make that "In a perfect world for food safety in Raymond's eyes."

Dr. Richard Raymond 1

November 20, 2016

5 Min Read
In a perfect world.... (commentary)

Make that "In a perfect world for food safety in Raymond’s eyes."

Four years ago to this day, I wrote a blog with my predictions as to what would be changing in the food safety world in the U.S. after President Obama’s bid for another four years was a success.

I was right only on about one out of every four predictions, so I am not going there again, especially with what I view as the unpredictability of this election’s winner for our next President.

Instead, I will just pontificate on what I would change if I were the elected President and had a partisan Congress to make my wishes become laws and regulations.

First and foremost I would not create a single food safety agency as many keep calling for.

The mindset and philosophies ingrained in the Food and Drug Administration (FDA) at HHS and the Food Safety Inspection Service (FSIS) at the USDA are so far apart as to appear bipolar. Trying to make them work nicely together would actually endanger our food supply in at least the short term.

In short, FDA likes to educate through things like “best practices” and “guidelines” documents and relies on states to do any inspection while FSIS likes to regulate through daily continuous inspection and writing non-compliance records, even shutting down plants on occasion.

But I would rearrange the chairs of food inspection to make more sense out of a non-sensical dual jurisdiction system that sees no inspections for veggie baby food, but daily continuous inspection for baby food that contains chicken or beef.

The biggest risk in both products is botulism from bad canning techniques, not salmonella or      E coli O157:H7 infections.

I would give FSIS all animal products, and that would include all fish and sea food, eggs and dairy products, almost all of which currently land in the non-regulatory laps over at the FDA.

Give FDA everything else, including all foods that contain meat and fish products that have already passed FSIS inspection, such as the baby food, pizza, open-faced sandwiches and soups.

Should be just about budget neutral as far as jobs are concerned, so the Union would not block this one as they have blocked other common sense ideas, such as risk-based inspection for meat and poultry processing plants (more on that later).

And if that is not doable because of budget or job security issues, I would at least give Catfish back to the FDA that currently has all the other swimmers, and take Bison from FDA and put them where they belong with the other four legged critters.

 After all, an average buffalo looks a lot more like a steer on steroids than does the whiskered catfish.

Back to risk based inspection for processing plants.  I have two ideas here.

One, spend more inspector hours in plants making high risk products, like ground beef vs. smoked, canned hams, and in plants with poor inspection records and spend less time in plants with sterling food safety records making those products rarely associated with food borne illnesses. The ground work and the matrix has already been done, but was shot down by Congresswoman Rosa DeLauro, D-CONN.

After all, if you want to cut down on the number of drunk drivers on the road, you do not spend your patrol force’s hours sitting outside church on Sundays, you put them out side bars on Saturday nights.

Secondly, with HACCP being what it is, much of an inspector’s time  in a plant is reviewing the plant’s HACCP plan, or temperature charts for cooking, bottling or canning, or SPS plans. All of this could be done out of a central location instead of an inspector spending four out of his/her inspection hours driving from plant to plant.

They would still do unannounced, on-site inspections 2-3 times per week but we would save on mileage and maybe wages. If not wages, then we have increased inspection times in the plants when there instead of paying for windshield time.

We could call it “e-Inspection” and move into the 21st century along with our smart phones and IPads.

The Trans-Pacific trade agreement would be a slam dunk.

HIMP needs to expand even faster than it is.

Cattle feeders need to find an alternative to macrolide use to prevent liver abscesses in cattle on feed.  They are out there, they just cost more; and the macrolide class is too critical to my well-being as I age to be used to prevent an illness that does not affect the steer’s health, just the ability to sell that liver.

I would change the Veterinary Feed Directive to include over the counter, medically  important antibiotics that are added to water (about 22% of the total sales).

I would initiate a positive message about whole carcass, low dose, irradiation of beef carcasses and eliminate the necessity of using the radura symbol on that product as it too closely resembles the radiation and bioterrorism symbols that warn of danger.

I would wipe out the sale of unpasteurized milk period. No more cow shares, no more intra state sales, no more misinformed parents endangering their kids’ lives.

We would once again be able to drink milk from cows supplemented with rbST to gain another 14% milk production per cow per cycle while having a positive effect on the environment and my pocket book.

I would name Al Almanza my Undersecretary for Food Safety at the USDA, making him the first person to be chosen for that seat because of his working knowledge of FSIS and his proven abilities in that arena, and not because he had a PhD or an MD after his name (present company included).

And I just might ban the sale of raw oysters to old men who drink too much alcohol. An infection with Vibrio is just as deadly as Listeria or E coli O157:H7. It just does not kill kids, so we don’t hear much about it.

OK, that is my early Christmas wish list, and I don’t expect to find any of the above packages in my stocking or under my tree a month from now, give or take a few days, but I know my 9 year old Grandson will love his new snow board he will get that day.

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