LETTER TO REPRESENTATIVE DINGELL RE: FOOD SAFETY ACT OF 1999

February 23, 1999

SAFE FOOD COALITION
888 Seventeenth Street, NW, Suite 800,
Washington, DC 20006 (202) 822-8060

The Honorable John Dingell
United States House of Representatives
2328 Rayburn House Office Building
Washington, D.C. 20515

Dear Representative Dingell:

The undersigned members of the Safe Food Coalition -- American Public Health Association; Center for Science in the Public Interest; Consumer Federation of America; Food & Allied Services Trade Department, AFL-CIO; Government Accountability Project; National Consumers League; Public Voice for Food and Health Policy; and S.T.O.P. - Safe Tables Our Priority -- support the Imported Food Safety Act of 1999, legislation designed to improve the Food and Drug Administration's oversight of imported food products. We thank you for introducing this important legislation.

Americans are exposed to unnecessary risks from food-borne illness because the Food and Drug Administration lacks the necessary authority, technology and funding to inspect both imported and domestic food products adequately. The problem is especially critical with regard to imported food. The General Accounting Office recently issued a report documenting the fact that fewer than two percent of food products subject to FDA regulation are inspected each year, down from eight percent in 1992.

Consumers enjoy the expanded choice in food products made possible by a world market. We are not, however, prepared to trade expanded choice for basic food safety protection. Foods imported into the United States must meet the same health standards as those produced in this country.

The Imported Food Safety Act complements President Clinton's Food Safety Initiative in addressing weaknesses in FDA's inspection system. It includes:

Enhanced FDA Authority to Inspect Imported Food Products

The bill provides FDA with new authority, comparable to that already exercised by the USDA over imported meat and poultry products, to:

• Require prior approval of imported foods, including fresh fruits and vegetables;
• Prohibit importation of food if FDA has been denied the right to perform an inspection in a foreign country or if the foreign country does not provide the same level of food safety protection as the United States;
• Increase the number of inspections of imported food performed at the border;
• Manhattan Project to Develop "Real Time" Tests to Detect Pathogens

We are especially enthusiastic about the provision establishing a "Manhattan Project" to develop "real time" tests to detect pathogens such as E. coli O157:H7, salmonella, and other food-borne pathogens. "Real time" tests are those that generate results within 60 minutes. Because our government has only recently begun to address food-borne illness as a serious public health problem, there is a dearth of research on technologically sophisticated technology to prevent, detect, and destroy food-borne pathogens. Most Americans are not aware of how primitive and time consuming present detection methods are. We are confident that the project you propose can, within a short time, produce new technology that will make possible important improvements in our ability to control food-borne pathogens.

Country- of- Origin Labeling

The bill would require food subject to FDA regulation to be marked with the country of origin from its entry into the United States through to the point of retail sale. We note that, in many upscale super markets, the country of origin of fresh fruits and vegetables is prominently displayed. It is viewed as a positive marketing device. Consumers, no matter where they shop, should be able to avail themselves of basic information on the source of the food they feed their families. We would hope that you would examine the benefits of taking this provision one step further to include the farm of origin so that a contaminated product could be traced back and further problems avoided.

"User-fees" to Cover Costs of Import Inspections

We recognize the benefits of seeking a mechanism to fund the new efforts authorized in this legislation. However, members of the Safe Food Coalition have, for many years, opposed user fees for food inspection. Food safety inspections are not a service intended to benefit producers, processors or retailers, but a basic public health service provided to protect all Americans. Inspectors on the dock are cops on the beat.

It is possible both to protect the integrity of the inspection function and to provide the resources required to fund an adequate FDA program. We urge you to require both domestic and foreign food companies to register with the Food and Drug Administration and authorize the Agency to charge a nominal registration fee. This would have the joint benefit of raising revenue for the level of food safety programs we need and of giving FDA the name and address of every food processor and importer the Agency is obliged to inspect. Registration of food plants was included in legislation introduced by Representative Pallone in the last Congress (H.R. 3676).

Again, the Safe Food Coalition recognizes and appreciates the contributions you have made to improving the safety of our nation's food supply. We look forward to working with you in this new and important effort.

Sincerely,

Carol Tucker Foreman, Coordinator, Safe Food Coalition

American Public Health Association

Government Accountability Project

Center for Science in the Public Interest

National Consumers League

Consumer Federation of America

Public Voice for Food & Health Policy

Food and Allied Services Trades Department, AFL-CIO

S.T.O.P. - Safe Tables Our Priority