Improving Stakeholder Collaboration in Food Safety

Laurie Girand
FDA Public Meeting on Stakeholder Collaboration
Stanford University, Stanford, CA
March 23, 2025

Good evening.

My name is Laurie Girand. I am an Advisory Board Member of S.T.O.P.-Safe Tables Our Priority, and the mother of a child who was hospitalized with life threatening kidney failure following consumption of unpasteurized Odwalla apple juice. While your original agenda did not address the need for collaboration with stakeholders concerned about food, we felt that it was important for us to come forward to indicate that there is a need for greater collaboration with consumers about food safety, and in particular at-risk groups.

In the three years since I began working with CFSAN, CFSAN has taken giant leaps forward in an effort to keep us informed of CFSAN's activities, and for this we are extremely grateful. Inquiries that went unreturned three years ago, are politely and promptly returned today. Even out here in California, we now receive notice of Federal Register documents. We credit Joe Levitt with taking enormous strides forward within CFSAN by making it responsive to parties that express interest.

Still, there is so much more we could ask for. Consumer groups may not be able to offer FDA the funding opportunities that would make us perfect partners for ambitious research projects, but we have expertise and constituencies to offer. Our ideas tonight focus on the creation of messages for consumers and the chain of communication by which they may ultimately arrive at the target audience.

Here are our suggestions:

1. First, it is crucial that your overall publity and education campaigns effectively target consumers. FDA needs to evaluate the effectiveness of its publicity and education campaigns for food safety. Last year, you issued an important press release warning consumers about health hazards associated with sprouts. To date, we have been unable to find anyone that has heard of this warning. We believe that the format of your publicity about recalls and food safety warnings is not conducive toward greater publicity. Similar to the situation with sprouts, you tend to issue a press release and then wait for the press to call. Consumers would suggest you need a standard format, such as a chart, that you can issue to newspapers weekly or biweekly. With a standard format, the press could just republish the box, instead of assigning a writer to generate an article around the data. Readers would become familiar with such a box and learn to look for it.
2. Second, messages directed toward consumers should be run past consumer groups before they go into print. You produce campaigns where the most critical information, like the fact that a disease is life threatening, is buried. You overpromote nutritional information, while spending virtually no publicity time or money on warnings. In my own family's sad situation we were led by FDA promotions to believe that juice qualified as one of the daily servings of fruit and vegetables. No one said it should be pasteurized juice. Consumer groups can offer you the broad perspective you need to understand the impact of your combined campaigns while helping to ensure that the right messages come through. Here's an example. You recently had your risk assessment department develop a list of questions directed toward focus groups about Listeria in order to help develop messages. Though S.T.O.P. has victims who have suffered the worst from Listeria, we have yet to be asked to review focus group questions to determine if they would have changed victims' behavior prior to their illness. We have valuable information to offer, and await the chance to become involved.
3. Third, the distribution channel for the bulk of your food safety educational programs is places where nutrition and cooking are taught; yet, the at-risk groups generally aren't going there. Instead, you need to work with key consituencies and authorities who can deliver the message, including the AARP, the National PTA, the American Academy of Pediatrics, the American College of Obstetricians and Gynecologists, and you need to target the audiences for when they are most receptive to information through the most popular avenues, such as the book "What to Expect When You're Expecting" for pregnant women. Here's an example of the type of program FDA should do to target food safety messages toward parents. At S.T.O.P., we have developed a brochure called "So Your Baby Is Starting Solids..." From a timing standpoint, it targets parents at the point at which they need to be most wary and at a point at which they are receptive to new information. It describes all the foods a parent should be concerned about today, and, importantly, WHY they should be cautious. It could be distributed by pediatricians...we have the relationship with the right person at the AAP. As a nonprofit, we don't have the money to produce it. But you do.
4. Fourth, if you want to use the internet most effectively, it would be very inexpensive to develop an e-mail information distribution channel. There are internet sites devoted to health targeting very specific groups: parents, arthritis patients, AIDS patients. The parent sites already pick up recall information from Consumer Product Safety Commission and the NTSI. They are thrilled to have current information of value to their constituencies. You could pay a college intern almost nothing to set this up a system of notification about recalls and outbreaks; yet, you would see instant results.
5. Lastly, you should be aware that pathogenic food safety appears is an area of FDA that does not have a single consumer on its advisory panels. We ask that you address this oversight.

We greatly appreciate the opportunity to speak to you today about the critical area of consumer collaboration with the agency. Thank you very much.