Managing Global Risk

The globalization of food has brought significant benefit to U.S. consumers, including increased product options and availability of previously less attainable foods. However, the growth of global trade also brings increased food safety risk, particularly to the aging population of the U.S. which is more susceptible to foodborne disease, said Richard Williams, director for policy research, Mercatus Center at George Mason University, Arlington, Va.

According to both Williams and Sandra Hoffman, co-author of the 2010 Resources for the Future discussion paper, “Food Safety and Risk Governance in Globalized Markets,” food safety, particularly infectious foodborne illness, is a significant and increasing global health concern.

But, Williams added, such risks, though increasing, are not new. “I don’t look at these as emerging risks as much as existing risks that we haven’t been able to do anything about,” he said. “I think the risks have always been with us. The question is what can we do with this?”

The answer, he believes, lies in business incentives and technology rather than regulation, while Hoffman also sees a helpful component as being the establishment of risk-based standards.

“A second generation of food policy reform is emerging,” said Hoffman in the discussion paper, written with William Harder. At the heart of which, she said, “is an emerging global consensus on the need for a risk-based, scientifically supported, integrated farm-to-fork policy.”

This is primarily due to the increase in foodborne disease, Hoffman noted. “Over the last two to three decades, foodborne infectious disease has emerged as the primary health concern driving food policy.” However, globalization has complicated the management of the foodborne hazards.

 In many of the developing countries, rapid urbanization is taking place that is accompanied by a shift from home to commercial food production and a need for training in related food hygiene practices, as well as a reemergence of problems of intentional adulteration for economic gain.

With U.S. imports continuing to rise, care must be taken, she said. “Without care, imported foods can also effectively result in the importation of another country’s sanitation problem.”

Hoffman sees those as able to make significant contributions to fleshing out globalized food policy reform as being, in particular, economists, food scientists and public health analysts.

Technology. In the past, Williams said, much of the progress that was made in food safety reform was through technological innovation rather than regulation. “The history of food safety shows that technology is where you get quantum leaps.”

Where the government could be of benefit, however, is in communication of the technologies. Too many innovations have been stifled because of the opposition of anti- factions. Noting irradiation as an example, Williams said, “There is literally zero risk to irradiated foods.” However, the new technology lost implementation because of the highly publicized resistance to it.

Because it can appear to be self-serving when promoted by industry, communication of innovation would be a good role for the government, particularly where there are problems with acceptance, he explained. He sees this as important today, as new developments which show great promise, such as nanotechnology, are also facing similar non-science-based resistance. “That’s what we need to guard against in the future,” he said.

Business Incentives. But the most promise that Williams sees in technology is in its creation of increased incentive for food manufacturers to take care of themselves. The example Williams gave in this arena was that of traceability.

The business impact of a contaminated food being traced back to one’s production can be much more personal and hard-hitting than that of a regulatory infraction in an inspection—particularly when one’s brand is implicated in the media.

“That will make much more of a difference than trying to inspect your way to food safety,” Williams said. “As we improve traceback and people find they have to take due diligence, that will make much more of a difference.

“It is easy to say, ‘You should be responsible”; what works, though, is to say, ‘Your liability will be affected,’” he said.

Williams also sees this as effective in food defense as well as food safety. “No matter who it is, you don’t want your food to be poisoned accidentally or on purpose.”

In addition, incentives can extend to employees themselves. Williams discussed one manufacturer who has a company store and “sells product to employees so cheaply that they can’t afford not to buy it.” This works because when you are part of the processing of a product you know your own family may be eating, it becomes personal, and you are likely to have even greater awareness of and care for the safety of that product.

“Anything you can do to provide increased incentive is better than the regulate-and-inspect approach,” Williams said.

Hoffman agreed with the concept of incentives, noting that the U.S. has been central to development of international consensus on modernizing food safety policy, based on business and national incentives. “This consensus is enforced by economic incentives such as the desire of multinational food firms to avoid disruption and liability and protect their brand names and market share. It is also enforced by the desire of national governments to promote their countries’ exports. And ultimately, it is enforced by the threat of trade sanctions and by national law.”

Regulation. Both Hoffman and Williams agree that “one size fits all” international regulation is not the answer, as cultural and other variations between nations must be taken into consideration both in applying U.S. standards to the world as well as attempting to apply other nation’s standards to the U.S. Hoffman explained that “an independent mind needs to be brought to the adaptation of international guidance to U.S. conditions.” Just as extreme situations, such as major recalls, have sometimes had extreme impact on U.S. regulation, “so too do domestic crises in other countries influence their laws and their roles in international negotiations in ways that may not provide wise guidance for the United States.”

Although the recently passed Food Safety Modernization Act includes regulations for increased international inspections by the FDA, Williams does not see regulation as the solution. Not only are there the well-published issues of inadequate FDA resources and funding for increased international inspections, but also, he said, international law says that such inspections can only be made if one is invited into the country. If the U.S. were to reciprocate by stating that no products can then be bought from that country, it could be construed as an unfair trade barrier, he said.

On the other hand, Williams said, a U.S. manufacturer could legally set similar restrictions on a foreign supplier. “If you are an importer, you can say that the only way I will use your products is if I come inspect your plants.

“That will make much more of a difference—if the incentive is on them because that product can be traced back.” In addition, he said, the large manufacturers who are importing product have greater resources to put toward such traceback than does the government.

But it is not simply the legalities of the regulation to which Williams takes exception. “The idea that we’re going to regulate or inspect our way to safer food is not going to work,” he said.

“We’ve had a domestic approach for over 100 years of top-down regulation. I understand why people are attracted to that approach, but I worry that it detracts from more positive, real solutions to the problem.

“Plants are different. Cultures are different. People are different,” he said. “The idea that there is a one-size-fits-all approach around the world—I don’t think that that will be tremendously useful.”