Here is a question and answer with Mike  Taylor, Deputy Commissioner for Foods for the FDA. I submitted the questions by email and Taylor responded by email May 10.

Tom Karst: What is a typical week like for you?

Mike Taylor:
  I’ve been here 10 months and have yet to have a typical week.  Produce safety is a major priority, so I’ve been traveling across the country, listening to people who know produce so we can have the best information possible as we develop a proposed rule on preventive controls for produce.  I recently traveled to San Antonio to meet with growers and tour farms and traveled out west to Tucson, where I met with the Produce Marketing Association.  I also went to Nogales to meet with produce importers.  We have had listening sessions around the country—in North Carolina, Florida, Delaware, New York, Maryland, Georgia, Oregon, and Ohio and will have visited 13 states by the end of May.    

Karst
: What is in your inbox?  What are your top priorities now?

Taylor:   The legislation pending in Congress is something we are watching very closely, of course.  The legislation would enable FDA to codify a number of principles that are important for food safety, such as prevention, science- and risk-based controls, and ensuring that imports meet the same standards as domestically produced food. We want to be ready when the legislation passes, and that includes fundamental changes within the Foods Program so we can work effectively to implement change.  

We also are evaluating the entire farm-to-table chain to see what improvements we can make.  In addition to our work on produce safety, for example, we just released an advance notice of proposed rulemaking to request information about the food and feed transportation industry so we can gather the best information we can about hazards at this point of the farm-to-table chain.  We also are working closely with state and local governments on retail food safety, since they exercise primary regulatory control over that segment of the food industry.  And we are looking for ways to step up our consumer education efforts.

We have a number of nutrition initiatives we are working on, such as nutrition labeling, especially on the front of packages.   Menu labeling, which is a component of the health care legislation, is another key issue.  The new law requires restaurants with 20 or more locations to disclose in a clear and conspicuous manner the number of calories contained in menu items.


Karst:  Can FDA proceed to create regulations on preventive controls for produce safety without Congress first finishing its work with food safety reform legislation?

Taylor:   FDA has authority under current law to set standards to address food safety hazards--we’ve done so already for seafood and juice.  But the legislation will give us a clear mandate, bolster our authority and provide us with the tools we need to perform our role of protecting public health.  FDA will continue to do its homework on standards for safe growing, harvesting, and packing of fresh produce so we can be “ahead” of the game when Congress acts on the pending legislation.  

Karst:   If food safety is not a "one size fits all" for large farms and small farms, where are the points of differentiation? Record keeping, training, testing? How difficult is it to write regulations that allow sufficient flexibility for smaller operations? How difficult is it to create a cost/benefit analysis for food safety regulations?

Taylor:   Produce safety is one of the most technically challenging food safety tasks FDA has ever faced in terms of diversity of product, crops, geography, and other factors.  On-farm produce food safety hazards are similar for both large and small scale growers, but the risk these hazards pose differ based on exposure of the population to the hazards.  We haven’t determined what our indicators will be in the “scaleability” area – we’re looking at comments, listening to people who are doing the job every day as we make decisions going forward with this rule.  I think whatever standards we propose need to be objective enough that they can actually be enforced, clear and flexible enough so that people know what the standards are and can actually work with them; and they have to be protective but practical.  FDA’s best regulations are those that outline standards of performance and allow industry to find the best means for reaching them.

Karst:  What are the critical control points for a farm to table food safety approach for fresh produce?

Taylor:   The safety of produce can be affected at any point along the farm-to-table chain, whether it is during production, packing, transportation, storage, or preparation.  Preventive controls at the farm and packing house are critical because if contamination occurs there, it can be carried to and multiplied at subsequent points in the farm-to-table chain.  But we still have to implement preventive controls at other points in the farm-to-table chain because hazards can enter at any of these points.  

Karst: Some people in the industry are still skeptical of the estimate of 76 million food borne illnesses in a year; are you confident of that number? Of that number, how many do you estimate are caused by produce?

Taylor:   The 76 million was the best estimate by CDC when it was published in 1999.   New estimates based on new methodologies are expected this year.  Regardless of the specific number, we know that the burden of illness is considerable.  

CDC also tries to attribute illnesses to specific products or food categories, but this is very difficult to do.  CDC is working on new methods for attributing illnesses to specific foods.

Karst:  As you look ahead, where would you like to see the FDA oversight of fresh produce safety in two to three years? What are your best hopes for progress?

Taylor:    I’m optimistic that we will be able to meet the challenge—I see progress already in terms of efforts the industry is making to improve practices and the positive input we are getting from so many in the produce sector as we work to design a proposed regulation.   I don’t see what FDA is doing in produce safety as an end in itself, however, but rather as part of a comprehensive program.  Improving the safety of produce requires a broad community effort. 

FDA’s job is to set produce safety standards, but we need to work with the community – federal, state and local agencies; extension; growers and packers -- to move toward high rates of compliance with safe growing practices.  It will take education, technical assistance, and a range of other public and private efforts.  This community approach is the best way to improve practices throughout the food system that will make food safer, build public confidence, and ensure ready access to an abundant, safe supply of fresh produce.