It has been a problem for a long time but it seems like it is getting worse and worse when we are trying to cross products and they have to stop and they are tested and it can take eight, nine ten days for the stuff to come through and we’re talking about perishable products. It has always been an issue. It will be interesting to see if we can work that through and if we can get third party laboratories accredited so we can have the testing done when the product is en route to the border or perhaps just before shipment.
I’m also interested what appears what could be two systems. So you could use a third party or accredited auditor to
do a food safety or GAP audit and a third party laboratory. But onshore domestically, it doesn’t seem that the same infrastructure is being considered. It will be interesting to see how that plays out and how much the industry can influence the FDA to take a broader view of these things and to use some the infrastructure already in place in the industry to be accommodated in the overall food safety scheme. It might be workable to have a system that uses some of the infrastructure that has already been set up by the industry.
I think the second thing that is going to be interesting is that a couple times in the legislation it talks about product testing, and where that might be used. I ‘m very interested to see how that might play out because there is a lot of duplication in the system right now. We see USDA testing programs, FDA testing program, state testing programs and contractor testing programs. There is a lot of surveillance going on. We do lots of recalls based on a positive test yet nobody is sick.
I think all of these things are simply a symptom of the fact that our testing methodologies have become very sophisticated. We can detect things, but we sometimes don’t know what that detection means. Would it really cause illness? How? What is the physiological or genetic state of that organism we find? What’s the validity of our sampling programs? What does that mean? I think FDA grappling with this just the way the industry is grappling with it and the research community is grappling with it. So how do we best use testing to monitor the effectiveness of our food safety programs? Who is best positioned to do that? What is the most efficient way to do that and share that information? Those are all questions we will have to come to grips within the next two to three years.