Limitations of Current Monitoring

The food supply system is sufficiently large that direct monitoring for biological contaminants, as is being contemplated for the water system, is not feasible. Security of the food chain against accidental contamination is achieved through a combination of supplier initiatives designed to protect their businesses as well as federal and state regulations and inspections. Although the food industry's procedures work well to contain the impact of most food-related outbreaks, their limitations currently preclude the early detection advocated by the government for bioterrorism incidents. In essence, despite the potential represented by data sources we discussed earlier, current efforts to protect the population from contaminated food are limited to trace-back methods. More proactive measures are not in use because of prohibitive cost and lack of appropriate tools.

In the event of a contamination, trace-back investigation is the basis for limiting the extent of the event and preventing future events. Although the logistical aspects of a trace-back may appear straight forward to the casual observer, they are not. The information systems of the supply chains are not vertically integrated. Each entity knows only to whom they shipped or from whom they received food; even this information may be incomplete, as the wholesale warehouse will know which suppliers sell which foods but may not have lot numbers and dates available for immediate inspection.

One consequence of this situation is that, although tracing the source of a can of spoiled or contaminated green beans with a known lot number is relatively quick and easy, tracking the source or ultimate destination of foodstuffs reported by public health with unknown lot numbers remains a painstaking, tedious process. For this reason, the FDA proposed rules that would require food suppliers to be able to quickly locate food items at every level of the supply chain. The proposal met with fierce resistance, mostly related to the high cost of the requisite technology. The bar codes present today on product labels, which can be found on every American supermarket shelf, are inadequate to contain the requested data. Suppliers have concluded that enlarged bar codes would still not accomplish the main goal; instead, food suppliers are examining the value of radio-frequency identification (RFID) transponders to allow food shipments to be identified and located anywhere in the supply chain. They want to equip each case and, even individual containers, of food with transponder chips; however, they judge the hardware available today as far too expensive. Moreover, businesses at different levels of the food supply chain (growers, packers, wholesale distributors and retail stores) have not yet agreed how to divide the bill for such hardware.

Without a financing plan approved at every level, or government support, the necessary investment will not occur.

In June 2002, Congress passed the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (Bioterrorism Act, Public Law 107-188), which President Bush signed into law on June 12, 2002. In October 2003, the FDA sent a report to Congress titled "Testing for Rapid Detection of Adulteration of Food.'' Congress wrote Title III of this law to empower the FDA to protect the food supply against terrorism and other threats (FDA, 2003).

The law's writers emphasized the FDA's authority to collect information about imported foods and to inspect incoming food shipments. Because rapid detection of adulterated foods is of high priority, Congress directed the Department of Health and Human Resources (HHS) to conduct research to determine the effectiveness of various techniques and technologies in detecting contamination in food, including biologic agents, chemical agents, and radioactive materials. Another research focus involves validating methods characterizing microbes that can work well in handheld kits.

In December 2004, to the consternation of the food distribution industry, the FDA took the first steps to requiring companies to track food distribution from one level to the next; the agency-issued regulations to interpret and administer the Bioterrorism Act. 21 CFR Parts 1 and 11 specify that persons involved in the processing, packaging, and distribution of food must maintain records regarding both the sources of the foods they receive and the recipients to whom they sell the food. The regulations apply principally to wholesale distributors, packers, importers, and others (The Federal Register, 2004).

Although the industry is complying, the thin margins inherent in the food distribution system, which includes processors, distributors, and retail stores, preclude heavy investment in new forms of information technology necessary to create a true "farm to dinner table'' database.Thus, although the industry creates records to comply with federal law, these records may not provide the kind of access required for effective early detection of inadvertent or purposeful contamination.

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