Integrating the Nation’s Food Safety System: What You Need to Know
In 1939, Connecticut Dairy and Food Commissioner E.G. Woodward was the vice president of the Association of Food and Drug Officials (AFDO) and expressed the following in the organization’s quarterly bulletin:
“The greatest single program of work before the Association is to follow through with its efforts for uniformity in state legislation until this whole nation has an integrated system of similar Food, Drug, and Cosmetic Laws, interpreted, administered, and enforced in a single spirit of uniformity.”
Little did Commissioner Woodward know that his words would become the hallmark issue for AFDO and that the organization would formally issue its vision for an integrated food safety system (IFSS) that would be validated in 2011 with the passage of the Food Safety Modernization Act (FSMA).
A Bit of History
Since 1896, AFDO has fought for uniformity among federal and state regulators in a number of ways. The organization was a strong advocate of the 1906 Pure Food and Drug Act and the 1938 Food, Drug and Cosmetic Act and even sent its legislative committee to Washington to argue for passage of them.
Passage of the 1906 measure in Congress was not assured, but lobbying by the association was vocal and well funded. Some members of Congress opposed the bill as being unconstitutional. President Theodore Roosevelt, however, overcame lawmakers’ objections and signed the landmark law. He was also very much repulsed by slaughterhouse practices that were described in Upton Sinclair’s book The Jungle and signed the Meat Inspection Act that same year. The country now had statutes dedicated to protection against the adulteration of food and drugs.
In 1913, AFDO requested that the U.S. Food and Drug Administration (FDA) form an Office of State Cooperation that would later become the Division of Federal State Relations and eventually the FDA Office of Partnerships. Today, the Office of Partnerships is a key promoter of an IFSS and has a dedicated staff that works with state and local food safety managers to advance this cause.
In 1927, AFDO approved adoption of a Model Uniform Food Law, which provided a basic food law model for the states to consider adopting. This model law identified foundational authorities and powers that state programs needed for effective enforcement of food safety laws. This model law is still useful today, as FDA and states begin implementing produce safety requirements at fresh produce farms—an arena traditionally absent of inspection and governmental oversight.
In 1937, a Tennessee drug company marketed a form of a new sulfa drug elixir, sulfanilamide. However, the solvent in this untested product was a highly toxic chemical analogue of antifreeze. Following the marketing of this product, more than 100 people would die, causing an enormous public outcry. The event resulted in the passage of the Food, Drug, and Cosmetic Act signed into law by President Franklin Roosevelt. The act completely overhauled the public health system and authorized FDA to demand evidence of safety for new drugs, to issue standards for food and to conduct inspections.
Another result of this tragic episode was the nationally coordinated effort by FDA and the states to track down any remaining sulfanilamide in the marketplace to prevent further deaths. This task was performed by all 239 FDA field officials and a multitude of state and local officials. This coordinated effort led to the retrieval of 234 of the 240 gallons of product believed to be marketed and was one of the first clear illustrations of what government agencies could accomplish by working closely together in a more integrated fashion.
“The NFSS project never really died—it just continued to evolve as all great ideas do. All those visions that were conceived through NFSS are still alive today. We may have changed presidents and changed the names of the food safety initiatives the nation would follow, but we never changed our strongly held belief in a fully integrated food safety system.”