Were Statistics on Food-borne Illnesses Manipulated for Political Reasons?

That seems to be the implication of a couple blog posts by Richard Raymond in his meatingplace.com blog.  Raymond isn't just some lackey - he is the former USDA undersecretary of agriculture for food safety. ​

In his first post, Raymond pointed out that:​

. . . it seems the CDC is reluctant to come right out and say that [our food is safer today than fiver years ago]. In fact, they have qualifiers advising people not to make that assumption.

Could the reason be that there needed to be data to support the new FSMA?  

Before the Food Safety Modernization Act (FSMA) was passed, the CDC, politicians and food safety advocates all quoted the CDC report that claimed 72 million Americans fell sick to a foodborne illness every year.

Within a week after the FSMA was signed into law, CDC had adjusted that number to 48 million, but said to draw no conclusions as to an increasingly safe food supply because they used different “multipliers”, etc.

Now it is down to 9.4 million foodborne illnesses caused by “known pathogens.”

​In his second post, Raymond went further:

Is data manipulated? Remember all those Iraqi weapons of mass destruction we saw pictures of and form you own conclusion.

Is data manipulated? How did we suddenly go from an estimated 72 million Americans suffering a foodborne illness per year to just 48 million within one week of signing the Food Safety Modernization Act into law.

and

Are there hidden agendas in DC? Most are pretty open if you read between the lines, and the agendas have been heavily discussed and debated during election campaigns, etc.

I personally think the bigger hidden agendas sometimes involve persons and/or groups wanting to reduce or do away with the consumption of meat under the disguise of promoting animal welfare and food safety.  . . .

Can we trust the government to always report the truth? Sometimes I wonder.

Animal Welfare and Food Safety

Food Safety Magazine just published an article Bailey Norwood and I wrote on animal welfare and food safety.  

Here are a few excerpts:

The premise of [the movie] Contagion is that raising hogs on “factory farms” encourages the emergence of deadly pathogens. How accurate is this caricature? In reality, a bat is more likely to drop food near hogs or chickens raised outdoors. Would the movie have been more realistic if the bat infected a pig raised on an organic farm, a farm where animals roamed “free range,” or a farm owned by a small producer slaughtering his own animals and selling locally? Or would a more accurate film show the bat shedding feces near a field of broccoli, sickening people consuming fruits and vegetables instead of meat? Is it true that animal welfare and food safety are trade-offs, or are they instead complements? When we pay more for humane meat, are we also getting safer food or are we accepting greater risk? These are the questions we investigate in the present article.

and

Americans today consume more poultry than any other meat product so even if a meal containing poultry is safer than beef or pork, more illnesses may result from poultry consumption simply because chicken is consumed on such a large scale. Using the data in Table 1 to claim poultry is risky is a bit like claiming roads in Texas are more dangerous than those in Wyoming simply because more Texans die in car crashes—however, the population size of the two states would seem the more logical culprit. Analogously, the volume and value of the food should be taken into consideration when comparing risks. Consumers might voluntarily accept riskier food if they value it more.

and in summary:

In general, production systems that provide animals outdoor access have the potential to expose animals to pathogens, viruses and other parasites. In some cases, it appears that this potential is realized. However, in other cases, perhaps due to effects of lower stocking densities or better managerial competence, the risks can be alleviated or even reversed. In short, animal housing conditions are but one factor, and a far from deciding factor, affecting food safety.

However, consumers don’t always see it that way. Consumers conflate perceptions of safety with perceptions of animal welfare. They are not necessarily irrational in doing so, as care and managerial competence in one domain are likely to be correlated with meticulousness in another. 

Meet Your Meat

I just returned from giving at talk at the International Production and Processing Expo (IPPE) in Atlanta.  According to the organizers, there were over 25,000 people in attendance from all aspects of the livestock, poultry, and egg production and processing industries.  I don't think it would be much of an exaggeration (in fact it may be an under-estimation) to say that there were two football field sized halls full of exhibits.  

While the expo was filled with lots of folks involved in livestock and meat production, I wish the "average" food consumer could have walked through the place (you can get a brief glance by checking out the video at the bottom of this page).  What they would have seen is an overwhelming number of technological marvels designed to make meat and eggs safer, tastier, healthier, and less expensive.  There were new insulated boxes to make shipping safer and more convenient, egg production facilities that were larger and provided more amenities for hens, automated technologies that keep workers from having to engage in some of the more unpleasant parts of the slaughter process, new medicines to improve animal health, technologies to improve worker health, new spices and flavors to improve taste, and on and on.  

There are those who seem to want agribusiness and large farms out of agriculture.  But, where do they think improvements in health, safety, and quality originate?  I hear a lot about the need to improve transparency in agriculture.  My advice to the event organizers for next year?  Give out a slew of tickets to the general public.  If the general public is more troubled than comforted by what they see, the meat industry really is doomed.  

PETA has a video and exhibition featuring Paul McCartney called "glass walls."  McCartney claims that if meat processing facilities had glass walls, everyone would be vegetarian.  There are thousands of years of human experience (during which the typical person was "closer" to animal agriculture) that would seem to contradict McCartney's claim.  Although I could be wrong, I think a visit to something like the IPPE (and making the walls glass) would have exactly the opposite effect McCartney claims.      

The Cost of Environmentalism

What is the impact of a ban on plastic bags used by grocery stores?  Unexpectedly, it is higher chances of foodborne illness.  Apparently carting around that same old bag back-and-forth to the grocery story also means carting around bacteria to-and-from the grocery store.  

Musings on the Food Safety Modernization Act

We all want safe food.  Right?  It's hard to argue with the intentions behind the new Food Safety Modernization Act (FSMA).  Indeed, when I've asked people on surveys, they almost always say that food safety is one of the most important food issues to them and that they support stricter government rules and government spending on food safety.  

I haven't weighed in much on the FSMA because before now I haven't taken the time to really dig into the meat of the rules.  However, the FDA recently released drafts of the proposed rules, so now is probably as good a time as any to start digging in.

My first thought after reading through the text of the law and the proposed rules is how overwhelming it all is.  Its like trying to read the IRS documents on how to fill out your taxes but even worse.  In this regard, its not any different than many other federal rules, but I suspect most people who say they want more food safety on surveys have never taken the time to read through these things (here is the text of the law; proposed rules are here; or see the 547 page document here).  I agree with a lot of the spirit of what the FDA is trying to do here (in short, firms have to create a "plan" for managing food safety that it is risk based), but if I put myself in the shoes of a food company owner, and tried to read these documents, I think I'd faint.  

Just to given one simple example, one of the proposed rules begins by indicating who the rules apply to, and answering this question is no easy task (we haven't even gotten to a description of what the rules are).  Here is but one exception to the rule: 

The proposed rule would provide a qualified exemption and modified requirements for farms that meet two requirements: (1) the farm must have food sales averaging less than $500,000 per year during the last three years; and (2) the farm’s sales to qualified end users must exceed sales to others. A qualified end-user is either (a) the consumer of the food or (b) a restaurant or retail food establishment that is located in the same State as the farm or not more than 275 miles away. Instead, these farms would be required to include their name and complete business address either on the label of the produce that would otherwise be covered . . . or at the point of purchase.  This exemption may be withdrawn in the event of an active investigation of an outbreak that is directly linked to the farm, or if it is necessary to protect the public health and prevent or mitigate an outbreak based on conduct or conditions on the farm that are material to the safety of the produce.

In other words, if you sell at farmers' markets or to nearby restaurants, you don't have to comply (because apparently you are incapable of selling unsafe food??).  Oh, but we want your name on the produce anyway.  And, if we think it's necessary, we will make you comply anyway, so basically you're not exempt.

At the end of the day, the question is: will the costs of the rule generate more benefits than costs.  And, while I appreciate the FDA's work in trying to answer this question (I've done similar calculations on other topics myself), we have to say: we really don't have a clue.  The agency conducted a regulatory impact analysis (see document 194 here).  In their own words, they:

lack sufficient information to fully estimate the proposed rule’s likely benefits

and they later say that:

. . . quantification of the human health benefits derived from this rule is difficult and complex . . .

One thing that struck me is the actual hard data on how many people are affected by the food safety outbreaks the FSMA is supposed to prevent.  Here is my re-working of one of their tables:

So, we have a law that will create roughly $1 billion annually (for the first few years) in costs.  And the actual hard evidence we have is that there were 37.5 annual hospitalizations and 1.7 annual deaths from the foods covered by the FSMA.  That's about $27 million in cost for every confirmed hospitalization or $588 million for every confirmed death.  

The authors rightly point out that these illness/death numbers are probably under-estimates of the true number of cases.  But, the extrapolations are - to put it bluntly - wild guesses based on the evidence of a single study.  They do ask:

We seek comment on our assumption that the share of illnesses caused by unknown pathogens that are attributable to food covered by this rulemaking is equal to the share of illnesses caused by known pathogens that are attributable to food covered by this rulemaking.

But I wonder if this is even knowable.  Even more difficult to ascertain is how implementation of FSMA will change the number of annual illnesses.  The impact report does the best it can to cobble together the available evidence, but it is simply sparse, and it often amounts to comparing companies who have already adopted plans like those mandated by FSMA to those who haven't.  But, surely selection is playing a big role here (i.e., the firms adopting food safety plans were already the kinds of companies that were going to have higher food safety than companies who weren't) and comparing these two types of firms does not give a causal impact of FSMA.    

As I said at the onset, the public seems to favor more food safety regulation.  But it sure is messy seeing the sausage being made.  And, I suspect fewer people would want the sausage if they took the time to see its proverbial production process.