Can food be too safe? Attorney Ricardo Carvajal asked this question in a July 4 post to the FDA Law Blog, a daily thought piece from Washington, D.C., law firm Hyman, Phelps & McNamara.
Carvajal cites the question as one often asked to federal regulators by certain interest groups, such as raw milk or oyster aficionados. Others question whether our system of pathogen genocide—highlighted by the consumer apotheosis of hand sanitizer—could be detrimental to biodiversity or our ability to fight off infection.
Jeff Leach, in a June 20 op-ed in the New York Times, posed a similar quandary, and in so doing, praised farmers’ markets for reintroducing consumers to the dirt that naturally covers our food. Below is an excerpt from Leach’s editorial:
"Increasing evidence suggests that the alarming rise in allergic and autoimmune disorders during the past few decades is at least partly attributable to our lack of exposure to microorganisms that once covered our food and us. As nature’s blanket, the potentially pathogenic and benign microorganisms associated with the dirt that once covered every aspect of our preindustrial day guaranteed a time-honored co-evolutionary process that established 'normal' background levels and kept our bodies from overreacting to foreign bodies. This research suggests that reintroducing some of the organisms from the mud and water of our natural world would help avoid an overreaction of an otherwise healthy immune response that results in such chronic diseases as Type 1 diabetes, inflammatory bowel disease, multiple sclerosis and a host of allergic disorders."
I’m no scientist, but intuitively this speaks to me. There’s no question that it would behoove all Americans to get closer and more involved in the food they eat, but perhaps they even need to get closer to the bugs and bacteria in the soil.
Food safety is, of course, no joke. Recent tragedies—like the 2011 outbreak of listeria on Colorado cantaloupe farms, or Diamond Pet Foods massive May 2012 salmonella-related recall—call this issue into sharp relief.
The issue is especially interesting in light of federal expectations of food safety and how they may be misguided. Perhaps the issue of food safety is nuanced in ways that Congress’s most recent legislative overhaul, the 2011 Food Safety Modernization Act (FSMA), does not address.
Carvajal explains that the metrics on foodborne-illness-related deaths tossed about by Congress before the passage of FSMA were actually amended thereafter by the Centers for Disease Control for being too high.
He goes on to point out contestable language from FSMA that could bring this issue of food safety to the fore:
"FSMA’s provision on preventive controls requires the owner, operator, or agent in charge of a facility to identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility. In some instances, there could be significant divergence between a manufacturer’s and the government’s assessment of whether a given hazard is reasonably foreseeable and thereby worthy of further analysis and possible mitigation. Given the consequences that could flow from that assessment, we expect debates over the standard of 'reasonable foreseeability' to be spirited."
We know we don’t want pesticides and synthetics in our food supply. Organic has us covered on that. But do we also need to reclaim some germs at the same time? Would the government oblige?
What say you, foodmakers? Is our food too safe, or not safe enough? Share in the comments.