Overseeing the U.S. Food Supply: Steps Should be Taken to Reduce Overlapping Inspections and Related Activities
Published: 2005-05-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: GAO has issued many reports documenting problems resulting from the fragmented nature of the federal food safety system--a system based on 30 primary laws. This testimony summarizes GAO's most recent work on the federal system for ensuring the safety of the U.S. food supply. It provides (1) an overview of food safety functions, (2) examples of overlapping and duplicative inspection and training activities, and (3) observations on efforts to better manage the system through interagency agreements. It also provides information on other countries' experiences with consolidation and the views of key stakeholders on possible consolidation in the United States.
section_title: What GAO Found
paragraphs: USDA and FDA have primary responsibility for overseeing the safety of the U.S. food supply; the Environmental Protection Agency (EPA) and the National Marine Fisheries Service also play key roles. In carrying out their responsibilities, these agencies spend resources on a number of overlapping activities, particularly inspection/enforcement, training, research, and rulemaking, for both domestic and imported food. For example, both USDA and FDA conduct similar inspections at 1,451 dual jurisdiction establishments--facilities that produce foods regulated by both agencies. To better manage the fragmented federal system, these agencies have entered into at least 71 interagency agreements--about a third of them highlight the need to reduce duplication and overlap or make efficient and effective use of resources. The agencies do not take full advantage of these agreements because they do not have adequate mechanisms for tracking them and, in some cases, do not fully implement them. Selected industry associations, food companies, consumer groups, and academic experts disagree on the extent of overlap, on how best to improve the federal system, and on whether to consolidate food safety-related functions into a single agency. However, they agreed that laws and regulations should be modernized to more effectively and efficiently control food safety hazards. As GAO recently reported, Canada, Denmark, Ireland, Germany, the Netherlands, New Zealand, and the United Kingdom also had fragmented systems. These countries took steps to consolidate food safety functions--each country modified its food safety laws and established a single agency to lead food safety management or enforcement of food safety legislation.

section_title: Letter
paragraphs: I am pleased to be here today to address the Subcommittee’s interest in  examining the potential for reorganizing the federal system for ensuring  the safety of the U.S. food supply. As the Comptroller General recently  testified, there is a need to bring government and its programs in line with  21st century realities. He noted that many, if not most, current federal  programs and policies, were designed decades ago to respond to trends  and challenges that existed at the time. These programs can be updated  and modernized by improving their targeting and efficiency through,  among other things, consolidating facilities and programs and streamlining  and reengineering operations and processes. The Comptroller General  specifically cited the federal food safety system as an area where  opportunities for crosscutting program integration exist.
In testimony last year before this Subcommittee, we described the  fragmented nature of our federal food safety system—one based on 30  principal laws related to food safety that are administered by 15 agencies.  We stated that the patchwork nature of the system governing inspection  and related activities hampers efforts to address the risks of inadvertent or  deliberate food contamination. Under this system, different agencies are  responsible for specific food commodities and have significantly different  authorities for carrying out these responsibilities. As a result, federal  agencies are spending resources on similar activities to ensure that the  food supply is safe, wholesome, and appropriately labeled. For example,  Food and Drug Administration (FDA) inspectors examine seafood  processors; U.S. Department of Agriculture (USDA) inspectors examine  meat- and poultry-processing facilities; and both agencies inspect the same  food-processing facilities if the facilities produce food products under the  jurisdiction of both agencies. For example, USDA inspects a canning  facility that produces soup containing meat or poultry; if the facility also  produces soup containing seafood, FDA inspects it as well. USDA spent  $665 million and FDA spent $219 million, totaling $884 million—and  dedicated 8,787 and 1,844 full-time equivalent staff, respectively—for  inspection and enforcement activities in fiscal year 2003. USDA and FDA  provided updated expenditures for fiscal year 2004 totaling $958 million— and dedicated 8,733 and 1,812 full-time equivalent staff, respectively, for  these activities.
We have recommended changes to the federal system for ensuring the  safety of our food supply. In particular, we recommended that the  Congress consider enacting comprehensive, uniform, and risk-based food  safety legislation to streamline inspection and enforcement efforts, and  consolidate food safety functions by establishing a single, independent  food safety agency or by designating one current agency as the lead  agency for all food safety inspection matters. Such an overhaul would  enable the federal system to more effectively and efficiently accomplish its  mission and meet new food safety challenges, such as the emerging  concerns about the deliberate contamination of our food supply through  bioterrorism.
In my testimony today, I will discuss GAO’s most recent work conducted  at the request of this Subcommittee and other Congressional requesters.  This GAO report, which is being released today, examines the need to  reduce overlap and better leverage resources. It provides (1) an overview  of the government’s food safety functions, activities, and expenditures, (2)  specific examples of overlapping and, at times, duplicative inspection and  training activities, and (3) observations on the agencies’ efforts to manage  this fragmented system through dozens of interagency agreements. At your  request, I will also provide a synopsis of selected industry and other  stakeholders’ views on the current federal approach to food inspection.  Finally, I will offer some observations on the experiences of several  countries that have recently undertaken consolidation efforts to achieve  more effective and efficient management of their food safety programs;  these observations are based on our recent report on foreign countries’  experiences consolidating food safety functions and activities. My  testimony also draws on our wide-ranging past reports and testimonies on  the fragmented nature of the federal system and upon completed work and  previous testimonies on issues related to government organization and  transformation. (See app. II.) We conducted our work in accordance with  generally accepted government auditing standards.
In the interest of clarity, I want to note at the outset that we are defining  overlaps as similar food safety-related activities being performed by more  than one agency—such as the training of food inspectors. We are defining  duplication as essentially identical activities performed by more than one  agency—such as inspecting the same food-processing facility for  compliance with sanitation and/or good manufacturing practices  requirements.
subsections: section_title: Background
paragraphs: The safety and quality of the U.S. food supply is governed by a highly  complex system stemming from 30 principal laws related to food safety  that are administered by 15 agencies. In addition, dozens of interagency  agreements are intended to address a wide range of food safety-related  activities. The federal system is supplemented by the states, which have  their own statutes, regulations, and agencies for regulating and inspecting  the safety and quality of food products. USDA and FDA, within the  Department of Health and Human Services, have most of the regulatory  responsibilities for ensuring the safety of the nation’s food supply and  account for most federal food safety spending. Under the Federal Meat  Inspection Act, the Poultry Products Inspection Act, and the Egg Products  Inspection Act, USDA is responsible for the safety of meat, poultry, and  certain egg products. FDA, under the Federal Food, Drug and Cosmetic  Act, and the Public Health Service Act, regulates all other foods, including  whole (or shell) eggs, seafood, milk, grain products, and fruits and  vegetables. Appendix 1 summarizes the agencies’ food safety  responsibilities.
The existing statutes also give the agencies different regulatory and  enforcement authorities. For example, food products under FDA’s  jurisdiction may be marketed without the agency’s prior approval. On the  other hand, food products under USDA’s jurisdiction must generally be  inspected and approved as meeting federal standards before being sold to  the public. Under current law, UDSA inspectors maintain continuous  inspection at slaughter facilities and examine each slaughtered meat and  poultry carcass. They also visit each processing facility at least once  during each operating day. For foods under FDA’s jurisdiction, however,  federal law does not mandate the frequency of inspections (which FDA  typically conducts every 1 to 5 years). Although recent legislative changes  have strengthened FDA’s enforcement authorities, the division of  inspection authorities and other food safety responsibilities has not  changed.
As we have reported, USDA traditionally has had more comprehensive  enforcement authority than FDA; however, the Public Health Security and  Bioterrorism Preparedness and Response Act of 2002 granted FDA  additional enforcement authorities that are similar to USDA’s. For  example, FDA now requires all food processors to register with the agency  so that they can be inspected. FDA also has the authority to temporarily  detain food products when it has credible evidence that the products  present a threat of serious adverse health consequences. Moreover, FDA  requires that entities such as the manufacturers, processors, and receivers  of imported foods keep records so that FDA can identify the immediate  previous source and the immediate subsequent recipients of food. This  record-keeping authority is designed to help FDA track foods in the event  of future health emergencies, such as terrorism-related contamination. In  addition, FDA now requires advance notice of imported food shipments  under its jurisdiction. Despite these additional authorities, important  differences remain between the agencies’ inspection and enforcement  authorities. For example, the Federal Meat Inspection Act and the Poultry  Products Inspection Act require that meat and poultry products be  inspected and approved for sale (i.e., stamped by USDA inspectors). The  Federal Food, Drug and Cosmetic Act does not require premarket  approval, in general, for FDA-regulated food products.
Finally, following the events of September 11, 2001, in addition to their  established food safety and quality responsibilities, the federal agencies  began to address the potential for deliberate contamination of agriculture  and food products. In 2001, by executive order, the President added the  food industry to the list of critical infrastructure sectors that need  protection from possible terrorist attack. As a result of this order, the  Homeland Security Act of 2002 establishing the Department of Homeland  Security, and subsequent presidential directives, the Department of  Homeland Security provides overall coordination on how to protect the  U.S. food supply from deliberate contamination. The Public Health  Security and Bioterrorism Preparedness and Response Act of 2002 also  included numerous provisions to strengthen and enhance food safety and  security.
Many proposals have been made to consolidate the U.S. food safety  system. In 2001, parallel Senate and House bills proposed consolidating  inspections and other food safety responsibilities in a single independent  agency. In 2004 and 2005, legislation was again introduced in the Senate  and the House to establish a single food safety agency. This proposed  legislation would combine the two food safety regulatory programs of  USDA and FDA, along with a voluntary seafood inspection program  operated by the National Marines Fisheries Service (NMFS) in the  Department of Commerce. In addition, in 1998, the National Academy of  Sciences recommended integrating the U.S. food safety system and  suggested several options, including a single food safety agency. More  recently, the National Commission on the Public Service recommended  that government programs designed to achieve similar outcomes be  combined into one agency and that agencies with similar or related  missions be combined into large departments. The commission chairman  testified before the Congress that important health and safety protections  fail when responsibility for regulation is dispersed among several  departments, as is the case with the U.S. system.
section_title: Federal Agencies’ Food Safety-Related Functions, Activities, and Expenditures
paragraphs: The four agencies we examined—USDA, FDA, the Environmental  Protection Agency (EPA), and NMFS—are involved in key program  functions related to food safety. These functions include inspection and  enforcement, research, risk assessment, education and outreach,  rulemaking and standard setting, surveillance and monitoring, food  security, and administration. These agencies spend resources on similar  food safety activities to ensure the safety of different food products.   Table 1 illustrates similar activities that these agencies conduct.
In fiscal year 2003, the four federal agencies spent nearly $1.7 billion on  food safety-related activities. As figure 1 shows, USDA and FDA together  are responsible for nearly 90 percent of federal expenditures for food  safety.
As figure 2 shows, most of the agencies’ expenditures were incurred for  inspection/enforcement activities, including inspections of domestic and  imported food. However, these expenditures are not based on the volume  of foods regulated by the agencies or consumed by the public. USDA’s  activities account for almost three-quarters of the agencies’ inspection and  enforcement expenditures. That is, the majority of federal expenditures  for food safety inspection are directed toward USDA’s programs for  ensuring the safety of meat, poultry, and egg products; however, USDA is  responsible for regulating about 20 percent of the food supply. In contrast,  FDA, which is responsible for regulating about 80 percent of the food  supply, accounted for only about 24 percent of these expenditures.
section_title: Federal Food Safety Agencies Conduct Overlapping Activities
paragraphs: As a result of the multiple laws governing food safety, several federal  agencies conduct activities—inspections of domestic and imported foods,  training, research, risk assessment, education, and rulemaking—that can  serve overlapping, if not identical, purposes.
subsections: section_title: USDA and FDA Inspections of Jointly Regulated Facilities Overlap
paragraphs: USDA and FDA conduct overlapping, and even duplicative, inspections at  more than 1,400 domestic facilities that produce foods such as canned  goods and frozen entrees. Both agencies inspect these facilities because  each has statutory responsibility for the safety of different foods or food  ingredients. USDA inspects canning facilities at least daily if the company  produces canned beans containing meat and poultry. If the facility  produces canned beans without meat or poultry, FDA also inspects it, with  a frequency ranging from 1 to 5 years. USDA and FDA inspections have  common features—both agencies spend inspection resources to verify that  facilities are sanitary and follow good manufacturing practices, such as  verifying that facilities do not have rodent or insect infestations.
At jointly regulated facilities, both USDA and FDA inspectors verify that  HACCP systems are in place. In these instances, each agency verifies that  the facility has created and implemented a HACCP plan specific to the  products that the agency regulates. Each agency’s regulations require the  facility to maintain separate HACCP plans for each product and to develop  separate analyses of critical control points and separate strategies to  mitigate or eliminate food contaminants. While separate HACCP plans are  generally necessary to address the specific hazards associated with  specific food products, maintaining these separate plans, and the  associated inspections and documentation that each agency requires, can  be burdensome. For example, at a facility we visited that produces both  crab cakes and breaded chicken, the manager must maintain a seafood  HACCP plan and a poultry HACCP plan. He said that although both plans  have similar elements, each agency’s inspectors expect different levels of  detail for the plans—something the manager finds confusing and difficult  to comply with.
USDA and FDA inspections of the same food-processing facility represent,  in our view, an inefficient use of scarce government resources. For  example, at a plant that produces both meat and seafood products, a  USDA inspector told us that as part of his daily, routine inspections he  walks through the seafood processing and storage section of the plant.  (See fig. 3.) However, because FDA regulates seafood, the USDA inspector  does not monitor or inspect the seafood storage section. The inspector  noted that, with minimum training on seafood temperature controls, he  could inspect this section of the plant as well. USDA headquarters officials  said the agency’s inspectors are capable of taking on FDA’s inspection  responsibilities at jointly regulated facilities, given the proper resources  and training.
USDA and FDA have new tools that could help reduce overlap in  inspections. Under the Bioterrorism Act, FDA could commission USDA  inspectors, who are present every day at these jointly regulated facilities,  to inspect FDA-regulated food. In doing so, FDA could reduce  overlapping inspections and redirect resources to other facilities for which  it has sole jurisdiction. While they did not disagree in principle with the  benefits of such an arrangement, FDA officials said that the savings would  be somewhat offset because FDA would likely have to reimburse USDA  for the costs of those inspections. Furthermore, FDA officials said that  they do not currently plan to pursue this option and have not conducted  any analyses of the costs or savings associated with it. USDA officials  commented that their inspectors are fully occupied and that they would  need to be trained before conducting joint inspections.
section_title: FDA and NMFS Inspections of Domestic Seafood Processors Overlap
paragraphs: Overlaps also occur at seafood processing facilities that both FDA and  NMFS inspect. NMFS currently inspects approximately 275 domestic  seafood facilities, and FDA inspects some of these plants as part of FDA’s  surveillance program. NMFS conducts safety and sanitation inspections, as  well as other product quality inspections, on a fee-for-service basis. NMFS  inspectors verify sanitation procedures, HACCP compliance, and good  manufacturing practices—many of the same components of an FDA  inspection. Although the two agencies’ seafood safety inspections are  similar, FDA does not take into account whether NMFS has already  inspected a particular facility when determining how frequently its  inspectors should visit that same facility.
FDA officials said they do not rely on NMFS inspections for two reasons.  First, FDA officials believe that NMFS has a potential conflict of interest  because companies pay NMFS for these inspections; and therefore, as a  regulatory agency, FDA should not rely on them. NMFS officials disagreed,  stating that their fee-for-service structure does not affect their ability to  conduct objective inspections. Furthermore, they noted, when NMFS  inspectors find noncompliance with FDA regulations, they refer  companies to FDA and/or to state regulatory authorities. NMFS officials  stated that companies that contract with NMFS need the agency’s  certification in order to satisfy their customers. Second, FDA officials  believe, it is difficult for FDA to determine which facilities NMFS inspects  at any given time because NMFS’ inspection schedules fluctuate often,  according to changes in NMFS’ contracts with individual companies.
However, we believe that if FDA were to recognize the results of NMFS’  inspection findings in targeting its resources, it could decrease or  eliminate inspections at facilities that NMFS inspectors find are in  compliance with sanitation and HACCP regulations.
section_title: USDA and FDA Both Inspect Imported Food
paragraphs: Both USDA and FDA maintain inspectors at 18 U.S. ports of entry to  inspect imported food but do not share inspection resources. In fiscal year  2004, USDA spent almost $16 million on imported food inspections, and  FDA spent about $121 million. According to USDA inspectors we  interviewed, FDA-regulated imported foods are sometimes handled and  stored in USDA-approved import inspection facilities. Although USDA  inspectors are present at these ports more often than FDA inspectors,  USDA inspectors have no jurisdiction over FDA-regulated products and,  therefore, the FDA-regulated products may remain at the facilities for  some time awaiting FDA inspection.
FDA and USDA are also not sharing information they gather during their  respective evaluations and/or visits to foreign countries to assess food  safety conditions. For example, USDA evaluated 34 countries in 2004 to  determine whether these countries’ food safety systems for ensuring the  safety of meat and poultry are equivalent to that of the United States. FDA  conducted inspections in 6 of these countries, but officials said they do not  take USDA’s evaluations of the foreign countries’ food safety systems into  account when determining which countries to visit and that USDA’s  findings would be of little use to FDA because they relate to products  under USDA’s jurisdiction.
section_title: USDA and FDA Have Similar Training Programs for Food Inspectors
paragraphs: Both USDA and FDA spend resources to provide similar training to food  inspection personnel. USDA spent about $13.4 million and FDA spent  about $1.7 million in fiscal year 2004. We found that, to a considerable  extent, food inspection training addresses the same subjects—such as  plant sanitation, good manufacturing practices, and HACCP principles,  albeit for different food products. FDA’s online curriculum includes over  106 courses that address topics common to both USDA and FDA, as well  as courses that are specific to FDA’s regulations and enforcement  authorities. NMFS currently uses 74 of these courses to train its seafood  inspectors. NMFS officials cite benefits to using FDA’s online training,  such as accessibility to training materials at times other than when their  inspectors are “on duty,” as well as cost savings attributable to reduced  expenses for course materials and management.
section_title: Interagency Agreements Are Not Reducing Overlaps
paragraphs: We identified 71 interagency agreements that the principal food safety  agencies—USDA, FDA, EPA, and NMFS—have entered into to better  protect the public health by addressing jurisdictional boundaries,  coordinating activities, reducing overlaps, and leveraging resources. About  one-third (24) of the agreements highlight the need to reduce duplication  and overlap or make efficient and effective use of resources. However, the  agencies cannot take full advantage of these agreements because they do  not have adequate mechanisms for tracking them and, in some cases, do  not effectively implement them. Agency officials had difficulty identifying  the food safety agreements they are party to, and in many instances, the  agencies did not agree on the number of agreements they had entered into.
In addition, for the two comprehensive inspection-related agreements that  we examined in detail, the agencies are not ensuring that their provisions  are adhered to or that the overall objectives of the agreements are being  achieved. For example:    USDA and FDA are not fully implementing an agreement to exchange  information about jointly regulated facilities in order to permit more  efficient use of both their resources and contribute to improved public  health protection. Under this agreement, the agencies are to share  inspection information, but FDA does not routinely consider compliance  information from USDA when deciding how to target its inspection  resources. Also, the agreement calls for the agencies to explore the  feasibility of granting each other access to appropriate computer- monitoring systems so that each agency can track inspection findings.  However, the agencies maintain separate databases and the inspectors  with whom we spoke continue to be largely unaware of a facility’s history  of compliance with the other agency’s regulations. Inspectors told us that  compliance information might be helpful when inspecting jointly regulated  facilities so they could focus on past violations.
An agreement between FDA and NMFS recognizes the agencies’ related  responsibilities at seafood-processing establishments. The agreement  details actions the agencies can take to enable each to discharge its  responsibilities as effectively as possible, minimizing FDA inspections at  these facilities. However, we found that FDA is not using information from  NMFS inspections, which could allow it to reduce the number of  inspections at those facilities. Also, FDA rarely notifies NMFS of seizure  actions it takes against NMFS-inspected plants, as outlined in the  agreement. Although FDA is not implementing the agreement, it has  recognized the potential benefits of working with NMFS to leverage  resources. In a January 2004 letter to the Under Secretary of Commerce  for Oceans and Atmosphere, the then-Commissioner of FDA noted,  among other things, that using NMFS inspectors could be cost effective  because the NMFS inspectors may already be on-site and the FDA  inspector therefore would not have to travel to conduct an inspection.
section_title: Stakeholders Disagree on the Significance of Overlapping Activities and on How to Improve the Federal Structure for Performing Food Safety Inspections and Related Activities
paragraphs: The stakeholders we contacted—selected industry associations, food- processing companies, consumer groups, and academic experts—disagree  on the extent to which overlaps exist and on how best to improve the  federal structure. Most of these stakeholders agree that the laws and  regulations governing the system should be modernized so that scientific  and technological advancements can be used to more effectively and  efficiently control current and emerging food safety hazards. However,  they differed about whether to consolidate food safety inspection and  related functions into a single federal agency.
Industry Associations: Representatives of industry associations do not  see the need to consolidate food safety-related functions, but they see the  need for minor changes within the existing regulatory framework to  enhance communication and coordination among the existing agencies.
Food Processing Companies: Representatives from the individual food  companies inspected by USDA and FDA believe that consolidation would  improve the effectiveness and efficiency of the system and ensure that  food safety resources are distributed based on the best available science.  They also said that overlaps can be burdensome or confusing. The  representatives did not see the added value of FDA’s once-a-year (or less)  inspections because USDA inspectors already visit their plants daily. At  one company, USDA and FDA inspectors gave the plant manager  contradictory instructions—the USDA inspector did not want the  company to paint sterilization equipment because he determined that paint  chips could contaminate the food; whereas the FDA inspector told the  company to paint the same equipment because he determined that it  would be easier to identify sanitation problems on lightly painted surfaces.
Academics and Consumer Groups: Academics and consumer groups  support consolidating food safety inspection and related functions into a  single agency. One group stated that the laws do not build prevention into  the farm-to-table continuum and divide responsibility and accountability  for food safety among federal agencies. Further, according to this group,  the laws prevent risk-based allocation of resources across the federal food  safety agencies.
section_title: Other Countries Have Modified Laws and Consolidated Food Safety Functions
paragraphs: The division of responsibility among several government agencies  responsible for food safety is not unique to the United States. According to  food safety officials in seven countries whose consolidations of food  safety systems we examined, they faced similar fragmentation and division  of responsibilities in their systems. As reported in February 2005, we  examined the efforts of Canada, Denmark, Ireland, Germany, the  Netherlands, New Zealand, and the United Kingdom to streamline and  consolidate their food safety systems. We found that, in each case, these  countries (1) modified existing laws to achieve the necessary  consolidation and (2) established a single agency to lead food safety  management or enforcement of food safety legislation.
We acknowledge that these countries have smaller populations than the  United States, but they face several similarities in their efforts to ensure  safe food. These countries, like the United States, are high-income  countries in which consumers have very high expectations about the  safety of their food supplies. In addition, U.S. consumers’ spending on  food as a percentage of total spending is somewhat similar to that of these  seven countries, ranging from about 10 percent in the United States to  over 16 percent in Ireland and the United Kingdom. In general, high- income countries tend to spend a smaller percentage of their income on  food than low-income countries.
The seven countries’ approaches for modifying their systems, of course,  differed. For example, Denmark created a new federal agency in which it  consolidated almost all food safety functions and activities, including  inspections, which were previously distributed among several government  agencies. In contrast, Germany’s new food safety agency functions as a  coordinating body to lead food safety management, while the German  federal states continue to be responsible for overseeing food inspections  performed by local governments. These countries had two primary  reasons for consolidating their food safety systems—public concern about  the safety of the food supply and the need to improve program  effectiveness and efficiency. In addition, an important factor motivating  the European Union (EU) countries’ consolidations has been the need to  comply with recently adopted EU legislation. These EU changes aim to  harmonize and simplify its food safety legislation and to create a single,  transparent set of food safety rules that is applicable to all EU-member  countries.
As we previously reported, Canada reorganized its food safety system in  1997. As part of its consolidation of food safety functions, Canada also  assigned responsibilities for animal disease control and feed inspections to  the Canadian Food Inspection Agency (CFIA). As a result, CFIA is  responsible for detecting animal diseases that may affect human health,  such as mad cow disease in cattle as well as for preventing the  introduction and spread of the disease through animal feed.
Not unexpectedly, the countries faced challenges in implementing their  new systems. Many countries had to determine (1) whether to place the  new agency within the existing health or agriculture ministry or establish  it as a stand-alone agency and (2) what responsibilities the new agency  would have. For example, Ireland chose to place its new independent food  safety agency under its existing Department of Health and Children, in  part, to separate food safety responsibilities from the promotion of the  food industry, which is the responsibility of the Department of Agriculture  and Food. On the other hand, to separate food safety regulation from  political pressures, New Zealand established a semi-autonomous food  safety agency attached to the Ministry of Agriculture and Forestry.  Officials in several countries also cited challenges in helping employees  assimilate into the new agency’s culture and support its priorities.
As expected, most countries incurred start-up costs in reorganizing,  including the costs associated with acquiring buildings and purchasing  new laboratory equipment. Some countries also reported that they  experienced a temporary reduction in the quantity of food safety activities  performed due to consolidation-related disruptions.
None of the countries has conducted an analysis to compare the  effectiveness and efficiency of its consolidated food safety system with  that of the previous system. However, government officials in these  countries as well as other stakeholders consistently stated that  consolidation of their systems has led to significant qualitative  improvements in operations that enhance effectiveness or efficiency.  According to these officials, the benefits included reduced overlaps in  inspections, more targeted inspections based on food safety risk, more  consistent or timely enforcement of food safety laws and regulations, and  greater clarity in responsibilities.
Danish officials stated that consolidation and the accompanying reform of  food safety laws facilitated risk-based inspections. The frequency of most  inspections is now based on an individual food product’s safety risk and  on an individual company’s food safety record, not on agencies’  jurisdiction, as was the case before consolidation. As a result, the  frequency of inspections at some food processing plants and of lower risk  food products has been reduced, making more resources available for  inspections of higher risk companies and foods.
Government officials in Canada, the Netherlands, and Denmark stated that  some cost savings may be achieved as a result of changes that have  already taken place or are expected from planned changes needed to  complete their consolidation efforts. For example, Dutch officials said that  reduced duplication in food safety inspections would likely result in  decreased spending. In addition, they anticipate savings from an expected  25-percent reduction in administrative and management personnel and  from selling excess property.
Figures 4 and 5 illustrate key functions and activities that the governments  of Denmark and Canada decided to consolidate in order to achieve more  efficient food safety systems.
section_title: Conclusions
paragraphs: In recent years, many proposals from the Congress and others have been  made to reform existing laws and consolidate the governmental structure  for ensuring the safety of the food supply. As we have reported in the past,  the current system is fragmented and causes inefficient use of resources,  inconsistent oversight and enforcement, and ineffective coordination. We  have recommended that the Congress consider statutory and  organizational reforms, and we continue to believe that the benefits of  establishing a single national system for the regulation of our food supply  outweigh the costs. In making these recommendations, we fully recognize  the time and effort needed to develop a reorganization plan and to transfer  authorities, as necessary, under such a reorganization.
We also recognize that improvements short of restructuring the current  system can be made to help reduce overlaps and duplication, and to  leverage existing resources. Therefore, in the report that you are releasing  today, we make several recommendations to that end. For example, if cost  effective, we recommend that FDA, as authorized under the Bioterrorism  Act, commission USDA inspectors to carry out inspections of FDA- regulated foods at food establishments that are under their joint  jurisdiction. We also recommend that USDA and FDA examine the  feasibility and cost effectiveness of establishing a joint training program  for their food inspectors.
section_title: Contacts and Staff Acknowledgements
paragraphs: For further information about this testimony, please contact Robert A.  Robinson, Managing Director, Natural Resources and Environment, (202)  512-3841. Maria Cristina Gobin, Terrance N. Horner, Jr., Gary Brown,  Katheryn Hubbell, Carol Herrnstadt Shulman, and Katherine Raheb made  key contributions to this statement.
section_title: Related GAO Products
paragraphs: Oversight of Food Safety Activities: Federal Agencies Should Pursue  Opportunities to Reduce Overlap and Better Leverage Resources. GAO-05- 213. Washington, D.C.: March 30, 2005.
Homeland Security: Much Is Being Done to Protect Agriculture from a  Terrorist Attack, but Important Challenges Remain. GAO-05-214.  Washington, D.C.: March 8, 2005.
Mad Cow Disease: FDA’s Management of the Feed Ban Has Improved, but  Oversight Weaknesses Continue to Limit Program Effectiveness. GAO-05- 101. Washington, D.C.: February 25, 2005.
Food Safety: Experiences of Seven Countries in Consolidating Their Food  Safety Systems. GAO-05-212. Washington, D.C.: February 22, 2005.
Food Safety: USDA and FDA Need to Better Ensure Prompt and Complete  Recalls of Potentially Unsafe Food. GAO-05-51. Washington, D.C.: October  7, 2004.
Posthearing Questions Related to Fragmentation and Overlap in the  Federal Food Safety System. GAO-04-832R. Washington, D.C.: May 26,  2004.
Federal Food Safety and Security System: Fundamental Restructuring Is  Needed to Address Fragmentation and Overlap. GAO-04-588T. Washington,  D.C.: March 30, 2004.
Food Safety: FDA’s Imported Seafood Safety Program Shows Some  Progress, but Further Improvements Are Needed. GAO-04-246.  Washington, D.C.: January 30, 2004.
Bioterrorism: A Threat to Agriculture and the Food Supply. GAO-04-259T.  Washington, D.C.: November 19, 2003.
Combating Bioterrorism: Actions Needed to Improve Security at Plum  Island Animal Disease Center. GAO-03-847. Washington, D.C.: September  19, 2003.
Results-Oriented Government: Shaping the Government to Meet 21st  Century Challenges. GAO-03-1168T. Washington, D.C.: September 17, 2003.
School Meal Programs: Few Instances of Foodborne Outbreaks Reported,  but Opportunities Exist to Enhance Outbreak Data and Food Safety  Practices. GAO-03-530. Washington, D.C.: May 9, 2003.
Agricultural Conservation: Survey Results on USDA’s Implementation of  Food Security Act Compliance Provisions. GAO-03-492SP. Washington,  D.C.: April 21, 2003.
Food-Processing Security: Voluntary Efforts Are Under Way, but Federal  Agencies Cannot Fully Assess Their Implementation. GAO-03-342.  Washington, D.C.: February 14, 2003.
Meat and Poultry: Better USDA Oversight and Enforcement of Safety  Rules Needed to Reduce Risk of Foodborne Illnesses. GAO-02-902.  Washington, D.C.: August 30, 2002.
Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain  Vigilant and Resolve Outstanding Issues. GAO-02-808. Washington,  D.C.: July 26, 2002.
Genetically Modified Foods: Experts View Regimen of Safety Tests as  Adequate, but FDA’s Evaluation Process Could Be Enhanced. GAO-02-566.  Washington, D.C.: May 23, 2002.
Food Safety: Continued Vigilance Needed to Ensure Safety of School  Meals. GAO-02-669T. Washington, D.C.: April 30, 2002.
Mad Cow Disease: Improvements in the Animal Feed Ban and Other  Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183.  Washington, D.C.: January 25, 2002.
Food Safety: Weaknesses in Meat and Poultry Inspection Pilot Should Be  Addressed Before Implementation. GAO-02-59. Washington, D.C.:  December 17, 2001.
Food Safety and Security: Fundamental Changes Needed to Ensure Safe  Food.GAO-02-47T. Washington, D.C.: October 10, 2001.
Food Safety: CDC Is Working to Address Limitations in Several of Its  Foodborne Disease Surveillance Systems. GAO-01-973. Washington, D.C.:  September 7, 2001.
Food Safety: Overview of Federal and State Expenditures. GAO-01-177.  Washington, D.C.: February 20, 2001.
Food Safety: Federal Oversight of Seafood Does Not Sufficiently Protect  Consumers. GAO-01-204. Washington, D.C.: January 31, 2001.
Food Safety: Actions Needed by USDA and FDA to Ensure That  Companies Promptly Carry Out Recalls. GAO/RCED-00-195. Washington,  D.C.: August 17, 2000.
Food Safety: Improvements Needed in Overseeing the Safety of Dietary  Supplements and “Functional Foods.” GAO/RCED-00-156. Washington,  D.C.: July 11, 2000.
School Meal Programs: Few Outbreaks of Foodborne Illness Reported.  GAO/RCED-00-53. Washington, D.C.: February 22, 2000.
Meat and Poultry: Improved Oversight and Training Will Strengthen New  Food Safety System. GAO/RCED-00-16. Washington, D.C.: December 8,  1999.
Food Safety: Agencies Should Further Test Plans for Responding to  Deliberate Contamination. GAO/RCED-00-3. Washington, D.C.: October 27,  1999.
Food Safety: U.S. Needs a Single Agency to Administer a Unified, Risk- Based Inspection System. GAO/T-RCED-99-256. Washington, D.C.: August  4, 1999.
Food Safety: U.S. Lacks a Consistent Farm-to-Table Approach to Egg  Safety. GAO/RCED-99-184. Washington, D.C.: July 1, 1999.
Food Safety: Experiences of Four Countries in Consolidating Their Food  Safety Systems. GAO/RCED-99-80. Washington, D.C.: April 20, 1999.
Food Safety: Opportunities to Redirect Federal Resources and Funds Can  Enhance Effectiveness. GAO/RCED-98-224. Washington, D.C.: August 6,  1998.
Food Safety: Federal Efforts to Ensure Imported Food Safety Are  Inconsistent and Unreliable. GAO/T-RCED-98-191. Washington, D.C.: May  14, 1998.
Food Safety: Federal Efforts to Ensure the Safety of Imported Foods Are  Inconsistent and Unreliable. GAO/RCED-98-103. Washington, D.C.: April  30, 1998.
Food Safety: Agencies’ Handling of a Dioxin Incident Caused Hardships  for Some Producers and Processors. GAO/RCED-98-104. Washington, D.C.:  April 10, 1998.
Food Safety: Fundamental Changes Needed to Improve Food  Safety. GAO/RCED-97-249R. Washington, D.C.: September 9, 1997.
Food Safety: Information on Foodborne Illnesses. GAO/RCED-96-96.  Washington, D.C.: May 8, 1996.
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