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. 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. 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. 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. 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.