During the storage and distribution of the billions of pounds of food consumed annually in the United States, some food is damaged or contaminated because of mishandling, accidents (e.g., fires, explosions, or truck and train accidents), or natural and man-made disasters (e.g., earthquakes, hurricanes, floods, or riots). Food that is adulterated or contaminated is generally destroyed. However, if the food is determined to be safe, it may be salvaged and “reconditioned” for consumption. Both FDA and the U.S. Department of Agriculture (USDA) are responsible for ensuring that all food shipped or received in interstate commerce is safe for consumption. FDA enters into contracts or initiates cooperative agreements with state authorities to inspect food manufacturers and warehouses, including operations to salvage food. According to FDA officials, state and local authorities are the most effective regulatory bodies for monitoring such operations because (1) FDA has no authority to place an embargo on hazardous food; (2) the states have intensive regulatory coverage of food warehouses and retail establishments, where most food salvaging operations occur; and (3) FDA has concentrated its resources on issues that pose a higher risk to public health, such as monitoring the blood supply and the safety of medical devices. USDA directly monitors meat and poultry salvaging operations using its own inspectors or designates states to perform inspections when they have inspection programs that meet requirements at least equal to federal laws. When a major disaster occurs, states may contact FDA and/or USDA field offices for assistance and advice. However, FDA’s operational procedures state that in unusual circumstances, such as those involving the interstate movement of merchandise or areas in which state or local political ramifications are anticipated, FDA may assume the primary role in overseeing salvaging operations. On December 28, 1991, a major disaster occurred when a fire began in a storage cave of approximately 100 acres owned by Americold Services Corporation in Kansas City, Kansas. This man-made limestone cave is the largest underground food storage facility in the world, with freezers, coolers, and dry storage areas accessible by truck and rail. Figure 1 shows the layout of the Americold cave, including the location of the fire. When the fire began, about 245 million pounds of food was stored in the cave. Of that amount, about 159 million pounds was owned by about 110 private food companies; USDA owned the remaining 86 million pounds. The products stored in the cave included dry milk, cheese, butter, fruit, nuts, and other dry goods, as well as canned and frozen meats, vegetables, and fruits. The fire started in an area of the cave containing grocery items, including cleaning compounds, pesticides, paper goods, and cooking oil. The fire reached temperatures approaching 2,000 degrees Fahrenheit and, despite continuous fire-fighting efforts, burned for about 2 months. (See fig. 2.) The fire was confined to one section of the cave, but smoke flowed throughout the cave, exposing food to smoke residue for a prolonged period. According to FDA, this event was unique in that no other fire had involved such a large quantity of food that was exposed to smoke for such a long time. Following the fire, the Kansas Department of Health and the Environment (KDHE) met with FDA and other federal, state, and local agencies to determine a course of action for protecting the public health and supervising the salvaging operations. It was decided that KDHE should take the lead in overseeing the salvaging, with assistance from FDA’s district office in Kansas City. Such an arrangement is typical in routine salvaging operations. According to FDA’s records, contaminants found in the air and on surfaces in the cave included toluene, benzene, and phenol—substances cited by the Environmental Protection Agency as being carcinogenic and causing genetic changes and mutations. Because of the potential risk to public health from these contaminants, KDHE, with advice from FDA, placed an embargo on all of the stored food. The embargo was to continue until the owners of the food presented KDHE with evidence, based on laboratory analysis, that the food was suitable for consumption. In many instances, ownership of the food transferred to insurance companies and, ultimately, to food salvagers. The insurers and salvagers were eager to begin salvaging operations and, according to KDHE officials, placed pressure on KDHE to release the food. The salvaging operations began almost immediately and continued for over 2 years. Table 1 summarizes the final disposition of the food stored in the cave. Over 143 million pounds of food was sent to landfills to be destroyed, and about 102 million pounds was released for reconditioning and consumption. Most of the 102 million pounds of food salvaged from the fire was released to the public with little apparent controversy. However, in December 1993, about 2 years after the fire began, a series of articles in the Kansas City Star raised questions about the release of food to a Minnesota food salvager. About 3.7 million pounds of food was shipped to this salvager, and all but about 100,000 pounds was eventually sold to the public. Appendix I provides a chronology of the key events in the release of the food to this salvager. Our review of food salvaging activities following the fire—particularly those involving the shipment of food to Minnesota—found two problems from which lessons can be learned to improve future salvaging operations. First, FDA did not adequately share information with KDHE about past problems it had experienced with a food owner’s consultant and his laboratories. This consultant’s laboratory test results were used to demonstrate to KDHE the safety of food later released to the public. Second, FDA did not communicate its guidance on food sampling to the KDHE officials responsible for overseeing the salvaging operations. FDA relies on such guidance internally to ensure the integrity of analytical data from private laboratories. Both of these problems suggest the need for FDA to be more proactive in helping states manage food salvaging following major disasters. KDHE allowed several million pounds of food salvaged from the Americold fire to be sent to Minnesota on the basis of laboratory results submitted by a consultant to one of the food owners. KDHE officials subsequently learned from FDA that this consultant and his laboratories had been under investigation by FDA and that two of his laboratories were on FDA’s “nonacceptance” list. However, FDA did not provide this information in a timely manner either to its Kansas City District Office or to the KDHE investigators overseeing the salvaging of the food. In April 1992, KDHE asked FDA’s Kansas City District Office for advice on the consultant’s plans for sampling and testing food that had been stored in the Americold cave. The consultant had been hired by a food owner to sample and test the food for chemical and smoke residues. FDA’s district office raised several concerns about the consultant’s plans. However, it provided no information to KDHE about the past performance of the consultant or his laboratories. This information was known within FDA but was not shared with the FDA investigator advising KDHE. FDA’s Division of Field Science in Washington, D.C., maintains and periodically distributes to FDA district offices a “nonacceptance” list of some private laboratories. According to FDA officials, the list provides information about private laboratories that at least one FDA district office has found to be unacceptable for performing certain or all analytical tests. FDA’s district offices may use this information in deciding whether to accept or reject analyses from a particular laboratory. Much of this information is based on enforcement activities in FDA’s program for monitoring imported food. FDA’s information indicated that two of the consultant’s laboratories were unacceptable for performing any analyses. The investigator from FDA’s district office said that he was unaware that such a list existed until June 13, 1992, when he learned of it from a visiting FDA scientist. A month later, he advised KDHE not to accept test results from the consultant’s laboratories. However, the consultant informed KDHE that the analyses were being performed by another laboratory that KDHE, on the basis of discussions with the Minnesota Department of Agriculture, had determined to be reputable. This laboratory was not affiliated with the consultant. On the basis of this information and subsequent laboratory results indicating that the tested food was not contaminated, KDHE allowed the food to be shipped, under embargo, to a Minnesota salvager. KDHE officials later learned from FDA that the consultant himself was the subject of an ongoing FDA investigation concerning the falsification of laboratory data. They said that if they had known this earlier, they would not have allowed the food to be shipped to Minnesota. After the food shipments to Minnesota began, the Minnesota Department of Agriculture asked FDA to test a truckload of cheese. Minnesota state food inspectors were concerned because the containers were covered with dust and smelled of smoke. FDA’s test results showed that some hazardous chemicals, including toluene, were present in the cheese. However, according to an FDA official, the levels of chemicals found did not pose a health hazard. The remaining food held by the salvager was retested by a private laboratory, judged to be safe for consumption, and eventually sold to the public. Officials from KDHE and the Minnesota Department of Agriculture told us that no illnesses have been attributed to this food. FDA has published guidance on food sampling to ensure the credibility, accuracy, and reliability of analytical data from private laboratories. This guidance, which primarily concerns FDA’s regulation of imported foods, was provided to KDHE’s state laboratory but not to the KDHE officials managing the food salvaging operations. The food sampling processes KDHE used in the salvaging operations following the fire lacked some important controls, thereby creating the risk that unsafe food might be released to the public. For example, food owners selected food samples without a KDHE official or other disinterested third party present. In addition, the consultant discussed earlier maintained control over food samples that were to be tested for chemical residues.