Here's a Federal Program That Actually Does Prevent Foodborne Illnesses
It's based on research and sharing information, not on more regulations.
A new study in the American Journal of Preventive Medicine by a team of researchers, led by Professor Robert Scharff of Ohio State University, concludes that PulseNet, a 20-year-old partnership between the Centers for Disease Control and Prevention (CDC) and state and local health agencies, prevents more than 275,000 cases of foodborne illness each year. And it does so with a tiny budget.
I'm hard on the federal government when it wastes money on food-safety approaches that don't make our food safer. I've attacked often-senseless food-safety rules that have threatened to put small farmers, artisanal cheesemakers, local meat producers, and others out of business. I've criticized lapses and oversights in existing federal food-safety oversight.
But I've always held firm in stating that the federal government, along with states and local governments, has an important role to play in helping to ensure the safety of America's food supply.
It's not often that I get to point to a federally orchestrated food-safety program that's working. But I'm happy to report that's just what I get to do this week.
To learn more about PulseNet and the new study that details its efficacy, I spoke with Prof. Scharff by email this week. My questions and his responses are below.
Reason: What is PulseNet, and how does it work?
Robert Scharff: PulseNet is a network of state and federal laboratories that uses DNA fingerprinting of bacteria to find connections between seemingly isolated cases of foodborne illness. This makes it easier (more likely and faster) to detect outbreaks and track illnesses to their source.
Reason: Your new study in the American Journal of Preventive Medicine indicates that PulseNet prevents about 276,000 cases of foodborne illness every year. That's amazing. To put that in perspective, according to FDA estimates I've cited previously, the two key provisions of FSMA (pertaining to good manufacturing practices and fruits and vegetables) together would prevent—under a best-case scenario—as few as 488,500 cases of foodborne illness per year. PulseNet costs about $7 million per year. FSMA costs hundreds of millions of dollars annually. What does this say about where and how we allocate (or, perhaps, misallocate) our resources in this area?
RS: Markets work best when consumers have full information about the products they consume. There is too much emphasis in government on regulation (often promulgated with a weak scientific basis) and too little on helping market[s] work better through the provision of information.
Reason: Can you give one example of a notable success PulseNet achieved during its two decades of existence?
RS: The biggest success stories aren't largely known by the public because the source of an outbreak is identified before the outbreak becomes large enough to garner national media attention. That said, the large peanut butter outbreak in 2008-2009 that was detected by PulseNet likely would have led to many more illnesses had PulseNet not been in existence. The resulting bankruptcy of the Peanut Corporation of America and 28 year criminal sentence for the president acts as a strong deterrent to other food company leaders that may have otherwise considered the reckless behavior PCA engaged in.
Reason: You've argued that PulseNet information facilitates not just the tracking of foodborne illness but also more efficient markets. How so?
RS: PulseNet results in more efficient markets by allowing consumers (often through grocers as their agents) to make more informed choices about the foods they eat. Producers, wanting to avoid recalls, litigation, and negative reputation externalities, respond by being more careful and reducing risks associated with their food.
Reason: You've shown PulseNet is a dramatic success. That's the great news. But what percentage of public-health agencies around the country are using PulseNet right now? Why isn't every public-health agency doing so?
RS: All States have used PulseNet to some degree. The problem is that limited budgets have resulted in major differences in the number of samples that are tested. I'm not sure why more states aren't using PulseNet more because it is a relatively low cost solution.
Reason: Your study demonstrates that PulseNet is a collaborative government effort that has had a tangible and positive impact on the number of foodborne illnesses in the United States. You told me that you believe that PulseNet's "provision of information to markets (rather than regulation of markets) [is w]hat has led to this steep decline in illness." For example, your study shows PulseNet's faster "outbreak response led to significant reductions in reported illnesses" of two very dangerous pathogens: Salmonella and E. coli. Using this lens, why is PulseNet so successful? What are some efforts to prevent foodborne illness that are comparatively less successful? Why?
RS: There are two mechanisms that lead to PulseNet's success. First, by detecting outbreaks earlier, recalls reduce the number of people exposed to harmful pathogens. Second, by informing consumers (and grocers who act as their agents) about risks, PulseNet imposes market generated costs on those companies that are selling tainted foods.
One example of an intervention that has been less successful is the FDA rule on shell eggs that became effective in 2010. This costs egg farmers over $80 million a year to adhere to a wide variety of standards. Though a comprehensive risk assessment predicted that 79,000 cases of Salmonella Enteritidis would be avoided, a recent analysis found no significant reduction of illness from this regulation, but did find that, if there was a reduction, it was significantly less than the 79,000 predicted.
What bothers me is that the regulations coming out of the FSMA have shown less of an inclination to rely on good science than the egg rule did.
The problem with regulation based on design standards, generally, is that it applies a one size fits all approach on industry. With eggs for example, what works for a small 2,000 bird farmer in California may not be the same as what works for a large 100,000 bird farmer in Iowa. Regulation typically does not allow farms to pick the interventions that work best for them. Markets, enforced through potential costs of litigation and reputation loss, allows for more efficient and effective interventions to be used.
