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From: TSS ()
Subject: OVERSEEING THE U.S. FOOD SUPPLY GAO-05-549T
Date: May 18, 2005 at 1:44 pm PST

-------- Original Message --------
Subject: OVERSEEING THE U.S. FOOD SUPPLY GAO-05-549T
Date: Tue, 17 May 2005 14:28:06 -0500
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
To: BSE-L@aegee.org


##################### Bovine Spongiform Encephalopathy #####################

What GAO Found
United States Government Accountability Office
Why GAO Did This Study
Highlights
Accountability Integrity Reliability
www.gao.gov/cgi-bin/getrpt?GAO-05-549T.
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Robert A.
Robinson at (202) 512-3841 or
robinsonr@gao.gov.
Highlights of GAO-05-549T, a testimony to
the Subcommittee on the Federal
Workforce and Agency Organization,
Committee on Government Reform,
House of Representatives

May 17, 2005
OVERSEEING THE U.S. FOOD SUPPLY

Steps Should Be Taken to Reduce
Overlapping Federal Inspections and
Related Activities

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, as
shown below.
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.

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.
What GAO Recommends
In the past, GAO has recommended
that the Congress consider
fundamental restructuring to
ensure the effective use of scarce
government resources. In the
report that the Subcommittee is
releasing today, GAO recognizes
that, short of reorganization, other
improvements can be made to help
reduce overlap and duplication and
to leverage existing resources. For
example, the Food and Drug
Administration (FDA) could use
existing authority to commission
U.S. Department of Agriculture
(USDA) inspections of dual
jurisdiction establishments.


http://www.gao.gov/highlights/d05213high.pdf


snip...full text below


http://www.gao.gov/new.items/d05213.pdf


> FDA could also leverage USDA’s efforts to ensure the safety of imported
> food by using information that USDA compiles in its determinations that
> exporting countries’ food safety systems are equivalent to the U.S.
> system.
> Under the Meat and Poultry Products Inspection Acts, the Secretary of
> Agriculture is required to certify that countries exporting meat and
> poultry


OR in meat and poultry products brought in by tourist via many routes,
as with one i mentioned that i was concerned about here, air traffic
passengers,
and the assumption that one country's BSE protocols are as with another's
country that may be better, with more restrictions ;


# Docket No: 02-088-1 RE-Agricultural Bioterrorism Protection Act of
2002; [TSS SUBMISSION ON POTENTIAL FOR BSE/TSE & FMD 'SUITCASE BOMBS'] -
TSS 1/27/03 (0)

Docket Management

Docket: 02N-0276 - Bioterrorism Preparedness; Registration of Food Facilities, Section 305
Comment Number: EC-254 [TSS SUBMISSION]

snip...


let me kick a madcow around here a bit.

on the imports from Poland and the infamous USA

'non-species' coding system.

the USDA/APHIS states;

> During the past four years (1998 - 2001), US imports from


> Poland included non-species specific animal products


> used in animal feeds and non-species specific sausage and offal


> products (Table 3). Given US restrictions on ruminant product


> imports, these US imports should not have contained ruminant


> material.


NOW, if you read Polands GBR risk assessment and opinion


on BSE, especially _cross-contamination_, it states;


ANNEX 1

Poland - Summary of the GBR-Assessment, February 2001

EXTERNAL CHALLENGE STABILITY INTERACTION OF EXTERNAL

CHALLENGE AND STABILITY

The very high to extremely high external

challenge met a very unstable system and

could have led to contamination of

domestic cattle in Poland from 1987

onwards.

This internal challenge again met the still

very unstable system and increased over

time.

The continuing very high external

challenge supported this development.

Not OK

MBM-ban

since 1997,

but no feed

controls.

Reasonably OK

Heat treatment

equivalent to

133°C / 20min / 3

bar standards, but

no evidence

provided on

compliance.

Not OK.

No SRM-ban,

SRM are

rendered and

included in

cattle feed.

BSE surveillance:

Not sufficient before

2001.

Cross-contamination:

Lines for ruminant

and non-ruminant

feed in feed-mills only

separated in time and

no analytical controls

carried out.

Likely present since 1987 and growing.

see full text and ANNEX 1 at;

http://europa.eu.int/comm/food/fs/sc/ssc/out185_en.pdf

so in my humble opinion, the statement by the USDA/APHIS

that ''these US imports _should_ not have contained ruminant

materials, is a joke. a sad joke indeed.

* POLAND BSE GBR RISK ASSESSMENT

http://europa.eu.int/comm/food/fs/sc/ssc/out185_en.pdf


snip...

see full text ;

http://www.fda.gov/ohrms/dockets/dockets/02n0276/02N-0276-EC-254.htm


.1 gram lethal, and one of these mishaps would be ample enough to start
an amplification process on a slow but confounded terrorist attack of TSE
in the USA. i mean come on, we never thought a shoe bomb possible either.
THIS BSE MRR policy must not be implemented. The BSE GBR risk assessments
must be strictly enforced by importing and exporting Country's...TSS


LETTER REPORT

Oversight of Food Safety Activities: Federal Agencies Should Pursue Opportunities to Reduce Overlap and Better Leverage Resources. GAO-05-213, March 30
http://www.gao.gov/cgi-bin/getrpt?GAO-05-213
Highlights - http://www.gao.gov/highlights/d05213high.pdf


TESTIMONY

Overseeing the U.S. Food Supply: Steps Should be Taken to Reduce Overlapping Inspections and Related Activities. GAO-05-549T, May 17
http://www.gao.gov/cgi-bin/getrpt?GAO-05-549T
Highlights - http://www.gao.gov/highlights/d05549thigh.pdf


TSS

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