Food Safety Magazine, August/September 2008

FOCUS ON STANDARDS
By Jim Griffiths and Darrell Abernethy
Improving Food
Through Public
Standards for Food
Ingredients
Safety
Recent food safety scares have
prompted a drop in public confidence
in our nation’s food supply. Foods are
not drugs, but an existing lack of over-
sight on food products provides insight
into ways we can enhance food safety.

But the regulatory landscape for food and food ingredients is much different than it is for drugs. There was no recognized food ingredient compendium at the time the FFDCA was enacted, so when early 20th century law specified conditions under which food would be considered adulterated and misbranded, it was done generically and not in reference to a food ingredient compendium. In 1958, the National Academy of Sciences created a food ingredient compendium for the United States, the Food Chemicals Codex (FCC). Unfortunately, the FCC was never broadly written into U.S. law as was done for the United States Pharmacopeia (USP) and the National Formulary (NF) for drugs. Rather, it was incorporated only sporadically into FDA regulations to approve certain specific food additives.

The 1906 Pure Food and Drugs Act focused primarily on adulter-
ation and misbranding. It also called for federal inspection of meat
products and plants, and forbade the manufacture of poisonous
foods and patent medicines. The Act’s parentage can be traced to
social activist authors, such as Upton Sinclair (whose 1906 novel,
The Jungle, created wide public awareness about conditions in the
meat packing industry) and federal researchers such as Harvey
Wiley (the first FDA commissioner) as well as then-President
Theodore Roosevelt. The 1906 Act paved the way for the creation of
the Food and Drug Administration.

The 1906 Act was largely replaced by the much more comprehensive 1938 Federal Food, Drug and Cosmetic Act (FFDCA), which, with periodic refinements, is still operative today. The FFDCA gives authority to the FDA to oversee the safety of foods (and food ingredients), drugs and cosmetics.

The Next Step

Where does this leave us today? In the U.S., pharmaceuticals are subject to strict premarket and postmarket requirements for which manufacturers must document quality, safety and efficacy. In contrast, the burden of identifying foods and food ingredients that may compromise public health often falls on the FDA, which lacks both the funding and resources for such a monumental task. By not demanding protection for foods similar to those that currently exist for drugs, we risk jeopardizing the quality of our food supply.

The current threat to the American food supply is best exemplified by a number of recent incidents of harmful economic adulteration, or the substitution of lower cost (but often dangerous) materials into foods and drugs for increased profit. These instances are especially problematic because they echo similar cases of harmful adulteration that occurred in the early 20th century.