Another review of the 2007 pet food crisis has emerged, this time from the Office of Inspector General (OIG) for the Department of Health and Human Services (HHS). Entitled, “Review of the Food and Drug Administration’s Monitoring of Pet Food Recalls [PDF]," the August report analyzes the recall of pet foods contaminated by melamine, but its recommendations apply to recalls of both human and animal food. The agency response is good news, agreeing with the report’s recommendations. But, there is bad news in what the report didn't say.
The HHS report makes only a fleeting reference to the misleading melamine risk assessments performed by FDA and its partner in petifoggery, the U.S. Department of Agriculture (USDA). An accurate risk assessment is critical to knowing what to recall; therefore, an inadequate assessment of the potential for harm in a food product undermines the very purpose of issuing recalls. (Perhaps, even the recall issues would not have been addressed had not Sen. Tom Harkin requested the report.) For a more detailed discussion of government’s flawed melamine risk assessments, please see my earlier articles posted at Daily Kos.
The report does include some worthwhile recommendations for improving recalls, such as recommending regulatory authority for FDA to “mandate food recalls and to assess penalties for noncompliance with the terms of the recalls.” Written recall strategies, better effectiveness and accuracy checks, and improved follow-up, also should prove helpful. But, the recommendations are little different from proposals pushed by consumer groups in the past.
Insufficiently detailed procedures were a common thread in the OIG investigation, and this is a problem that is more easily recognized than resolved. In my experience as an emergency preparedness specialist, many career officials dislike written procedures, which they claim are “too restrictive.” But, a well-written, detailed procedure has many advantages over a idea in someone’s head; which may be at odds with the idea in the head of a counterpart working on the same problem. Possibly, the resistance is based on a fear of being held accountable for failing to follow a procedure, although that worry also is unfounded.
Despite finding evidence of “lax adherence to its [FDA’s] recall guidance and internal procedures,” the OIG report sidesteps the issue of individual accountability. In attributing failures to “the FDA” rather than to FDA managers or employees, the OIG follows a well-worn path whereby deadly debacles are routinely framed by federal officials as “system failures,” as if human hands had no part in the disastrous results. Managers are rarely disciplined, even for colossal failures.
We should not have to wait two years or more for an investigative report on what officials should have done to avoid poisonings, deaths and disruption. But, before witnesses will come forward (and before managers will feel compelled to listen to them), Congress must pass the better whistleblower protections recommended by more than 300 public interest groups. Unfortunately, a bill passed by the House of Representatives earlier this year was watered down by the Senate and differences between the two have yet to be worked out as the legislative session nears its end.
As I write about other food safety issues, I will address the OIG report in additional detail. Meanwhile, please eat wisely and keep an eye on this website for recalls and alerts.
Cross-posted from Daily Kos
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