ARE YOU SURE WE CAN AFFORD
TO PASS S-510,
THE FOOD SAFETY MODERNIZATION ACT?????
S-510 increases/ gives FDA rule on the Farm.
Testimony of Michael R Taylor at Kucinich Healing July 2009
During his tenure there, Taylor represented Monsanto's efforts to gain FDA
approval for rBGH. Taylor left the firm in 1991 to rejoin the FDA, this
time as deputy commissioner for policy. In that position, he wrote the
guidelines on the use and marketing of rBGH, which turned out to be very
favorable for Monsanto. The FDA guidelines exempted milk producers from
labeling dairy products from cows that had been treated with rBGH. Now
Taylor has resumed to Monsanto, working on what the company calls "long
range planning."
During his days at King and Spaulding, Taylor also authored more than a
dozen articles critical of the Delaney Clause, a 1958 federal law
prohibiting the introduction of known carcinogens into processed foods,
which had long been opposed by Monsanto and other chemical and pesticide
companies. When Taylor rejoined the federal government, he continued
advocating that Delaney should be overturned.
Date: 9/21/2010 7:45:11 AM ( 14 y ) ... viewed 47702 times
&letter
LATE BREAKING NEWS
I called Senator's Coburn's office.
Talked to Liz.
LATE BREAKING NEWS
10:44 am
September 22, 2010
S. 3767 is in the Judiciary Committee
today September 22.
THE BILL IS CALLED
S. 3767:
Food Safety Accountability Act of 2010
111th Congress
2009-2010
is that it will be rushed through
September 23, 2010
I prefer other sources, but this is the
news, as I am understanding it.
Leslie
Rumor in Washington DC is that S.3767 will be rushed through the Senate Judiciary Committee and onto the Senate floor, where it will be amended to add to it the language of the S.510 (or efven the long-discredited S.3002) as a way of makring an end-run around the opposition.
We say this is too serious a matter to be pushed through what is increasingly a "lame-duck" Congress. Issues such as this should be debated, considered and decided by the newly elected Congress which may have a greater degree of public trust than the current Congress.
If you agree, please use the form below to tell your Senators and the Senate Judiciary Committee.
S. 3767 Date of Scheduled Consideration
[e.g, bill could be voted into law that day or S. 510
could be introduced as an amendment and put forward in that manner.
Stop it before gets to the Senate floor to be rammed through into law.
Take Action Items Above to Prevent These Events From Taking Place. Then Share Them With Everyone Who Eats - Anything!
I registered. I trust that it is good to register
with this organization.
CONGRESS.ORG:
This I found more cumbersome.
A WAY TO CALL YOUR SENATOR
It's easy to call:
Go to Congress.org and type in your zip code. Click on your Senator's name, and then on the contact tab for their phone number.
You can also call the Capitol Switchboard and ask to be directly connected to your Senator's office: 202-224-3121.
Once connected ask to speak to the legislative staff person responsible for agriculture If they are unavailable leave a voice mail message. Be sure to include your name and phone number.
There are 225 pages of new regulations, many of which are problematic. While some regulations are potentially onerous, but perhaps reasonable – such as requiring every facility to have a scientifically-based, but very flexible, food safety plan—others give FDA sweeping authority with potentially significant consequences.
While it is hard to pull out just 1 or 2 regulations in the bill that make the entire thing unpalatable, on the whole this bill represents a weighty new regulatory structure on the food industry that will be particularly difficult for small producers and farms to comply with (with little evidence it will make food safer). The following regulations are perhaps the most troubling:
• Performance standards. The bill gives the Secretary the authority to “issue contaminant-specific and science-based guidance documents, action levels, or regulations.” The way the bill is written the authority is extremely broad and could be used by FDA to issue very specific and onerous regulations on food facilities, without even the normal rule-making and guidance process FDA food regulations normally go through.
• Traceability. FDA is required to establish a “product tracing system within the FDA” based and develop additional recordkeeping requirements for foods determined to be “high risk.” The House legislation includes “full pedigree” traceback which puts FDA in charge of tracing the entire supply chain. The final bill requires the FDA to do this for high-risk foods, and while there are some limitations on FDA, anything further than the “one-up-one-back” requirement in the bioterrorism law will be very onerous on industry.
• Standards for produce safety. For produce, this bill gives FDA the authority to create commodity-specific safety standards for produce. Instead of trusting industry and the free-market, this provision implies that complying with government standards is the best way to keep consumers safe. A lot of the produce industry lobbied for these standards to provide “consumer confidence” after the jalapeno and tomato scare, but federal regulations could particularly adversely impact small providers.
Other regulations in this bill are overly punitive and could set up an adverse relationship with industry. They include:
• Administrative Detention of Food. The bill lowers the threshold for detaining articles of food to “adulterated or misbranded.” The threshold is currently higher for a reason—administrative detention is an authority that should only be used when there is clear, imminent danger.
EXCERPT ABOVE FROM DR COBURN, Senator from OKLAHOMA
ARE YOU SURE WE CAN AFFORD
TO PASS S-510, THE FOOD SAFETY MODERNIZATION ACT?????
Please oppose H.R. 2749, S.510, and all other so-called food safety bills.
This bill is serious. Please study
what happened at La Milpa Organica Farm in San Diego.
It has already broken regulations that should
not be applied to small micro farms.
This bill S-5120 will increase regulations
where they do not belong.
It will not fix the problem of the bugged industrial food system.
The large ag systems is the problem.
It is unsafe and cannot be fixed.
This will will not fix it.
LATE BREAKING NEWS
September 23, 2010:
S. 3767 Date of Scheduled Consideration [e.g, bill could be voted into law that day or S. 510
could be introduced as an amendment and put forward in that manner.
Stop it before gets to the Senate floor to be rammed through into law.
Take Action Items Above to Prevent These Events From Taking Place. Then Share Them With Everyone Who Eats - Anything!
FDA APPROVAL OF ASPARTAME
brain toxin. Approved in 1981.
TRAILING FROM
A BEAUTIFUL TRUTH.
DVD knocks flourine
in dentist offices
FDA approval of Amalgams
in fillings
A logical approach to the amalgam issue would be for the F.D.A. to reclassify amalgam to a Class III device. Such a classification would require the manufacturers to submit the results of safety and effectiveness research in order to continue its manufacture. In other words - to prove that amalgam is safe - the same request that the F.D.A. has made of silicone breast implant manufacturers.
The World Health Organization, O.S.H.A., N.I.O.S.H., etc, all agree that mercury is an environmental poison and have established specific occupational exposure limits. The Environment Protection Agency has declared amalgam removed from teeth to be a toxic waste. Even the American Dental Association warns that amalgam filling material is hazardous to dental office personnel, but is safe in patients' mouths.
The most puzzling thing about this 160 year old controversy is that it is still a controversy.
Mercury in Fish: FDA Faulted
An FDA scientist criticizes the agency's loose regulations, which allow fish with high levels of mercury into the U.S. and let importers escape scrutiny
by John Carey
BW EXCLUSIVES
Eating fish is good for you, as numerous studies confirm. But there are certain fish, such as swordfish and shark, that you might want to eat sparingly. Large fish belonging to these species often contain high levels of mercury, a neurotoxin, and regulatory agencies are doing a poor job of keeping such specimens off of Americans' dinner plates. That criticism has been voiced by some of the government's own scientists, who believe the system for inspecting imports of fish is weak and can be easily circumvented by savvy importers.
My FAVORITE QUOTE
FROM MICHAEL R. TAYLOR
came from his testimony here:
7:59 PM
July 31, 09
MICHAEL TAYLOR
BEFORE the DENNIS KUCINICH
Hearing JULY 29:
"In addition, FDA is leading an effort
through the Codex Alimentarius Commission,
the international food safety standards body,
with support of the Food and Agriculture
Organization/World Health Organization,
to develop commodity-
specific annexes to the Codex hygienic code
for fresh fruit and vegetable production,
starting with an annex for fresh leafy
vegetables and herbs."
--Mr MICHAEL TAYLOR
Our Food Czar for the FDA
Senior Adviser to the Commissioner on food issues
The above quote is from the written testimony
of MICHAEL TAYLOR July 29 at the
REP DENNIS KUCINICH
SUBCOMMITTEE ON DOMESTIC POLICY
COMMITTEE ON OVERSIGHT
AND GOVERNMENT REFORM
U.S. HOUSE OF REPRESENTATIVES.
The Subcommittee Hearing was Titled:
"Ready to Eat or Not? It Examined
the Impact of Leafy Green Marketing Agreements.
You can read Michael Taylor's complete
testimony at the above link.
Here is another great story that
discusses the contribution of this
highly successful man who
achieves many of his goals.
Public Health Service
Food and Drug Administration
Silver Spr¡ng MD 20993
TESTIMONY OF
MICHAEL R. TAYLOR, J.D.
SENIOR ADVISOR TO TFIE COMMISSIONER
FOOD AND DRUG ADMINISTRATION
DEPARTMENT OF FIEALTH AND HUMAN SERVICES
BEFORE TITE
SUBCOMMITTEE ON DOMESTIC POLICY
COMMITTEE ON OVERSIGHT AND GOVERNMENT REFORM
U.S. HOUSE OF REPRESENTATIVES
JULY 29,2009
FOR RELEASE ONLY UPON DELIVERY
INTRODUCTION
Good aftemoon, Chairman Kucinich and Members of the Subcommittee. I am Michael Taylor,
Senior Advisor to the Commissioner at the Food and Drug Administration (FDA or the Agency),
which is part of the Department of Health and Human Services (HHS). I am pleased to be with
you today to discuss issues related to the safety offreshproduce.
FDA ís the federal agency that is responsible for most of the food supply except for meat,
poultry, and processed egg products, which are overseen by our partners at the U.S. Department
of Agriculture (USDA). FDA is committed to ensuring that the U.S. food supply continues to be
among the safest in the world.
Food can become contamínated at many different steps - on the farm, in processing or
distribution facilities, dùring transit, at retail and food service establishments, and in the home.
In ¡ecent years, we have done a great deal to prevent both intentional and unintentional
contamination of food at each of these steps. FDA has worked with other federal, state, local,
tribal, and foreign counterpart food safety agencies, as well as with law enforcement and
intelligence-gathering agencies, and with industry, consr¡mer groups, and academia to strengthen
the n¿ition's food safety and food defense system across the entire distribution chain.
This cooperation has resulted in greater awareness ofpotential vulnerabilities, the creation of
more effective prevention programs, new surveillance systems, and the ability to respond more
quickly to outbreaks of foodborne illness. However, changes in consumer dietary patterns,
changes in industry practices, changes in the U.S. population, and an increasingly globalized
food supply chain pose challenges that are requiring us to adapt our cunent food protection
strategies.
President Obama has made a personal commitment to improving food safety. On July 7,2009,
the multiagency Food Safety'Working Group (Working Group), which he established, issued its
key findings on how to upgrade the food safety system for the 2l't century. The Working Group
recommends a new public-health-focused approach to food safety based on three core principles:
prioritizing prevention, strengthening surveillance and enforcement, and improving response and
recovery. FDA is playing an integral part in the Working Group's continuing efforts, I will
describe below a couple of initiatives specifically related to fresh produce that FDA is taking to
implement the WorHng Group's initial key findings.
In discussing these initiatives, my testimony also will describe some of the challenges we face
both in preventing fresh produce from becoming contaminated and in investigating outbreaks
associated with fresh produce. I will also discuss some of the specific measures FDA is taking to
enhance the safety of fresh produce to prevent future outbreaks and to improve product tuacing
when an outbreak occurs or there is a product recall. Finall¡ I will address some of the
legislative authorities the'Working Group identified as necessary for modernizing the food safäty
statutes.
CHALLENGES OF FRESH PRODUCE
Fresh produce presents special safety challenges, and the number of illnesses associated with
fresh produce is a continuing concern for FDA. Consumption of produce in its fresh (or raw)
form, particularly "ready-to-eat" products such as bagged, prewashed lettuce, has increased
substantially during the past decade. These new products and consumption patterns challenge
our food safety efforts' Because produce is often consumed raw or with only minimal
processing, without intervention that would eliminate pathogens (if they are present) prior to
consumption, it has the potential to be a source of foodborne illness.
Most produce is grown in an outdoor environment, and it is susceptible to contamination from
pathogens that may be present in the soil, in agricultural water or water used for postharvest
practices (e.g., washing or cooling), in manure used as fertilizer, or due to the presence of
animals in or near fields or packing areas. Produce also may be vulnerable to contamination due
to inadequate worker health and hygiene protections, environmental conditions, inadequate
production safeguards, or inadequate sanitation of equipment and facilities. Fresh produce is
produced on tens of thousands of farms, and contamination at any one step in the growing,
packing, and processing chain can be amplified throughout the subsequent steps.
'We
also note that traceback investigations for contaminated food are more difflrcult when they
involve fresh produce because the food is perishable and the produce item (along with any
packaging or labels) is usually no longer available for examination or testing by the time
ill¡esses are reported. In addition, fresh fruits and vegetables are often sold loose without any
packaging that could provide information about their source. Further, practices such as packing
or repacking produce fiom multiple sources add complexity to traceback investigations.
Consequently, addressing the way fresh produce is grown, hawested, and moved from field to
fork is crucial to minimizing the risk of microbial contamination. In recent years, FDA has
initiated several activities to address safety concerns associated with the production of fresh
produce. Some of these activities include: working with industry and others to develop
commodity-specific guidance on ways to prevent or minimize potential contamination; working
with the states to increase inspections and to develop commodity-specific food safety programs;
conducting educational outreach to consumers on safe food handling practices; investigating
farms and packing sheds implicated in outbreaks to learn how the produce may have become
contaminated; sampling and analynng both domestic and imported produce for pathogens;
developing risk assessment methods and tools to better characterize and understand the
effectiveness of controls to reduce hazards in produce; and working with industry and foreign
counhies to promote the use of good growing, harvesting, packing, transporting, and processing
practices.
It also is important to emphasize the critical role of food producers and processors in ensuring
the safety of the foods they introduce into coülmerce. Stong food safety programs begin with
the promotion of a strong culture of food safety throughout each famr or firm in the supply chain,
including the need for preventive measures and ways to detect and corect problems before they
cause harm. Establishing this culture requires a strong sense of corporate responsibility and
continuous management oversight.
One of the key messages that FDA has been emphasizing over the last few years is that all food
companies, both large and small, must know their suppliers. In today's complex, global market,
this may require close interaction with entities throughout the food supply chain, including
growers, manufacturers, distributors, retailers, food service providers, and importers.
From the perspective of both public health and economic interests, preventing foodborne illness
from occurring is much more desirable than having to minimize not only the adverse public
health impact caused by such outbreaks but also the economic damage by undertaking food
recalls, which can often bring production to a halt, disrupt markets, affect consumer confidence,
and cause financial loss, It is critical that all segments of the food supply chain, from farm to
retailer, take measures to ensure the safety of their ingredients and thei¡ finished products.
You asked about the current science on the safety ofready-to-eat bagged leafu greens, especially
with regard to the risk of bacterial growth, including Listeria and Escheríchia coli (8. coti)
Ol57:H7 pathogens, and about phages. The differences in growth and survival of pathogens on
both whole and fresh-cut leafy greens are not suffrciently documented and not fully understood,
although some studies have shown the ability of pathogens to survive and grow on fresh-cut
products. While comparisons between whole and cut products are scarce in the scientific
literature, some studies have demonstrated that pathogens can attach to both cut and intact
surfaces of lettuce tissue. Fresh-cut vegetables provide a higher level of moisture, nutrients, and
more st¡tface area, which make ready-to-ealfresh-cutproducts more susceptible to microbial
growth (non-pathogens and pathogens) than the orþinal intact product, Leafy greens that are
processed may be exposed to further risk of microbial contamination from workers, surfaces,
equipment, water, and ae¡osols, enabling microorganisms to persist and grow.
Some processes have the potential to reduce microbial risks (e.g., disinfection), control microbial
growth (e.g., chilling), and protect the product from further exposure (e.g., packaging). Current
technologies or practices do not effectively eliminate all risk incuned during postharvest
processing and packaging of fresh and fresh-cut leafy greens, although, some risk reduction is
possible. Storage temperature and length of storage time of ready-to-eat leaff greens are of
critical importance for the control of bacterial pathogens and ultimately the safety of these
products. Growth of Listeria monocytogenes (L. monocytogenes) at 3-5oC in refrigerated freshcut
packaged leafy greens has been demonstrated. E. coli Ol57.H7 has also been shown to
survive for several days under refrigerated conditions. Viability of vi¡uses is influenced very
little or not at all by low temperatures. However studies have shown that naturally occurring
viruses were not typically found on fresh vegetables or in the processing environment of these
products. Viruses are primarily introduced through human handling processes. Phages infect
bacteria and do not pose a public health risk to humans. In fact, certain types of phages are
under investigation for biocontrol of pathogens, such as L. monocytogenes and E. coli Ol57:H7 '
INITIATIVES TO ENHANCE PRODUCE SAFETY
In the short term, FDA's approach is to issue commodþ-specific guidance for industry on the
measures they can implement to prevent o¡ minimize microbial hazards of f¡esh produce. To
improve compliance with suchmeasures, FDA also plans to work with USDA's Agricultural
Marketing Service (AMS) to include these recommended standards in their marketing
agrcements and orders when appropriate. Our long-term plan is to set .nfo.r.ubl. produce
safety standards through a regulation. I will discuss these activities in more detail below.
Fed eral Com mo dity-Specific P ro du ce S afety D raft G u id ances
Soon FDA will be publishing new commodity-speciflrc draft guidances for improving the safety
of leafy greens, melons, and tomatoes. The guidances describe preventive controls that industry
can implement to reduce the risk of microbial contamination in the growing, harvesting,
transporting, and distributing of these commodities. These guidance documents build on FDA's
1998 general guidance on good agricultural practices for freshproduce but go beyond it by
tailoring the guidance to these three specific commodities that have been associated with
foodborne illness outbreaks and taking into account knowledge gained since 1998.
FDA's guidances recognize and embrace the progress industry has made in establishing
quantitative metrics for the control of some of the factors affecting produce safety. FDA is
studying the scientific basis for these metrics and will incorporate appropriate metrics in its
produce safety regulation.
FDA's commodity-specific draft guidances represent the Agency's current thinking on how to
improve the safety of leafu greens, melons, and tomatoes and are a step along the path to
enforceable standards and a safer supply of fresh producq. They reflect and promote the best
practices fo¡ the industry and aÌe an attempt to heþ both domestic and foreign firms minimize
the risk of microbial contamination of their products throughout the entire supply chain.
In addition to the general guidance on good agricultural practices and guidance for safe
production of safe sprouts, in recent years, FDA also has published final guidance for industry to
minimize microbial food safety hazards for fresh-cut fruits and vegetables (the Fresh-Cut Guide).
The Fresh-Cut Guide, which FDA published in 2008, complements FDA's Current Good
Manufacturing Practices for food processing facilities. It is intended to assist frms by providing
recommendations specific to fr esh-cut processing operati ons.
In addition, FDA is leading an effort through the Codex Alimentarius Commission, the
international food safety standards body, with support of the Food and Agriculture
OryanzationlWorld Health Organization, to develop commodity-specific annexes to the Codex
hygienic code for fresh fruit and vegetable production, starting with an annex for fresh leafy
vegetables and herbs. In June 2009, FDA conducted the first Codex international elechonic
working group with members of the Codex Committee on Food Hygiene (CCFÐ to advance the
drafr Annex for Fresh Leafy Vegetables to the next stage of completion. In November 2009,
CCFH will consider how to proceed with the next tier of priority commodities.
Produce Safety Regulation
As I mentioned earlier, preventing harm to consumers is one of the core principles identified by
the Working Group, and it is our first priority. Too often in the past, the food safety system has
focused on reacting to problems rather than preventing harm in the fust place. The Working
Group recommends that food regulators shift towards prioritizing prevention and move
aggressively to implement sensible measures to prevent problems before they occur.
As the federal regulatory agency responsible for ensuring produce safet¡ FDA has begun work
on a regulation to establish enforceable standards forproduce safety under our cu¡rent
authorities. The regulation will be based on the prevention-oriented public health principles
embraced by the Working Group. It will capitalize on what we have learned over the past
decade, since we published our "good agricultural practices" guidelines in 1998. The regulation
also will utilize the progress industry has made in establishing quantitative metrics for the control
of some of the factors affecting produce safety by incorporating appropriate measures of success,
These metrics, or measures, will improve our ability to verify that certain measures or practices
are being carried out and are effective.
Together with its federal and state partners, FDA will work to plan and implement an inspection
and enforcement progrâm to ensure high rates of compliance with the produce safety regulation.
If Congress passes food safety legislation that includes explicit authority to require preventive
controls, FDA would modifu and update this rulemaking in light of the new authority.
The regulation will include the following key elements:
clear standards for implementation of modern preventive controls by all participants in
the fresh produce supply chain, from farm to market. These performance-oriented
standards will recognize that operators must tailor their preventive controls to the
particular hazards and conditions affecting their operations, but the regulation will ensure
they do so in accordance with modern food safety principles;
product-specific standards and guidance, where appropriate, for high-risk commodities;
quantitative measures of the effectiveness of control systems, to the extent they are
feasible and valid; and
microbial testing protocols to verify the effectiveness of preventive controls.
FDA will work with the industry to facilitate compliance with the new regulation through the
following ways:
issuance ofa science-based "hazards guide" to assist producers and processors in
designing their preventive controls;
provision of other technical assistance and guidance on how to comply with the new
rules;
establishment of reasonable time periods for implementation of the rules, taking into
account firm size; and
cooperation with USDA extension programs and industry-sponsored education efforts to
foster understanding and implementation of the requirements.
FDA recognizes that the produce sector consists not only of large national and international
operators but also many small producers, including many who market directly to consumers at
roadside stands and farmers markets, FDA will carefully consider the public health and
economic impacts of applying the requirements of the newrules to very small producers and will
consider appropriate adjustments in the regulation.
Enhancing Product Tracing
Another key finding of the Working Group is the need to build a national tracing and response
system. A system that permits rapid tracing to the source of the product contamination will
protect consumers and also help industry recover faster. Yet, despite the dedicated efforts of
food safety officials across the country, our current capacity to trace the sources ofproducerelated
illness suffers from serious limitations.
10
The ability to trace pathways of any food, including fresh produce, fo¡-ward and back tl'ough
every point in the supply chain is crucial for limiting foodborne illness in an outbreak, for
preventing future outbreaks, and for reducing the impact on the segments of the industry whose
products were not associated with the ilinesses. The pathways that fresh produce travels from
field to consumer have become increasingly complex, with items sometimes changing hands
many times in the supply chain.
FDA has reached out to various organizations, including trade associations and consumer
organizations, to gain a better understanding of best industy practices for product tracing. For
example, in late 2008 and early 2009,FD4 held two public hearings requesting data and other
information on industry practices a¡rd available technologies relevant to improving our ability to
more quickly and accurately track fresh produce through the supply chain, especially during a
produce-associated foodborne illness outbreak. Using this information from our stakeholders,
FDA will issue draft guidance withinthe next three months on the steps the food industry can
take to establish product tracing systems to improve our national capacity for identirying the
origins of foodborne illness.
FDA also has entered into a contract with the Institute for Food Technology to conduct a mock
traceback scenario with tomatoes, with the cooperation of representatives of the tomato industry
and two technology companies. The pilot is scheduled for completion in September 2009. FDA
plans to pursue additional pilots to focus on other commodity-technology combinations in the
future.
il
We have been working extensively with states and the fresh produce indus$ to encourage
incorporation of product tracing procedures and technology. For example, FDA assisted the
Florida Tomato Commission and the University of Florida/Institute of Food and Agricultural
Sciences in the development of Florida's Tomato Best Practices Manual. This Manual
incorporates Good Agriculhrral Practices, Good Handling Practices, and traceability
recommendations for industry. The Manual formed the basis of the State of Florida's tomato
safety rule.
Research
Strengthening the research programs that support FDA's program to improve food safety is
essential to improving the Agency's effectiveness at protecting public health. Our cunent
research agenda is focused on improving the identification and detection of disease-causing
bacteria and contaminants in a variety of foods. Current research topics include questions related
to how and where in the food chain microbiological and chemical contamination of foods takes
place, biotechnology and allergenicity issues, seafood safety, dietary supplement safety, color
additive safety, and consumer studies. The determination of microbiological and chemical risks
and their mitigation drives our research progrrìm.
FDA and our food safety partners are doing extensive research on the detection, characterization,
and behavior of foodborne pathogens, microbial genetics, and molecular virology. For instance,
the Centers for Disease Control and Prevention and FDA have developed rapid methods for
serotyping Salmonella in produce (such as cantaloupes, tomatoes, and peppers). These rapid
t2
methods will aid FDA as we perform analysis of both domestic and imported produce samples.
These efforts also a¡e vital for our development of risk assess¡nent models for pathogens and
intervention strategies to reduce the public health risk that these pathogens present. More rapid
and precise testing methods to identi$ contaminants are important for minimizing the spread of
foodborne disease once it occurs.
Collaborative research efforts further strengthen the scientific basis for our food safety programs.
For example, for the past decade, FDA has worked closely with USDA's Agricultural Research
Service and Cooperative State Research, Education, and Extension Service to coordinate and
mutually support ow respective research eflorts related to produce safety. In addition, we are
working with academia" industry, other federal agencies, and state governments to develop both
risk-based microbiological research programs and technology transfer programs to ensure that
the latest food technology reaches the appropriate end users along the supply chain.
As part ofthe Center for Excellence program, FDA maintains four topic-specific centers: the
National Center for Natural Products Research at the University of Mississippi; the National
Center for Food Safety and Technology at the Illinois Institute of Technology; the Joint Institute
for Food Safety and Applied Nutrition (JIFSAN) at the University of Maryland; and the newly
established (2008) Western Center for Food Safety (WCFS) at the University of California at
Davis, which focuses on the intersection between production agriculture and food safety.
In its first year, the WCFS has focused on conducting produce safety research addressing the
science behind Good Agricultural Practices and developing outcome metrics and an updated
t3
Iiterature review related to perchlorate and its impact on food safety. The WCFS quickly
responded to our need for work on the validation of processes to destroy Salmonella on
pistachios and is working with both the pistachio and almond industries to control Salmonella on
those tee nuts.
Last year, FDA, working with the Interagency Risk Assessment Consortium and with JIFSAN,
held a workshop to identiS and prioritize research needs for conducting a quantitative risk
assessment of foodborne illness caused by E. coli OL57:H7 from the consumption of leafy green
vegetables. That workshop assisted in the development of risk assessment tools to better
characterize the hazards in produce. This effort is being enhanced by our contract with Research
Triangle Instihrte for the development of scientific assessments. Other collaborative projects are
planned and currently are being executed to interact with other academic institutions to augment
our in-house and Center for Excellence research. Such projects are based on current needs and
are meant to provide FDA with resources that may not otherwise be di¡ectly available to the
Agency.
We will continue to work with federal, state, local and international food safety partners and with
industryto develop guidance, conduct research, develop educational outreach materials, and
initiate other commodity- or region-specific programs to enhance the safety of fresh produce.
Marketing Orders and Agreements
You asked FDA to discuss the Agency's regulation of food safety provisions in agriculture
marketing agreements. Although FDA has not had a direct role in creating such agreements, we
do work collaboratively with our colleagues at AMS, which is the federal agency responsible for
t4
marketing agreements and orders. When AMS has incorporated food safety standards into its
marketing orders, FDA has provided technical assistance to AMS on the appropriate safety
practices and would provide such assistance for marketing agreements as well. It is our sha¡ed
goal that any AMS safety standards would incorporate the applicable FDA regulations or
guidance documents. I will defer to my colleague from AMS to describe these programs in more
detail.
As FDA moves forward to establish science-based standards to improve the safety of produce,
the Agency must have a plan to help ensure high rates of adoption, Given the number of
producers, FDA recognizes the importance of leveraging its resources with other federal, state,
and local agencies to help achieve greater compliance. In paficular, FDA plans to continue to
work closely with USDA, which has a great deal of experience in agricultural production and
which has a significant workforce, including through its contracts with states. We believe that
AMS, by incorporating FDA's produce safety standards in produce-related marketing
agreements or orders, can help ensure high rates of compliance with FDA's standards.
LEGISLATIVE INITIATIVES
In addition to highlighting measures that the Executive Branch could implement to enhance food
safety, the Working Group also noted the need for Congress to modemize the food safety statutes
to provide key tools for FDA, the Food Safety and lnspection Service at USDA, and othe¡
components of the federal government to keep food safe. Legislative authorities for FDA that
would enhance the safety of produce include:
o enhanced ability to require science-based preventive controls;
l5
. enhanced ability to establish and enforce performance standards to measure the
implementation of proper food safety procedures;
. access to basic food safety records at facilities;
. enhanced inspection tools to foster compliance with science-based standards;
. new tools to strengthen standards and oversight for food imports;
o the ability to require the establishment of product hacing systems; and to
. require mandatory recalls.
There are several bills in Congress that incorporate many of the authorities listed above. We
look forward to working with Congress on this important legislation to strengthen our food
safety system.
CONCLUSION
The safety of fresh produce depends on every participant in the farm-to-table supply chain
implementing modern preventive controls to minimize and, where possible, eliminate
contamination that can cause illness. We look forward to continuing to work with the produce
industry, consr¡mer groups, academia, and our food safety parbrers at the federal, state, local,
tribal, and international levels to help us reduce the incidence of foodbome illness to the lowest
Ievel possible. Thank you for the opportunity to discuss FDA's continuing efforts to improve the
safety of fresh produce. I would be happy to answer any questions.
l6
FROM FOOD INC
Some reference to Michael R. Taylor in
Food Inc.
MORE
The FDA and Monsanto: Strange bedfellows
Monsanto was required to submit a scientific report on rBGH to the FDA so the agency could determine the growth hormone's safety. Margaret Miller put the report together, and in 1989 shortly before she submitted the report, Miller left Monsanto to work for the FDA. Guess what her first job was? Strangely enough, to determine whether or not to approve the report she wrote for Monsanto! The bottom line is that Monsanto approved its own report. Miller was assisted by another former Monsanto researcher, Susan Sechen.
But in an article titled "Not Milk: The USDA, Monsanto, and the U.S. Dairy Industry" Ché Green, founder and director of The ARMEDIA Institute, a nonprofit research and advocacy organization focusing on farm animal issues in the United States, writes that, "The results of the study, in fact, were not made available to the public until 1998, when a group of Canadian scientists obtained the full documentation and completed an independent analysis of the results. Among other instances of neglect, the documents showed that the FDA had never even reviewed Monsanto's original studies (on which the approval for Posilac {rBGH} had been based), so in the end the point was moot whether or not the report had contained all of the original data."7
And as though the FDA didn't already exhibit enough audacity it handed Michael Taylor the responsibility to make the decision as to whether or not rBGH-derived milk should be labeled. (At the time, Michael Taylor, who had previously worked as a lawyer for Monsanto, was executive assistant to the Commissioner of the FDA.)
In 1994, Taylor ended up writing the rBGH labeling guidelines that prohibit the dairy industry from stating that their products either contain or are free from rBGH. Even worse, to keep rBGH-milk from being "stigmatized" in the marketplace, the FDA ruled that the labels of non-rBGH products must state that there is no difference between rBGH and the natural hormone.8
According to journalist Jennifer Ferraro, "while working for Monsanto,Taylor had prepared a memo for the company as to whether or not it would be constitutional for states to erect labeling laws concerning rBGH dairy products. In other words, Taylor helped Monsanto figure out whether or not the corporation could sue states or companies that wanted to tell the public that their products were free of Monsanto's drug."9
MICHAEL R. TAYLOR,
brought us hormone added milk
when he worked for the FDA in the 90;s
HOW DID THAT GO?
READ THIS REPORT FROM JOHN ROBBINS
Congressman Bernie Sanders was specifically referring to Taylor when he said "the FDA allowed corporate influence to run rampant in its approval of BGH." Documentaries including "The World According to Monsanto" and "The Future of Food" present Taylor's pro-Monsanto actions at the FDA as a dramatic example of the how corporate influence has exerted massive control over the FDA. Today, Taylor again works for the FDA, now as Deputy Commissioner of Foods.
New Official Named With Portfolio to Unite Agencies and Improve Food Safety
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By GARDINER HARRIS
Published: January 13, 2010
WASHINGTON — The Obama administration, moving to address the nation’s fractured food safety system, on Wednesday appointed Michael R. Taylor, a veteran food expert, as deputy commissioner for foods at the Food and Drug Administration. The newly created position is the first to oversee all the agency’s many food and nutrition programs.
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Alfan Dangin/F.D.A. Center for Veterinary Medicine
Michael R. Taylor was named to a new position at the F.D.A.
Related
Times Topics: Food Safety
The federal government’s oversight of the nation’s food supply has for decades been split among 13 disparate and sometimes feuding agencies. The result has been a growing menu of food recalls, including contaminated peanut butter, spinach and cookie dough, and the annual sickening of about 70 million people.
With new powers and extensive Washington experience, Mr. Taylor is supposed to fix this mess. But he is likely to be on a short leash.
People have been drinking raw milk for a long time, of course — at least since sheep and goats were domesticated in the 8th or 9th century B.C. Raw milk is rich in protein and fat, and milk from cows became a staple of the American diet in colonial times. When milk leaves the animal, however, it can also contain any number of pathogens, which is why most doctors consider pasteurization — subjecting milk to a short burst of heat followed by rapid cooling — one of the great public-health success stories of the 20th century. By eliminating most of the pathogens that cause disease, including E. coli, salmonella and listeria, they say, pasteurization has helped lower infectious-disease rates in the U.S. more than 90% over the past century.
Raw-milk enthusiasts have a different perspective. They insist that along with the bad pathogens, heat-treating milk destroys beneficial bacteria, proteins and enzymes that aid in digestion. Some people with a history of digestive-tract problems, such as Crohn's disease, swear by the curative powers of unpasteurized milk. Others praise its nutritional value and its ability to strengthen the immune system. "I have seen so many of my patients recover their health with raw milk that I perceive this as one of the most profoundly healthy foods you can consume," says Dr. Joseph Mercola, an osteopathic physician and author who rails against the medical establishment on his website, mercola.com.
Raw-food raid highlights a hunger
Some people balk at restrictions on selling unprocessed milk and other foods. 'How can we not have the freedom to choose what we eat?' one says. Regulators say the rules exist for safety and fairness.
July 25, 2010|By P.J. Huffstutter, Los Angeles Times
With no warning one weekday morning, investigators entered an organic grocery with a search warrant and ordered the hemp-clad workers to put down their buckets of mashed coconut cream and to step away from the nuts.
Then, guns drawn, four officers fanned out across Rawesome Foods in Venice. Skirting past the arugula and peering under crates of zucchini, they found the raid's target inside a walk-in refrigerator: unmarked jugs of raw milk.
"I still can't believe they took our yogurt," said Rawesome volunteer Sea J. Jones, a few days after the raid. "There's a medical marijuana shop a couple miles away, and they're raiding us because we're selling raw dairy products?"
Cartons of raw goat and cow milk and blocks of unpasteurized goat cheese were among the groceries seized in the June 30 raid by federal, state and local authorities — the latest salvo in the heated food fight over what people can put in their mouths.
ON GE GMO FOODS
Boycott Kellogg's Monsanto-Made Frankenfoods!
Total Signatures:
3,619 of 10,000 signatures
Causes Featuring:
Add your cause to this list
Top Signature Gatherers:
Alan Felauer
12 signatures
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9 signatures
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9 signatures
Petition Sponsor:
ORGANIC CONSUMERS ASSOCIATION wrote and will deliver this petition.
Petition Due Date:
December 31, 2010
101 days left
About this Petition:
Kellogg's loves its Monsanto-made Frankenfoods!
In Kellogg's most recent letter to consumers, "Consumer Specialist" Christina Calleros writes:
"Biotech ingredients are safe and have become common in the open market. Sixty to seventy percent of packaged foods in the U.S. include biotechnology crops. Even organic ingredients can contain biotech ingredients due to cross-pollination."
Please sign this petition to Calleros.
Tell her that Frankenfoods are not safe! Scientists reviewing Monsanto's own studies "have proven that genetically engineered foods are neither sufficiently healthy or proper to be commercialized."
Let her know that organic consumers don't appreciate Kellogg's attitude toward the genetic contamination of organic! The Supreme Court recently ruled that the potential of genetically engineered crops to pollute organic varieties is a reason to hold back Monsanto's Frankencrops -- not promote them!
Haitian Farmers Commit to Burning Monsanto Hybrid Seeds
Posted by phunkychic666 on
May 20, 2010
Beverly Bell, Associate Fellow at the Institute for Policy Studies, writing for Huffington Post:
“A new earthquake” is what peasant farmer leader Chavannes Jean-Baptiste of the Peasant Movement of Papay (MPP) called the news that Monsanto will be donating 60,000 seed sacks (475 tons) of hybrid corn seeds and vegetable seeds, some of them treated with highly toxic pesticides. The MPP has committed to burning Monsanto’s seeds, and has called for a march to protest the corporation’s presence in Haiti on June 4, for World Environment Day.
In an open letter sent of May 14, Chavannes Jean-Baptiste, the Executive Director of MPP and the spokesperson for the National Peasant Movement of the Congress of Papay (MPNKP), called the entry of Monsanto seeds into Haiti “a very strong attack on small agriculture, on farmers, on biodiversity, on Creole seeds…, and on what is left our environment in Haiti.”[1] Haitian social movements have been…
(Fedco has since dropped all Seminis varieties.)
To keep Monsanto out of your garden this season, avoid buying seed produced by Monsanto-Seminis — and ask your gardener friends to do the same. The list of varieties they produce is too long for me to list here, but you can use Seminis’ website to research specific varieties. Make sure you look at products for both home gardeners and professional growers.
Johnny’s currently carries 21 varieties produced by Monsanto-Seminis, and they’re working on phasing out those varieties as suitable replacements are found. They sent Emily of Eat Close to Home this list of all the products in their catalog currently supplied by Monsanto-Seminis:
103 SIERRA BLANCA onion
224 FREMONT cauliflower
240 HANSEL eggplant
241 GRETEL eggplant
568 BISCAYNE pepper
642 DULCE pepper
733 CELEBRITY tomatoes
2038 KING ARTHUR pepper
2063 BIG BEEF tomatoes
2212 PRIZEWINNER pumpkin
2260 FAIRY TALE eggplant
2309 X3R RED KNIGHT pepper
2365 ORANGE SMOOTHIE pumpkin
2368 PATTY GREEN TINT summer squash
2894 SERRANO DEL SOL pepper
2954 CHEDDAR cauliflower
2991 CANDY onion
122 BEAUFORT tomatoes
2794 GERONIMO tomatoes
2700 MAXIFORT tomatoes
2373 TRUST tomatoes
Alternately, you could get your seeds from one of the many distributors that isn’t supplied by The Devil Monsanto; High Mowing Seeds, Fedco, Seed Savers Exchange and Baker Creek are all good examples, and Botanical Interests, whose first-ever print catalog comes out very soon, carries only one Monsanto-Seminis variety (the “celebrity” tomato).
Obama Puts GMO Booster in Charge of Food Safety
By Alexis Baden-Mayer, Esq.
Organic Consumers Association, July 22, 2009
Straight to the Source
Genetically modified foods are not safe. The only reason they're in our food supply is because government bureaucrats with ties to industry suppressed or manipulated scientific research and deprived consumers of the information they need to make informed choices about whether or not to eat genetically modified foods.
Now, the Obama Administration has put a two notorious biotech bully in charge of food safety! Former Monsanto lobbyist Michael Taylor is the senior adviser to the Food and Drug Administration Commissioner on food safety.
About Michael Taylor
Michael Taylor is a lawyer who has spent the last few decades moving through the revolving door between the employ of GMO-seed giant Monsanto and the FDA and USDA. Taylor is widely credited with ushering Monsanto's recombinant bovine growth hormone (rBGH) through the FDA regulatory process and into the milk supply -- unlabeled. A Government Accounting Office (GAO) investigated whether Taylor had a conflict of interest and or had engaged in ethical misconduct in the approval of rBGH. The report's conclusion that there was no wrongdoing conflicted with the 30 pages of evidence that Vermont Congressman Bernie Sanders (I-VT) described as proof that "the FDA allowed corporate influence to run rampant in its approval" of the drug.
Taylor is also responsible for the FDA's decision to treat genetically modified organisms as "substantially equivalent" to natural foods and therefore not require any safety studies. The "substantially equivalent" rule allowed the FDA to ignore evidence that genetically engineered foods, including soy, are in fact very different from natural foods and pose specific health risks.
In November 2008, Tom Philpott reported that Taylor was among President-Elect Obama's "team members" looking at energy and natural resources agencies, including USDA. In March 2009, President Obama announced the creation of a White House Food Safety Working Group to improve and coordinate the government's approach to the nationwide food safety crisis. Agri-Pulse reported that Taylor was "the leading candidate to staff the White House [food safety] working group." While anti-GMO activists, including the Organic Consumers Association, protested -- OCA members sent 13,435 letters to USDA Sec. Tom Vilsack, who co-chairs the Food Safety Working Group with HHS Sec. Sebelius -- Taylor laid low. He was nowhere to be found at the White House Food Safety Working Group's May 13th Listening Session. But, the rumor proved true. On July 7, 2009, the FDA announced that Taylor had joined the agency as senior adviser to the commissioner.
TAYLOR HOSTILE TO SMALL FARMING?????
As Philpott describes in a July 8th article, Taylor's food safety agenda is to "shift much more of the burden for funding food-safety operations to the state and local level" and to promote HACCP (Hazard Analysis and Critical Control Point) systems where the points in a process that pose the most risk are identified and “fixed” with remedies like ammonia washes and irradiation. Taylor's approach -- putting a few bandaids on an industrialized food system gone wrong -- is in direct conflict with organic practices and is likely to unduly burden small producers.
Taylor has long been hostile to real food safety. While working as a lobbyist, Taylor authored more than a dozen articles critical of the Delaney Clause, a 1958 federal law prohibiting the introduction of known carcinogens into processed foods, which had long been opposed by Monsanto and other chemical and pesticide companies. When Taylor rejoined the federal government, he continued advocating that Delaney should be overturned. This was finally done when President Clinton signed the so-called Food Quality Protection Act on the eve of the 1996 elections.
Taylor is featured in the documentary, The World According to Monsanto, which you can watch on OCA's Millions Against Monsanto page.
MONSANTO INFLUENCE IN WASHINGTON THROUGH
MICHAEL R TAYLOR
DELANEY CLAUSE
Perhaps no American company has so zealously exploited Washington's
revolving door as Monsanto, which has seized on ex-Clinton aides and federal
bureaucrats to advance its interests. Consider the case of Michael Taylor:
After graduating from law school in 1976, Taylor went to work for the FDA,
rising through the ranks. He left the Federal government for a post in the
high-poweredWashington law firm of King and Spaulding to become their FDA specialist.
During his tenure there, Taylor represented Monsanto's efforts to gain FDA
approval for rBGH. Taylor left the firm in 1991 to rejoin the FDA, this
time as deputy commissioner for policy. In that position, he wrote the
guidelines on the use and marketing of rBGH, which turned out to be very
favorable for Monsanto. The FDA guidelines exempted milk producers from
labeling dairy products from cows that had been treated with rBGH. Now
Taylor has resumed to Monsanto, working on what the company calls "long
range planning."
During his days at King and Spaulding, Taylor also authored more than a
dozen articles critical of the Delaney Clause, a 1958 federal law
prohibiting the introduction of known carcinogens into processed foods,
which had long been opposed by Monsanto and other chemical and pesticide
companies. When Taylor rejoined the federal government, he continued
advocating that Delaney should be overturned.
In the fight to bring down Delaney, Monsanto also secured the services of
the Duberstein Group, the lobbying firm of Ken Duberstein, former chief of
staff under George Bush and a close friend of Gen. Colin Powell.
Duberstein's outfit is a sterling example of the bipartisan nature of
lobbying, since its roster of lobbyists includes former Reagan and Bush
administration officials, an adviser to former Vice President Walter
Mondale, a former aide to Senate Majority Leader Trent Lott and House
Democratic Whip David Bonior's former chief legislative aide.
Monsanto's lobbying apparatus even has penetrated the ranks of a nonprofit
consumer group, the Safe Food Campaign, which advocates tougher food
inspection standards. The group was founded by Carol Tucker Foreman, who
served as an assistant secretary of agriculture in the Carter
administration.
Letters To Leaders
All messages are published with permission of the sender. The general topic of this message is Agriculture/Food:
Subject:
Oppose S.510
To:
President Barack Obama
Rep. John Tanner
Sen. Lamar Alexander
Sen. Bob Corker
September 1, 2010
KEEP A "HOLD" ON S.510! This bill is NOT a 'noncontroversial' bill that the Senate can sneak through as a unanimous consent action! Your constituents and others all around the US, in our determination to protect the right of every American to clean, healthy, clearly labeled, unadulterated food, have brought strenuous objection to degrading our food supply and implementing the well-presented, but very dangerous Codex HARMonziation which the corrupt and dangerous FDA, USDA and other industry-led agencies are so eager to present to us as faits accompli.
Instead, we look to you to preserve our right to clean food, labeled to indicate pesticides, adulterants, GMOs and other dangerous ingredients and to make sure that S. 510, the mis-named "Food SAFETY Bill" is defeated through either inaction or a successful Nay vote and any similar bill is, likewise, defeated. This is a controversial matter that should not be pushed through the Senate by "unanimous consent." Among the dangers facing our food and our freedom is the FDA's determination to destroy our access to high potency nutrients although guaranteed by the 1994 Dietary Supplements Health and Education Act (DSHEA). Amendments and bills to do so, along with the FDA's illegal Codex activities constantly threaten this freedom of choice. I look to you as my elected legislator to protect this right along with all other food and health freedom related ones. I will be monitoring your activities on these issues closely. Thank you in advance for your work in the service of health and freedom. I take these issues very seriously and will vote on the basis of their support by my legislators and other elected officials. PLEASE PLACE OR KEEP A "HOLD" ON THIS BILL! Have your staff call the Senate Cloak Room staff and tell them this bill is, in deed, a controversial matter that should not proceed by unanimous consent. I repeat: this is not a non-controversial matter that could pass the Senate as a "unanimous consent" item. Therefore, please place a "hold" on this bill so it does not "sneak" through the Senate. STOP THE MONOPOLY BILL! STOP FORCED INDUSTRIALIZATION OF OUR LOCAL FOOD SUPPLIES! STOP THE BIG AGRI BIZ POWER GRAB!" This is a very important matter to me and I will keep track of your actions on this bad bill.
Dover , TN
FROM DOWNSIZE D.C>
YOU are to be thanked for this. DC Downsizers were part of a large army of concerned citizens that killed earlier bills.
But the bad news is still very bad. This bill . . .
authorizes warrantless searches of farms
imposes a $500 tax (or "registration fee") of all operators in all steps of the food production chain
imposes civil penalties up to $20,000 per individual for each violation
creates a food trace-back system, burdening farms and small businesses with reams of new paperwork
empowers the Dept. of Health and Human Services to micro-manage the raising and harvesting of crops (you might have assumed that Congress would've handed the U.S. Dept of Agriculture this terrible power).
In essence, Congress wants to punish the innocent and protect the guilty. It is not small farms and businesses that were the source of contaminated food scares, but rather the processing facilities of large corporations. Yet this bill will only drive small farms out of business, which means reduced competition and higher prices in an already-bad economy.
Please send an URGENT letter to Congress telling them to defeat H.R. 2749. Tell them the bill will only hurt competition and put undue burdens on small farmers.
Sending a message is easy. You can write as much or as litt