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Food Safety Concerns (section 2)

The fundamental reason for addressing food safety is to minimize the risk that consumers become ill from the food they eat.  A closely related objective for food law is that consumers are provided adequate and accurate information they can use when deciding which foods they want to consume.

“The World Health Organization (WHO) and Food and Agriculture Organization (FAO) define food safety as food that is free from all hazards, whether chronic or acute, that may make food injurious to the health of the consumer.”  Elmi in Food safety: current situation, unaddressed issues and the emerging priorities at http://www.emro.who.int/Publications/EMHJ/1006/PDF/13%20Food%20safety.pdf citing Assuring food safety and quality: guidelines for strengthening national food control systems. Rome, Food and Agriculture Organization of the United Nations and World Health Organization, 2003.

This web page is an opportunity to briefly consider why food could be dangerous to a consumer.

“Sources of food contamination are almost as numerous and varied as the contaminants themselves. These include everything from preharvest conditions to contamination introduced during processing, packaging, transportation, and preparation. Some of CFSAN's current areas of food safety concern are:

• biological pathogens (e.g., bacteria, viruses, parasites)
• naturally occurring toxins (e.g., mycotoxins, ciguatera toxin, paralytic shellfish poison)
• dietary supplements (e.g., ephedra)
• pesticide residues
• toxic metals (e.g., lead, mercury)
• decomposition and filth (e.g., insect fragments)
• food allergens (e.g., eggs, peanuts, wheat, milk)
• nutrient concerns (e.g., vitamin D overdose, pediatric iron toxicity)
• dietary components (e.g., fat, cholesterol)
• radionuclides
• TSE-type diseases (e.g., chronic wasting disease in elk)
• product tampering.”

Excerpt from “Center for Food Safety and Applied Nutrition – Overview”; as will be explained in a subsequent section, the Center for Food Safety and Applied Nutrition (CFSAN) is part of the Food and Drug Administration (FDA) in the Department of Health and Human Services.

Why food would make a consumer ill?

• The food was produced from a spoiled or contaminated product; for example, it was produced from a diseased animal, a spoiled plant, a crop with a pesticide residue, or an animal with carryover medication.
• The food has spoiled as a result of natural processes.
• The food was contaminated by something that was added to the food or something that the food came in contact with.
• A substance being added to the food or came in contact with the food during processing may have been inadvertently contaminated, such as a contaminated ingredient; the food may also be contaminated as a result of being processed with contaminated water.
• A substance was intentionally added to aid production (such as applying a pesticide) or to enhance the product (such as adding a nutrient supplement e.g., adding a vitamin to a breakfast cereal), but the substance unexpectedly made the food dangerous to the consumer.
• A substance was intentionally added to the food for economic gain for the processor, such as reducing the cost of producing the food. Some past examples include adding water to milk or using a lower quality flour (e.g., flour derived from beans rather than wheat) to produce a dough product.
• Intentionally adding a substance for the purpose of making the consumer ill; that is, a malicious attacks on the food system.  An example would be a terrorist attack on the food system.
• The food was contaminated by something it came in contact with; e.g., dirty or contaminated equipment in a processing facility, packaging material that impacts the quality of the food product, or unsanitary preparation practices at home or at an establishment where food is being prepared to be consumed away from home.

These several examples illustrate some of the situations that can result in unsafe food.

Adulterated

From a legal perspective, food is considered adulterated if it is rendered unsafe as a result of being contaminated by a substance that had been inadvertently or intentionally added to the product. 

Note that a basic principle of US food law is that “adulterated” food is prohibited from being marketed.  Authority for this concept can be found in federal statutory law at 21 USC §331.

“The following acts … are prohibited:
(a) The introduction or delivery … into interstate commerce of any food … that is adulterated or misbranded.
(b) The adulteration or misbranding of any food … in interstate commerce.
(c) The receipt in interstate commerce of any food … that is adulterated or misbranded …”

The definition of adulterated is not limited to adding substances.  A food product is also adulterated if something has been removed from the food, something that the consumer would normally expect the food to contain, something that now that it has been removed reduces the value of the food, something that has been removed without the processor informing the consumer that it has been removed.  For example, removing fat from milk but still selling the product as whole milk.  Reference to this concept can be found in federal statutory law at 21 USC §342(b)(1).

“A food shall be deemed to be adulterated … If any valuable constituent has been in whole or in part omitted or abstracted therefrom …”

The concept of “adulterated” is addressed in more detail in another section.

Misbranded

A second concern is whether consumers have adequate and accurate information on which to base their decisions about which food they want to consume.  The law recognizes this concern by prohibiting the sale of any food that is misbranded.  As stated previously, authority for this concept can be found in federal statutory law at 21 USC §331.

“The following acts … are prohibited:
(a) The introduction or delivery … into interstate commerce of any food … that is adulterated or misbranded.
(b) The adulteration or misbranding of any food … in interstate commerce.
(c) The receipt in interstate commerce of any food … that is adulterated or misbranded …”

In implementing this prohibition, US federal law prohibits the sale of food that is being promoted or marketed with misleading information.  The law requires that certain information be provided to consumers, generally as part of the product label.  The law also addresses this concern by promoting consumer education and regulating advertising claims.

Adulteration and misbranding of foods are discussed throughout these materials.  These two concepts provide the foundation for addressing the concerns about the safety of food and information about food products.

Some Commonly-Used Terminology

The discussion has focused on food safety; sometimes there are references to food security, food protection, and similar terms.  A question is whether these terms have the same meaning and can be used interchangeably, or whether they are referencing different concepts.  Although there does not appear to be a general agreement as the meaning of the terms, I would offer some observations.

Food security appears to have at least two definitions.  Sometimes within the US, food security is used interchangeably with food safety.  Outside the US, food security often means the concern about assembling a food supply that meets the nutritional and caloric requirements of the consumers.  I would suggest we use the “international” definition of food security; that is, having enough food.

Food safety then can be used to mean the concern over whether the food will make the consumer ill.

Food protection is apparently defined as sheltering our food from intentional attacks that are intended to make the consumer ill.  Agro-security, bio-security and similar terms often are used to refer to concerns over intentional attacks on our food system.

There are no standard definitions for several terms and that can lead to confusion, this is especially the situation for “food security.”

Additional Readings that may be of Interest

• See http://www.trap-it.com/food_security_vs_food_safety.htm for commentary on the distinction between food safety and food security (US definition).
• Interesting site with a discussion of food safety and food security -- http://foodafrica.nri.org/index.html
• World Events Helped Define Food Safety (2006 NAFFS Yearbook) at http://naffs.mytradeassociation.org/3/3_10/world-events-helped-defin.shtml

Last Updated January 4, 2008

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