May 6, 2015
RealReasonFoodIsNotSafe
The word “recall” sends the average American into a panic checking lot codes and best buy dates on everything from spinach to peanut butter. Here is the secret, the scary thing about a recall is not the Salmonella and here is why:

For the majority of my career life, I worked in IT as a project manager; a field that is far from government-regulated. It is probably safe to say that it is self-regulated, where the risk of compromising a customer’s personal information is the driving factor for extensive security measures and strict programming methodology. In the second phase of my career, I have entered the pet food industry; it is a far cry from technology in many ways, not least of which is the ways in which it is regulated.

When I started with Steve’s Real Food I was a liberal Obama supporter whose perception of the government was positive and filled with excitement; something that was not felt my many Americans back in 2010. Now, after five years of navigating the muddy waters of federal, state and industry regulations, my stance on government has shifted. I am not anti-government but have found that between the corporate influence and the naïveté that is a result of mass group thought, not only is it nearly impossible to make change happen, but the change that is attempted is based on archaic information, making it hard to keep up with the speed of reality. The result is that the majority of the consumer population is misinformed, and in turn, given a false sense of security.

FSMA

One of the biggest misunderstandings about food safety is the Food Safety Modernization Act. Modernizing the food system to ensure that there are not bacteria in our peanut butter sounds like a good idea. However, relying on a large governing body who requires billions of dollars to make small changes is, in my opinion, not the solution.FSMA-4-30-Regulations
In 2011, Obama signed into law the Food Safety Modernization Act (FSMA), which gave the FDA the ability to proactively test food for bacteria and then require “voluntary ” recalls by the manufacturers when pathogens were found. In theory, this is a good idea; however, there are two major issues.

The first issue is that in their attempt to protect the consumer, they miss the real source of the problem and cause irreparable damage to companies that are not at fault for the problem. If you want to stop bacteria from being in our food (raw pet food in particular), then you need to go to the source – the suppliers of raw material.

The bacteria starts at that point, and it would make sense to improve processes to keep the bacteria out of the food source in the first place, rather than adding processes to sanitize the food after the issue exists. This leads to regulations that over process food and depletes it of important nutrients. Better to keep bad bacteria from reaching unsafe levels to begin with, but there lies another problem surrounding the whole concept of “unsafe levels.” Which brings me to my next point – overly sensitive tests.The second issue with FSMA is that the testing is extremely sensitive and will have a positive test result even with minute amounts of bacterial contamination. Before you get defensive and start commenting that you want zero amount of bacteria in your food, let’s remember that there are over 1 billion microbes in a gram of soil. Bacteria is all around us and it is in our food in many different forms. We have identified specific types which will make us sick, but the level of sickness is more dependent on the health of our immune system rather than how much harmful pathogens we are exposed to.The FDA’s hyper-sensitive tests can test a sample of food twice and get two different results. This means that there is a possibility that some of the recalls that go into effect may be unnecessary, especially when we are talking about raw pet food. In addition, the levels that are required for industry standards vary widely – with raw pet food, we are held to incredibly strict standards of bacteria levels in our testing results. Yet have you noticed the number of listeria recalls lately? An employee of Avure HPP foods, Dr. Errol Raghubeer, said off the cuff in a conference presentation in 2013 that in his opinion, a company that met the minimum USDA standards of listeria in their factories shouldn’t be in business because those levels were ridiculously lax.

Funding FISMA

Now let’s talk about the logistics of the Food Safety Modernization Act. As with most government run initiatives it is very expensive and yet can’t get much done. Prior to the bill going into law, the FDA requested $583 million which was planned to cover expenses from 2011 to 2015. By the end of 2011, the FDA reported that they will need an additional 400-450 million.

At a state budget hearing in March of this year, Commissioner Margret Hamburg stated “Significant funding gaps still loom”, and that “A shortfall in funding will undermine Congress’ intent to transform our country’s food safety program.” Without the proper funding, the FDA will not be able to properly train inspectors or hire enough inspectors to provide proper oversight, which will result in fragmented implementation.

The most upsetting part about all this is that last year in an American population of 319,000,000, there were 380 deaths due to salmonella; compare that to 611,105 deaths due to heart disease and 75,578 due to diabetes. Salmonella is certainly good fodder for news program’s ratings, but is it worth spending over a billion dollars on when that money could be used so someone on food stamps could afford to buy whole foods instead of mac and cheese or on a national educational program on the importance of a healthy gut? If we put the dollars where the problems were – on overly processed, nutritionally depleted junk food and an ignorant public – we would see a safer, healthier American public.

processingTO THE SCARY PART

Now to the truly scary part. This overregulation and government inefficiency will physically make us sick. It is true. The “cleaner” our food, the worse off we are – something that is directly fueled by overregulation.

In the raw pet food sector, the best way to save a company from a costly recall is to implement a “kill” step in the manufacturing process. There are two highly effective options – Irradiation or High Pressure Processing (HPP). Irradiation is the process of using ionizing radiation to attack bacteria by breaking chemical bonds in molecules that are vital for cell growth. It does not result in radioactive food, but it does increase the free radicals and has shown to reduce nutritional values of food in the same way that cooking does. High Pressure Processing (HPP) is another sterilization process where food is put in a plastic bag, submerge it in a vat of water, and 50,000 pounds of pressure is applied. This technology is fairly new and studies are showing that there may be degradation of enzymes. An abundance of enzymes in raw pet food is the very reason we feed raw pet food. Top it off with the fact additional processing increases the cost of your food. HPP and Irradiation are being used on meats, produce, juice, and many other ingredients that we assume to be raw when we purchase them. These processes do not have to be indicated on the package leaving the consumer misinformed as to what they are eating. 

If Americans keep pushing for a sanitized food system we will end up with enzyme and probiotic-deficient raw food. We will slowly see our immune systems deteriorate, leading to more disease at younger and younger ages. Enzymes disorders will leave our vital organs struggling to function and our overall health will diminish.

The answer to food safety is a combination of buying local to get cleaner foods, eating fewer processed foods to improve overall health, and handling your food properly. If we do this we may not only reduce the 380 deaths caused by salmonella, a more statistically significant, the 686,000 due to diabetes and heart disease combined.


 Sources

Sylvia, D. (author), Fuhrmann, J. (Author), Hartel, P. (Author), Zuberer, D. (Author). Principals and Applications of Soil Microbilogy (2nd ed., p. 672). Prentice Hall.


http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm436160.htm

http://www.foodsafetynews.com/2015/03/hamburg-tells-senate-budget-committee-fsma-funding-needed-to-fill-significant-gaps/#.VT5nNyFViko

http://www.cdc.gov/salmonella/

http://www.cdc.gov/nchs/fastats/deaths.htm

http://www.epa.gov/radiation/sources/food_irrad.html

http://www.foodnavigator-usa.com/Regulation/Suja-Life-raw-juices-in-lawsuit-on-high-pressure-processing-HPP

 

2 Responses to

  • Might there be a petition started to urge the gov to stop this High Pressure treatments of meats? It’s a jobs program and unnecessary. That’s not to say Fast Food human stores don’t need policing – they get their meat, I think, from vast western meat suppliers who grind and mix from many sources so any bacteria are spread throughout. They have had big problems over the years. But we who feed meat to dogs have had no problems (unlike kibble etc recalls) are disgusted at the destruction of beneficial components. Why fix a non existent problem? Bureaucracy!! Ignorant pols!!

  • We have sent letters to the FDA and CVM making many requests that would allow us to minimize the processing we have to do to the food. We are shouting as loud as we can but are not being listened to. It will take expensive lobbyists to get any traction. Unfortunately since we are not Iams with millions in profits, we do not have the funds to buy lobbyists.

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