Jim Prevor, the Perishable Pundit, has written a provocative piece, “How to Improve Food Safety: Aggrandizing the FDA Only Distracts from Real Solutions,” for The New Atlantis. Jim Prevor’s lead point—that attention on improving the FDA distracts from real solutions for nagging food safety concerns with raw produce—is well taken. Ironically, the article’s leading points—a cursory dismissal of the FDA Food Safety Modernization Act and a flawed discussion of product liability standards—are distractions from other solutions proposed that deserved far more attention. Indeed, the FDA Food Safety Modernization Act will not solve our food safety concerns with raw produce. Nor will the law eliminate all problems with the Food and Drug Administration (FDA). Nevertheless, these points do not add up to a reason to withhold support for the bill.
But read on. Jim Prevor is a voice crying out in the wilderness about the need to invest in food safety research, state health laboratories, food safety education, and agricultural extension. These crying needs are why discussion of strict liability versus negligence are a distraction. No system of liability will generate the level of private investment in research and extension that are desired. Private interests should not be expected to invest in the commons. That is why there is a need for public investments in food safety research, state health laboratories, food safety education, and agricultural extension for the greater common good.
For my Francophone readership, Jim Prevor’s article was translated into French and is available here.