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International decisions about such issues are difficult to track, as they change constantly in response to political pressures. When the European Union approved sales of transgenic corn in 1996, the biotechnology industry was optimistic that Europeans would readily accept genetically modified foods. In 1997, however, the European Parliament required the foods to be labeled, and in 1999 the European Union also required manufacturers to conduct risk assessments, public consultations, and post-market safety reviews. Some national governments permitted transgenic crops to be grown, but others did not. In mid-2000, Time Time magazine classified countries by their attitude toward genetically modified foods-pro-GM (Argentina, China), cautiously pro (Canada, U.S., India), very cautiously pro (Brazil, Japan), or strongly anti (Britain, France)-but the policies of these countries changed constantly in response to new information, ongoing pressures, and decisions of international bodies attempting to deal with issues raised by these foods. magazine classified countries by their attitude toward genetically modified foods-pro-GM (Argentina, China), cautiously pro (Canada, U.S., India), very cautiously pro (Brazil, Japan), or strongly anti (Britain, France)-but the policies of these countries changed constantly in response to new information, ongoing pressures, and decisions of international bodies attempting to deal with issues raised by these foods.41 To illustrate the complexity of the international picture, To illustrate the complexity of the international picture, table 13 table 13 summarizes decisions about transgenic foods made by various countries summarizes decisions about transgenic foods made by various countries just just during the 2001 calendar year. during the 2001 calendar year.

TABLE 13. Actions of selected countries and the European Union regarding planting, labeling, or importing of genetically modified foods, 2001 Country Action Taken Argentina Permits planting.

Australia Permits planting, but also requires posting of locations of planting sites, investigation of violations, and imposition of fines. With New Zealand, issues guidelines for labeling.

Brazil Permits planting, but requires permits and labeling.

China Permits planting, but requires certification of production, sale, and import as safe for humans, animals, and environment.

Japan Establishes labeling threshold of 5% for genetically modified corn or soybeans.

Philippines Rules that failure to label foods containing genetically modified ingredients is punishable by prison (up to 12 years) and fines (up to $2,000).

Saudi Arabia Bans import of transgenic animals; requires health certificates for transgenic plants; requires mandatory labeling of processed foods containing genetically modified ingredients.

Sri Lanka Bans all transgenic foods as of September 1, but later postpones ban indefinitely.

Thailand Bans new field trials; approves Roundup Ready soybeans.

European Union Requires member states to ensure the traceability of genetically modified foods at all stages of marketing; restricts new product approvals to 10 years with renewal for another 10 years; establishes public registers for field-testing sites; phases out use of certain antibiotic-resistance markers; establishes labeling threshold of 1%. France, Italy, Luxembourg, Austria, Denmark and Greece declare moratorium on planting until these rules take effect.

SOURCE: Food Chemical News Food Chemical News, 2001.

The inconsistent decisions of international bodies in dealing with genetically modified foods do little to engender trust that the system will operate in the public interest. In 1999, for example, the Biosafety Protocol, an international committee formed as a result of the 1992 biodiversity treaty forged in Rio de Janeiro, proposed to require shipments of transgenic foods to be approved in advance in advance by importing countries. The United States refused to sign the treaty, which was also opposed by other large food-exporting nations such as Canada, Australia, Chile, Argentina, and Uruguay. The reason: the requirement could institute "a draconian regime that we have never seen before except for highly toxic and hazardous substances." by importing countries. The United States refused to sign the treaty, which was also opposed by other large food-exporting nations such as Canada, Australia, Chile, Argentina, and Uruguay. The reason: the requirement could institute "a draconian regime that we have never seen before except for highly toxic and hazardous substances."42 In January 2000, delegates from 130 nations adopted the treaty, but with compromises; they permitted genetically modified foods to be exported without advance notice but allowed countries to decide for themselves whether transgenic foods, seeds, and microbes posed a threat to the environment. If countries decided to prohibit imports on that basis, they could. Industry leaders considered the compromise as a win and hoped that the treaty would help counter the perception that food biotechnology was not adequately regulated. Some European countries viewed such trade agreements as barely masked attempts to achieve political goals. Many Europeans resented U.S. trade restrictions against countries that conduct business with Iran, Libya, or Cuba, and perceived the aggressive marketing of American transgenic crops as arrogant, controlling, and insensitive. They thought the phrase, "what's good for G.M. is good for America," now meant that genetic modification had replaced General Motors as the symbol of United States corporate power. In January 2000, delegates from 130 nations adopted the treaty, but with compromises; they permitted genetically modified foods to be exported without advance notice but allowed countries to decide for themselves whether transgenic foods, seeds, and microbes posed a threat to the environment. If countries decided to prohibit imports on that basis, they could. Industry leaders considered the compromise as a win and hoped that the treaty would help counter the perception that food biotechnology was not adequately regulated. Some European countries viewed such trade agreements as barely masked attempts to achieve political goals. Many Europeans resented U.S. trade restrictions against countries that conduct business with Iran, Libya, or Cuba, and perceived the aggressive marketing of American transgenic crops as arrogant, controlling, and insensitive. They thought the phrase, "what's good for G.M. is good for America," now meant that genetic modification had replaced General Motors as the symbol of United States corporate power.43 Europeans particularly resented the lack of labeling, as it left them little choice at the marketplace. If labels were required, however, U.S. companies would have to take several complicated and expensive actions: segregate conventional crops from transgenic crops in fields as well as during storage, transport, and processing; document the traceability of the crops; and establish thresholds for levels of transgenic contamination. U.S. food producers oppose these measures as impractical and expensive, and international authorities have yet to agree on the lowest level of contaminating transgenes that will permit crops to be labeled "GM-free."

The views of different countries on such issues are "harmonized" by the WTO, but also to a lesser extent by the Codex Alimentarius (food code) Commission of the United Nations. In 1994, an international consumers' group petitioned the Codex to develop standards for mandatory labeling of transgenic foods because "the burden of labeling should fall on those who wish to use and profit from biotechnology and not on those who choose not to use it"; the group renewed such requests through the 1990s. By 1999, public opinion in Europe, especially in Great Britain, overwhelmingly favored labeling and segregation of conventional crops from transgenic crops. When the European Union asked the Codex Commission to require labels for all foods containing identifiable transgenic ingredients, only the United States and Argentina (which also exports transgenic crops) opposed this proposal.44 U.S. Codex representatives argue that the true purpose of calls for labeling is to protect European trade restrictions: "a mandatory process-based label on genetically engineered food has the potential to be perceived by many consumers as a warning label that the product is unsafe, and therefore could be misleading and, consequently, inappropriate as a mandatory international guideline. Foods derived from biotechnology are not inherently less safe than other foods." U.S. Codex representatives argue that the true purpose of calls for labeling is to protect European trade restrictions: "a mandatory process-based label on genetically engineered food has the potential to be perceived by many consumers as a warning label that the product is unsafe, and therefore could be misleading and, consequently, inappropriate as a mandatory international guideline. Foods derived from biotechnology are not inherently less safe than other foods."45 Such arguments, along with the other concerns discussed here, convince critics that the goal of the food biotechnology industry is to control the world's food supply for private profit, and that neither the industry nor governing bodies can be trusted to make decisions in the public interest-whether or not the products are safe. Such arguments, along with the other concerns discussed here, convince critics that the goal of the food biotechnology industry is to control the world's food supply for private profit, and that neither the industry nor governing bodies can be trusted to make decisions in the public interest-whether or not the products are safe.

THE POLITICS OF ANTIBIOTECHNOLOGY ADVOCACY.

We have seen that objections to genetically engineered foods focus as much on issues of distrust as they do on matters of safety, and are likely to continue to do so unless the industry ceases acting in ways that engender suspicion. Public protests against transgenic foods occurred more swiftly and dramatically in Europe, especially in Great Britain, than in the United States, not least because the British were better informed about the issues. At the peak of the "GM crisis" early in 1999, the seven largest daily newspapers in Great Britain ran hundreds of articles on the subject, nearly all of them negative. Many of the articles focused on the extent to which the Clinton administration pressured the British government to accept American transgenic crops and collaborated in efforts to get those crops approved by the European Union.46 Antibiotechnology advocacy-international and domestic-is a constant source of worry to the industry. Such advocacy forms part of a larger trend in organized opposition to other aspects of globalization. During the 1990s, the number of international nongovernmental organizations increased from 6,000 to 26,000, and thousands of such groups exist in the United States alone. These groups are increasingly effective at the corporate, national, and international levels, and business analysts consider them especially difficult to manage because of their skill at using the Internet-an uncontrollable venue-to mobilize support. Yet another irony is the complaint of industry leaders that groups opposed to food biotechnology are so well funded. They point to Greenpeace, for example, which attracts a worldwide income of more than $100 million annually. This amount may seem large, but it is minuscule in comparison to the annual income of the large biotechnology corporations whose officials make that complaint.47 Advocacy has been slower to develop in the United States than in Europe, perhaps because Americans generally are less politically active, but also because they tend to have more positive attitudes toward technology, greater trust in regulatory agencies, and less immediate contact with agriculture. Nevertheless, opposition to food biotechnology exists in this country and appears to be growing. Advocacy groups include environmental organizations (such as Environmental Defense, the Union of Concerned Scientists, and the Sierra Club) but also an extraordinary variety of less familiar organizations such as the International Center for Technology Assessment, the Foundation for Deep Ecology, the International Forum on Globalization, and the Rainforest Action Network. Countless local groups like NW Rage (Northwest Resistance against Genetic Engineering) educate members "to resist the intrusion of genetic engineering . . . into our lives."48 Coalition groups like Genetically Engineered Food Alert demand that food companies refuse to use genetically modified ingredients. Most organizing occurs through dozens of antibiotechnology Internet Web sites and electronic mail services that keep subscribers well informed about the daily actions of companies, government regulators, and critics. Coalition groups like Genetically Engineered Food Alert demand that food companies refuse to use genetically modified ingredients. Most organizing occurs through dozens of antibiotechnology Internet Web sites and electronic mail services that keep subscribers well informed about the daily actions of companies, government regulators, and critics.49 Biotechnology companies appear helpless in the face of such tactics and make little attempt to counter them beyond statements on their own Web sites and in the public relations campaigns of the Council for Biotechnology Information ( Biotechnology companies appear helpless in the face of such tactics and make little attempt to counter them beyond statements on their own Web sites and in the public relations campaigns of the Council for Biotechnology Information (figures 12, 14 14, and 17 17).

Away from the Internet, action against food biotechnology takes many forms, nearly all of which mix safety with other issues to evoke distrust, dismay, contempt, or outrage. To begin with, advocates write books-lots of them. My personal collection includes two or three dozen, of which at least ten were written for a popular audience just from 1998 to 2002.50 Books on the ethics of food biotechnology form an additional publishing genre. I am not the only person who collects such volumes. The geneticist Richard Lewontin reviewed his own collection of books and found that most opposed genetically modified foods for reasons that he judged muddled. He said, "whatever fears [one] might have of possible allergic reactions to food produced from genetically modified organisms, they are not more unsettling than the allergies induced . . . by the quality of the arguments about them. . . . Even the most judicious and seemingly dispassionate examinations of the scientific questions turn out, in the end, to be manifestoes." Books on the ethics of food biotechnology form an additional publishing genre. I am not the only person who collects such volumes. The geneticist Richard Lewontin reviewed his own collection of books and found that most opposed genetically modified foods for reasons that he judged muddled. He said, "whatever fears [one] might have of possible allergic reactions to food produced from genetically modified organisms, they are not more unsettling than the allergies induced . . . by the quality of the arguments about them. . . . Even the most judicious and seemingly dispassionate examinations of the scientific questions turn out, in the end, to be manifestoes."51 By this, he seemed to mean that critics do not clearly distinguish scientific concerns about safety from concerns about social issues. By this, he seemed to mean that critics do not clearly distinguish scientific concerns about safety from concerns about social issues.

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FIGURE 27. Greenpeace uses cards like this one to generate support for campaigns to stop sales of genetically modified foods. Text on the back of the card explains why companies should stop selling genetically engineered food and what consumers can do to encourage that action. (Courtesy of Greenpeace, 2000.) The books have a political effect, but not always the one intended. Among the most recent, only one favors food biotechnology: Pandora's Picnic Basket Pandora's Picnic Basket.52 Although written by a scientist who claims to be objective, this book also can be viewed as a manifesto. An instructor in my New York University department assigned it to a graduate class on contemporary food issues. He said the class found the science parts useful but also found the book infuriatingly patronizing, biased in coverage, and lacking in coherent social analysis. Informing the public about science is valuable, but that alone is not nearly enough to help people understand how scientific and social issues interact in matters of public policy. Although written by a scientist who claims to be objective, this book also can be viewed as a manifesto. An instructor in my New York University department assigned it to a graduate class on contemporary food issues. He said the class found the science parts useful but also found the book infuriatingly patronizing, biased in coverage, and lacking in coherent social analysis. Informing the public about science is valuable, but that alone is not nearly enough to help people understand how scientific and social issues interact in matters of public policy.

Greenpeace is especially adept at producing materials that use scientific concerns about safety to score points about distrust. Figure 27 Figure 27 gives my favorite example: using the "horror" of transgenic foods to emphasize the lack of transparency in marketing. Another example: at the time of the 1999 WTO meeting in Seattle, a coalition of more than 60 nonprofit groups (The Turning Point Project) placed a series of full-page advertisements on food biotechnology and globalization in the gives my favorite example: using the "horror" of transgenic foods to emphasize the lack of transparency in marketing. Another example: at the time of the 1999 WTO meeting in Seattle, a coalition of more than 60 nonprofit groups (The Turning Point Project) placed a series of full-page advertisements on food biotechnology and globalization in the New York Times New York Times. One, headlined "Unlabeled, Untested . . . and You're Eating It" (October 18, 1999), listed common food products containing genetically modified ingredients and discussed the hazards of toxicity, allergic reactions, and antibiotic resistance. Subsequent advertisements provided lengthy and thought-provoking discussions of various health, environmental, or economic consequences of biotechnology or economic globalization, along with information about how to learn more about such issues. Figure 28 Figure 28 gives yet another example-this one, a painting-of the commingling of safety and social issues as they apply to transgenic foods. gives yet another example-this one, a painting-of the commingling of safety and social issues as they apply to transgenic foods.

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FIGURE 28. In conjunction with an exhibition of artworks on the theme "artists picturing our genetic future," Alexis Rockman's The Farm The Farm appeared on a lower Manhattan billboard (Lafayette and Houston Streets) in fall 2000. (Courtesy of Alexis Rockman and Creative Time; photograph by Charlie Samuels.) appeared on a lower Manhattan billboard (Lafayette and Houston Streets) in fall 2000. (Courtesy of Alexis Rockman and Creative Time; photograph by Charlie Samuels.) This commingling of safety with other issues is most visible in street demonstrations. The 1999 FDA labeling hearings, for example, attracted protests in all three cities where they were held (figure 18, page 190 page 190). The Oakland, California, hearing attracted 500 antibiotechnology demonstrators and received much attention from the press, largely because it also drew a smaller group of counter-demonstrators. These were researchers and graduate students from the nearby University of California, Berkeley, Department of Plant and Microbial Biology, infamous for having been "bought" by Novartis the year before (the department had auctioned itself to Novartis in an exclusive partnership arrangement giving that company the right to select faculty, review research results prior to publication, negotiate licensing agreements, and veto faculty decisions in some areas).53 They said they were demonstrating "out of concern that the public was not being informed about the benefits of biotechnology." They said they were demonstrating "out of concern that the public was not being informed about the benefits of biotechnology."54 Advocates also use the legal system to pursue antibiotechnology goals. In 2001 alone, 36 states considered bills aimed at transgenic foods: restricting plantings or sales; requiring labeling, notification, tracking, or evaluation of environmental impact; banning terminator technology; or prohibiting the use of such foods in school lunch programs. Few such bills pass, however. By 2001, Maryland was the only state to ban a genetically modified food, in this case fish in waterways that connect to other bodies of water.55 Consumer groups, chefs, and some scientists have filed lawsuits and organized petition campaigns to compel the FDA to institute labeling and safety testing. The Alliance for Bio-Integrity (Iowa City, IA), led by Steven Druker, has filed such suits. Other suits argue that transgenic manipulations make it impossible to observe religious dietary laws; one was cosigned by 113 Christians, 37 Jews, 12 Buddhists, and 122 people who checked, "my faith is not easily categorized." Still others have filed antitrust lawsuits based on the idea that the industry's control over seeds inhibits competition. A petition organized by Mothers for Natural Law collected an astounding number of signatures-nearly 500,000-from people favoring transparency in labeling. Jeremy Rifkin organized a class-action suit against Monsanto arguing that the company is part of an international conspiracy to control the world's corn and soybean supply through intimidation and deceptive business practices. Regardless of the outcome of the bills and lawsuits, they force attention to be paid to societal as well as safety issues. Consumer groups, chefs, and some scientists have filed lawsuits and organized petition campaigns to compel the FDA to institute labeling and safety testing. The Alliance for Bio-Integrity (Iowa City, IA), led by Steven Druker, has filed such suits. Other suits argue that transgenic manipulations make it impossible to observe religious dietary laws; one was cosigned by 113 Christians, 37 Jews, 12 Buddhists, and 122 people who checked, "my faith is not easily categorized." Still others have filed antitrust lawsuits based on the idea that the industry's control over seeds inhibits competition. A petition organized by Mothers for Natural Law collected an astounding number of signatures-nearly 500,000-from people favoring transparency in labeling. Jeremy Rifkin organized a class-action suit against Monsanto arguing that the company is part of an international conspiracy to control the world's corn and soybean supply through intimidation and deceptive business practices. Regardless of the outcome of the bills and lawsuits, they force attention to be paid to societal as well as safety issues.56 Such methods may annoy (and sometimes infuriate) biotechnology companies, government regulators, and scientists, but they are traditional ways of taking political action in a pluralistic democracy; they are legal, fair, and-given the many reasons for distrust-thoroughly justifiable. Transgenic sabotage, however, is another matter. When Ingo Potrykus complains about "those who would damage humanitarian projects" (discussed in chapter 5 chapter 5), he worries most that vandals will destroy test plantings of Golden Rice. In Great Britain, Greenpeace and other groups conducted "destruction actions" against test plots of transgenic crops, sometimes dressed in full-body anticontamination suits and goggles. In the United States, numerous incidents of uprooting transgenic crops, trashing laboratories, burning genetic engineering materials, and making personal threats against scientists cross a legal line and enter into the realm of food terrorism.57 Such actions undermine the legitimacy of the political goals they are designed to accomplish, as do the controlling actions of corporations (see concluding chapter). Such actions undermine the legitimacy of the political goals they are designed to accomplish, as do the controlling actions of corporations (see concluding chapter).

TOWARD DIALOGUE, IF NOT CONSENSUS.

Protests against genetically modified foods-or the threat of such protests-affect the behavior of retailers who understand that consumers can choose to buy organic products, now labeled as such. Many companies label their products "GM-free" (see figure 25 figure 25, page 226 page 226). In the late 1990s, Gerber's and Heinz announced that they would stop using genetically modified ingredients in their baby foods, and McDonald's "quietly" told farmers to stop growing Monsanto's transgenic potatoes. Frito-Lay told its suppliers not to grow transgenic corn, and Archer Daniels Midland warned its grain suppliers to begin segregating bioengineered crops. Corn growers viewed such developments as a clear sign that "GM organisms have become the albatross around the neck of farmers."58 The loss of both domestic and foreign sales outlets coupled with more general problems of overproduction caused corn prices to drop to their lowest point in ten years. As a partial remedy, the American Corn Growers Association advised its members to consider planting only conventional seeds. Wall Street analysts were well aware of this problem, seeing current events as very bad news for farmers, seed companies, and seed stocks. They predicted that premium prices would go to conventional rather than transgenic crops because "GMOs are good science but bad politics." The loss of both domestic and foreign sales outlets coupled with more general problems of overproduction caused corn prices to drop to their lowest point in ten years. As a partial remedy, the American Corn Growers Association advised its members to consider planting only conventional seeds. Wall Street analysts were well aware of this problem, seeing current events as very bad news for farmers, seed companies, and seed stocks. They predicted that premium prices would go to conventional rather than transgenic crops because "GMOs are good science but bad politics."59 Their predictions were correct; corn acres planted in genetically modified seeds fell from 25 million in 1999 to just over 16 million in 2001. By then, more than half of the Midwest grain elevators required segregation of transgenic seeds, and 20% were offering premium prices for conventional corn or soybeans. Their predictions were correct; corn acres planted in genetically modified seeds fell from 25 million in 1999 to just over 16 million in 2001. By then, more than half of the Midwest grain elevators required segregation of transgenic seeds, and 20% were offering premium prices for conventional corn or soybeans.60 In part because of objections to transgenic varieties, revenues from U.S. corn exports fell drastically from 1996 to 2000. Exports to Japan fell from $2.4 billion to $1.5 billion (a decline of 38%), to Taiwan from $960 million to $460 million (52%), and to European Union countries from $413 million to $69 million (83%). In part because of objections to transgenic varieties, revenues from U.S. corn exports fell drastically from 1996 to 2000. Exports to Japan fell from $2.4 billion to $1.5 billion (a decline of 38%), to Taiwan from $960 million to $460 million (52%), and to European Union countries from $413 million to $69 million (83%).61 Despite these reactions, genetically engineered traits are widely dispersed in the environment, and transgenic ingredients pervade the food supply. Despite these reactions, genetically engineered traits are widely dispersed in the environment, and transgenic ingredients pervade the food supply.

Figuring out what to do about this confusing picture preoccupies federal agencies responsible for the regulation of transgenic foods. They worry that food biotechnology will suffer the fate of nuclear power and that its potential benefits will be lost to humanity. Like public protests over early recombinant-DNA experiments, those over food biotechnology may become muted if companies produce genetically modified foods that really do make farming more efficient or benefit consumers. What cannot be predicted is the strength and persistence of public distrust or the willingness of the industry to respond to it and submit the products and marketing methods to greater scrutiny. To help the industry gain public approval, federal agencies recruit advisory organizations to bring together groups of disparate stakeholders to seek points of agreement. As a participant in several such meetings, I can attest that they require people with differing perspectives to listen to one another (itself a step forward) and to attempt to identify issues of consensus. These meetings invariably identify labeling, segregation, traceability, and government oversight as necessary first steps toward achieving public confidence. Although reaching consensus on such steps may never be possible, such meetings permit participants to discuss matters that extend beyond safety and place societal issues of trust firmly on the agenda.

The messy political debates about food biotechnology are not likely to be resolved soon without major changes in the ways the industry conducts business. Genetically engineered foods may be relatively safe by the standards of science-based approaches to risk assessment, but industry decisions have caused them to rank high on the dread-and-outrage scale. To inspire public confidence, the industry must share control of the food supply with consumers. Until people actually have some choice about whether to consume transgenic foods, there is little reason to accept them. Companies need to label the foods and keep them separate from conventional foods. They also need to make more serious efforts to ensure that transgenes do not escape into the wild. They must work with organic farmers to prevent transgenic contamination of organic crops, and they must stop using public relations to "sell" people on the idea that the products are necessary and safe. If biotechnology companies want to convince people that their foods are beneficial, they must make products that are are beneficial-to consumers and to society. Finally, they must stop acting so aggressively against people who raise questions about the products, stop prosecuting small-scale "violators" of patent rights, and stop insisting that science education-important as it is-will solve the industry's public relations problems. Even some industry supporters understand that biotechnology companies need to become less disingenuous, and set some restraints on "their insatiable appetite for control." beneficial-to consumers and to society. Finally, they must stop acting so aggressively against people who raise questions about the products, stop prosecuting small-scale "violators" of patent rights, and stop insisting that science education-important as it is-will solve the industry's public relations problems. Even some industry supporters understand that biotechnology companies need to become less disingenuous, and set some restraints on "their insatiable appetite for control."62 If food biotechnology does have benefits for individuals and society-and it is still too early to say whether it does-such benefits can only be achieved when the products are viewed as low in science-based safety risk as well as in value-based dread and outrage. If food biotechnology does have benefits for individuals and society-and it is still too early to say whether it does-such benefits can only be achieved when the products are viewed as low in science-based safety risk as well as in value-based dread and outrage.

If companies are going to claim that their work will solve world food problems, they need to put substantial resources into working with scientists in developing countries to help farmers produce more food under local conditions. Such efforts could prove worthwhile if supported by policies designed to support sustainable and organic agriculture, protect against environmental risks, and prevent exploitation of small farmers or of consumers. For some years now, I have suggested that the industry institute a "tithing" program and apply 10% of income to research on projects that address the food needs of developing countries, regardless of their eventual profitability. This approach might indicate that the industry recognizes the difference between its commercial and humanitarian goals. Although I am not aware of any company that has taken on this challenge, I continue to believe that to be perceived as credible, the industry must be be credible. credible.

If government agencies want to promote food biotechnology, they are going to have to regulate it more effectively. They must insist that companies label, segregate, and ensure the traceability of genetically engineered crops, provide adequate areas of refuge, and keep their transgenes from pollinating out of control. Government regulators should be working with industry to figure out how to label the products and establish workable thresholds for transgenic contaminants. On the international level, they should stop obstructing multinational agreements and cooperate with government policies of other countries. They should grant consumer protection at least the same level of priority as promotion of industry objectives. Federal regulators must recognize as well that science-based decisions also have political dimensions and must find ways to consider societal and environmental implications when approving genetically modified foods.

And what should the public think or do about food biotechnology? As with other aspects of food politics, much depends on point of view. Eating foods containing transgenic ingredients appears unlikely to cause direct harm to human health, but at the moment there also is little evidence for benefit. If a goal is to reduce pesticides in the environment, genetically modifying foods may be an appropriate method for achieving that goal, but so may other methods that also deserve consideration. If the ultimate goal is to ensure food security for the world's population, other means to do so deserve equal time and resources. Overall, the role of genetically modified foods in these larger aspects of the food system is as yet uncertain and unlikely to be known for some time to come.

With that said, we now turn to the concluding chapter in which we will examine some emerging food safety issues. Like food biotechnology, these issues are relatively low in science-based risk but relatively high in dread: mad cow disease, foot-and-mouth disease, anthrax, and other potential weapons of food bioterrorism.

CONCLUSION.

THE FUTURE OF FOOD SAFETY.

PUBLIC HEALTH VERSUS BIOTERRORISM.

SAFE FOOD IS ONE OF THE GREAT ACHIEVEMENTS OF TWENTIETH-century public health, a result of scientific advances in refrigeration, pasteurization, insecticides, and disease surveillance. This book proposes that food safety also depends on politics. Any doubts about that idea should be thoroughly dispelled by the events of September 2001, when terrorists used airplanes as weapons of destruction and an anonymous correspondent sent letters filled with anthrax spores to civic and media leaders. One consequence of these events was to reveal the vulnerability of food and water supplies to malevolent tampering. Another was to expose the glaring gaps in federal oversight of food safety.1 This concluding chapter examines emerging food safety threats in these contexts. Some of the threats are diseases that affect farm animals and only rarely cause disease in humans. Even so, their effects on human welfare can be profound: massive destruction of food animals, loss of livelihoods and community, and restrictions on personal liberty. The outbreaks of mad cow disease and foot-and-mouth disease that occurred in Europe in the 1990s and early 2000s, for example, were destructive, but they occurred as accidental results of production practices. In contrast, bioterrorism is deliberate-the purposeful use of biological or chemical materials to achieve political goals. Bioterrorism introduces a new and especially frightening political dimension to food safety risk: the intention intention to cause harm, regardless of who gets hurt. to cause harm, regardless of who gets hurt.

In this chapter, we will see how bioterrorism brings up questions of food security and expands the common meaning of that term. In the United States, food security usually refers to the reliability of a family's food supply; people who lack food security qualify for federal or private food assistance. Since the anthrax mailings, food security has also come to mean "food safe from bioterrorism." We begin our discussion of this definitional transition with diseases of farm animals: mad cow disease, foot-and-mouth disease, and anthrax. In recent years, these diseases did not exist or were rare veterinary problems posing relatively little risk to human health. Today, we are concerned about their potential to make us ill, create havoc in the food system, or become tools of bioterrorism. The chapter concludes with a discussion of how we-as a society and as individuals-can take action to address the problems and politics of food safety, now and in the future.

THE POLITICS OF ANIMAL DISEASES.

Because one consequence of globalization is the rapid transport of food across national borders and over long distances, a disease that affects the food supply can travel rapidly from one country to another. Animal diseases have trade implications; if a country harbors sick animals, no other country will accept its meat. Trade implications have political consequences.

As we will see, the British epidemics of mad cow disease and foot-and-mouth disease occurred as inadvertent results of meat production practices. In contrast, the U.S. anthrax mailings were a deliberate act. All three risks, however, rank high in dread; they are involuntary, uncontrollable, and cause exotic disease. Just as important, they undermine trust in the food supply and in government and divert resources from more pressing matters of public health.

Mad Cow Disease: Prions and Species Jumps Mad cow disease emerged as a highly publicized food safety crisis of the mid-1990s, largely confined to Great Britain. The story of this disease is relevant to our discussion for its interweaving of politics and science and its effect on public confidence. The manner in which British officials handled the mad cow crisis, for example, later contributed to public distrust of genetically modified foods. Prior to the early 1980s, hardly anyone had heard of the disease, but by 1999 it had affected at least 175,000 British cows. Its results were catastrophic: destruction of more than 4 million cattle, estimated costs of $7 billion, transmission to at least 18 countries, and worldwide rejection of British beef. By 2001, although "only" about 120 people had died of the human variant of mad cow disease, more deaths-perhaps as many as 100,000-were expected.2 Because this story reveals many aspects of the modern politics of food safety, it is well worth recounting. Because this story reveals many aspects of the modern politics of food safety, it is well worth recounting.

The mad cow epidemic originated in the late 1970s when the political climate in Great Britain favored cost cutting and deregulation-in this case, of the meat-rendering industry. This industry converts the otherwise unusable (offal) parts of dead animals into "meat-and-bone meal" used to supplement the diets of farm animals. In Britain, rendering then involved the use of organic solvents and steam applied under high pressure; this process sterilized the resulting mess and killed anything that might be infectious. The solvents were dangerously flammable, however, and the energy costs high. In the late 1970s, the British industry-but not renderers in other countries-adopted a cheaper method, one that omitted solvents and cooked the offal at lower temperatures. Most rendering plants in Great Britain switched to that system by the early 1980s.3 The new method killed most bacteria and viruses. It did not, however, inactivate prions prions, a generic term for the highly unusual infectious agents believed to cause a disease called scrapie in sheep and related diseases in other animals. These invariably fatal diseases affect the brain and nervous system; they are called spongiform encephalopathies because they cause sponge-like holes in the brains of animals and people. Prion diseases present fascinating biological problems. They appear to involve transmission via proteins proteins (rather than bacteria, viruses, or DNA), as well as "species jumps" from one kind of animal to another. In the era before mad cow disease, prion diseases seemed to be confined to their particular host animal. Scrapie, for example, affected sheep in Britain for at least three centuries but did not bother people. Instead, people exhibited their own specific and rare form of the disease, as did cows; both appeared spontaneously and were considered "sporadic." At this point, we need to know the names of these diseases: scrapie in sheep, bovine spongiform encephalopathy (BSE) in cows, and Creutzfeldt-Jakob Disease (CJD) in people. (rather than bacteria, viruses, or DNA), as well as "species jumps" from one kind of animal to another. In the era before mad cow disease, prion diseases seemed to be confined to their particular host animal. Scrapie, for example, affected sheep in Britain for at least three centuries but did not bother people. Instead, people exhibited their own specific and rare form of the disease, as did cows; both appeared spontaneously and were considered "sporadic." At this point, we need to know the names of these diseases: scrapie in sheep, bovine spongiform encephalopathy (BSE) in cows, and Creutzfeldt-Jakob Disease (CJD) in people.4 Because of the way sick cows behave, BSE soon became known as mad cow disease. In turn, mad cow disease soon emerged as the link between prion diseases in sheep and in people. Because of the way sick cows behave, BSE soon became known as mad cow disease. In turn, mad cow disease soon emerged as the link between prion diseases in sheep and in people.5 BSE first appeared soon after cows ate the inadequately rendered meat-and-bone meal supplements. These supplements almost certainly contained offal from sheep infected with scrapie; Great Britain raises far more sheep than cattle, and scrapie is common in British sheep. Later, they surely also contained offal from cows with as yet unrecognized BSE. Veterinarians observed the first case of BSE in a cow in 1984 and confirmed the disease in 1985. During the next few years, the number of BSE cases in cows increased, signaling a growing epidemic. In 1988, an investigating committee deduced that the sheep disease must have jumped to cows. At this point, the British government banned the use of offal in cow feed and required farmers to report BSE cases and to destroy suspect cattle, all the while repeatedly reassuring the public that British beef posed no health risk.

Despite the new regulations, government officials promised support to the beef industry. The prime minister, John Major, said he was "absolutely determined to reduce the burden of regulation on business."6 Although the government vehemently denied it, beef producers often ignored the 1988 feed ban and nearly half of all the BSE cases occurred in cows born Although the government vehemently denied it, beef producers often ignored the 1988 feed ban and nearly half of all the BSE cases occurred in cows born after after that year. In 1990, the government appointed yet another BSE review committee, but, according to a later investigation, pressured its members to declare beef safe to eat. Meanwhile, cases of BSE in cows continued to rise, reaching a peak in 1993 and then declining gradually as the use of rendered meat-and-bone meal ceased. During the next few years, scientists became increasingly convinced that mad cow disease might be transmitted to people. Britain banned the use in human food of mechanically recovered meat from cow vertebrae (lest it be contaminated with brain or nervous tissue), but health officials continued to deny any risk from this practice. The European Union, however, banned the sale of British beef for three years, noting that the disease seemed to be a particularly British problem. that year. In 1990, the government appointed yet another BSE review committee, but, according to a later investigation, pressured its members to declare beef safe to eat. Meanwhile, cases of BSE in cows continued to rise, reaching a peak in 1993 and then declining gradually as the use of rendered meat-and-bone meal ceased. During the next few years, scientists became increasingly convinced that mad cow disease might be transmitted to people. Britain banned the use in human food of mechanically recovered meat from cow vertebrae (lest it be contaminated with brain or nervous tissue), but health officials continued to deny any risk from this practice. The European Union, however, banned the sale of British beef for three years, noting that the disease seemed to be a particularly British problem.7 These actions came much too late. In 1996, British doctors identified ten young people with a previously unknown variant of Creutzfeldt-Jakob Disease (vCJD). The new disease differed from the slowly progressing CJD that typically occurs in older people. It affected young young adults, it looked different, and it progressed much more rapidly. Dismayed scientists immediately suspected that the new variant disease represented yet another species jump, this time from cows to people. People who "caught" the new disease must have eaten BSE-contaminated beef before the offal-feeding bans went into effect or during the period of government delays, denials, finger pointings, and failures to enforce rules. adults, it looked different, and it progressed much more rapidly. Dismayed scientists immediately suspected that the new variant disease represented yet another species jump, this time from cows to people. People who "caught" the new disease must have eaten BSE-contaminated beef before the offal-feeding bans went into effect or during the period of government delays, denials, finger pointings, and failures to enforce rules.8 By all accounts, British officials did not handle this new crisis any better and only grudgingly admitted the link between mad cow disease and the human variant. In what appeared to be an act of explicit manipulation, the agriculture minister, John Gummer, appeared on television to show his faith in British meat: he fed a hamburger to his four-year-old daughter. Overall, the government seemed to be acting on behalf of the cattle industry rather than protecting public health. Reinforcing a familiar theme in this book, the Lancet Lancet blamed the secret ways in which government and expert committees operate-and the lack of public accountability-for the failure of government to do something to stop mad cow disease and prevent its transmission to people. It pointed to "the weaknesses of separating agricultural and medical science, and of allowing one Government department to protect the interests of both the food consumers and the farming industry." blamed the secret ways in which government and expert committees operate-and the lack of public accountability-for the failure of government to do something to stop mad cow disease and prevent its transmission to people. It pointed to "the weaknesses of separating agricultural and medical science, and of allowing one Government department to protect the interests of both the food consumers and the farming industry."9 The appearance of the new variant disease in people caused a further crisis, this time in international trade. The European Union banned member countries from buying British beef, and McDonald's and other such companies quickly removed it from sale. To protect the industry, the British government stopped permitting older cows (which are more likely to have developed BSE) to be used as food and began destroying them at a rate of 15,000 per week. By the end of 1998, the crisis subsided, and the European Union ended its ban. When that order took effect the next year, France continued to refuse to accept British beef. British officials threatened legal action: "We have science and the law on our side and it is regrettable that the French had ignored science and defied the law."10 Soon after, BSE turned up in cows in Germany, Italy, Spain, and Japan, most likely because the animals had been fed meat-and-bone meal exported from Great Britain. Human cases of vCJD also appeared outside of Britain, perhaps because people ate British beef before the offal ban took effect. Soon after, BSE turned up in cows in Germany, Italy, Spain, and Japan, most likely because the animals had been fed meat-and-bone meal exported from Great Britain. Human cases of vCJD also appeared outside of Britain, perhaps because people ate British beef before the offal ban took effect.

In the United States, federal agencies first took action against BSE in 1997, when the USDA banned imports of European cattle and sheep and the FDA banned the use of animal proteins as feed for ruminant animals. In 2000, the agencies banned imports of rendered animal products from 31 countries that had either reported BSE in their cattle or could not demonstrate that cattle were free of the disease. Food safety officials say the absence of mad cow disease and vCJD in the United States is due to such preventive actions. Others, however, are skeptical that the country can remain free of either disease. More than 30 shipments of animal byproducts from prohibited countries entered the United States after the ban, but regulatory agencies could not track what happened to at least half of them, perfectly illustrating the need for a system of food traceability. FDA officials said that most of the by-products ended up in pet food, but this fate cannot be confirmed (and would be unlikely to reassure pet owners, regardless). Inspections revealed that 20% of about 2,500 feed mills handling meat-and-bone meal took no precautions to prevent the meal from getting into animal feed. No federal agency tests for prohibited material in feed for cattle. Worse, the bans on use of meat-and-bone meal do not apply to other farm animals such as pigs or chickens because officials assume that feed for these animals never enters the food supply for cows or people. This assumption, as we learned from the StarLink episode, is overly optimistic.11 Because evidence of BSE in U.S. cows would be catastrophic for the industry, the USDA commissioned a three-year study from the Harvard Center for Risk Analysis, a group sponsored in part by industry. This study, based on a "probabilistic simulation model" (translation: assumptions and best guesses), said mad cow disease posed only minimal risk to American cattle or people: "Our analysis finds that the U.S. is highly resistant to any introduction of BSE or a similar disease. . . . Measures taken by the U.S. government and industry make the U.S. robust against the spread of BSE to animals or humans should it be introduced into this country." The report did not say that BSE could never enter the country, just that "The new cases of BSE would come primarily from lack of compliance with the regulations enacted to protect animal feed. . . . Even if they existed, these hypothetical sources of BSE could give rise to only one to two cases per year." Therefore, "the disease is virtually certain to be eliminated from the country within 20 years after its introduction."12 These conclusions may reassure or not depending, as usual, on point of view. A spokesman for the National Cattlemen's Beef Association said they gave "consumers and cattle producers the assurance of the safety of the American beef supply," and the president of the American Meat Institute agreed: "The U.S. is free of many animal diseases that plague other nations, testaments to the success of government-industry efforts." British observers, however, thought such groups must be "in denial." Other countries, they said, also claim not to have mad cow disease but find it as soon as they look for it; any failure to test for it in large numbers of cattle is a serious mistake. But, as a BSE researcher in Oregon explained, "let's face it, no country wants to find the disease."13 Early in 2002, the General Accounting Office (GAO) criticized the Harvard study as based on flawed assumptions, and identified glaring weaknesses in U.S. inspection, testing, and enforcement policies against animal (and, therefore, human) prion diseases: "While BSE has not been found in the United States, federal actions do not sufficiently ensure that all BSE-infected animals or products are kept out or that if BSE were found, it would be detected promptly and not spread to other cattle through animal feed or enter the human food supply."14 A meat industry spokesman dismissed the GAO report as a "rehash" and complained that it failed to recognize that "the risk of BSE ever occurring in the United States is extremely low and getting lower every day." A meat industry spokesman dismissed the GAO report as a "rehash" and complained that it failed to recognize that "the risk of BSE ever occurring in the United States is extremely low and getting lower every day."15 As if to admit its unease with the current level of protection, however, the USDA announced that it was considering a variety of more stringent bans on use of brain, nervous tissue, and other offal from older and "downer" cows (those that died before slaughter), and that it had commissioned another report from the Harvard Center to evaluate such options. As if to admit its unease with the current level of protection, however, the USDA announced that it was considering a variety of more stringent bans on use of brain, nervous tissue, and other offal from older and "downer" cows (those that died before slaughter), and that it had commissioned another report from the Harvard Center to evaluate such options.16 All in all, the experience with mad cow disease confirms that the British beef industry, like that in the United States, acts in its own self-interest regardless of consequences for public health. It also confirms that no government agency willingly makes decisions in the public interest if those decisions oppose industry interests. Finally, the mad cow experience reveals the international nature of diseases that affect the food supply. Two examples: in Japan, British meat-and-bone meal caused a case of mad cow disease, which, in turn, induced a scare responsible for a 50% drop in Japanese imports of U.S. beef, and the first case of vCJD in the United States occurred in a young British woman living in Florida. All borders are porous, food problems are global, and international strategies are required to ensure the safety of any country's food supply.17 Foot-and-Mouth Disease: A Contagious and Virulent Virus Such lessons were firmly reinforced in spring 2001 when an epidemic of foot-and-mouth disease devastated cattle not only in Great Britain but also in other European countries. By the time the epidemic ended, officials had destroyed 4 million animals, quarantined entire communities, and witnessed the destruction of British tourism. Foot-and-mouth disease only occasionally infects humans, but it is a severe political threat-to governments, economies, communities, and international relations.18 The cause of foot-and-mouth disease is a virus with several particularly dread-inspiring attributes. It spreads rapidly in air and water and over long distances, is highly contagious by inhalation or contact, and can be transmitted through shoes, clothing, automobile tires, pets, and wild animals. It affects cattle, sheep, goats, pigs, and deer, but people only rarely. It makes animals very sick; they eventually recover from the symptoms-fever and blistered mouths and hooves-but never catch up in growth, weight, or vitality. Animals infected with this disease become useless as meat. The United States takes precautions against foot-and-mouth disease and has not experienced an outbreak since 1929. The last previous British epidemic occurred in the late 1960s. Since early 2000, however, the disease has been reported in Russia, five countries in Asia, seven in Africa, and five in South America. Once started, it is not easy to contain.19 Thus, countries go to a great deal of trouble to eradicate foot-and-mouth disease and prevent its entry, and this disease is one of the main reasons why U.S. customs officials ask travelers whether they have recently visited farms. Thus, countries go to a great deal of trouble to eradicate foot-and-mouth disease and prevent its entry, and this disease is one of the main reasons why U.S. customs officials ask travelers whether they have recently visited farms.

A vaccine exists but poses its own international problems of trade and politics. Vaccinated animals could be carrying the virus but display no symptoms, and no country wants to import an infected animal or its products. Most countries refuse entry to meat or milk from vaccinated animals, and the rules of the European Union (EU) do not allow vaccination. Six weeks into the outbreak, however, the EU granted a waiver and allowed Britain to vaccinate animals against the disease. The British government chose not to do so, however. The Nestle corporation, which controls much of the milk processing in the affected region, strongly opposed vaccination because it might have "potential massive negative impact on export of products to other countries."20 Under pressure from this company and a food trade association, the government instead decided to follow standard procedures for dealing with foot-and-mouth disease outbreaks. Under pressure from this company and a food trade association, the government instead decided to follow standard procedures for dealing with foot-and-mouth disease outbreaks.

These procedures require officials to take three prompt actions: (1) destroy sick animals, (2) destroy healthy animals that might have come in contact with sick animals, and (3) quarantine people living in the vicinity of affected animals. Some countries confine farm families with animals that have the disease-or might have it-to what is effectively a war zone. In Holland, for example, officials did not permit members of such families to leave their property even to go to school, church, or the doctor. They permitted the besieged families to pick up supplies only at checkpoint barriers.21 Given the extent of this virus's contagion and its ability to disrupt the food supply and the lives of citizens, it is not difficult to imagine foot-and-mouth disease as an instrument of terror. Scientists may argue about whether it is better to vaccinate animals or destroy them promptly, but this disease can destroy food supplies, communities, and international trade as well as the confidence of a population in its government. The foot-and-mouth epidemic also pointed out gaps in food safety oversight. While it was in progress, the United States banned import of meat from the European Union. Nevertheless, at least 750,000 pounds of prohibited meat entered U.S. warehouses after the ban, in part because of the inadequate inspection capability of federal agencies.22 Anthrax: A Bacterial Instrument of Terror?

Before a possible bioterrorist mailed letters laced with anthrax spores, biologists knew this microbe best as a prototype for Koch's Postulates, the rules developed in 1884 by Robert Koch, a German scientist, to prove that bacteria cause disease.23 Anthrax bacteria ( Anthrax bacteria (Bacillus anthracis) are common in soil and are eaten by grazing animals. They exist in two stages: rod-shaped bacteria bacteria that reproduce into long chains and form that reproduce into long chains and form spores spores when food sources are depleted. The spores are exceptionally hardy; when eaten, they reconstitute into bacteria, invade the bloodstream, reproduce rapidly, and produce deadly toxins. When an infected animal dies, the bacteria turn into spores that eventually drop into the soil and continue the cycle. when food sources are depleted. The spores are exceptionally hardy; when eaten, they reconstitute into bacteria, invade the bloodstream, reproduce rapidly, and produce deadly toxins. When an infected animal dies, the bacteria turn into spores that eventually drop into the soil and continue the cycle.24 Anthrax is normally a veterinary problem. Infected animals are so visibly sick that farmers cull them before they get into the meat supply. Infected cows are too sick to produce milk, or they produce milk of unusable quality, which is why milk and cheese are not known sources of anthrax. Digestive acids and enzymes-and cooking-ordinarily kill the bacteria, and people seem to have some natural immunity. Because heavy bacterial infestations overcome these defenses and spores resist them, people occasionally acquire anthrax from eating undercooked meat from sick or downer water buffalo, goats, sheep, and cattle. Even so, food-borne anthrax is so rare that medical journals like to report the occasional cases. In August 2000, for example, Minnesota health officials described an outbreak of anthrax in a farm family whose members ate meat from a downer steer. When family members became ill, investigators discovered that the carcass was heavily infested with anthrax bacteria.25 Anthrax would be almost nonexistent in people if eating it were the only route of infection, but it also causes disease through the skin and lungs. The skin disease comes from handling infected carcasses. The lung disease comes from breathing in spores from infected animal skins or soil. These forms also are relatively rare. In the United States, health officials reported about 225 cases of the skin disease over the 50-year period from 1944 to 1994. In 2001, they added to this total a man in North Dakota who had disposed of five cows dead of anthrax. Officials logged only 18 cases of inhalation anthrax from 1900 to 1978, and just two from 1992 to 2000.26 Nevertheless, the hardiness and lethality of anthrax spores has long suggested their potential as agents of germ warfare, and numerous countries worked on secret anthrax bioweapons projects during the Cold War. Much of what is known about weapons-grade anthrax comes from studies of a single epidemic in the former Soviet Union in 1979. When the Soviet state collapsed, scientists were able to trace the epidemic to an accidental release of an aerosol of anthrax spores from a nearby germ weapons factory. Nearly all of the unlucky people and animals who developed the disease were downwind of the factory when the plume of invisible spores blew over.27 Even before the U.S. anthrax mailings in 2001, experts on bioterrorism understood that anthrax is simple to grow, is durable, and is suitable for many forms of delivery, and that many countries had stockpiled spores: "The long-dreaded concern that chemical and biological weapons might reach terrorist hands is now a reality." Even before the U.S. anthrax mailings in 2001, experts on bioterrorism understood that anthrax is simple to grow, is durable, and is suitable for many forms of delivery, and that many countries had stockpiled spores: "The long-dreaded concern that chemical and biological weapons might reach terrorist hands is now a reality."28 The United States worked on inhalation anthrax during the Cold War, and although it and numerous other countries signed a treaty in 1993 against this use, at least 10 countries are thought to be working on such projects. Ironically, because the spores mailed in 2001 were weapons-grade, some experts suspected they must have come from a U.S. military insider eager to demonstrate the need for more research on biological weapons. They were proven correct after a long, poorly handled investigation. The United States worked on inhalation anthrax during the Cold War, and although it and numerous other countries signed a treaty in 1993 against this use, at least 10 countries are thought to be working on such projects. Ironically, because the spores mailed in 2001 were weapons-grade, some experts suspected they must have come from a U.S. military insider eager to demonstrate the need for more research on biological weapons. They were proven correct after a long, poorly handled investigation.29 The effects were devastating. During the following year, health officials logged 22 cases of anthrax caused by the mailings, among them five deaths. They investigated hundreds of reports of possible exposure and closed several government buildings to clear them of spores. As political commentator Daniel Greenberg explained, it had taken a "malevolently brilliant [attack] ideal to reach the ears and fears of the public." The attack focused attention on anthrax and induced political leaders to take action against bioterrorism. In 2002, President George W. Bush authorized $1.1 billion for bioterrorism control, much of it for strengthening the capacity of the public health system.30 Dealing with anthrax attacks, however, is no simple matter. As a preventive measure, officials treated 32,000 people who might might have been exposed to anthrax with the protective antibiotic ciprofloxacin (cipro). Cipro is the most effective antibiotic against anthrax, largely because weapons programs deliberately created strains of the bacteria resistant to more common antibiotics such as penicillin. The drug produces unpleasant side effects-itching, swelling, and breathing problems-in nearly 20% of its takers. For this reason, and because of carelessness or inconvenience, many people stop taking the drug before completing the full course of treatment, thereby establishing conditions that favor the emergence of cipro-resistant anthrax-an utterly alarming scenario. have been exposed to anthrax with the protective antibiotic ciprofloxacin (cipro). Cipro is the most effective antibiotic against anthrax, largely because weapons programs deliberately created strains of the bacteria resistant to more common antibiotics such as penicillin. The drug produces unpleasant side effects-itching, swelling, and breathing problems-in nearly 20% of its takers. For this reason, and because of carelessness or inconvenience, many people stop taking the drug before completing the full course of treatment, thereby establishing conditions that favor the emergence of cipro-resistant anthrax-an utterly alarming scenario.31 Cipro has additional connections to food safety issues. It is a fluoroquinolone antibiotic closely related to another antibiotic, enrofloxacin, that is widely used to treat chickens and turkeys for respiratory ailments. The antibiotics are essentially the same; chickens metabolize enrofloxacin to cipro. Doctors have treated human infections with fluoroquinolone antibiotics since 1986, but resistance did not become a problem until 1996, when the FDA authorized use of these drugs to treat bacterial infections in poultry. As is customary, farmers fed the drug to entire flocks of chickens even if just a few were sick. Baytril, the enrofloxacin drug produced by Bayer, for example, is used on 128 million chickens worldwide and generates about $150 million in annual sales. By 1999, 18% of Campylobacter Campylobacter in chickens resisted enrofloxacin, and people exposed to such chicken bacteria could no longer be treated with cipro; 9,000 such cases were recorded that year. In 2000, the FDA proposed to ban the use of fluoroquinolone antibiotics in poultry feed. The other company making the poultry drug, Abbott Laboratories, agreed to discontinue using it in chickens, but Bayer contested the ban and keeps Baytril on the market. Bayer argues that the problem is overestimated and that withdrawing the drug would have little effect on the extent of antibiotic resistance. The company explains that using antibiotics in chickens is good for people as well as poultry: "If we are what we eat, we're healthier if they're healthier." in chickens resisted enrofloxacin, and people exposed to such chicken bacteria could no longer be treated with cipro; 9,000 such cases were recorded that year. In 2000, the FDA proposed to ban the use of fluoroquinolone antibiotics in poultry feed. The other company making the poultry drug, Abbott Laboratories, agreed to discontinue using it in chickens, but Bayer contested the ban and keeps Baytril on the market. Bayer argues that the problem is overestimated and that withdrawing the drug would have little effect on the extent of antibiotic resistance. The company explains that using antibiotics in chickens is good for people as well as poultry: "If we are what we eat, we're healthier if they're healthier."32 Drug companies may have little choice about giving up such drugs, however. Early in 2002, the three largest U.S. chicken producers, Tyson Foods among them, said they would reduce use of enrofloxacin, and McDonald's said it had decided a year earlier not to use meat from animals treated with fluoroquinolone antibiotics. Drug companies may have little choice about giving up such drugs, however. Early in 2002, the three largest U.S. chicken producers, Tyson Foods among them, said they would reduce use of enrofloxacin, and McDonald's said it had decided a year earlier not to use meat from animals treated with fluoroquinolone antibiotics.33 Anthrax is not yet resistant to cipro, but it is likely to become so if the drug is given indiscriminately to large numbers of people who do not need it and do not complete the full course of treatment. The continued use of the analogous drug in chickens will almost certainly increase the numbers and kinds of resistant bacteria. In Taiwan, 60% of pathogenic Salmonella Salmonella isolated from hospital patients have been shown to resist cipro; genetic techniques indicated that the resistant bacteria originated in herds of pigs treated with the drug. Scientists have now shown that giving cipro to chickens rapidly selects for resistant isolated from hospital patients have been shown to resist cipro; genetic techniques indicated that the resistant bacteria originated in herds of pigs treated with the drug. Scientists have now shown that giving cipro to chickens rapidly selects for resistant Campylobacter Campylobacter.34 These antibiotics connect to the issues discussed in this book in one other way. In yet another ironic twist, Bayer, the maker of enrofloxacin, acquired Aventis CropScience in December 2001 for[image] 6 billion (euros), thereby becoming the owner of StarLink corn and other transgenic varieties. The merger unites the crop protection activities of Bayer and Aventis into a new company, Bayer CropScience, expected to generate more than 6 billion (euros), thereby becoming the owner of StarLink corn and other transgenic varieties. The merger unites the crop protection activities of Bayer and Aventis into a new company, Bayer CropScience, expected to generate more than[image] 8 billion in annual sales by 2005. 8 billion in annual sales by 2005.35 THE NEW POLITICS OF FOOD SAFETY: BIOTERRORISM.

In revealing the vulnerability of the United States to harm from terrorists, the September 2001 attacks affected food safety issues in at least four ways. They (1) shifted the common use of the term food security food security to mean protection of the food supply against bioterrorism, (2) raised alarms about the ways food and biotechnology could be used as biological weapons, (3) encouraged more forceful calls for a single food agency to ensure food security, and (4) focused attention on the need for a stronger public health system to address food safety crises. Despite the apparent unity of purpose in dealing with the aftermath of the attacks, each of these effects displays the usual politics, to which we now turn. to mean protection of the food supply against bioterrorism, (2) raised alarms about the ways food and biotechnology could be used as biological weapons, (3) encouraged more forceful calls for a single food agency to ensure food security, and (4) focused attention on the need for a stronger public health system to address food safety crises. Despite the apparent unity of purpose in dealing with the aftermath of the attacks, each of these effects displays the usual politics, to which we now turn.

A New Emphasis for Food Security: Safety from Bioterrorism Prior to the terrorist attacks, food security in the United States had a relatively narrow meaning that derived from the need to establish criteria for deciding whether people were eligible to receive welfare and food assistance. In the 1980s, the U.S. government expanded its definition of "hunger" to include involuntary lack of access to food-the risk risk of hunger as well as the physical experience. By this definition, food security came to mean of hunger as well as the physical experience. By this definition, food security came to mean reliable access to adequate food reliable access to adequate food.36 The international definition is broader, however. In 1948, the United Nations adopted the Universal Declaration on Human Rights, which said, "Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and the necessary social services, and the right to security in the event of unemployment, sickness, disability, widow-hood, old age or other lack of livelihood in circumstances beyond his control."37 Many interpret this provision to mean that people have a Many interpret this provision to mean that people have a right right to food security, in this case encompassing five elements: (1) reliable access to food that is not only (2) adequate in quantity and quality, but also (3) readily available, (4) culturally acceptable, and (5) safe. With respect to safety, the Geneva Convention of August 1949, an international agreement on the protection of civilians during armed conflict, expressly prohibited deliberate destruction or pollution of agriculture or of supplies of food and water. These broader meanings derived from work in international development, where it was necessary to distinguish the physical sensation of hunger (which can be temporary or voluntary), from the chronic, involuntary lack of food that results from economic inequities, resource constraints, or political disruption. to food security, in this case encompassing five elements: (1) reliable access to food that is not only (2) adequate in quantity and quality, but also (3) readily available, (4) culturally acceptable, and (5) safe. With respect to safety, the Geneva Convention of August 1949, an international agreement on the protection of civilians during armed conflict, expressly prohibited deliberate destruction or pollution of agriculture or of supplies of food and water. These broader meanings derived from work in international development, where it was necessary to distinguish the physical sensation of hunger (which can be temporary or voluntary), from the chronic, involuntary lack of food that results from economic inequities, resource constraints, or political disruption.38 The significance of the lack-of-access meaning of food security is evident from a health survey conducted in a remote region of Afghanistan just a few months prior to the September 2001 attacks. Not least because of decades of civil strife, Afghanistan is one of the poorest countries in the world, and its health indices are dismal: a life expectancy of 46 years (as compared to 77 years in the United States) and an infant mortality rate of 165 per 1,000 live births (as compared to 7).39 At the time of the survey, the United Nations World Food Programme estimated that 3.8 million people in Afghanistan lacked food security and therefore required food aid. Investigators examined the health consequences of this lack and found poor nutritional status to be rampant in the population and a contributing factor in nearly all of the deaths that occurred during the survey period. Half of the children showed signs of stunted growth as a result of chronic malnutrition. Scurvy (the disease resulting from severe vitamin C deficiency) alone accounted for 7% of deaths among children and adults. Because visible nutrient deficiency diseases like scurvy are At the time of the survey, the United Nations World Food Programme estimated that 3.8 million people in Afghanistan lacked food security and therefore required food aid. Investigators examined the health consequences of this lack and found poor nutritional status to be rampant in the population and a contributing factor in nearly all of the deaths that occurred during the survey period. Half of the children showed signs of stunted growth as a result of chronic malnutrition. Scurvy (the disease resulting from severe vitamin C deficiency) alone accounted for 7% of deaths among children and adults. Because visible nutrient deficiency diseases like scurvy are late late indicators of malnutrition, the investigators viewed the level of food insecurity as a humanitarian crisis-less serious than in parts of Africa, but worse than in Kosovo during its 1999 upheavals. indicators of malnutrition, the investigators viewed the level of food insecurity as a humanitarian crisis-less serious than in parts of Africa, but worse than in Kosovo during its 1999 upheavals.40 After October 2001, when bombing raids led to further displacement of the population, the United Nations increased its estimate of the size of the food insecure population to 6 million and predicted that the number would grow even larger as humanitarian aid became more difficult to deliver. After October 2001, when bombing raids led to further displacement of the population, the United Nations increased its estimate of the size of the food insecure population to 6 million and predicted that the number would grow even larger as humanitarian aid became more difficult to deliver.

In part to alleviate shortages caused by the bombings, resulting dislocations, and the collapse of civic order, the United States began a program of food relief through airdrops. The packages, labeled "Food gifts from the people of the United States of America," contained freeze-dried lentil soup, beef stew, peanut butter, jelly, crackers, some spices, and a set of plastic utensils, and provided one day's food ration for an adult-about 2,200 calories. Beginning in October 2001, airplanes dropped about 35,000 food packages a day. The quantities alone suggested that their purpose had more to do with politics than food security.41 A British commentator did the calorie counts: A British commentator did the calorie counts: If you believe, as some commentators do, that this is an impressive or even meaningful operation, I urge you to conduct a simple calculation. The United Nations estimates that there are 7.5 [million] hungry people in Afghanistan. If every ration pack reached a starving person, then one two hundredth of the vulnerable were fed by the humanitarian effort on Sunday. . . . But the purpose of the food drops is not to feed the starving but to tell them they are being fed. President Bush explained on Sunday that by means of these packages, "the oppressed people of Afghanistan will know the generosity of America and our allies.42 Even with a possible exaggeration of the extent of food insecurity, this comment suggests that food aid is a complicated business, and at best a temporary expedient. One problem is getting dropped food to the people who need it most. Figure 29 Figure 29 illustrates the fate of some of the food aid packages. As often happens, enterprising people collect the packages and sell them on the open market; this gets the food into public circulation, but at a price. In this instance, the packages also encountered unexpected safety hazards. The Pentagon warned that the Taliban might try to poison the packages or spread rumors of poisoning as a means of propaganda against the United States, but Taliban leaders denied this accusation: "No one can be that brutal and ignorant as to poison his own people." illustrates the fate of some of the food aid packages. As often happens, enterprising people collect the packages and sell them on the open market; this gets the food into public circulation, but at a price. In this instance, the packages also encountered unexpected safety hazards. The Pentagon warned that the Taliban might try to poison the packages or spread rumors of poisoning as a means of propaganda against the United States, but Taliban leaders denied this accusation: "No one can be that brutal and ignorant as to poison his own people."43 The packages themselves presented hazards. They were packed in specially designed plywood containers that could be dropped from 30,000 feet without breaking, but several landed in the wrong place and destroyed people's homes. Children sent to collect the food packages died or lost limbs when they ran across fields planted with land mines. While the food drop was in progress, the political situation made it impossible for food aid to get into the country through conventional routes. Later, warlords stole shipments, and riots broke out when supplies ran out. The packages themselves presented hazards. They were packed in specially designed plywood containers that could be dropped from 30,000 feet without breaking, but several landed in the wrong place and destroyed people's homes. Children sent to collect the food packages died or lost limbs when they ran across fields planted with land mines. While the food drop was in progress, the political situation made it impossible for food aid to get into the country through conventional routes. Later, warlords stole shipments, and riots broke out when supplies ran out.44 Political stability depends on food security, and food security is inextricably linked to political stability. Without such stability, food aid alleviates a small part of the humanitarian crisis-better than nothing, but never a long-term solution. Political stability depends on food security, and food security is inextricably linked to political stability. Without such stability, food aid alleviates a small part of the humanitarian crisis-better than nothing, but never a long-term solution.45 Would increasing the amount of food aid alleviate the crisis? Former Senator George McGovern, U.S. ambassador to the World Food Programme said, "If these people have nourishment for healthy lives, this is less fertile territory for cultivation by terrorist leaders." Bringing in another issue germane to this book, he said that the war on hunger in Afghanistan and elsewhere cannot be waged without biotechnology: biotechnology: "It is probably true that affluent countries can afford to reject scientific agriculture and pay more for food produced by so-called natural methods. But the 800 million poor, chronically hungry people of Asia, Africa and Latin America cannot afford such foods." "It is probably true that affluent countries can afford to reject scientific agriculture and pay more for food produced by so-called natural methods. But the 800 million poor, chronically hungry people of Asia, Africa and Latin America cannot afford such foods."46 As we have seen, biotechnology is still a remote solution to food security problems, and it is difficult to imagine how it might have alleviated immediate food shortages in Afghanistan. As we have seen, biotechnology is still a remote solution to food security problems, and it is difficult to imagine how it might have alleviated immediate food shortages in Afghanistan.

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FIGURE 29. On October 13, 2001, New York Times New York Times photographer James Hill took this photograph of U.S. "Humanitarian Daily Rations" dropped over Afghanistan. The photograph appeared in the Week in Review section on October 21. Mr. Hill said the food packets were available in local markets for the equivalent of 60 cents each. ( photographer James Hill took this photograph of U.S. "Humanitarian Daily Rations" dropped over Afghanistan. The photograph appeared in the Week in Review section on October 21. Mr. Hill said the food packets were available in local markets for the equivalent of 60 cents each. (Photographer's Journal: War Is a Way of Life, November 19, 2001. Online: www.nytimes.com/photojournal. 2001 New York Times Photo Archive. Used with permission.) While aid agencies were attempting to deal with that situation, food security in the United States shifted to another aspect of its broader meaning: protecting the food supply against terrorists. Officials soon identified safe food and water as key components of "homeland security," as indicated by the rather frightening chart that appeared soon after the attacks (see figure 30 figure 30). The chart demonstrates that security in this sense is no simple matter, as it requires the cooperation of nearly four-dozen federal bureaucracies to protect the nation's borders, nuclear power plants, and public facilities; fight bioterrorism; obtain intelligence; and protect food and water supplies. Whether this chart demonstrates the need for coordination-or its impossibility-is a matter of interpretation, but one aspect is striking: the minimal role allotted to the Department of Health and Human Services (DHHS). Although the DHHS secretary announced that his agency "was more fearful about the safety of the American food supply than anything else," one critical piece of his domain is noticeably missing: the FDA-the agency responsible for the safety of 75% of foods, domestic and imported. In contrast, the USDA receives detailed attention, perhaps indicating the relative degree to which the two agencies command the respect of Congress.47 [image]

FIGURE 30. The byzantine organization of government units participating in the Office of Homeland Security. Agencies of the Department of Health and Human Services (shown here as HHS) appear immediately above those of the Agriculture Department (USDA) on the left side of the diagram. The Food and Drug Administration (of DHHS) is conspicuously absent as a separate entity on this chart, despite its responsibility for the safety of three-fourths of the food supply, domestic and imported. ( 2001 Dr. Jay Jakub & The Monterey Institute of International Studies. Used with permission.) Food as a Biological Weapon A second result of the events of fall 2001 is heightened awareness of the possibility that terrorists might deliberately poison food and water supplies. Protection against food bioterrorism is difficult because of the long list of agents that can be used as bioweapons and the vast number of possibilities for delivering them. Experts point to the increasing centralization of the food supply as a factor increasing its vulnerability to sabotage. If, as mentioned in chapter 1 chapter 1, an accidental contamination of ice cream with Salmonella Salmonella can make hundreds of thousands of people ill, it is easy to imagine the damage that could be caused by deliberate tampering. can make hundreds of thousands of people ill, it is easy to imagine the damage that could be caused by deliberate tampering.48 The low rate of inspection of imported foods is an especially weak link in the chain of protection. Well before he was appointed director of the Office of Public Health Preparedness, Dr. Donald Henderson, an expert on infectious diseases, smallpox eradication, and now bioterrorism, wrote: "Of the weapons of mass destruction (nuclear, chemical, and biological), the biological ones are the most greatly feared, but the country is least well prepared to deal with them." The low rate of inspection of imported foods is an especially weak link in the chain of protection. Well before he was appointed director of the Office of Public Health Preparedness, Dr. Donald Henderson, an expert on infectious diseases, smallpox eradication, and now bioterrorism, wrote: "Of the weapons of mass destruction (nuclear, chemical, and biological), the biological ones are the most greatly feared, but the country is least well prepared to deal with them."49 Of particular concern is the role of biotechnology in developing weapons of bioterrorism. The research methods used to transmit desired genes into plants could easily be adapted for nefarious purposes: creating pathogenic bacteria resistant to multiple antibiotics or able to synthesize lethal toxins, or superweeds resistant to herbicides. As half the nation's soybeans resist Roundup, genetic mischief could do a great deal of damage. On this point, Dr. Henderson commented, "At least 10 countries are now engaged in developing and producing biological weapons. What with the growing power of biotechnology, one has to anticipate that this technology, like all others before it, will eventually be misused."50 Public health experts concerned about such possibilities cite precedents, ancient and modern, for the use of poisoned food and drink to achieve political ends. The Athenians forced Socrates to drink hemlock; Shakespeare's Queen Gertrude succumbed to poisoned wine intended for Hamlet; the Borgias were notorious for their deft poisoning of political opponents. Medieval leaders of church and state employed tasters to protect against precisely such activities. As such examples demonstrate, food-borne biological weapons do not need to be confined to wartime but can be used to achieve more personal political objectives.51 Modern instances also abound. In 1997, an evidently disgruntled U.S. laboratory employee sent electronic mail messages inviting coworkers to partake of doughnuts; his message failed to mention that he had laced his treats with a particularly virulent type of Modern instances also abound. In 1997, an evidently disgruntled U.S. laboratory employee sent electronic mail messages inviting coworkers to partake of doughnuts; his message failed to mention that he had laced his treats with a particularly virulent type of Shigella Shigella, and 45 people became ill. Also in the U.S., during the 2001 December holidays, nearly 300,000 pounds of ham products had to be recalled because an angry employee spiked them with nails, screws, and other nonfood materials.52 A review of such episodes, published early in 2001, describes poisonings of water at German prisoner-of-war camps with arsenic, Israeli citrus fruit with mercury, and Chilean grapes with cyanide, suggesting that no food or drink is invulnerable to such contamination. A review of such episodes, published early in 2001, describes poisonings of water at German prisoner-of-war camps with arsenic, Israeli citrus fruit with mercury, and Chilean grapes with cyanide, suggesting that no food or drink is invulnerable to such contamination.53 Far-fetched as it may seem, the single known case of food terrorism designed to achieve political goals in the United States involved the deliberate poisoning of salad bars with Salmonella Salmonella. This widely cited incident occurred in 1984 soon after followers of the Indian guru Bhagwan Shree Rajneesh established communal headquarters in a small rural town in Oregon. Followers were easily identifiable by their red clothing, red beads, and aggressive interactions with neighbors, and they soon came into conflict over issues related to land use and building permits. To keep local residents from voting in an election for county commissioners who might enforce zoning laws, members of the commune sprinkled Salmonella Salmonella over salad bars and into cream pitchers at 10 restaurants, thereby making at least 750 people sick. over salad bars and into cream pitchers at 10 restaurants, thereby making at least 750 people sick.

This incident taught many lessons, not least that biological agents are easy to use and to obtain: the commune clinic merely ordered them from a biological supply house. Investigators had serious problems tracing the source of contamination, however. For one thing, they could not imagine that the poisonings were deliberate; nobody claimed responsibility, no motive was evident, and no such incident had been reported previously. They only were able to identify the perpetrators when one confessed. Officials also decided that publicity about the outbreak might incite copycat behavior and did not publish their findings until 1997. The incident became a classic example of how bioterrorism-even when causing no loss of life-can induce havoc. Although none of the victims died, 45 were hospitalized, and all but one of the affected restaurants soon went out of business.54 Beyond this example, the threat of food bioterrorism for political purposes remains theoretical. Nevertheless, fears of that possibility induce a wide range of responses, among them exploitation-the promotion and sale of unproved remedies. One practitioner, for example, suggests vitamin C as an alternative to vaccinations and antibiotics for bioterrorist-induced smallpox or anthrax: "Vitamin C . . . should prove highly effective against both of these conditions. I say 'should' only because their rareness has prevented any single vitamin C researcher from encountering enough cases to conduct a meaningful study and publish it. However, the likelihood that both of these conditions could be completely cured, even in their advanced stages, is compelling."55 Largely as a result of such misleading suggestions, the National Center for Complementary and Alternative Medicine informs visitors to its Web site that no herbal or vitamin products can protect against bioterrorism, and the Federal Trade Commission sends warning letters to Web sites that make unsupportable claims that products such as oregano oil, coconut oil, or zinc mineral water protect against bioweapons. Largely as a result of such misleading suggestions, the National Center for Complementary and Alternative Medicine informs visitors to its Web site that no herbal or vitamin products can protect against bioterrorism, and the Federal Trade Commission sends warning letters to Web sites that make unsupportable claims that products such as oregano oil, coconut oil, or zinc mineral water protect against bioweapons.56 Although experts agree that such products are ineffective, they profoundly disagree about the degree of danger posed by food bioterrorism and the extent to which the country should devote resources to guard against it. Some believe that the food supply remains too diffuse to permit terrorists to harm very many people at one time, and that the water supply is even less vulnerable-for reasons of dilution, chlorination, sunlight, and filtration. They prefer to approach the problem from a public health standpoint and to determine the most important food safety risks and the ways those can best be addressed. They emphasize the vastly greater harm caused by foodborne microbes, tobacco, and inappropriate use of antibiotics in animal agriculture, and suggest that applying scarce resources to these problems-rather than to the frightening but much smaller risk of bioterrorism-will ultimately save more lives. As one group puts the matter, "Our security will be better enhanced by primary prevention of war and terrorism than by military counterattacks and reactive preparedness efforts. Instead of engendering fear of bioterrorism, let's build a health care system that can handle the real health crises that we face."57 In this view, national preparedness against food bioterrorism inappropriately diverts resources from seeking solutions to more compelling food safety problems. Such perspectives are grounded in studies of risk communication. In their 1982 analysis of risk and culture referred to in the introductory chapter, Mary Douglas and Aaron Wildavsky said: "Risk aversion is a preoccupation with anticipating danger that leads to large-scale organization and centralization of power in order to mobilize massive resources against possible evils. The probability that any known danger will occur declines because of anticipatory measures. But the probability that if the unexpected happens it will prove catastrophic increases, because resources required for response have been used up in anticipation." In this view, national preparedness against food bioterrorism inappropriately diverts resources from seeking solutions to more compelling food safety problems. Such perspectives are grounded in studies of risk communication. In their 1982 analysis of risk and culture referred to in the introductory chapter, Mary Douglas and Aaron Wildavsky said: "Risk aversion is a preoccupation with anticipating danger that leads to large-scale organization and centralization of power in order to mobilize massive resources against possible evils. The probability that any known danger will occur declines because of anticipatory measures. But the probability that if the unexpected happens it will prove catastrophic increases, because resources required for response have been used up in anticipation."58 Ensuring Food Security: A Single Food Agency One repeated suggestion for a better method to address food safety problems is to centralize their oversight in a single administrative unit. Soon after the September 2001 events, officials throughout government agencies called on Congress to fund improvements in food safety and public health systems, especially those involving disease surveillance, food production quality control, food security (in the antibioterrorism sense), and inspection of imported foods.59 The GAO pointed out that the threat of bioterrorism provided further evidence for the need to create a single food agency, and the Senate held hearings to debate that suggestion. While mulling over (or dismissing) the merits of this idea, Congress increased funding to allow the FDA to hire inspectors so the agency could double its capacity to oversee the safety of imported foods-from 1% to 2% of the total entering the country. The FDA asked for additional authority: to issue recalls, and to require food companies to increase preparedness against sabotage and demonstrate the traceability of ingredients and products. The consumer advocacy organization Center for Science in the Public Interest (CSPI) supported these requests, saying, "The success of such efforts would benefit from measures that CSPI has advocated for years-measures thwarted by the lobbying power of the food industry. If there has ever been a time to put safety before profits, it is now." The GAO pointed out that the threat of bioterrorism provided further evidence for the need to create a single food agency, and the Senate held hearings to debate that suggestion. While mulling over (or dismissing) the merits of this idea, Congress increased funding to allow the FDA to hire inspectors so the agency could double its capacity to oversee the safety of imported foods-from 1% to 2% of the total entering the country. The FDA asked for additional authority: to issue recalls, and to require food companies to increase preparedness against sabotage and demonstrate the traceability of ingredients and products. The consumer advocacy organization Center for Science in the Public Interest (CSPI) supported these requests, saying, "The success of such efforts would benefit from measures that CSPI has advocated for years-measures thwarted by the lobbying power of the food industry. If there has ever been a time to put safety before profits, it is now."60 At the Senate hearings, however, food industry officials flatly opposed such measures on the grounds that they would be expensive to implement and would force companies to open their books to federal regulators. One official of the Grocery Manufacturers of America said, "Before we scrap a system that is regarded as the best in the world, we should fully explore strategies to enhance the current system, through adequate funding, better coordination, and continued innovation"; another said, "I think we've already got the system in place to deal with terrorism. . . . We just need more information from the government to make sure we can address any potential threat."61 Officials of the National Food Processors Association (NFPA) insisted that mandatory recall authority was not needed because its members were already recalling products. Instead, the only action needed is to Officials of the National Food Processors Association (NFPA) insisted that mandatory recall authority was not needed because its members were already recalling products. Instead, the only action needed is to heighten awareness of food security issues on the part of the food industry, across the board, while at the same time not increasing anxiety on the part of consumers. . . . Our current food safety system not only works, but works well. . . . We strongly believe that the best way to improve our nation's already admirable record on food safety is to continue progress towards a unified science- and risk-based food safety policy, including increased communications and improved coordination, rather than focusing on the creation of a new bureaucracy in the form of a single food agency.62 Instead, the NFPA preferred another strategy. It called on food industry trade groups to help create an Alliance for Food Security, a coalition of 80 food companies, government agencies, and public health groups united in encouraging federal agencies to cooperate and provide information about measures to enhance food safety. The alliance would develop guidance materials to help members "prevent-to the extent we can-threats from occurring to the safety of our nation's food supply . . . [and provide] a vital comprehensive, and cooperative forum for industry and government at all levels to effectively enhance and augment-where necessary-our food security systems."62 At least 18 trade associations representing every conceivable facet of food processing and marketing used such arguments and alliances to try to persuade legislators to drop provisions in bioterrorism bills that might give the FDA further authority over domestic and imported foods. At least 18 trade associations representing every conceivable facet of food processing and marketing used such arguments and alliances to try to persuade legislators to drop provisions in bioterrorism bills that might give the FDA further authority over domestic and imported foods.63 While the bills were under consideration, both the FDA and USDA issued nonbinding guidelines for importers and domestic food producers, processors, transporters, and retailers. While the bills were under consideration, both the FDA and USDA issued nonbinding guidelines for importers and domestic food producers, processors, transporters, and retailers. Table 14 Table 14 summarizes just a few of the FDA's suggestions. Many of these measures seem more appropriate to penal institutions and are especially disturbing for what they conspicuously fail to mention-Pathogen Reduction: HACCP. Perhaps because following the advice is voluntary, the NFPA praised the FDA guidelines for "not identifying weaknesses in the system that could help terrorists and for giving companies flexibility in adopting security measures." summarizes just a few of the FDA's suggestions. Many of these measures seem more appropriate to penal institutions and are especially disturbing for what they conspicuously fail to mention-Pathogen Reduction: HACCP. Perhaps because following the advice is voluntary, the NFPA praised the FDA guidelines for "not identifying weaknesses in the system that could help terrorists and for giving companies flexibility in adopting security measures."64 In the early months of 2002, Congress worked on antibioterrorism legislation to increase the FDA's capacity to inspect imported food and allow the agency to detain suspect foods without a court order, and to require food companies to register and open their records to government inspectors. Industry groups such as the NFPA, the Grocery Manufacturers of America, and the Food Marketing Institute lobbied against these provisions and requested exemptions for their members, arguing that any new legislation would be "a vehicle for a huge expanse in federal power."65 When the final bill sailed through the House and Senate, industry groups called it "much improved," no doubt because the bill required the FDA to put the new regulations through a standard rulemaking process and delay their implementation for another 18 months. When the final bill sailed through the House and Senate, industry groups called it "much improved," no doubt because the bill required the FDA to put the new regulations through a standard rulemaking process and delay their implementation for another 18 months.66 TABLE 14. FDA advice to food importers, producers, processors, transporters, and retailers about how to prevent problems with food security, 2002 Screen employees and check immigration status.Establish an employee identification system.Watch for unusual behavior (staying late, arriving early, removing documents, asking inappropriate questions).Restrict personal items allowed (purses, lunches).Inspect personal items.Change locks when employees leave.Inspect products for authenticity and package integrity.Ensure that suppliers are known to practice appropriate food security measures.Inspect incoming vehicles.Secure and supervise mailrooms.Restrict access by visitors.Restrict access to computer systems.Protect the perimeter; secure doors.Notify authorities of evidence of unusual behavior, tampering, or sabotage.

SOURCE: FDA. FDA. Food Security Preventive Measures Guidance Food Security Preventive Measures Guidance, January 9, 2002. Online: www.fda.gov.

Food Security as a Public Health Issue Soon after the September 2001 terrorist attacks, commentators identified at least one cause of the nation's inability to respond adequately to such crises: years of neglecting the public health "infrastructure"-the oversight systems and personnel needed to track and prevent disease. The focus on "homeland security," they said, although perhaps politically necessary to allay public anxiety, diverted attention and resources away from basic public health needs. International actions also focused on matters other than public health, even when providing food aid. No responses to the crisis-domestic or international-were addressing "root causes"-the underlying social, cultural, economic, or environmental factors that might encourage terrorist activities. From the perspective of public health, bioterrorism may never entirely disappear, but it seems less likely to be used as a political weapon by people who have access to education, health care, and food, and who trust their governments to help improve their lot in life. If, as many believe, terrorism reflects frustration resulting from political and social inequities, it is most likely to thrive in countries that fail to provide access to basic needs, or that give lesser rights to ethnic, religious, or other minority groups. In such situations, public health can be a useful means to strengthen society as well as to avert terrorism.

The recent history of Afghanistan illustrates these points. Its health care system is poor by any standard, and its high infant mortality rate is approached by only one other country (Pakistan) outside of sub-Saharan Africa. As noted earlier, malnutrition is widespread, in part because only slightly more than one-tenth of the population has access to clean water supplies (contaminated water induces diarrheal and other infectious diseases that, in turn, contribute to malnutrition). In this situation, advised Richard Horton, editor of the Lancet Lancet, "Attacking hunger, disease, poverty, and social exclusion might do more good than air marshals, asylum restrictions, and identity cards. Global security will be achieved only by building stable and strong societies."67 Because a healthy population is an essential factor in economic development, the health effects of globalization-positive and negative-become important concerns. Globalization has improved the social, dietary, and material resources of many populations, but it has also heightened economic and health inequities. Globalization brings safe drinking water and antibiotics, but it also brings pressures to reduce food safety standards, protect intellectual property rights, and accept the marketing of high-profit "junk" foods. Food shortages are of particular concern for at least three reasons: their harm to health, their destabilizing effects on civil order and economic development, and, not least, their breach of the social contract in which food security-in every sense of the term-is a basic human right.68 With these ideas in mind, the American Public Health Association suggests short- and long-term strategies to prevent terrorism and its adverse health consequences: address poverty, social injustice, and disparities; provide humanitarian assistance; strengthen the ability of the public health system to respond to terrorism; protect the environment and food and water supplies; and advocate for control and eventual elimination of biological, chemical, and nuclear weapons.69 Writer Laurie Garrett explains, "Public health is a bond-a trust-between a government and its people. . . . In return, individuals agree to cooperate by providing tax monies, accepting vaccines, and abiding by the rules and guidelines laid out by government public health leaders. If either side betrays that trust the system collapses like a house of cards." The value of public health approaches, in her view, is to bridge the inequities and help bring a sense of community in which the health of each individual depends on the health of others. Writer Laurie Garrett explains, "Public health is a bond-a trust-between a government and its people. . . . In return, individuals agree to cooperate by providing tax monies, accepting vaccines, and abiding by the rules and guidelines laid out by government public health leaders. If either side betrays that trust the system collapses like a house of cards." The value of public health approaches, in her view, is to bridge the inequities and help bring a sense of community in which the health of each individual depends on the health of others.70 This idea makes sense, but it makes even more sense for societies to ensure safe and secure food for all citizens simply because it is the right thing to do. This idea makes sense, but it makes even more sense for societies to ensure safe and secure food for all citizens simply because it is the right thing to do.

ENSURING SAFE FOOD.

I argue in this book that food safety is a political problem inextricably linked to matters of commerce, trade, and international relations. Ensuring food safety requires much more than following safe handling practices: it requires political action. We have seen how food companies often place commercial interests above those of consumer protection, and how government agencies often support business interests over those of public health. Today, the threat of food bioterrorism-the ultimate dread factor-reveals the importance of closing the long-standing gaps in oversight of food safety.

As consumers, we want to know that our government cares that the food we eat and the water we drink are safe (or safe enough). Given the topics discussed in this book, the FDA is less than reassuring when it tells us, "Consumers are final judges of the safety of the food they buy. . . . If there is any doubt about its safety, don't eat it."60 Surely, we would feel better if we knew that food companies were doing everything possible to minimize food hazards, and that the government was looking out for our interests and making sure food companies were doing what they were supposed to. In the absence of such reassurance, we lose trust. In the absence of trust, we are most frightened by food hazards that we cannot control: genetically modified foods, mad cow disease, and food bioterrorism, for example. Surely, we would feel better if we knew that food companies were doing everything possible to minimize food hazards, and that the government was looking out for our interests and making sure food companies were doing what they were supposed to. In the absence of such reassurance, we lose trust. In the absence of trust, we are most frightened by food hazards that we cannot control: genetically modified foods, mad cow disease, and food bioterrorism, for example.

If food safety is a matter of politics, what kinds of political actions are necessary to ensure safe food and restore trust in our food supply? Table 15 Table 15 summarizes a few actions that we might demand of the food industry, our government, and ourselves. We can begin with the food industry: What is reasonable for us to expect from companies that produce, prepare, and distribute our food? Like any other industry, the goals of the food industry are to maximize income by reducing costs and eliminating inconvenient regulatory intervention. It is unrealistic to trust food companies to keep the interests of consumers paramount, and we have seen that they are unlikely to pay much attention to consumer concerns unless forced to by government, public protest, or fear of poor public relations. If food companies want consumers to trust them, they must earn that trust by following the rules, disclosing production practices as well as nutrient contents, taking responsibility for lapses in safety, and telling the truth about matters of public interest. We would be more likely to trust the motives of food companies if they embraced Pathogen Reduction: HACCP, incorporated environmental protection into every stage of production and distribution, argued in international forums for stronger food safety and environmental standards, and worked with-not against-domestic and international regulatory policies. summarizes a few actions that we might demand of the food industry, our government, and ourselves. We can begin with the food industry: What is reasonable for us to expect from companies that produce, prepare, and distribute our food? Like any other industry, the goals of the food industry are to maximize income by reducing costs and eliminating inconvenient regulatory intervention. It is unrealistic to trust food companies to keep the interests of consumers paramount, and we have seen that they are unlikely to pay much attention to consumer concerns unless forced to by government, public protest, or fear of poor public relations. If food companies want consumers to trust them, they must earn that trust by following the rules, disclosing production practices as well as nutrient contents, taking responsibility for lapses in safety, and telling the truth about matters of public interest. We would be more likely to trust the motives of food companies if they embraced Pathogen Reduction: HACCP, incorporated environmental protection into every stage of production and distribution, argued in international forums for stronger food safety and environmental standards, and worked with-not against-domestic and international regulatory policies.

TABLE 15. Suggestions for political actions to ensure safe food and improve trust in the food supply The Food Industry Accept responsibility for producing safe food.Develop and follow Pathogen Reduction: HACCP plans at all stages of production, distribution, and service.Disclose production processes on food labels.Protect the environment at all stages of production and use.Adhere to federal regulations for food production, distribution, and service.Eliminate indiscriminate use of antibiotics in animal agriculture.Promote high standards for food safety and environmental protection in international trade.

The Federal Government Create a single food agency.Institute mechanisms to include the views of consumers when making regulatory decisions.Provide greater resources for food safety functions of regulatory agencies.Move congressional funding authority for the FDA from agriculture to health committees.Authorize regulatory agencies to recall unsafe foods.

Require food companies to document the traceability of foods and ingredients.Require labeling of genetically modified foods.Support international treaties that protect the environment, public health, and food security (including the right to food as well as food safety).Strengthen international treaties to prevent development of biological weapons; prohibit the use of genetic engineering for that purpose.Actively develop and support international policies to promote public health, human rights, and food security in all countries.

The Public Join consumer groups that promote food safety, environmental protection, and broader aspects of food security.Advocate for domestic and international programs and policies to ensure safe food, protect the environment, support public health, and guarantee rights to food and food security.Encourage others to join in such actions.Elect officials committed to such actions.

The government also could do better to ensure safe food and restore trust in the food supply. Congress could help by putting consumer protection first and creating a single food agency with genuine authority over safety in the production and distribution of foods as well as over their effects on environmental and public health. Such an agency could be empowered to promote food security in all of its humanitarian aspects: reliable access, adequate quantity and quality, appropriate cultural relevance, and safety. While thinking about how to develop this agency, Congress could provide greater resources for food inspection, and give existing agencies the authority to enforce regulations, issue recalls, ensure traceability, and protect public health. One measure to reduce political influences on the FDA, for example, would be to transfer its funding decisions from agriculture committees to those devoted to health. Congress also could require genetically modified foods to be labeled-the issue that most inflames public distrust of the food biotechnology industry-and demand that the foods undergo examination of their safety and environmental effects before they are marketed.

On the international level, the government could sign and actively support treaties that promote food safety, environmental protection, and the right to food, as well as agreements to stop producing biological weapons, genetically modified or otherwise. If we are going to protect our country against bioterrorism, our government must become more actively involved in international policies to promote health and food security as human rights for everyone, everywhere.

What can we, as individuals, do to promote such actions? We can join consumer organizations that work for environmental protection, food assistance, public health, and human rights-all of which support food safety as a necessary component of food security. We can advocate for domestic and international programs and policies directed toward those goals, and we can elect officials committed to such purposes. We can explain to our friends and colleagues that the meaning of food safety extends well beyond "cook, chill, clean, separate." Food safety-and food security-are indicators of the integrity of our democratic institutions. They are worth our political commitment.

EPILOGUE.

SINCE 2003, WHEN SAFE FOOD SAFE FOOD FIRST APPEARED, FOOD SAFETY ISSUES FIRST APPEARED, FOOD SAFETY ISSUES have evolved against a background of ongoing wars in Iraq and Afghanistan, the rise of China as an economic powerhouse, and deepening international concerns about climate change. Americans experienced revelations of abuses of corporate power, the deflation of the housing bubble, job losses, economic depression, and deep divisions in public opinion about abortion, immigration, and health care. If people now agree about anything, it is that they, as individuals, have little power to affect such events and divisions. In contrast, everyone can do something about food. The food revolution has arrived. have evolved against a background of ongoing wars in Iraq and Afghanistan, the rise of China as an economic powerhouse, and deepening international concerns about climate change. Americans experienced revelations of abuses of corporate power, the deflation of the housing bubble, job losses, economic depression, and deep divisions in public opinion about abortion, immigration, and health care. If people now agree about anything, it is that they, as individuals, have little power to affect such events and divisions. In contrast, everyone can do something about food. The food revolution has arrived.

Signs of the food revolution are everywhere, fueled in large part by the writings of Eric Schlosser, Michael Pollan, Alice Waters, and Slow Food's Carlo Petrini. By the end of 2009, Pollan's Omnivore's Dilemma Omnivore's Dilemma had been on the had been on the New York Times New York Times best-seller list for nearly one hundred twenty weeks. Food is now a respectable topic for academic study and much on the public agenda. best-seller list for nearly one hundred twenty weeks. Food is now a respectable topic for academic study and much on the public agenda.1 Food safety ought to be part of this movement. The 2008 election of President Barack Obama inspired hope that improvements in the nation's food system would at last be possible. Food safety ought to be part of this movement. The 2008 election of President Barack Obama inspired hope that improvements in the nation's food system would at last be possible.

THE POLITICS OF FOOD BIOTECHNOLOGY: UPDATE.

This book explores the disconnect between science- and value-based views of microbial contaminants and food biotechnology. With respect to genetically modified (GM) foods, what is most remarkable is how little has happened to resolve the disconnect. My shelf of books about GM foods gets longer each year, yet none of them has anything new to say. Agricultural biotechnology companies such as Monsanto and other proponents of GM foods continue to insist that use of this technology is essential for meeting the food needs of the world's expanding population, particularly in developing countries. Opponents continue to ask when the promises of food biotechnology will be fulfilled and to question its purported benefits and safety.2 Although these conflicting views seem immovable, a few changes have occurred. Let's take a look. Although these conflicting views seem immovable, a few changes have occurred. Let's take a look.

Use of GM Crops The FDA has been approving GM commodity crops since 1994, yet few are in production today. These few, however, are so widely adopted that virtually all of the corn (85 percent), cotton (88 percent), soybeans (91 percent), and sugar beets (95 percent) planted in the United States are varieties engineered to resist herbicides or insects.3 Farmers prefer to plant GM varieties because such crops do not need to be treated with pesticides and herbicides as frequently as conventional crops. Farmers also believe that the yields of GM varieties are better. Whether such benefits are real and will last over time remains in dispute. Farmers prefer to plant GM varieties because such crops do not need to be treated with pesticides and herbicides as frequently as conventional crops. Farmers also believe that the yields of GM varieties are better. Whether such benefits are real and will last over time remains in dispute.

Despite continued international opposition, GM crops were grown in fifteen developing countries and ten industrial countries in 2008. In 2009, the European Union permitted farmers to plant only one GM crop: corn. Even so, Germany, France, Austria, Greece, Hungary, and Luxembourg banned GM corn, and Monsanto's production of GM wheat also was expected to elicit opposition in foreign markets.4 Since 1994, the FDA has approved several GM fruits and vegetables for production and marketing. But were these foods actually for sale in the produce sections of American supermarkets? When researching What to Eat What to Eat, I found no regulator or advocate who knew. Most thought that production failures or consumer opposition kept GM produce off the market. The one GM food that seemed most likely to be available was Hawaiian papaya engineered to resist ringspot virus. In 2005, as I explained in What to Eat What to Eat, I paid a biotechnology testing company, Genetic ID, to check several different kinds of supermarket papayas for modified genes. Indeed, the conventionally grown Hawaiian papayas tested positive. A certified organic Hawaiian papaya did not, and neither did a papaya grown in Jamaica. But because GM foods remain unlabeled, the public has no way to know.

Genetic "Pollution"

In chapter 8 chapter 8, I discuss the travails of the Berkeley plant biology professor Ignacio Chapela, whose article in Nature Nature came under attack for demonstrating that genes from GM corn had drifted into native Mexican varieties and that these genes were more unstable than others. came under attack for demonstrating that genes from GM corn had drifted into native Mexican varieties and that these genes were more unstable than others. Nature Nature wished it had never accepted the article and said so publicly. Berkeley denied tenure to Professor Chapela, but later granted it after extensive protest. That the criticism of his work was the result of politics-not science-became evident when wished it had never accepted the article and said so publicly. Berkeley denied tenure to Professor Chapela, but later granted it after extensive protest. That the criticism of his work was the result of politics-not science-became evident when Nature Nature reported that other researchers had confirmed some of his findings. Eventually, reported that other researchers had confirmed some of his findings. Eventually, Nature Nature suggested, he would probably be proved right on all counts. Nevertheless, researchers who published more recent studies critical of agricultural biotechnology have also experienced unusually forceful attacks on the quality of their work by company and other pro-GM scientists. suggested, he would probably be proved right on all counts. Nevertheless, researchers who published more recent studies critical of agricultural biotechnology have also experienced unusually forceful attacks on the quality of their work by company and other pro-GM scientists.5 Roundup-Resistant "Superweeds"

Late in 2004, weeds resistant to Monsanto's herbicide Roundup began appearing in GM plantings in Georgia and soon spread to other Southern states. By 2009, more than one hundred thousand acres in Georgia were infested with Roundup-resistant pigweed. Planters were advised to apply multiple herbicides, thereby defeating the point of Roundup: to reduce chemical applications. In 2009, a supposedly inert surfactant in Roundup was found to kill human embryonic tissue cells. More than 250 environmental, health, and labor groups petitioned the EPA to take a closer look at the safety of solvents, preservatives, and surfactants in agricultural chemicals. "Inert" ingredients could no longer be considered benign.6 Golden Rice Golden Rice (discussed in chapter 5 chapter 5) is the most prominent example of the public benefits of agricultural biotechnology, but ten years after its initial construction it remains a promise unfulfilled. Field trials began in 2008 and its developers hope they can produce the rice by 2011. In the interim, researchers reengineered the rice to contain higher levels of beta-carotene and demonstrated that people who ate it could, as expected, convert beta-carotene to vitamin A. Supporters of Golden Rice continue to complain about the impossible demands of regulators and anti-biotechnology advocates. Advocates continue to argue that GM crops are unnecessary and threaten indigenous food security. The Gates Foundation is now the major funder of GM projects involving nutrient-enriched indigenous crops. Such technological approaches, advocates maintain, are doomed to fail unless they also address the underlying social causes of food insecurity and malnutrition.7 rBGH (Recombinant Bovine Growth Hormone) Milk from cows treated with rBGH has become the flashpoint for concerns about GM foods and a major public incentive to choose organic dairy foods; the USDA's organic rules expressly forbid use of hormones and GM technology. Late in 2009, many countries continued to ban rBGH. In the United States, several states introduced legislation to allow GM-free labels, particularly on organic and other untreated dairy foods. In response, Monsanto organized a pro-rBGH public relations campaign that included its own "grassroots" organization. A spokesman for that group complained that critics of rBGH were backed by Consumers Union and PETA (People for the Ethical Treatment of Animals), "who make a profit, living and business by striking fear in citizens." Perhaps, but widespread public opposition to rBGH induced mainstream food processors and retailers such as Dannon, General Mills, and Walmart to stop buying rBGH-milk and to require suppliers to guarantee milk as GM-free: "We've done focus groups, and people don't want it."8 Without a mass market for rBGH milk, use of this hormone seems unlikely to continue. Without a mass market for rBGH milk, use of this hormone seems unlikely to continue.

GM Labeling As predicted, the failure to label GM foods continues to pose problems for the public and for industry. Because the vast majority of processed foods contain unlabeled GM oil, protein, or sweetener ingredients, organic foods are viewed as an increasingly attractive option. Organic suppliers such as Whole Foods, concerned that GM pollution might destroy consumer trust in organics, created the Non-GMO Project: "Our shared belief is that everyone deserves an informed choice about whether or not to consume genetically modified products." The Non-GMO Project seal guarantees a GM level of no more than 0.9 percent, the standard used in Europe, where higher percentages require labeling.9 In Europe, McDonald's has gone GM-free. In 2009, I collected McDonald's brochures in England and Italy that read, "We'd like to reassure you that we don't use any GM products or ingredients containing GM material in our food." In contrast, Hershey's British products use GM ingredients and say so. The company labels Reese's Nutrageous candy bars: "Contains: Peanuts, Genetically Modified Sugar, Soya and Corn."

Labeling may be a problem easily solved, but positions on GM foods are unlikely to budge until the benefits of food biotechnology are seen to accrue to the public as well as to the food biotechnology industry.

THE POLITICS OF MICROBIAL FOOD SAFETY: UPDATE.

In contrast, since this book first appeared, value-based views of microbial contamination have shifted somewhat toward science-based views as a result of a seemingly unending series of outbreaks and recalls. Microbes continue to account for massive illness in the United States. Although noroviruses remain the leading cause, toxic forms of Salmonella Salmonella and and E. coli E. coli get far more attention, perhaps because they cause more serious harm to health and show up in the riskiest foods: meat, poultry, and produce. get far more attention, perhaps because they cause more serious harm to health and show up in the riskiest foods: meat, poultry, and produce.10 The Politics of Raw The most prominent examples of recent clashes between science and values are those involving raw foods, particularly milk and oysters.

The Raw Milk Debates. Although dairy foods account for only 3 percent of reported cases of foodborne illness, a whopping 71 percent of those cases are caused by pathogens in raw milk.11 Raw milk creates little dread or outrage in the public, but it enormously distresses health officials. Because pathogens are easily killed by pasteurization, deaths caused by pathogens in raw milk are easily prevented. Raw milk creates little dread or outrage in the public, but it enormously distresses health officials. Because pathogens are easily killed by pasteurization, deaths caused by pathogens in raw milk are easily prevented.

Safety scientists are baffled by the raw food movement, whose constituents believe-against all evidence-that raw milk is healthier and safer than pasteurized milk. To read the statements of raw milk advocates is to enter a parallel universe in which the usual standards of scientific judgment are thoroughly discounted. Such views are most prominently expressed by the Weston Price Foundation, named after the author of Nutrition and Physical Degeneration Nutrition and Physical Degeneration (1939). With considerable justification, Price argued that many of today's chronic diseases could be prevented by avoiding highly processed and refined foods. (1939). With considerable justification, Price argued that many of today's chronic diseases could be prevented by avoiding highly processed and refined foods.

The foundation, however, interprets this advice as "avoid pasteurization." It recommends "raw whole milk from grass-fed cows . . . produced under clean conditions and promptly refrigerated." One would hope that by "clean conditions" the foundation means a HACCP plan (discussed in chapters 2 chapters 2 and and 3 3), but it does not say so. Instead it says that "natural protective systems can be overwhelmed, and the milk contaminated, in situations conducive to filth and disease. Know your farmer!" Raw milk, it says, contains many antimicrobial and immune-supporting components (but, I would add, so does pasteurized milk). The foundation argues that grass feeding is healthier for cows, as well it may be. But researchers find grass-fed cattle capable of shedding almost as much E. coli E. coli O157:H7 as those in feedlots. To the question "Is it safe to consume raw milk?" the FDA's answer is blunt: "No. Raw milk is inherently dangerous and it should not be consumed by anyone at any time for any purpose." O157:H7 as those in feedlots. To the question "Is it safe to consume raw milk?" the FDA's answer is blunt: "No. Raw milk is inherently dangerous and it should not be consumed by anyone at any time for any purpose."12 For proponents of raw milk, the issue is not safety; it is values and personal choice. Demand for raw milk is increasing and mail-order sales thrive. Although more than half the states allow raw milk to be sold within their territory, federal rules prohibit shipping of raw milk between states. Mail-order companies can get around this restriction by marketing raw milk as pet food. Raw milk is sold through pet food outlets and also through use of clandestine codes, cash transactions, secret drop-off points, buyers clubs, and cow-sharing programs. Are such programs safe? Although most raw milk does not cause illness, the CDC regularly reports outbreaks caused by pathogens in raw milk. Other values come into play when such pathogens are responsible for the death of a child fed raw milk from a cow share.13 When belief systems are at stake, science-based arguments rarely work. A better strategy might be to legalize raw milk production but regulate its safety. Some raw milk producers voluntarily use HACCP plans. The FDA could require such plans and also require testing for pathogens. But doing so would undoubtedly elicit a level of opposition similar to that confronted by the FDA when it attempted to regulate the safety of raw oysters. When belief systems are at stake, science-based arguments rarely work. A better strategy might be to legalize raw milk production but regulate its safety. Some raw milk producers voluntarily use HACCP plans. The FDA could require such plans and also require testing for pathogens. But doing so would undoubtedly elicit a level of opposition similar to that confronted by the FDA when it attempted to regulate the safety of raw oysters.

The Raw Oyster Debates. For more than a decade, the FDA has been trying to prevent deaths caused by Vibrio vulnificus Vibrio vulnificus bacteria that contaminate raw oysters grown in the Gulf of Mexico. These "flesh-eating" bacteria proliferate in warm months and are especially deadly; they kill half of the thirty or so people who develop infections from them each year. Such people tend to have weakened immune systems or chronic diseases, but often do not realize they are at risk. bacteria that contaminate raw oysters grown in the Gulf of Mexico. These "flesh-eating" bacteria proliferate in warm months and are especially deadly; they kill half of the thirty or so people who develop infections from them each year. Such people tend to have weakened immune systems or chronic diseases, but often do not realize they are at risk.

In 2001, the oyster industry trade association, the Interstate Shellfish Sanitation Conference (ISSC), promised the FDA that the industry would substantially reduce Vibrio Vibrio infections in oysters within seven years through a program of voluntary self-regulation and education aimed at high-risk groups. If this program failed to reduce the infection rate, the ISSC agreed that the FDA could require oysters to be treated after harvesting to kill pathogenic infections in oysters within seven years through a program of voluntary self-regulation and education aimed at high-risk groups. If this program failed to reduce the infection rate, the ISSC agreed that the FDA could require oysters to be treated after harvesting to kill pathogenic Vibrio Vibrio.14 Treatment, in this case, means postharvest processing through techniques such as quick freezing, frozen storage, high hydrostatic pressure, mild heat, or low-dose gamma irradiation, any of which reduces Vibrio vulnificus Vibrio vulnificus to undetectable levels. By most reports, the effect of treatment on the taste and texture of oysters is slight, although raw oyster aficionados argue otherwise. In 2003, California refused to allow Gulf Coast oysters to enter the state unless they had undergone postharvest processing. The result? Sales of oysters remained the same but oyster-related deaths dropped to zero. to undetectable levels. By most reports, the effect of treatment on the taste and texture of oysters is slight, although raw oyster aficionados argue otherwise. In 2003, California refused to allow Gulf Coast oysters to enter the state unless they had undergone postharvest processing. The result? Sales of oysters remained the same but oyster-related deaths dropped to zero.

In contrast, states that did not require postharvest processing experienced no change in the number of deaths, meaning that the ISSC program had failed. Late in 2009, Michael Taylor, whom we met in chapters 2 chapters 2 and and 7 7, reappeared in his newly appointed position as senior advisor to the FDA. In an almost exact reprise of his 1994 speech to the cattle industry about the need to regulate E. coli E. coli in ground beef, he informed participants at an ISSC meeting that the FDA intended to issue rules requiring postharvest processing of Gulf Coast oysters in summer months. in ground beef, he informed participants at an ISSC meeting that the FDA intended to issue rules requiring postharvest processing of Gulf Coast oysters in summer months.15 But less than one month later, the FDA backed off. It said it would postpone the oyster-processing rules indefinitely: Since making its initial announcement, the FDA has heard from Gulf Coast oyster harvesters, state officials, and elected representatives from across the region about the feasibility of implementing post-harvest processing or other equivalent controls by the summer of 2011. These are legitimate concerns. It is clear to the FDA from our discussions to date that there is a need to further examine both the process and timing for large and small oyster harvesters to gain access to processing facilities or equivalent controls in order to address this important public health goal. Therefore, before proceeding, we will conduct an independent study to assess how post-harvest processing or other equivalent controls can be feasibly implemented in the Gulf Coast in the fastest, safest and most economical way.16 Apparently, fifteen or more preventable preventable deaths every year are not enough to elicit preventive action by industry or the FDA. Despite years of warning and unmet promises, this industry was able to induce Congress to force the FDA to back down, thereby raising uncomfortable questions about the new administration's ability to improve the safety of the nation's food supply. deaths every year are not enough to elicit preventive action by industry or the FDA. Despite years of warning and unmet promises, this industry was able to induce Congress to force the FDA to back down, thereby raising uncomfortable questions about the new administration's ability to improve the safety of the nation's food supply.

Outbreaks and Major Recalls During the mid-2000s, the United States experienced an astonishing sequence of foodborne outbreaks, each with unique revelations of safety failures followed by calls for regulation, largely unheeded. Despite lack of recall authority, the FDA and the USDA frequently announced "voluntary" recalls. In July 2009, for example, the FDA announced fifty-six voluntary food recalls or market withdrawals because of health risk or mislabeling. The USDA announced four: pork skins (no inspection) and ground beef and dry milk contaminated with Salmonella Salmonella or or E. coli E. coli O157:H7. Some outbreaks involved hundreds of cases of illness dispersed among many states. These required the CDC to conduct intense investigations, not always successfully. O157:H7. Some outbreaks involved hundreds of cases of illness dispersed among many states. These required the CDC to conduct intense investigations, not always successfully.17 Table 16 summarizes some of the most prominent incidents from 2006 to 2009. Each of these incidents reveals key flaws in the present food safety system and the need for legislative measures to address these flaws. summarizes some of the most prominent incidents from 2006 to 2009. Each of these incidents reveals key flaws in the present food safety system and the need for legislative measures to address these flaws.

2006: Spinach (E. coli (E. coli O157:H7) O157:H7). This outbreak was notable for the trouble it caused and its source. Of the 205 people who became ill, about 30 developed hemolytic uremia syndrome, and three died. The source was a widely distributed Dole brand of bagged baby spinach packed by Natural Selection Foods, a company run by Earthbound Farms, a leading supplier of organic vegetables. Because the packing plant washed the spinach thoroughly, the company and growers were shocked to learn that washing was insufficient to remove the pathogen. Growers also were shocked by the subsequent losses of sales, estimated at $100 million. By 2009, spinach sales had not yet returned to pre-outbreak levels.18 Investigators traced the spinach to a particular field in the middle of a cattle ranch one mile away from a stream used by the free-range cattle as a crossing. They isolated the outbreak E. coli E. coli strain from stream water, cattle feces, and the feces of wild boar at the crossing, but found none in the spinach field. Contaminated water from the cattle crossing seemed a likely source, as did wild boar. Investigators sampled wild animals in the area and found the outbreak strain in cattle (34 percent of samples), wild boar (15 percent), water, and soil, but in no other animals. Later, the California Department of Fish and Game found the strain in only one of 184 wild boar. Investigators concluded that "no definitive determination could be made regarding how strain from stream water, cattle feces, and the feces of wild boar at the crossing, but found none in the spinach field. Contaminated water from the cattle crossing seemed a likely source, as did wild boar. Investigators sampled wild animals in the area and found the outbreak strain in cattle (34 percent of samples), wild boar (15 percent), water, and soil, but in no other animals. Later, the California Department of Fish and Game found the strain in only one of 184 wild boar. Investigators concluded that "no definitive determination could be made regarding how E. coli E. coli O157:H7 pathogens contaminated spinach in this outbreak." O157:H7 pathogens contaminated spinach in this outbreak."19 But how had the bacteria survived washing? The packing plant used state-of-the-art washing procedures under a HACCP plan. Investigations revealed only minor procedural flaws. Although this was the twentieth E. coli E. coli O157:H7 outbreak from leafy greens in recent years, nobody seemed to have come to grips with how firmly these bacteria adhere to leaf surfaces. They can be incorporated into lettuce or spinach leaves just under the surface and form tightly adhering biofilms. O157:H7 outbreak from leafy greens in recent years, nobody seemed to have come to grips with how firmly these bacteria adhere to leaf surfaces. They can be incorporated into lettuce or spinach leaves just under the surface and form tightly adhering biofilms.20 Although the spinach was marketed as conventional, industrial growers immediately blamed the outbreak on manure-based fertilizers used in organic production. In October 2006, I wrote an opinion piece for the San Jose Mercury News San Jose Mercury News listing the obvious lessons taught by the outbreak-prevention is essential, voluntary never works, industrial agriculture has its down side-among them, "don't blame organics this time." listing the obvious lessons taught by the outbreak-prevention is essential, voluntary never works, industrial agriculture has its down side-among them, "don't blame organics this time."21 A vegetable grower in California soon set me straight. He knew that the spinach was in the second year of the three-year transition required for organic certification. Even so, manure was probably not the source, as no trace of the outbreak strain appeared on the spinach field. A vegetable grower in California soon set me straight. He knew that the spinach was in the second year of the three-year transition required for organic certification. Even so, manure was probably not the source, as no trace of the outbreak strain appeared on the spinach field.

Early in 2007, I visited Earthbound Farms and its packing plant and met with its microbiological consultant. The company had instituted test-and-hold procedures to prevent contaminated produce from coming into or leaving the plant. Such practices should be standard for this industry. California now requires the leafy greens industry to use good manufacturing practices (GMPs), but these are voluntary. The FDA, which had been advising lettuce growers to use GMPs for years, extended its voluntary guidance to spinach.22 In spring 2007, I attended a meeting of California vegetable producers at which Bill Marler, an attorney who represents victims of foodborne illness, challenged growers to "put me out of business." He warned that voluntary actions would not succeed and nothing short of mandatory federal regulations would be effective, not least because of the high human costs of foodborne illness. One of his spinach clients spent 51 days in the hospital and 18 days on dialysis, with medical bills of $500,000.23 Regulations are politically unpopular. They are difficult to implement, generate costs, and are not always applied fairly or consistently. But without accountability and enforcement, nothing stops outbreaks from occurring. Without a congressional mandate to take stronger action, the FDA again in July 2009 issued guidance to the producers of lettuce and spinach, necessarily voluntary and nonbinding.24 TABLE 16. Selected examples of food recalls and outbreaks of foodborne illness in the United States, 2006-2009 [image]

2006: Iceberg Lettuce, Taco Bell (E. coli O157:H7) O157:H7). This incident exposed the challenges faced by investigators looking for the source of outbreaks caused by restaurant meals. Late in 2006, nine of eleven people in New Jersey who became ill from foodborne E. coli E. coli said they had eaten at a Taco Bell restaurant. Because meat is cooked-a kill step-investigators focused on foods eaten raw: cilantro, cheese, green onions, yellow onions, tomatoes, and shredded lettuce. These came from a central distributor and were difficult to trace, but Taco Bell reported finding said they had eaten at a Taco Bell restaurant. Because meat is cooked-a kill step-investigators focused on foods eaten raw: cilantro, cheese, green onions, yellow onions, tomatoes, and shredded lettuce. These came from a central distributor and were difficult to trace, but Taco Bell reported finding E. coli E. coli O157:H7 in green onions from a California supplier. It removed the onions from its restaurants and stopped the supply chain. O157:H7 in green onions from a California supplier. It removed the onions from its restaurants and stopped the supply chain.25 The company also launched a public relations offensive. It bought full-page advertisements, sent out news releases, and conducted nearly a thousand interviews with the media. Its president explained, "Neither the health department nor we know what caused [the outbreak]. Not everybody that got sick ate at Taco Bell." A manager said, "We're losing money for no reason. . . . Nobody found anything and nobody proved anything."26 What food was the source? Federal investigators did their own testing, cleared green onions, and identified the outbreak strain in one sample of yellow onions. The CDC identified foods eaten more frequently by people who had become ill-lettuce, cheddar cheese, and ground beef-and guessed that lettuce was the most likely source. Because multiple Taco Bell outlets were involved, the lettuce must have been contaminated early in the distribution chain. With that uncertain speculation, the CDC investigations concluded.27 Calls for regulation followed. Eric Schlosser wrote, "Aside from industry lobbyists and their Congressional allies, there is little public support for the right to sell contaminated food. Whether you're a Republican or a Democrat, you still have to eat." A New York Times New York Times editorial said, "Surely it is time to give government regulators the power and resources they need to ensure the safety of fresh fruits and vegetables." editorial said, "Surely it is time to give government regulators the power and resources they need to ensure the safety of fresh fruits and vegetables."28 Representatives introduced food safety bills in Congress. None passed. Representatives introduced food safety bills in Congress. None passed.

2007: Pet Foods (Melamine). In March 2007, Menu Foods, a Canadian pet food manufacturer, recalled a record-breaking sixty million cans and pouches sold under ninety-five brand names.29 Although this incident involved pet, not human, food, it was such a stunning example of safety systems gone awry that I thought it deserved book-length analysis: Although this incident involved pet, not human, food, it was such a stunning example of safety systems gone awry that I thought it deserved book-length analysis: Pet Food Politics: The Chihuahua in the Coal Mine Pet Food Politics: The Chihuahua in the Coal Mine (University of California Press, 2008). (University of California Press, 2008).

To summarize: Menu Foods obtained two ingredients commonly used to increase the protein content of pet foods, wheat gluten and rice protein concentrate, through a supply chain that began in China. There, manufacturers fraudulently added an industrial chemical, melamine, to wheat flour and sold it as wheat and rice proteins. Melamine is 67 percent nitrogen. Because tests for protein in food actually measure nitrogen, not protein itself, melamine fooled the test and boosted the apparent protein content.

Melamine, a constituent of plastic dinnerware, is toxic only when consumed in large amounts. But when mixed with one of its by-products, cyanuric acid, even small amounts spontaneously form crystals in the urinary tracts of dogs and cats. More than six thousand pet owners participated in class-action lawsuits and were awarded $30 million in judgments. The FDA, which regulates pet food as animal feed, was overwhelmed by calls from distraught pet owners, but its main concern was whether melamine had entered the human food supply, and for good reason. Some of the melamine-tainted pet food had been fed to pigs and chickens, and the false rice protein went into fish feed.

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