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United States General Accounting Office: 
GAO: 

Testimony: 

Before the Subcommittee on Oversight of Government Management, 
Restructuring and the District of Columbia, Committee on Governmental 
Affairs, U.S. Senate, and the Subcommittee on Government Efficiency, 
Financial Management, and Intergovernmental Relations, Committee on 
Government Reform, U.S. House of Representatives. 

For Release on Delivery: 
Expected at 2:30 p.m. EDT: 
Tuesday, April 30, 2002: 

Food Safety: 

Continued Vigilance Needed to Ensure Safety of School Meals: 

Statement of Lawrence J. Dyckman: 
Director, Natural Resources and Environment: 

GAO-02-669T: 

Mr. Chairmen and Members of the Subcommittees: 

I appreciate this opportunity to come before you today to discuss the
safety of the foods served in our schools. As you know, more than
27 million children are provided low-cost or free meals daily through 
two federally assisted programs administered by the U.S. Department of
Agriculture’s (USDA) Food and Nutrition Service (FNS)—the National
School Lunch and School Breakfast programs. In fiscal year 2001, these
programs were funded at about $8 billion dollars. According to the 
Centers for Disease Control and Prevention (CDC), between 1990 and 
1999, nearly 300 outbreaks of foodborne illness occurred in schools 
affecting approximately 16,000 children. Outbreaks of foodborne illness 
in our schools are of particular concern because of children’s 
vulnerability to harmful pathogens. According to CDC, only a fraction 
of foodborne illnesses are routinely reported, and since most foodborne 
illnesses are sporadic, only a small number are identified as being 
part of an outbreak.[Footnote 1] 

In February 2000, we reported that USDA should take actions to better
ensure the safety of foods served in federal school meal programs. 
[Footnote 2] In response to your request, Mr. Chairmen, our testimony 
today (1) provides information on the frequency of outbreaks of 
foodborne illness in schools between 1990 and 1999, (2) discusses the 
status of our February 2000 recommendations to better safeguard the 
food served in our schools, (3) offers additional observations on how 
the safety of the school meal programs could be further enhanced, (4) 
discusses the status of efforts to minimize the risk of deliberate 
contamination of school meals, an issue of heightened importance in the 
wake of recent events, and (5) because the safety of the school meals 
hinges on the effectiveness of the nation’s overall food safety system, 
our testimony summarizes several endemic problems that we have found in 
the federal food safety system as a whole. 

Results in Brief: 

Our current analysis of CDC’s outbreak data shows an increase in the
number of school-related outbreaks reported to CDC between 1990 and
1999 (the last year for which complete outbreak data is available). 
Overall, our analysis of these data indicates that the rise in the 
number of outbreaks reported in schools since 1990 mirrors the rise in 
the number of outbreaks reported in the general population. We cannot 
determine the extent to which foods served in the school meal programs 
are the cause of reported outbreaks because CDC’s data also includes 
outbreaks that are attributable to foods brought from home or other 
sources. Our examination of 20 large school outbreaks in 1998 and 1999 
does show, however, that the majority of the outbreaks in those years 
were caused by foods served through the school meal programs. CDC 
attributes much of the increases in reported outbreaks to the improved 
data collection procedures initiated in 1998, when it began encouraging 
states to report foodborne outbreaks and to verify the data they 
submitted. CDC also suggests that increased resources for outbreak 
investigations and greater pubic awareness regarding foodborne disease 
might also account for the increased number of reported outbreaks. 
However, after accounting for CDC’s more active surveillance approach, 
our analysis revealed an increase in reported outbreaks in schools, 
generally averaging 10 percent per year. Our analysis also shows that, 
of those outbreaks with a known cause, the most commonly identified 
cause of the illnesses were foods contaminated with salmonella and 
Norwalk-like viruses.[Footnote 3] 

USDA has been, for the most part, responsive to the two recommendations
we made in our February 2000 report. Our first recommendation entailed
USDA establishing a database to track all of the actions it takes to 
hold or recall USDA-donated foods that could potentially cause 
foodborne illness in schools. We made this recommendation so that USDA 
could document its responsiveness to food safety concerns and 
potentially identify problematic vendors or foods. USDA agreed with our 
recommendation and established a database that currently contains 
records of 11 food safety actions. We also recommended that USDA revise 
its school food service manual to include guidance for state and local 
school authorities on enhanced safety provisions that are normally 
included in USDA’s procurement contracts for donated foods. USDA plans 
to address our recommendation by revising its school procurement 
guidance to include an example that addresses safety concerns. However, 
we believe USDA should include more information that would be useful to 
schools. We made this recommendation because state and local school 
food authorities purchase 83 percent of the dollar value of foods for 
the school lunch program. 

Based on the limited work we conducted in preparing for this testimony,
we have identified two other issues that may warrant additional study 
and could contribute to improving the safety of school meals. First, as 
we reported in February 2000, USDA’s procurement officials have routine
access to the federal inspection and compliance records of potential
suppliers, and they take these records into account when considering 
bids before contracting for donated foods. However, our recent 
interviews with USDA officials suggest that there is currently no 
mechanism for state and local authorities to easily and routinely 
access such information. Because state and local school authorities 
purchase the majority of foods for school meals, they may benefit from 
having ready access to the inspection and compliance information that 
the U.S. Department of Health and Human Services’ Food and Drug 
Administration (FDA) and USDA collect. Such data sharing could enable 
them to make more informed purchasing decisions. USDA officials stated 
that this idea would have to be explored further to address potential 
legal impediments to such information sharing. FDA officials said that 
the idea might have merit. Second, in the course of preparing for this 
testimony, we observed that FNS has an established process for holding 
and recalling USDA-donated foods when safety concerns arise. As the 
single common point of contact for all schools participating in the 
school meal programs, FNS may want to study the possibility of 
extending its hold and recall procedures to include school-purchased 
foods. In this manner, FNS would coordinate and track safety actions 
pertaining to all foods served in the school meal programs rather than 
just those pertaining to USDA-donated foods. USDA officials agreed with 
this concept and indicated that they intend to share the hold and 
recall procedures with schools in fiscal year 2003. 

USDA and FDA have not developed specific security provisions to protect
food served in the school meal programs from potential deliberate 
contamination. But, according to USDA and FDA officials, actions 
designed to enhance the security of the federal food safety system as a
whole would also enhance the security of school meals. As we testified 
in October 2001, recent events have raised the specter of bioterrorism 
as an emerging risk factor for our food supply. Moreover, under the 
current structure, there are questions about the food safety system’s 
ability to detect and quickly respond to any such event. Since our 
October 2001 testimony, FDA and USDA officials stated that they are 
better prepared to detect and respond to such an event. The agencies 
are in the process of conducting risk assessments to determine where in 
the farm-to-table food continuum the food supply may be most 
vulnerable. In addition, FDA has issued voluntary guidelines to the 
sectors of the food industry that it regulates to enhance, among other 
things, the physical security of processing and storage facilities. 
USDA is also working on a similar set of guidelines. Finally, agency 
officials told us that they have asked their field personnel to be on 
heightened alert for potential security concerns. 

Finally, Mr. Chairmen, as we have frequently reported in the past, a 
series of structural weaknesses in our federal food safety system can 
affect all consumers, including children who eat school meals. As we 
reported in February 2000, while no federal agency specifically 
monitors the safety of school meals, USDA and FDA are responsible for 
enforcing regulations that ensure the safety of the nation’s food 
supply. As we testified in October 2001 the existing food safety system 
is a patchwork structure that hampers efforts to adequately address 
existing and emerging food safety risks whether those risks involve 
inadvertent or deliberate contamination.[Footnote 4] The food safety 
system is affected by a series of overarching problems that impede 
efforts to address public health concerns associated with existing and 
emerging safety risks. For example, when unsafe foods are detected, 
neither USDA nor FDA has the authority to recall them from distributors,
although the appropriate agency can request manufacturers to do so
voluntarily. Therefore, today we re-emphasize the need for the creation 
of a single food safety agency with new legislative authority. Such an 
action would go a long way toward improving overall food safety. 

Background: 

The extent of foodborne illness in the United States and its associated
costs are significant. CDC estimates that unsafe foods cause as many as
76 million illnesses, 325,000 hospitalizations, and 5,000 deaths 
annually.[Footnote 5] In terms of medical costs and productivity 
losses, foodborne illnesses associated with seven major pathogens cost 
the nation between $7 billion and $37 billion annually, according to 
USDA’s estimates. 

The National School Lunch Program and the School Breakfast Program
share the goals of improving children’s nutrition, increasing lower-
income children’s access to nutritious meals, and supporting the 
agricultural economy. The school lunch program is available in almost 
all public schools and in many private schools. About 70 percent of 
those schools also participate in the breakfast program. Schools 
participating in the school lunch or breakfast programs receive a per-
meal federal cash reimbursement for all meals they serve to children, 
as long as the meals meet federal nutrition standards. In fiscal year 
2001, school meal programs provided lunch, breakfast, and snacks to 
over 27 million school children daily. 

At the federal level, FNS administers the school meal programs. At the
state level, the program is usually administered by state education
agencies, which operate them through agreements with local school food
authorities. Overall, USDA donates about 17 percent of the dollar value 
of food that goes on the table in school lunch programs through its Food
Distribution Program. USDA purchases and distributes commodities to
remove surpluses from the marketplace and to provide nutritious foods to
the nation’s children. Schools purchase the remaining 83 percent of the
dollar value of food served using USDA’s cash reimbursement and their
own funds. In fiscal year 2001, the total cost of the school meal
programs—including cash reimbursements to schools, USDA purchases of
donated foods, and program administration—was nearly $8 billion. By far
the largest component of the school meal programs is the school lunch
program. In fiscal year 2001, the school lunch program cost about
$5.7 billion. 

The procurement process for foods served in school lunch program differs
depending on whether federal or state/local food authorities procure the
foods (see figure 1). 

Figure 1: School Lunch Program Procurement Process: 

[See PDF for image] 

This figure illustrates the school lunch program procurement process as 
follows: 

National School Lunch Program: 

17% USDA donated: 
* FNS food distribution program; 
- FSA; 
- AMS; 
-Manufacturer. 

83% State/School purchased: 
* State; 
* School food authority; 
* Direct purchase; 
- Distributor; 
- Manufacturer; 
* Contracted: 
- Food service management company; 
- Distributor; 
- Manufacturer. 

[End of figure] 

USDA’s Agricultural Marketing Service (AMS) and Farm Service Agency 
(FSA) are responsible for procuring USDA-donated foods. The Agricultural
Marketing Service purchases meat, poultry, fish, and fruits and 
vegetables for donation; the Farm Service Agency purchases grains, 
oils, peanut products, dairy products, and other foods. USDA contracts 
for the purchase of these products with manufacturers that are selected 
through a formally advertised competitive bidding process. FNS, through 
its Food Distribution Division, provides the donated foods to state 
agencies for distribution to schools. Schools then purchase the 
remainder of food for school meals independently using their own 
procurement practices, either purchasing foods directly from 
manufacturers or distributors, or contracting with food service 
management companies that procure the foods for them. 

USDA provides little guidance to promote safety in school food 
procurements. FNS’ guidance to schools emphasizes safe food handling
because, according to USDA officials, most cases of foodborne illness at
schools are due to poor food storage, handling, and serving practices.
Therefore, the priority is on guidance to ensure food safety through 
proper handling and preparation of foods at schools. For example, 
manuals are provided that address appropriate temperatures for 
reheating ready-to-eat foods and for hot-holding potentially hazardous 
foods. Similarly, FNS provides information on employee personal hygiene 
and how it relates to cross-contamination of foods. 

Data Show an Increase in School Outbreaks: 

CDC’s outbreak data shows an increase in the number of school-related
outbreaks since 1990. Between 1990 and 1999 (the most recent year for
which complete outbreak data is available from CDC), 292 school-related
outbreaks were reported to CDC, averaging 17 outbreaks in the first
4 years of the decade, 28 in the next 4 years, and 57 in the final 2 
years (see table 1). In total, approximately 16,000 individuals, mostly 
children, were affected.[Footnote 6] For those outbreaks with a known 
cause, the most commonly identified cause of the illnesses were foods 
contaminated with salmonella or Norwalk-like viruses. 

Table 1: Outbreaks and Illnesses in Schools and Non-School Settings, 
1990-1999: 

Year: 1990; 
School Outbreaks: 25; 
Other Outbreaks: 508; 
School Illnesses: 1212; 
Other Illnesses: 18,019. 

Year: 1991; 
School Outbreaks: 14; 
Other Outbreaks: 517; 
School Illnesses: 486; 
Other Illnesses: 14,566. 

Year: 1992; 
School Outbreaks: 14; 
Other Outbreaks: 397; 
School Illnesses: 991; 
Other Illnesses: 10,092. 

Year: 1993; 
School Outbreaks: 15; 
Other Outbreaks: 499; 
School Illnesses: 676; 
Other Illnesses: 131,404. 

Year: 1994; 
School Outbreaks: 31; 
Other Outbreaks: 659; 
School Illnesses: 1,807; 
Other Illnesses: 15,188. 

Year: 1995; 
School Outbreaks: 9; 
Other Outbreaks: 636; 
School Illnesses: 436; 
Other Illnesses: 13,061. 

Year: 1996; 
School Outbreaks: 32; 
Other Outbreaks: 570; 
School Illnesses: 1,772; 
Other Illnesses: 13,649. 

Year: 1997; 
School Outbreaks: 39; 
Other Outbreaks: 767; 
School Illnesses: 2,026; 
Other Illnesses: 16,776. 

Year: 1998; 
School Outbreaks: 63; 
Other Outbreaks: 1,251; 
School Illnesses: 3,944; 
Other Illnesses: 22,775. 

Year: 1999; 
School Outbreaks: 50; 
Other Outbreaks: 1,294; 
School Illnesses: 2,882; 
Other Illnesses: 22,404. 

Year: Total; 
School Outbreaks: 292; 
Other Outbreaks: 7,098; 
School Illnesses: 16,232; 
Other Illnesses: 159,934. 

Note: As explained later, this outbreak data includes outbreaks caused 
by foods in the school meal programs as well as foods brought from 
home. 

Source: Centers for Disease Control and Prevention data. 

[End of table] 

According to CDC officials, some unknown portion of the increase in
reported outbreaks extends from CDC’s transition from a completely
passive surveillance data collection method to a more active 
surveillance methodology in early 1998. In effect, CDC went from 
accepting data from the states to actively soliciting states for more 
comprehensive information and having the states verify the information 
that they submit. As a result, states began to report more of all types 
of foodborne outbreaks, including school outbreaks, to CDC beginning in 
1998. Moreover, CDC suggests that increased resources for outbreak 
investigations and greater awareness among the general public about 
foodborne disease might also account for the increased number of 
reported outbreaks. 

To evaluate the trend in the number of school outbreaks, and in their
number relative to non-school outbreaks, we compared the observed
numbers to the estimated numbers of school and non-school outbreaks. 
[Footnote 7] This analysis shows that there is an upward trend in 
foodborne illness outbreaks reported in schools between 1990 and 1999 
and that not all of this increasing trend is attributable to changes 
that took place when CDC began a more active data collection effort. 
Outbreaks in the general population have increased by a comparable 
amount over the same period; therefore, there is no statistically 
significant difference between increased outbreaks in schools and 
increased outbreaks in general. As figure 2 shows, our analysis of 
CDC’s data indicates that, even after adjusting for CDC’s improved data 
collection, the number of school-related foodborne outbreaks increased, 
on average, about 10 percent per year between 1990 and 1999. 

Figure 2: Trends in School-Related Foodborne Outbreaks (1990-1999): 

[See PDF for image] 

This figure is a multiple line graph depicting trends in school-related 
foodborne outbreaks (1990-1999). Depicted are actual outbreaks and a 
GAO computed trend. 

Source: GAO’s analysis of CDC data. 

[End of figure] 

We also analyzed trends in participation in the school meal programs 
over this same time period and found that the changes in school 
outbreaks reported did not simply mirror changes in the number of 
students participating in the school meal programs. While the number of 
reported school outbreaks doubled over the decade, and generally 
increased by an average of about 10 percent from one year to the next, 
the number of school lunch participants increased by only 12 percent 
over the entire decade, or by just over 1 percent per year. Thus, the 
increase in school outbreaks reported is not explained by the increase 
in children’s participation in the school meal programs. 

One should exercise caution, however, when analyzing school outbreak 
data. CDC’s data must be supplemented with more detailed state or local
information to determine the extent of foodborne illness outbreaks 
actually associated with the school meal programs in any given year. We
gathered additional state and local health department information for 
the 20 largest school outbreaks in CDC’s database for 1998 and 1999, 
each of which resulted in 100 or more illnesses. We determined that 13 
of the 20 outbreaks (65 percent) were associated with foods served in 
the school meal programs. Three of the 13 outbreaks were linked to 
tainted burritos that were distributed to schools nationwide and are 
thought to have caused approximately 1,700 illnesses. The other 7 
outbreaks were not linked to foods served in the school meal programs, 
but with foods brought to schools from home or other sources. 
Therefore, data limitations make it difficult to assert with complete 
certainty to what extent the foods served in the school meal programs 
are the cause of the reported outbreaks from 1990 to 1999. 

USDA Has Been Largely Responsive to Our February 2000 Recommendations: 

USDA has, for the most part, been responsive to the two recommendations
we made in our February 2000 report. First, we recommended that USDA
develop a database to track the actions it takes to hold or recall 
donated foods when safety concerns arise regarding foods donated to the 
school meal programs. Second, we recommended that the agency revise its
school food service manual to include guidance regarding food safety
procurement contract provisions, which could be used by state and local
school authorities. 

We made our first recommendation because, without comprehensive records 
of such safety actions, USDA had no reliable basis for identifying 
problematic foods or suppliers, or for documenting the agency’s 
responsiveness to concerns over the safety of USDA-donated foods. In
response to our February 2000 recommendation, USDA implemented its
food safety action database in April 2000. The database identifies and
tracks key hold and recall information starting in October 1998. As of 
April 2002, the database lists 11 food safety actions, including, for 
example, the recall of 114,000 pounds of chicken that was contaminated 
with listeria in February 2000.[Footnote 8] Because of the limited 
number of actions recorded thus far, USDA has not conducted any 
analysis of the information contained in the database, but plans to 
continue maintaining it for future use. 

We made our second recommendation because, although USDA has 
established procurement policies and procedures to ensure the safety of
foods donated to schools, these policies and procedures do not apply to
foods purchased independently by schools. For example, contracts for
donated foods may specify pathogen testing for every lot of certain
products that are highly susceptible to contamination, or may contain
contract provisions that establish specific temperature requirements for
chilled and frozen products during processing and storage at the plant,
transportation between processing plants, upon shipment from the plant,
and upon arrival at final destination. However, there is no requirement 
that state and local authorities include similar food safety provisions 
in their procurement contracts. According to USDA’s regulations for 
schools participating in the school meal programs, the responsible 
school food authority may use its own procurement procedures, which 
reflect applicable state and local laws and regulations. Therefore, the 
extent to which schools address safety in their food procurement 
contracts may vary depending on state and local laws and procurement 
guidance that is available to them. To assist state and local 
authorities, we recommended that USDA provide them guidance on food 
safety provisions that could be included in their procurement 
contracts. 

USDA officials told us that they plan to address our recommendation by
revising the school procurement guidance to include an example that
addresses safety concerns. We believe, however, that USDA should
include more information that would be useful to schools. Specifically,
providing a list of the specific food safety provisions found in USDA-
donated food contracts would help schools in preparing their own food
procurement contracts. While USDA officials contend that local school
districts have little negotiating power to require safety provisions 
because their purchases are mainly low-volume from commercial sources, 
USDA’s own data indicates that in the 1996-1997 school year, the latest 
year for which this data was available, 37 percent of school food 
authorities participated in cooperative arrangements that purchase in 
larger volume. Therefore, we believe that more detailed information on 
contract safety provisions could enhance the safety of foods purchased 
directly by schools. In particular, since local school authorities 
purchase 83 percent of the dollar value of school meals, it is 
important that they receive guidance from FNS on how best to achieve a 
comparable level of safety precautions through their procurement 
process. 

Potential Opportunity to Further Enhance the Safety of School Meals: 

Based on limited work conducted in preparation for this testimony, we
offer two additional observations that, if validated by further study, 
may contribute to greater safety for school children at minimal cost. 
First, USDA’s procurement officials told us that they have routine 
access to federal inspection and compliance records of potential 
suppliers and that they consider this information when they review bids 
before contracting. However, there is currently no established 
mechanism for state and local authorities in charge of purchasing food 
for schools to easily and routinely access such information. It may be 
desirable for USDA to consider whether it should provide state and 
local school officials with access to information collected through 
FDA’s and USDA’s inspections of school lunch food suppliers, 
potentially enabling them to make more informed purchasing decisions. 
USDA officials stated that this idea would have to be explored further 
to address potential legal impediments to such information sharing. FDA 
officials commented that this idea is worth considering. 

Second, FNS has developed a process for holding foods suspected of
contamination that applies exclusively to food commodities that USDA
purchases for donation to schools. The hold allows time for additional
testing and inspection prior to asking for a recall of donated foods 
when safety concerns arise. Because FNS is the single common point of 
contact for all schools participating in the school meal programs, and 
because it does provide guidance to the schools on food nutrition and 
quality, an extension of FNS’ hold and recall procedures to include non-
donated (school-purchased) foods would seem logical. USDA officials 
agreed with this concept and indicated that they intend to share the 
hold and recall procedures with schools in fiscal year 2003. 

There Are No Special Security Provisions for the School Meal Programs: 

USDA and FDA have not developed any specific security provisions to
help protect food served through the school meal programs from potential
deliberate contamination. But, according to USDA and FDA officials,
actions designed to enhance the security of the federal food safety 
system as a whole would also enhance the security of meals served at 
schools. As we testified in October 2001, however, recent events have 
raised the specter of bioterrorism as an emerging risk factor for our 
food safety system. We further stated that under the current structure, 
there are questions about the system’s ability to detect and quickly 
respond to any such event. Since our October 2001 testimony, both FDA 
and USDA have stated that they are better prepared to detect and 
respond to such an event. Both agencies are in the process of 
conducting risk assessments to determine where in the farm-to-table 
food continuum there is a critical need to provide additional 
resources. In addition, FDA staffing has already increased inspections 
of imported foods, added more inspections of domestic producers, and 
more laboratory testing of food products. Further, FDA has issued 
voluntary security guidelines to the sector of the food industry that 
it regulates on the need to (1) ensure physical security of processing 
and storage facilities, (2) ensure that chemical and biological agents 
that may be kept in their facilities or at in-house laboratories are 
under appropriate controls, and (3) verify the background of plant 
employees. Currently, the agency is receiving public comments and 
expects to revise the guidelines. USDA is also working on a similar set 
of guidelines that meat, poultry, and egg products processors could
voluntarily adopt. Finally, agency officials told us that they have 
generally asked their field personnel to be on heightened alert for 
potential security concerns. We are initiating a review to determine 
how these guidelines are being implemented and how federal agencies 
plan to monitor their implementation. 

Overarching Problems in the National Food Safety System Also Affect the 
Safety of School Meals: 

As we reported in February 2000, while no federal agency monitors the
safety of school meals, USDA’s Food Safety and Inspection Service (FSIS)
and FDA are responsible for enforcing regulations that ensure the 
safety of the nation’s food supply. FSIS is responsible for the safety 
of meat, poultry, and some eggs and egg products, while the FDA is 
responsible for all other foods, including fish, fruit, vegetables, 
milk, and grain products. However, as we stated most recently in our 
October 2001 testimony, the existing food safety system is a patchwork 
structure that hampers efforts to adequately address existing and 
emerging food safety risks whether those risks involve inadvertent or 
deliberate contamination. The food safety system is also affected by 
other overarching problems, such as the challenge of effectively 
coordinating the food safety activities of multiple agencies including 
coordinating multi-state outbreaks. For example, the current 
organizational and legal structure of our federal food safety system 
has given responsibility for specific food commodities to different 
agencies and provided them with significantly different regulatory 
authorities and responsibilities. As a result, we have inefficient use 
of resources and inconsistencies in oversight and enforcement. 

USDA and FDA oversee recalls when the foods they regulate are 
contaminated or adulterated. If a USDA-regulated company does not 
voluntarily conduct the recall, USDA can detain the product for up to
20 days. On the other hand, FDA, which currently does not have 
administrative detention authority for food under the Federal Food, 
Drug, and Cosmetic Act, must seek a court order to seize the food. 
Moreover, as we reported in August 2000,[Footnote 9] neither USDA nor 
FDA had provided guidance to industry on how to quickly initiate and 
carry out food recalls that involve potentially serious adverse health 
risk. We recommended that such guidelines instruct companies on time 
frames for quickly initiating and carrying out recalls, including 
procedures that expeditiously notify distribution chains and alert the 
public. USDA has revised its guidelines, and FDA is in the process of 
revising its guidance and expects to reissue the guidance in September 
2002. 

Finally, Mr. Chairmen, in working on food safety issues over the past
decade, we have reviewed USDA’s and FDA’s inspection systems and 
identified weaknesses in both. The agencies agreed with most of our
recommendations and have either taken steps or are taking steps to
improve inspections. We have also focused on specific products, many of
which are included in school meals. For example, because of concerns
about the risk of salmonella in eggs, we reviewed the adequacy of the
federal system for ensuring egg safety. Our work shows that the current
regulatory and organizational framework for egg safety makes it 
difficult to ensure that resources are directed to areas of highest 
risk. Similarly, we evaluated the seafood and shellfish safety program 
and determined that theses programs do not sufficiently protect 
consumers because of weaknesses in FDA’s implementation of the new 
science-based inspection system. FDA agreed with most of our 
recommendations. We also reviewed USDA’s oversight of meat and poultry 
products and concluded that, in order to better ensure safety, USDA 
needed to ensure that inspectors are properly trained on the new 
science-based system. USDA agreed with our recommendation and is 
providing enhanced training. In January 2002,[Footnote 10] our report 
on mad cow disease concluded that, although bovine spongiform 
encephalopathy (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 of the country or that if BSE were found, it 
would be detected promptly and not spread. FDA, USDA, and Customs 
generally agreed with the report’s recommendations. 

Conclusions: 

Mr. Chairmen, in conclusion, schools face the difficult task of 
providing healthy, nutritious meals to millions of children daily. As 
the data indicate, the number of school-related foodborne illness 
outbreaks reported between 1990 and 1999 has generally increased 
despite the efforts of these schools, as well as the federal regulatory 
agencies, to prevent tainted food from reaching cafeteria plates. We 
believe that to make substantial improvements in the safety of school 
meals will require, in part, addressing the overarching problems that 
affect the nation’s federal food safety system as a whole. 
Nevertheless, as we have discussed today, there are steps that USDA 
could take within the existing safety system to better ensure the 
safety of school meals, such as providing state and local school 
authorities with specific food safety provisions that could be included 
in their procurement contracts. Additionally, continued vigilance is
necessary to determine the true extent and cause of the problems, to
ensure that schools obtain the safest food possible for our children, 
and also to ensure that unsafe foods are promptly and effectively 
withdrawn from schools when illnesses occur. 

Mr. Chairmen, this completes my prepared statement. I would be happy to
respond to any questions you or other members of the Subcommittees
may have. 

Contacts and Acknowledgments: 

For future contacts regarding this testimony, please contact Lawrence J.
Dyckman at 202-512-3841. Individuals making key contributions to this
testimony included Maria Cristina Gobin, Brad Dobbins, John M. 
Nicholson, Jr., John C. Johnson, Doug Sloane, Stuart Ryba, and Maria-
Alaina I. Rambus. 

[End of section] 

Footnotes: 

[1] CDC defines an outbreak as an incident in which two or more persons 
experience a similar illness after ingestion of a common food. 

[2] U.S. General Accounting Office, School Meal Programs: Few Outbreaks 
of Foodborne Illness Reported, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO/RCED-00-53] (Washington, D.C.: Feb. 22, 2000). 

[3] Food contaminated with salmonella may cause nausea, vomiting, 
diarrhea, and headaches. Nausea, vomiting, diarrhea, and abdominal pain 
also characterize Norwalk-like viral infections. Headache and low-grade 
fever may also occur. 

[4] U.S. General Accounting Office, Food Safety and Security: 
Fundamental Changes Needed to Ensure Safe Food, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-02-47T] (Washington, D.C.: Oct. 
10, 2001). 

[5] On Apr. 19, 2002, CDC reported that there has been a decrease in 
several major bacterial foodborne illnesses, including infections due 
to salmonella, campylobacter, and listeria. However, CDC has not 
revised its estimates of the overall incidence of foodborne illness in
the United States. 

[6] According to CDC, foodborne illnesses are underreported because (1) 
milder cases are often undetected; (2) pathogens that are transmitted 
through food may also be spread through water or from person to person, 
obscuring the role of foodborne transmission; and (3) some proportion 
of foodborne illness is caused by pathogens or agents that have not yet
been identified and thus cannot be diagnosed. Furthermore, CDC relies 
on states to voluntarily report outbreak information. 

[7] We used traditional statistical tests to determine how well the 
different models fit the observed data and which models were preferable 
to distinguish the pattern in the observed data from random 
fluctuations. 

[8] Listeria is a foodborne contaminant that can cause meningitis, 
septicemia, and perinatal disease. 

[9] U.S. General Accounting Office, Food Safety: Actions Needed by USDA 
and FDA to Ensure that Companies Promptly Carry Out Recalls, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/RCED-00-195] 
(Washington, D.C.: Aug. 17, 2000). 

[10] U.S. General Accounting Office, Mad Cow Disease: Improvements in 
the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. 
Prevention Efforts, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-
02-183] (Washington, D.C.: Jan. 25, 2002). 

[End of section]