This is the accessible text file for GAO report number GAO-10-699T 
entitled 'Food Safety: FDA Could Strengthen Oversight of Imported Food 
by Improving Enforcement and Seeking Additional Authorities' which was 
released on May 6, 2010. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Testimony: 

Before the Subcommittee on Oversight and Investigations, Committee on 
Energy and Commerce, House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 2:00 p.m. EDT:
Thursday, May 6, 2010: 

Food Safety: 

FDA Could Strengthen Oversight of Imported Food by Improving 
Enforcement and Seeking Additional Authorities: 

Statement of Lisa Shames, Director:
Natural Resources and Environment: 

GAO-10-699T: 

GAO Highlights: 

Highlights of GAO-10-699T, testimony before the Subcommittee on 
Oversight and Investigations, Committee on Energy and Commerce, House 
of Representatives. 

Why GAO Did This Study: 

Food imported from around the world constitutes a substantial and 
increasing percentage of the U.S. food supply. Ensuring the safety of 
imported food challenges the Food and Drug Administration (FDA) to 
better target its resources on the foods posing the greatest risks to 
public health and to coordinate efforts with the Department of 
Homeland Security’s Customs and Border Protection (CBP) so that unsafe 
food does not enter U.S. commerce. 

This testimony focuses on (1) FDA’s overseas inspections, (2) 
identified gaps in agencies’ enforcement efforts to ensure the safety 
of imported food, and (3) statutory authorities that GAO has 
identified that could help FDA’s oversight of food safety. This 
testimony is principally based on GAO’s September 2009 report, Food 
Safety: Agencies Need to Address Gaps in Enforcement and Collaboration 
to Enhance Safety of Imported Food (GAO-09-873) and has been updated 
with information from FDA. 

What GAO Found: 

While the number of FDA overseas inspections has fluctuated, FDA has 
opened up several overseas offices to address the safety of imported 
food at the point of origin, and is testing a computer-based system to 
target high-risk imports for additional inspection when they arrive at 
ports of entry. Specifically, in 2008, FDA inspected 153 foreign food 
facilities out of an estimated 189,000 such facilities registered with 
FDA; in 2007, FDA inspected 95 facilities. FDA estimated that it would 
conduct 200 inspections in 2009 and 600 in 2010. In addition, FDA 
opened offices in China, Costa Rica, and India and expects to open 
offices in Mexico and Chile and to post staff at European Union 
agencies. Furthermore, FDA’s testing of a new computer screening 
system—-the Predictive Risk-Based Evaluation for Dynamic Import 
Compliance Targeting (PREDICT)—-indicates that the system could 
enhance FDA’s risk-based screening efforts at ports of entry, but the 
system is not yet fully operational. PREDICT is to generate a 
numerical risk score for all FDA-regulated products by analyzing 
importers’ shipment information using sets of FDA-developed risk 
criteria and to target for inspection products that have a high risk 
score. 

GAO previously identified several gaps in enforcement that could allow 
food products that violate safety laws to enter U.S. commerce. For 
example, FDA has limited authority to assess penalties on importers 
who introduce such food products, and the lack of a unique identifier 
for firms exporting food products may allow contaminated food to evade 
FDA’s review. In addition, FDA’s and CBP’s computer systems do not 
share information. FDA does not always share certain distribution-
related information, such as a recalling firm’s product distribution 
lists with states, which impedes states’ efforts to quickly remove 
contaminated products from grocery stores and warehouses. 

GAO identified certain statutory authorities that could help FDA in 
its oversight of the food supply. Specifically, GAO previously 
reported that FDA currently lacks mandatory recall authority for 
companies that do not voluntarily recall food products identified as 
unsafe. Limitations in FDA’s food recall authorities heighten the risk 
that unsafe food will remain in the food supply. In addition, under 
current FDA regulations, companies may conclude a food ingredient is 
generally recognized as safe without FDA’s approval or knowledge. GAO 
recommended that, if FDA determines that it does not have the 
authority to implement one or more recommendations, the agency should 
seek the authority from Congress. Finally, GAO reported that FDA has 
identified a need for explicit authority from the Congress to issue 
regulations requiring preventive controls by firms producing foods 
that have been associated with repeated instances of serious health 
problems or death. FDA already has preventive regulations for seafood 
and juice, which require firms to analyze safety hazards and implement 
plans to address those hazards. 

What GAO Recommends: 

GAO recommended that FDA explore a unique identifier for firms, among 
other things. GAO also recommended FDA seek statutory authorities, 
such as for recalls and preventive controls. FDA agreed with these 
recommendations and has sought authorities. 

View [hyperlink, http://www.gao.gov/products/GAO-10-699T] or key 
components. For more information, contact Lisa Shames at (202) 512-
3841 or shamesl@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss findings from our work on the 
Food and Drug Administration's (FDA's) efforts to ensure the safety of 
imported food and on our other recently issued food safety work. 
According to U.S. Department of Agriculture (USDA) data, food imported 
from more than 150 countries and territories constitutes a substantial 
and increasing percentage of the U.S. food supply. Imported food 
constitutes 15 percent of the U.S. food supply, including 60 percent 
of fresh fruits and vegetables and 80 percent of seafood. 
Additionally, the volume of agricultural and seafood products imported 
for consumption increased 29 percent from fiscal years 2003 to 2008, 
and the value of these products increased 65 percent. Ensuring the 
safety of imported food challenges federal agencies to better target 
their resources on the foods posing the greatest risks to public 
health and to coordinate efforts so that unsafe food does not enter 
U.S. commerce. 

We have reported on the safety of imported food for many years. In 
1998, we assessed the federal government's efforts to ensure the 
safety of imported foods and determined that federal agencies could 
not be certain that the growing volume of imported food was safe for 
consumers.[Footnote 1] More recently, we reported in September 2009 
that agencies need to address gaps in enforcement and collaboration to 
enhance the safety of imported food.[Footnote 2] Federal agencies 
involved in the oversight of food imports include the following: 

* FDA--which is responsible for dairy products, seafood, fruits, and 
vegetables--oversees imported food safety through targeted 
inspections, sampling, and surveillance, among other things. Owing in 
part to the volume of imported products it regulates, FDA physically 
examines only approximately 1 percent of imported food; however, the 
agency is developing the Predictive Risk-Based Evaluation for Dynamic 
Import Compliance Targeting (PREDICT) computer system to improve its 
targeted screening efforts. 

* Customs and Border Protection (CBP), under the Department of 
Homeland Security, is responsible for enforcing FDA's food safety 
regulations at the border, among other things. CBP's computerized 
screening system processes all imported shipments, including food. CBP 
requires importers to (1) give a manufacturer identification number 
for each imported shipment and (2) post a monetary bond for formal 
entries to provide assurance that these shipments meet U.S. 
requirements, among other things. 

* The U.S. Department of Agriculture's Food Safety and Inspection 
Service (FSIS) has responsibility for the safety of imported meat and 
poultry and relies on an equivalency system whereby exporting 
countries must demonstrate that their systems meet standards that are 
equivalent to those of the U.S. system. 

Furthermore, food safety responsibility is divided among the 50 
states, which may have their own statutes, regulations, and agencies 
for regulating and inspecting the safety and quality of food products. 
This fragmentation is the key reason that we added federal oversight 
of food safety to our high risk-series in January 2007 and called for 
a governmentwide examination of the food safety system.[Footnote 3] 

Several food safety bills have recently been introduced in the 
Congress, and a comprehensive bill, H.R. 2749, passed the House of 
Representatives in July 2009.[Footnote 4] The House bill seeks tighter 
control over food imports and would require importers to register 
annually with FDA and to submit an appropriate unique facility 
identifier as a condition of such registration, among other 
provisions. The bill would also authorize FDA to issue a mandatory 
recall of foods that may cause serious adverse health consequences or 
death to humans or animals and would expand the agency's authority to 
assess criminal and civil penalties. Our September 2009 report made 
some of the same recommendations. 

My testimony today will focus on three key issues: (1) FDA overseas 
inspections to address the safety of imported food, (2) identified 
gaps in agencies' enforcement that undermine efforts to ensure the 
safety of imported food, and (3) statutory authorities that we have 
identified that could help FDA's oversight of food safety. 

As detailed in our reports, we found the following: 

* First, while the number of FDA's foreign inspections has fluctuated, 
the agency has opened several overseas offices to address the safety 
of imported food at the point of origin. In addition, FDA testing of 
PREDICT indicates that the system could enhance FDA's risk-based 
screening efforts, but the system is not yet fully operational. FDA 
officials stated that a scheduled nationwide rollout this summer of 
PREDICT has been delayed primarily because of technical problems, such 
as server crashes and overloads, which are affecting FDA's field data 
systems nationwide. 

* Second, gaps in FDA's and other agencies' enforcement could allow 
violative food products to enter U.S. commerce. For example, FDA has 
limited authority to assess penalties on importers who introduce 
violative food products, and the lack of a unique identifier for firms 
exporting food products may allow contaminated food to evade FDA 
review. 

* Finally, we have made several recommendations that would help FDA 
improve food safety oversight. For example, we recommended that FDA 
seek additional authorities, such as more explicit authority to create 
preventive controls for high-risk foods, or that Congress consider 
giving FDA additional authority, such as mandatory recall authority. 
FDA agreed with these recommendations and has sought authority to 
order food safety recalls and issue additional preventive controls for 
high-risk foods. 

This testimony is largely based on our September 2009 report on 
imported food safety, as well as other recent reports, and updated 
with information from FDA. See Appendix I for highlights of our prior 
work. We conducted our work in accordance with generally accepted 
government auditing standards. 

While the Number of FDA Overseas Inspections Has Fluctuated, the 
Agency Has Opened Overseas Offices, and Has Piloted PREDICT: 

In 2008, FDA inspected 153 foreign food facilities out of an estimated 
189,000 such facilities registered with FDA and estimated that it 
would conduct 200 inspections in 2009 and 600 in 2010.[Footnote 5] In 
2007, FDA inspected 95 facilities. Table 1 shows the number of FDA 
inspections of foreign food facilities, by country, from fiscal years 
2001 through 2008. As the table shows, FDA conducted 1,186 inspections 
in 56 countries from fiscal years 2001 through 2008; the majority of 
FDA inspections were in Mexico, followed by Ecuador, Thailand, and 
Chile. FDA conducted a total of 46 inspections in China during this 
period. 

Table 1: FDA Inspections of Food Firms in Foreign Countries, Fiscal 
Years 2001 through 2008: 

Mexico; 
2001: 17; 
2002: 15; 
2003: 8; 
2004: 15; 
2005: 7; 
2006: 16; 
2007: 26; 
2008: 29; 
Total: 133. 

Ecuador; 
2001: 8; 
2002: 0; 
2003: 11; 
2004: 24; 
2005: 0; 
2006: 11; 
2007: 10; 
2008: 0; 
Total: 64. 

Thailand; 
2001: 4; 
2002: 10; 
2003: 0; 
2004: 10; 
2005: 0; 
2006: 22; 
2007: 0; 
2008: 12; 
Total: 58. 

Chile; 
2001: 13; 
2002: 0; 
2003: 15; 
2004: 6; 
2005: 7; 
2006: 11; 
2007: 0; 
2008: 5; 
Total: 57. 

Peru; 
2001: 13; 
2002: 0; 
2003: 0; 
2004: 18; 
2005: 1; 
2006: 9; 
2007: 9; 
2008: 4; 
Total: 54. 

Brazil; 
2001: 0; 
2002: 12; 
2003: 6; 
2004: 7; 
2005: 21; 
2006: 0; 
2007: 0; 
2008: 7; 
Total: 53. 

China; 
2001: 0; 
2002: 9; 
2003: 2; 
2004: 6; 
2005: 16; 
2006: 0; 
2007: 0; 
2008: 13; 
Total: 46. 

Taiwan; 
2001: 9; 
2002: 7; 
2003: 0; 
2004: 9; 
2005: 0; 
2006: 7; 
2007: 0; 
2008: 7; 
Total: 39. 

Canada; 
2001: 13; 
2002: 0; 
2003: 13; 
2004: 1; 
2005: 0; 
2006: 7; 
2007: 4; 
2008: 0; 
Total: 38. 

Costa Rica; 
2001: 0; 
2002: 11; 
2003: 0; 
2004: 4; 
2005: 5; 
2006: 7; 
2007: 0; 
2008: 7; 
Total: 34. 

Honduras; 
2001: 9; 
2002: 8; 
2003: 0; 
2004: 0; 
2005: 7; 
2006: 0; 
2007: 0; 
2008: 8; 
Total: 32. 

Vietnam; 
2001: 0; 
2002: 9; 
2003: 0; 
2004: 10; 
2005: 8; 
2006: 0; 
2007: 0; 
2008: 4; 
Total: 31. 

Argentina; 
2001: 7; 
2002: 5; 
2003: 0; 
2004: 0; 
2005: 0; 
2006: 0; 
2007: 19; 
2008: 0; 
Total: 31. 

India; 
2001: 6; 
2002: 0; 
2003: 10; 
2004: 0; 
2005: 7; 
2006: 7; 
2007: 0; 
2008: 0; 
Total: 30. 

South Korea; 
2001: 14; 
2002: 0; 
2003: 0; 
2004: 1; 
2005: 7; 
2006: 0; 
2007: 6; 
2008: 0; 
Total: 28. 

Australia; 
2001: 12; 
2002: 0; 
2003: 6; 
2004: 0; 
2005: 0; 
2006: 9; 
2007: 0; 
2008: 0; 
Total: 27. 

Jamaica; 
2001: 2; 
2002: 6; 
2003: 0; 
2004: 3; 
2005: 0; 
2006: 3; 
2007: 0; 
2008: 8; 
Total: 22. 

Fiji; 
2001: 0; 
2002: 0; 
2003: 8; 
2004: 0; 
2005: 0; 
2006: 0; 
2007: 13; 
2008: 0; 
Total: 21. 

Guatemala; 
2001: 0; 
2002: 10; 
2003: 0; 
2004: 0; 
2005: 6; 
2006: 0; 
2007: 0; 
2008: 5; 
Total: 21. 

Singapore; 
2001: 10; 
2002: 0; 
2003: 0; 
2004: 8; 
2005: 0; 
2006: 0; 
2007: 0; 
2008: 3; 
Total: 21. 

Nicaragua; 
2001: 0; 
2002: 8; 
2003: 0; 
2004: 0; 
2005: 0; 
2006: 7; 
2007: 0; 
2008: 4; 
Total: 19. 

El Salvador; 
2001: 0; 
2002: 0; 
2003: 8; 
2004: 0; 
2005: 6; 
2006: 0; 
2007: 0; 
2008: 4; 
Total: 18. 

Germany; 
2001: 5; 
2002: 4; 
2003: 4; 
2004: 0; 
2005: 0; 
2006: 1; 
2007: 1; 
2008: 2; 
Total: 17. 

Estonia; 
2001: 8; 
2002: 0; 
2003: 0; 
2004: 8; 
2005: 0; 
2006: 0; 
2007: 0; 
2008: 0; 
Total: 16. 

Panama; 
2001: 0; 
2002: 0; 
2003: 7; 
2004: 0; 
2005: 0; 
2006: 0; 
2007: 0; 
2008: 9; 
Total: 16. 

South Africa; 
2001: 5; 
2002: 0; 
2003: 11; 
2004: 0; 
2005: 0; 
2006: 0; 
2007: 0; 
2008: 0; 
Total: 16. 

Malaysia; 
2001: 0; 
2002: 0; 
2003: 0; 
2004: 0; 
2005: 9; 
2006: 0; 
2007: 0; 
2008: 6; 
Total: 15. 

28 additional countries[A]; 
2001: [Empty]; 
2002: [Empty]; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
Total: [Empty]. 

Total number of countries that had firms inspected by FDA during the 
specific fiscal year listed above; 
2001: 26; 
2002: 22; 
2003: 22; 
2004: 20; 
2005: 16; 
2006: 15; 
2007: 11; 
2008: 24; 
Total: 56. 

Total inspections; 
2001: 211; 
2002: 169; 
2003: 148; 
2004: 153; 
2005: 132; 
2006: 125; 
2007: 95; 
2008: 153; 
Total: 1,186. 

Source: GAO analysis of FDA data. 

[A] Countries with a total of 14 or fewer inspections between 2001 and 
2008 are not listed in the table. These countries include: Italy (14 
inspections), Latvia (14), Uruguay (14), Venezuela (14), Morocco (13), 
New Zealand (13), Poland (13), Trinidad and Tobago (12), France (11), 
Norway (11), Romania (10), Surinam (10), Iceland (9), Bulgaria 
(8),Colombia (8), United Kingdom (8), Cyprus (7), Turkey (5), Belize 
(4), Spain (4), Belgium (3), Greece (3), Hungary (3), Indonesia (3), 
Finland (2), Haiti (2), Japan (2), and the Netherlands (2). 

[End of table] 

For fiscal year 2009, FDA allocated 272 full-time employees to examine 
imported food shipments at U.S. ports of entry and estimated a budget 
of approximately $93.1 million for field import activities.[Footnote 
6] The total estimated 2009 FDA budget for all FDA products and 
programs, including food, drugs, medical devices, and other products, 
was $2.7 billion. In 2008, we testified that if FDA were to inspect 
each of the 189,000 registered foreign facilities--at the FDA 
Commissioner's estimated cost of $16,700 per inspection--it would cost 
FDA approximately $3.16 billion to inspect all of these facilities 
once.[Footnote 7] 

Since November 2008, FDA has opened overseas offices to help prevent 
food that violates U.S. standards from reaching the United States. 
These offices are expected to provide FDA with direct access to 
information about foreign facilities' food manufacturing practices so 
that its staff at U.S. ports of entry can make more informed decisions 
about which food imports to examine. For example, FDA's overseas staff 
are working with staff at counterpart regulatory agencies overseas, as 
well as with other stakeholders who may be knowledgeable about certain 
industries. Overseas staff are also educating local exporters to make 
sure they understand U.S. food safety laws and regulations and FDA 
expectations. FDA opened offices in China (Beijing, Guangzhou, and 
Shanghai); in Europe (Brussels, London, and soon in Parma, Italy); in 
Latin America (San Jose, Costa Rica; Santiago, Chile; and Mexico City, 
Mexico); and in India (New Delhi and Mumbai). The FDA Middle East 
Office is operating out of FDA headquarters because the Department of 
State denied its request to locate in Amman, Jordan, due to security 
concerns. 

In addition to overseas offices assisting FDA's oversight of imported 
food, the agency is developing PREDICT. PREDICT is intended to assist 
FDA's oversight of imported food. PREDICT uses FDA-developed criteria 
to estimate the risk of imported food shipments. These criteria are to 
incorporate, among other things, the violative histories of the 
product, importer, manufacturer, consignee, and country of origin; the 
results of laboratory analyses and foreign facility inspections; and 
general intelligence on recent world events--such as natural 
disasters, foreign recalls, and disease outbreaks--that may affect the 
safety of a particular imported food product. In addition, agency 
officials stated that PREDICT will assign higher risk scores to firms 
for which the system does not have historical data. 

PREDICT generates a numerical risk score for all FDA-regulated 
products. According to FDA, PREDICT is to present the shipment's risk 
score to FDA reviewers if the score is above an FDA-specified 
threshold. Shipments that are below the threshold are to receive a 
system "may proceed" (cleared) message unless other conditions are 
present, such as an FDA import alert.[Footnote 8] FDA intends that 
reviewers using PREDICT will also be able to view the specific risk 
factors that contributed to the shipment's risk score, such as whether 
the product or importer has a history of FDA violations. FDA expects 
entry reviewers to use PREDICT to supplement, rather than replace, 
their professional judgment when deciding what food products to 
inspect. 

A 2007 pilot test of PREDICT in Los Angeles for seafood products 
indicated that the system could enhance FDA's risk-based import 
screening efforts. When compared with baseline data from FDA's 
existing import screening system, the Operational and Administrative 
System for Import Support (OASIS), PREDICT improved FDA's ability to 
target imports that the agency considers to be high risk for further 
examinations and allowed a greater percentage of products the agency 
considers to be low risk to enter U.S. commerce without requiring a 
reviewer's intervention. Specifically, PREDICT nearly doubled the 
percentage of field examinations--and increased by approximately one- 
third the percentage of laboratory examinations--that resulted in 
violations, relative to baseline OASIS data. In addition, according to 
FDA, the violations in shipments that reviewers targeted using 
PREDICT, on average, posed a greater risk to human health than the 
violations that OASIS detected. 

FDA told us on April 12, 2010, that PREDICT is fully operational in 
the Los Angeles and New York districts, but due to technical problems, 
FDA has not determined when the system will be deployed in the Seattle 
district. In addition, FDA officials stated that a scheduled 
nationwide rollout this summer of PREDICT has been delayed primarily 
because of technical problems, such as server crashes and overloads, 
which are affecting FDA's field data systems nationwide. 

Although the PREDICT pilot produced positive results and demonstrated 
the system's potential to improve import screening efforts, we 
reported that further agency actions were needed to help ensure that 
the system is effective. For example, FDA had not yet developed a 
performance measurement plan to evaluate, among other things, 
PREDICT's ability to identify high-risk shipments for manual review 
while simultaneously returning "may proceed" messages for low-risk 
shipments and enabling them to enter U.S. commerce. We recommended FDA 
develop such a plan. According to agency officials, since our report 
was issued in September 2009, FDA had completed a draft performance 
measurement plan. However, we have not reviewed this draft plan. 

FDA and Other Agencies Face Gaps in Enforcement That Undermine Efforts 
to Ensure the Safety of Imported Food: 

We identified specific gaps in enforcement that could allow violative 
food products to enter U.S. commerce: (1) FDA's limited authority to 
assess civil penalties on certain violators; (2) lack of unique 
identifiers for firms exporting FDA-regulated products; (3) lack of 
information-sharing between agencies' computer systems and (4) FDA's 
not sharing share product distribution information during a recall. 

FDA Has Limited Authority to Ensure Importers' Compliance: 

Importers can retain possession of their food shipments until FDA 
approves their release into U.S. commerce. However, FDA and CBP 
officials do not believe that CBP's current bonding procedures for FDA-
regulated food effectively deter importers from introducing violative 
food products into U.S. commerce. Specifically, importers post a 
monetary bond for formal entries (i.e., all shipments exceeding $2,000 
or certain shipments valued below that amount) to provide assurance 
that these shipments meet U.S. requirements. According to these 
officials, many importers still consider the occasional payment of 
forfeited bonds as part of the cost of doing business. Indeed, as we 
reported in 1998, forfeiture of the shipment's maximum bond value is 
often not sufficient to deter the sale of imported goods that FDA has 
not yet released. In its response to our September 2009 report, FDA 
agreed with this finding. According to FDA's regulatory procedures 
manual, the bond penalty is intended to make the unauthorized 
distribution of articles unprofitable, but liquidated damages incurred 
by importers are often so small that they, in effect, encourage future 
illegal distribution of imported shipments. Even though the bond may 
be up to three times the value of the shipment, for a large importer, 
this sum may be negligible, especially when the importer successfully 
petitions CBP to reduce the amount. 

We recommended that the FDA Commissioner seek authority from the 
Congress to assess civil penalties on firms and persons who violate 
FDA's food safety laws and that the Commissioner determine what 
violations should be subject to this new FDA civil penalties 
authority, as well as the appropriate nature and magnitude of the 
penalties. FDA agreed with this recommendation and was working with 
Congress to include civil penalty authority in food safety 
legislation. FDA officials also told us that if the agency had the 
authority to impose civil penalties on importers, which is also 
provided for in H.R. 2749, FDA might be better able to deter 
violations. 

FDA and CBP Do Not Provide Unique Identification Numbers to Firms: 

High-risk foods may enter U.S. commerce because the identification 
numbers that FDA uses to target manufacturers that have violated FDA 
standards in the past are not unique and therefore these 
manufacturers, and their shipments, may evade FDA review. Importers 
generate a manufacturer identification number at the time of import, 
when, among other things, they electronically file entry information 
with CBP. (CBP is responsible for validating the manufacturer 
identification numbers and ensuring they are unique.) CBP 
electronically sends this information to FDA's computer system. From 
this new manufacturer identification number, FDA's computer system 
automatically creates an FDA firm identification number--called the 
FDA establishment identifier. Officials told us that a single firm may 
often have multiple CBP manufacturer identification numbers--and 
therefore multiple FDA establishment identifiers. FDA officials told 
us that because CBP has multiple identification numbers for many 
firms, FDA has an average of three "unique" identifiers per firm, and 
one firm had 75 identifiers. 

The creation of multiple identifiers can happen in a number of ways. 
For example, if information about an establishment--such as its name-- 
is entered by importers incorrectly at the time of filing with CBP, a 
new manufacturer identification number, and therefore a new FDA 
establishment identifier, could be created for an establishment that 
already has an FDA number. In this scenario, a importer may-- 
intentionally or unintentionally--enter a firm's name or address 
slightly differently from the way it is displayed in FDA's computer 
system. This entry would lead to the creation of an additional FDA 
number for that firm. If an import alert was set using the original 
FDA establishment identifier, a shipment that should be subject to the 
import alert may be overlooked because the new number does not match 
the one identified in the alert. 

In addition, foreign facilities that manufacture, process, pack, or 
hold food for consumption in the United States, with some exceptions, 
are required to register with FDA. Upon registration, FDA assigns a 
registration number. FDA calculated that in 2008, 189,000 foreign 
firms were registered under this requirement. However, some of the 
firms included in that total may be duplicates because the facility 
may have been reregistered without the cancellation of the original 
registration; consequently FDA may not know the precise number of 
foreign firms registered. As we previously reported, FDA officials 
told us they are working to address the unique identifier problem by 
establishing an interactive process in which FDA's systems recognize 
when a product's identifier does not match its manufacturer's 
registration number. 

As we reported, FDA could consider requiring food manufacturers to use 
a unique identification number that FDA or a designated private sector 
firm provides at the time of import. However, the use of this unique 
number would necessitate collaboration with CBP, since importers would 
use such a number each time they file with CBP to ship goods to the 
United States. That is, CBP's computer system would need to be 
programmed to accept an FDA unique identification number. According to 
CBP officials, it is unknown if or when CBP's system will have this 
capability. To improve FDA's and CBP's ability to identify foreign 
firms with violative histories, we recommended that the FDA 
Commissioner explore ways to improve the agency's ability to identify 
foreign firms with a unique identifier and that the CBP Commissioner 
ensure that its computer system is able to accept a unique 
identification number for foreign firms that export FDA-regulated 
foods. Both FDA and CBP agreed with our recommendation, and CBP 
officials told us that the agency has developed a plan for 
implementing a unique identifier. However, we have not reviewed this 
plan. We observe that H.R. 2749 contains a provision that may allow 
the Secretary of Health and Human Services, in consultation with the 
Commissioner of CBP, to specify the unique numerical identifier system 
to be used, taking into account compatibility with CBP's automated 
systems. Such actions would help prevent high-risk foods from entering 
U.S. commerce. 

Information Is Not Shared between Computer Systems: 

When we issued our report in September 2009, we reported that CBP's 
computer system did not notify FDA's or FSIS's systems when imported 
food shipments arrive at U.S. ports, which increases the risk that 
potentially unsafe food may enter U.S. commerce, particularly at truck 
ports. If FDA chooses to examine a shipment as part of its 
admissibility review, the agency notifies both CBP and the importer 
through its computer system, OASIS. However, once the shipment arrives 
at the port and clears CBP's inspection process, the importer is not 
required to wait at the port for FDA to conduct its examination. 
Instead, the importer may choose to transport the shipment to the 
consignee's warehouse or other facility within the United States. The 
importer might choose to do so because, for example, CBP and FDA do 
not have the same hours of operation at some ports, and FDA's port 
office may be closed when the shipment arrives. In such cases, as a 
condition of the bond with CBP, the importer agrees to hold the 
shipment intact and not distribute any portion of it into U.S. 
commerce until FDA has examined it. 

CBP and FDA officials told us that, occasionally, an importer will 
transport the shipment to the consignee's warehouse without first 
notifying FDA. If this occurs, FDA will not quickly know that the 
shipment has arrived and been transported to a U.S. warehouse because 
CBP's computer system does not notify FDA's OASIS computer system when 
the shipment arrives at the port. Instead, from the perspective of an 
FDA reviewer using OASIS, it will appear as if the shipment's arrival 
is still pending. FDA port officials told us that it could be 2 or 3 
days before FDA reviewers become suspicious and contact CBP to inquire 
about the shipment's arrival status. By this time, an unscrupulous 
importer could have distributed the shipment's contents into U.S. 
commerce without FDA's approval. As we reported, if CBP communicated 
time-of-arrival information directly to OASIS, then FDA would be able 
to quickly identify shipments that are transported into the United 
States without agency notification and arrange to examine them before 
they are distributed to U.S. markets. Since our report was issued in 
September 2009, CBP told us that it had modified its software to 
notify FDA of a shipment's time of arrival. However, we have not 
reviewed the effectiveness of these modifications. We are still 
waiting to see whether CBP has an agreement regarding time of arrival 
modifications for FSIS. 

FDA Does Not Always Share Product Distribution Information During a 
Recall: 

One key issue of concern, according to officials we spoke with from 
several states, is that FDA does not always share with states certain 
distribution-related information, such as a recalling firm's product 
distribution lists, which impedes the states' efforts to quickly 
remove contaminated products from grocery stores and warehouses. 
According to one state official, because FDA does not provide this 
information, the state has to spend time tracking it down on its own. 
Public health may be at risk during the time it takes for the states 
to independently track distribution information when a product is 
found to be contaminated. FDA told us that it usually considers such 
information to be confidential commercial information, the disclosure 
of which is subject to statutory restrictions, such as the Trade 
Secrets Act. However, FDA's regulations allow for sharing of 
confidential commercial information with state and local government 
officials if, for example, 

* the state has provided a written statement that it has the authority 
to protect the information from public disclosure and that it will not 
further disclose the information without FDA's permission, and FDA has 
determined that disclosure would be in the interest of public health, 
if such sharing is necessary to effectuate a recall, or: 

* the information is shared only with state and local officials who 
are duly commissioned to conduct examinations or investigations under 
the Federal Food, Drug, and Cosmetic Act. In certain circumstances, 
FDA may also seek a firm's consent to disclose its market distribution 
information. 

Statutory Authorities We Identified Could Help FDA Oversee Food Safety: 

In our past work, we have pointed out that mandatory recall--the 
authority to require a food company to recall a contaminated product-- 
would help ensure that unsafe food does not remain in the food supply. 
We also reported that FDA should strengthen its oversight of food 
ingredients determined to be generally recognized as safe for their 
intended use and to seek the authority if the agency deems necessary. 
Likewise, we reported that FDA has identified a need for explicit 
authority from the Congress to issue regulations to require preventive 
measures by firms producing foods that have been associated with 
repeated instances of serious health problems or death. 

FDA Lacks Mandatory Recall Authority: 

We have reported that food recalls are largely voluntary; federal 
agencies responsible for food safety, including FDA, have no authority 
to compel companies to recall contaminated foods, with the exception 
of FDA's authority to require a recall for infant formula.[Footnote 9] 
FDA does have authority, through the courts, to seize, condemn, and 
destroy adulterated or misbranded food under its jurisdiction and to 
disseminate information about foods that are believed to present a 
danger to public health. However, government agencies that regulate 
the safety of other products, such as toys and automobile tires, have 
recall authority not available to FDA for food and have had to use 
their authority to ensure that recalls were conducted when companies 
did not cooperate. We have noted that limitations in the FDA's food 
recall authorities heighten the risk that unsafe food will remain in 
the food supply and have proposed that the Congress consider giving 
FDA similar authorities. H.R. 2749 authorizes the Secretary of Health 
and Human Services to request that a person recall an article of food 
if the Secretary has reason to believe it is adulterated, misbranded, 
or otherwise in violation of the Federal Food, Drug, and Cosmetic Act; 
and to require a person to cease distribution if the Secretary has 
reason to believe the article of food "may cause serious adverse 
health consequences or death to humans or animals." It also requires 
the Secretary to order a recall of such an article of food if the 
Secretary determines (after an informal hearing opportunity) it is 
necessary. Finally, it authorizes the Secretary to proceed directly to 
a mandatory recall order if the Secretary has credible evidence that 
an article of food subject to an order to cease distribution presents 
an imminent threat of serious adverse health consequences or death to 
humans or animals. As our previous work has shown, mandatory recall 
authority would allow FDA to ensure that unsafe food does not remain 
in the food supply. 

FDA Has Limited Oversight of Food Ingredients Determined to be 
Generally Recognized as Safe: 

We have reported that FDA should strengthen its oversight of food 
ingredients determined to be generally recognized as safe (GRAS) for 
their intended use.[Footnote 10] Manufacturers add these substances-- 
hundreds of spices and artificial flavors, emulsifiers and binders, 
vitamins and minerals, and preservatives--to enhance a food's taste, 
texture, nutritional content, or shelf life. Currently, companies may 
conclude a substance is GRAS without FDA's approval or knowledge. We 
reported that FDA only reviews those GRAS determinations that 
companies submit to the agency's voluntary notification program. The 
agency generally does not have information about other GRAS 
determinations companies have made because companies are not required 
to inform FDA of them. Among other things, we recommended to FDA that 
it develop a strategy to require any company that conducts a GRAS 
determination to provide the agency with basic information about this 
determination, and to incorporate such information into its public Web 
site. We also reported that FDA is not systematically ensuring the 
continued safety of current GRAS substances. According to FDA 
regulations, the GRAS status of a substance must be reconsidered as 
new scientific information emerges, but the agency has not 
systematically reconsidered GRAS substances since the 1980s. Rather, 
FDA officials said, they keep up with new developments in the 
scientific literature and, on a case-by-case basis, information 
brought to the agency's attention could prompt them to reconsider the 
safety of a GRAS substance. We recommended that FDA develop a strategy 
to conduct reconsiderations of the safety of GRAS substances in a more 
systematic manner. We also recommended that, if FDA determines that it 
does not have the authority to implement one or more of our 
recommendations, the agency should seek the authority from Congress. 
FDA generally agreed with the report's findings and recommendations. 
In addition, we reported that FDA has taken steps to make information 
about its GRAS notification program available to the public by posting 
its inventory of all GRAS notices FDA has received on its Web site. By 
placing information about the GRAS notice and its response on its Web 
site, FDA enhances the ability of the Congress, stakeholders, and the 
general public to be better informed about GRAS substances. H.R. 2749 
contains provisions on GRAS substances, including a requirement that 
the Secretary post on FDA's Web site information about GRAS notices 
submitted to FDA within 60 days of receipt of the notice. 

FDA Lacks Explicit Authority to Issue Regulations Requiring Food 
Producing Firms to Institute Preventive Measures: 

We have also reported that FDA should strengthen its oversight of 
fresh produce.[Footnote 11] For example, we noted that FDA has 
identified a need for explicit authority from the Congress to issue 
regulations requiring preventive controls (risk-based safety 
regulations) by firms producing foods that have been associated with 
repeated instances of serious health problems or death. FDA already 
has preventive regulations for seafood and juice, which require firms 
to analyze safety hazards and implement plans to address those 
hazards. According to FDA, such authority would strengthen the 
agency's ability to implement risk-based processes to reduce illnesses 
from high-risk foods. FDA officials told us that issuing preventive 
regulations may be one of the most important things they can do to 
enhance their oversight of fresh produce. We therefore recommended 
that the Commissioner of FDA seek authority from the Congress to make 
explicit FDA's authority to adopt preventive controls for high-risk 
foods. FDA agreed with this recommendation and has sought authority to 
issue additional preventive controls for high-risk foods. Furthermore, 
H.R. 2749 requires FDA to create preventive controls for produce and 
certain raw agricultural commodities. Such measures could help the 
agency reduce illnesses from these high-risk foods. 

In conclusion, food imports from around the world constitute a 
substantial and increasing volume of imported foods. Our work has 
shown that FDA could strengthen its oversight of imported food by 
improving its enforcement, such as by assessing civil penalties and 
providing unique identification numbers to firms. Additional statutory 
authorities, such as mandatory recall authority, could also help FDA 
oversee food safety. FDA generally agreed with our recommendations and 
has some taken actions to address them. 

Mr. Chairman, this concludes my statement. I would be pleased to 
answer any questions that you or other members of this subcommittee 
may have. 

Contact and Staff Acknowledgments: 

For further information about this testimony, please contact Lisa 
Shames at (202) 512-3841 or shamesl@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this statement. 

Key contributors to this statement were José Alfredo Gómez, Assistant 
Director; Kevin Bray; Candace Carpenter; Jeff Jensen; Anne Johnson; 
Carol Herrnstadt Shulman; Nico Sloss; and Rebecca Yurman. 

[End of section] 

Appendix I: GAO-09-873 (Food Imports): 

Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

September 2009: 

Food Safety: 

Agencies Need to Address Gaps in Enforcement and Collaboration to 
Enhance Safety of Imported Food: 

GAO-09-873: 

GAO Highlights: 

Highlights of GAO-09-873, a report to congressional committees. 

Why GAO Did This Study: 

Imported food makes up a substantial and growing portion of the U.S. 
food supply. To ensure imported food safety, federal agencies must 
focus their resources on high risk foods and coordinate efforts. 

In this context, GAO was asked to (1) assess how Customs and Border 
Protection (CBP), the Food and Drug Administration (FDA), and the U.S. 
Department of Agriculture’s (USDA’s) Food Safety and Inspection Service 
(FSIS) are addressing challenges in overseeing the safety of imported 
food; (2) assess how FDA leverages resources by working with other 
entities, such as state and foreign governments; and (3) determine how 
FDA is using its Predictive Risk-Based Evaluation for Dynamic Import 
Compliance Targeting (PREDICT) system to oversee imported food safety. 
GAO analyzed CBP, FDA, and FSIS procedures, reports, and regulations 
and interviewed agency officials and key stakeholders. 

What GAO Found: 

CBP, FDA, and FSIS have taken steps to address challenges in ensuring 
the safety of the increasing volume of imported food. For example, CBP 
maintains the system that importers use to provide information to FDA 
on food shipments; FDA electronically reviews food imports and inspects 
some foreign food production facilities to prevent violative food from 
reaching U.S. shores; and FSIS employs an equivalency system that 
requires countries to demonstrate that their food safety systems 
provide the same level of protection as the U.S. system. However, gaps 
in enforcement and collaboration undermine these efforts. First, CBP’s 
computer system does not currently notify FDA or FSIS when imported 
food shipments arrive at U.S. ports, although efforts are underway to 
provide this information to FDA for air and truck shipments. This lack 
of communication may potentially increase the risk that unsafe food 
could enter U.S. commerce without FDA review, particularly at truck 
ports. Second, FDA has limited authority to ensure importers’ 
compliance with its regulations. Third, CBP and FDA do not identify 
importers with a unique number; as a result, FDA cannot always target 
food shipments originating from high risk importers. Finally, CBP faces 
challenges in managing in-bond shipments—those that move within the 
United States without formally entering U.S. commerce—and such 
shipments possibly could be diverted into commerce. 

FDA generally collaborates with select states and foreign governments 
on imported food safety. FDA has entered into a contract, several 
cooperative agreements, and informal partnerships for imported food 
with certain states, and some state officials told GAO that they would 
like to collaborate further with FDA on food imports. However, citing 
legal restrictions, FDA does not fully share certain information, such 
as product distribution lists, with states during a recall. This 
impedes states’ efforts to quickly remove contaminated products from 
grocery stores and warehouses. FSIS has begun to make available to the 
public a list of retail establishments that have likely received food 
products that are subject to a serious recall. FDA is also expanding 
efforts to coordinate with other countries. In particular, through its 
Beyond Our Borders initiative, FDA intends to station investigators and 
technical experts in China, Europe, and India, to provide technical 
assistance and gather information about food manufacturing practices to 
improve risk-based screening at U.S. ports. 

According to FDA, PREDICT will analyze food shipments using criteria 
that include a product’s inherent food safety risk and the importer’s 
violative history, among other things, to estimate each shipment’s 
risk. A 2007 pilot test of PREDICT indicated that the system improved 
FDA’s ability to identify products it considers to be high risk while 
allowing a greater percentage of products it considers low risk to 
enter U.S. commerce without a manual review. However, FDA has not yet 
developed a plan to measure the system’s performance, and GAO 
previously identified shortcomings in FDA’s information technology 
modernization efforts. FDA plans to begin deploying PREDICT at all 
ports and for all FDA-regulated products in September 2009. 

What GAO Recommends: 

GAO recommends, among other things, that FDA seek authority from the 
Congress to assess civil penalties on firms and persons who violate FDA 
laws, and that the FDA Commissioner explore ways to improve the agency’
s ability to identify foreign firms with a unique identifier. CBP and 
FDA generally agreed with our recommendations. FSIS provided technical 
comments only. 

View [hyperlink, http://www.gao.gov/products/GAO-09-873] or key 
components. For more information, contact Lisa Shames at (202) 512-3841 
or shamesl@gao.gov. 

[End of section] 

Appendix II: GAO-07-785T (High-Risk Designation): 

Testimony: 

Before the Subcommittee on Oversight and Investigations, Committee on 
Energy and Commerce, House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 9:30 a.m. EDT: 
Tuesday, April 24, 2007: 

Federal Oversight of Food Safety: 

High-Risk Designation Can Bring Attention to Limitations in the 
Government's Food Recall Programs: 

Statement of Lisa Shames, Acting Director: 
Natural Resources and Environment: 

GAO-07-785T: 

GAO Highlights: 

Highlights of GAO-07-785T, a testimony before the Subcommittee on 
Oversight and Investigations, Committee on Energy and Commerce, House 
of Representatives 

Why GAO Did This Study: 

Each year, about 76 million people contract a foodborne illness in the 
United States; about 325,000 require hospitalization; and about 5,000 
die. The outbreaks of E. coli in spinach and Salmonella in peanut 
butter, along with contamination in pet food, have highlighted the 
risks posed by accidental food contamination. The attacks of September 
11, 2001, heightened awareness that the food supply could also be 
vulnerable to deliberate contamination. This testimony focuses on the 
(1) role that GAO’s high-risk series can play in raising the priority 
and visibility of the need to transform federal oversight of food 
safety, (2) fragmented nature of federal oversight of food safety, and 
(3) limitations in federal food recall programs. 

What GAO Found: 

GAO’s High-Risk Series is intended to raise the priority and visibility 
of government programs that are in need of broad-based transformation 
to achieve greater economy, efficiency, effectiveness, accountability, 
and sustainability. These reports also help Congress and the executive 
branch carry out their responsibilities while improving the 
government’s performance and enhancing its accountability for the 
benefit of the American people. In January 2007, as part of our regular 
update of this series for each new Congress, GAO designated the federal 
oversight of food safety as a high-risk area for the first time. 

We designated federal oversight of food safety as a high-risk area 
because of the need to transform this system to reduce risks to public 
health as well as the economy. While this nation enjoys a plentiful and 
varied food supply that is generally considered to be safe, the federal 
oversight of food safety is fragmented, with 15 agencies collectively 
administering at least 30 laws related to food safety. The two primary 
agencies are the U.S. Department of Agriculture (USDA), which is 
responsible for the safety of meat, poultry, and processed egg 
products, and the Food and Drug Administration (FDA), which is 
responsible for virtually all other food. We have identified examples 
where the federal government’s resources and enforcement activities can 
better align with the risks of food contamination. For example, the 
majority of federal expenditures for food safety inspection were 
directed toward USDA’s programs for ensuring the safety of meat, 
poultry, and egg products; however, USDA is responsible for regulating 
only about 20 percent of the food supply. In contrast, FDA, which is 
responsible for regulating about 80 percent of the food supply, 
accounted for only about 24 percent of expenditures. 

Among the reasons we designated federal oversight of food safety as a 
high-risk area is that limitations in the federal government’s food 
recalls heighten the risk that unsafe food will remain in the food 
supply and ultimately be consumed. Food recalls are voluntary, and 
federal agencies responsible for food safety have no authority to 
compel companies to carry out recalls—with the exception of FDA’s 
authority to require a recall for infant formula. USDA and FDA provided 
guidance for companies to carry out voluntary recalls. We have reported 
that USDA and FDA could do a better job carrying out their food recall 
programs so they can quickly remove potentially unsafe food from the 
marketplace. At the time of our review, these agencies did not know how 
promptly and completely companies were carrying out recalls, did not 
promptly verify that recalls had reached all segments of the 
distribution chain, and used procedures that may not have been 
effective to alert consumers to a recall. 

What GAO Recommends: 

While many of GAO’s recommendations to promote the safety of the 
nation’s food supply have been acted upon, others have not yet been 
addressed. For example, GAO recommended that the executive branch 
reconvene the President’s Council on Food Safety to facilitate 
interagency coordination. GAO also proposed that Congress enact 
comprehensive, uniform, and risk-based food safety legislation; analyze 
alternative organizational food safety structures; and consider 
legislation giving agencies authority to order food recalls. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-785T]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Lisa Shames at (202) 512-
3841 or ShamesL@gao.gov. 

[End of section] 

Appendix III: GAO-10-246 (GRAS): 

Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

February 2010: 

Food Safety: 

FDA Should Strengthen Its Oversight of Food Ingredients Determined to 
Be Generally Recognized as Safe (GRAS): 

GAO-10-246: 

GAO Highlights: 

Highlights of GAO-10-246, a report to congressional requesters. 

Why GAO Did This Study: 

The Food and Drug Administration (FDA), which is responsible for 
ensuring the safety of most of the U.S. food supply, is not required 
to review substances, such as spices and preservatives, added to food 
that are generally recognized as safe (GRAS) for their intended use. 
Currently, companies may determine a substance is GRAS without FDA’s 
approval or knowledge. However, a few substances previously considered 
GRAS have later been banned; and concerns have been raised about the 
safety of other GRAS substances, including those containing engineered 
nanomaterials, materials manufactured at a tiny scale to take 
advantage of novel properties. GAO was asked to review the extent to 
which (1) FDA’s oversight of new GRAS determinations helps ensure the 
safety of these substances, (2) FDA ensures the continued safety of 
current GRAS substances, and (3) FDA’s approach to regulating 
engineered nanomaterials in GRAS substances helps ensure the safety of 
the food supply. GAO reviewed FDA data on GRAS substances and 
interviewed a range of stakeholders, among other things. 

What GAO Found: 

FDA’s oversight process does not help ensure the safety of all new 
GRAS determinations. FDA only reviews those GRAS determinations that 
companies submit to the agency’s voluntary notification program—the 
agency generally does not have information about other GRAS 
determinations companies have made because companies are not required 
to inform FDA of them. Furthermore, FDA has not taken certain steps 
that could help ensure the safety of GRAS determinations, particularly 
those about which the agency has not been notified. FDA has not issued 
guidance to companies on how to document their GRAS determinations or 
monitored companies to ensure that they have conducted GRAS 
determinations appropriately. Lastly, FDA has yet to issue a final 
regulation for its 1997 proposed rule that sets forth the framework 
and criteria for the voluntary notification program, potentially 
detracting from the program’s credibility. 

FDA is not systematically ensuring the continued safety of current 
GRAS substances. While, according to FDA regulations, the GRAS status 
of a substance must be reconsidered as new scientific information 
emerges, the agency has not systematically reconsidered GRAS 
substances since the 1980s. FDA officials said they keep up with new 
developments in the scientific literature and, on a case-by-case 
basis, information brought to the agency’s attention could prompt them 
to reconsider the safety of a GRAS substance. However, FDA has largely 
not responded to concerns about GRAS substances, such as salt and the 
trans fats in partially hydrogenated vegetable oils, that individuals 
and consumer groups have raised through 11 citizen petitions submitted 
to the agency between 2004 and 2008. In fact, FDA has decided on the 
validity of these concerns in only 1 of 11 cases. In addition, FDA 
does not know to what extent, or even whether, companies track 
evolving scientific information about their GRAS substances. 

FDA’s approach to regulating nanotechnology allows engineered 
nanomaterials to enter the food supply as GRAS substances without 
FDA’s knowledge. While some uses of engineered nanomaterials have the 
potential to help ensure food safety, uncertainties remain about how 
to determine their safety in food. After reviewing the uncertainties 
associated with the safety of engineered nanomaterials, FDA has 
decided that it does not need additional authority to regulate 
products containing such materials. Rather, FDA encourages, but does 
not require, companies considering using engineered nanomaterials in 
food to consult with the agency regarding whether such substances 
might be GRAS. Because GRAS notification is voluntary and companies 
are not required to identify nanomaterials in their GRAS substances, 
FDA has no way of knowing the full extent to which engineered 
nanomaterials have entered the U.S. food supply as part of GRAS 
substances. In contrast to FDA’s approach, all food ingredients that 
incorporate engineered nanomaterials must be submitted to regulators 
in Canada and the European Union before they can be marketed. 

What GAO Recommends: 

GAO recommends that FDA take steps to better ensure the safety of GRAS 
substances, including developing a strategy to require any company 
that conducts a GRAS determination to provide FDA with basic 
information about it. FDA generally agreed, while raising concerns 
about certain aspects of several of the recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-10-246] or key 
components. For more information, contact Lisa Shames at (202) 512-
3841 or shamesl@gao.gov. 

[End of section] 

Appendix IV: GAO-08-1047 (Fresh Produce): 

Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

September 2008: 

Food Safety: 

Improvements Needed in FDA Oversight of Fresh Produce: 

GAO-08-1047: 

GAO Highlights: 

Highlights of GAO-08-1047, a report to congressional requesters. 

Why GAO Did This Study: 

In recent years, both domestic and imported produce have been linked to 
reported outbreaks of foodborne illness. Contamination in produce is of 
particular concern because produce is often consumed raw. The Food and 
Drug Administration (FDA) has primary responsibility for ensuring the 
safety of both domestic and imported fresh produce. GAO was asked to 
examine (1) the resources FDA has spent on fresh produce safety and how 
it has allocated those resources, (2) the effectiveness of FDA’s 
actions to oversee fresh produce safety, and (3) the extent to which 
FDA’s planned actions to enhance fresh produce oversight address 
identified challenges. For this review, GAO analyzed FDA spending data 
and estimates and FDA activities data, reviewed FDA plans, and 
interviewed FDA officials and others. 

What GAO Found: 

While FDA has considered fresh produce safety a priority for many 
years, resource constraints and other work—including counterterrorism 
efforts and unplanned events such as foodborne illness outbreaks—have 
caused FDA to delay key produce safety activities. FDA has no formal 
program devoted exclusively to fresh produce and has not consistently 
and reliably tracked its fresh produce spending. Based on FDA 
estimates, FDA spent at least $20 million and 130 staff years on fresh 
produce in fiscal year 2007—or about 3 percent of its food safety 
dollars and 4 percent of its food safety staff years. In addition, FDA 
had few staff dedicated solely to fresh produce safety. Moreover, FDA 
acknowledged that it has not yet been able to conduct certain fresh 
produce work crucial to understanding the incidence of contamination of 
produce by pathogens such as E. coli O157:H7 or Salmonella, because it 
has lacked the resources to either fund its extramural research grant 
program or perform some critical research internally. Finally, FDA 
delayed issuing final fresh-cut produce guidance at least 6 years 
because it had to shift staff to counterterrorism and outbreak 
investigation work. 

FDA has provided limited oversight of domestic and imported fresh 
produce. For example, while FDA has issued guidance for industry on 
recommended practices for reducing the risk of contamination during the 
processing of fresh-cut produce, it has not issued regulations 
requiring firms to take action to prevent contamination, even though 
some industry groups would like it to do so. FDA’s intervention efforts 
have also been limited. Specifically, domestic fresh produce firms were 
inspected infrequently. Furthermore, FDA examined less than 1 percent 
of the 7.6 million fresh produce lines imported from fiscal years 2002 
through 2007. Finally, FDA has improved some elements of its emergency 
response by, for example, partnering with California on outbreak 
investigations. However, it faces challenges in tracing an outbreak 
involving fresh produce back to its source because produce is highly 
perishable and may no longer be available for testing. Also, when 
product is available, it may be unlabeled or mixed in packages 
containing products from multiple sources. 

FDA has proposed changes through its Food Protection Plan that could 
significantly enhance its fresh produce oversight. However, the agency 
is still in the planning stages for several enhancements and has not 
provided specific information on strategies and resources, making it 
difficult to assess the likelihood of success. To help prevent 
contamination, FDA plans to update its existing guidance on good 
agricultural practices and regulations on current good manufacturing 
practice for food, and has identified a need for explicit authority to 
issue preventive safety regulations for high-risk foods and enhanced 
access to records. To enhance intervention efforts, FDA plans to use 
more rigorous risk-based criteria to target domestic firm inspections 
and is testing a new import screening software tool. To improve 
response efforts, FDA is examining best practices for tracing 
contaminated foods to their source. 

What GAO Recommends: 

GAO recommends, among other things, that the Commissioner of FDA update 
its guidance on good agricultural practices and its regulations on 
current good manufacturing practice for food, and seek explicit 
authority from the Congress to adopt preventive controls for high-risk 
foods and authority for enhanced access to records. 

FDA agreed with most of GAO’s recommendations but believed that it had 
sought authority from the Congress. FDA should continue to take steps 
to obtain these authorities so that it can conduct its oversight 
responsibilities. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-1047]. For more 
information, contact Lisa Shames at (202) 512-3841 or shamesl@gao.gov. 

[End of section] 

Footnotes: 

[1] GAO, Food Safety: Federal Efforts to Ensure the Safety of Imported 
Foods Are Inconsistent and Unreliable, [hyperlink, 
http://www.gao.gov/products/GAO/RCED-98-103] (Washington, D.C.: Apr. 
30, 1998). 

[2] GAO, Food Safety: Agencies Need to Address Gaps in Enforcement and 
Collaboration to Enhance Safety of Imported Food, [hyperlink, 
http://www.gao.gov/products/GAO-09-873] (Washington, D.C.: Sept. 15, 
2009). 

[3] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-07-310] (Washington, D.C.: January 
2007). 

[4] H.R. 2749, 111th Cong. See also S. 510, 111th Cong. 

[5] FDA was not able to provide 2009 inspection data in time for this 
statement, according to FDA officials. 

[6] This category includes all nonlaboratory activities, such as field 
examinations and tests, import sample collections, import label exams, 
Prior Notice Center security reviews, import entry reviews, and other 
import investigations, as well as associated infrastructure support. 

[7] GAO, Federal Oversight of Food Safety: FDA has Provided Few 
Details on the Resources and Strategies Needed to Implement Its Food 
Protection Plan, [hyperlink, http://www.gao.gov/products/GAO-08-909T] 
(Washington, D.C.: June 12, 2008). 

[8] Import alerts communicate information and policy to FDA field 
staff. Usually, they provide information that products covered by the 
alert are subject to detention. If detained, the importer is provided 
an opportunity to prove that the imported product is compliant, such 
as by providing FDA with the results of third-party laboratory 
analysis of the product. 

[9] GAO, Food Safety: USDA and FDA Need to Better Ensure Prompt and 
Complete Recalls of Potentially Unsafe Food, [hyperlink, 
http://www.gao.gov/products/GAO-05-51] (Washington, D.C.: Oct. 6, 
2004) and GAO, Federal Oversight of Food Safety: High Risk Designation 
Can Bring Attention to Limitations in the Federal Government's Food 
Recall Programs, [hyperlink, http://www.gao.gov/products/GAO-07-785T] 
(Washington, D.C.: Apr. 24, 2007) 

[10] GAO, Food Safety: FDA Should Strengthen Its Oversight of Food 
Ingredients Determined to Be Generally Recognized as Safe (GRAS), 
[hyperlink, http://www.gao.gov/products/GAO-10-246] (Washington, D.C.: 
Feb. 3, 2010). 

[11] GAO, Food Safety: Improvements Needed in FDA Oversight of Fresh 
Produce, [hyperlink, http://www.gao.gov/products/GAO-08-1047] 
(Washington, D.C.: Sept. 26, 2008). 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 
[hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 
information. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: