According to Professor Timothy Lytton in his article Known Unknowns: Unmeasurable Hazards and the Limits of Risk Regulation : “When known unknowns cause harm, public pressure often leads Congress to mandate that agencies establish specific, science-based thresholds for acceptable risk. In response, regulators, who lack scientific evidence to justify such rules, face a choice: they can either delay the rulemaking process or fabricate a scientific justification.” We face many known unknowns in food safety. That is why it is critical to recognize knowledge gaps and advance science where we can address the remaining uncertainty. We are countering two polarized positions – advocates for robust government intervention vs. unregulated markets – both of which do little to address the effectiveness of regulation and the integrity of private governance. It is time to counter extremes with private-public cooperation and collective learning that can yield better results and support food safety and security.
According to the ERS, all farm production costs for major crops have risen since 2020, with individual cost increases ranging from 2 percent to 78 percent, while the farm share of total food dollar expenditure has been declining (e.g.,14.9 cents in 2022 from 15.2 cents in 2021). The average price of food in the U.S. increased 2.2 percent in the 12 months ending in June, according to the latest inflation data published July 11, 2024, by the U.S. Labor Department’s Bureau of Labor Statistics (BLS). The cost increase is impacted in part by regulatory and buyer demands. Regulatory and buyer demands are meant to ensure the safety and availability of food but can at times be influenced by public pressure created by distorted activism. For instance, based on media reports, it is easy to believe that foodborne illness outbreaks attributed to fresh produce are increasing because the industry is not doing enough to prevent outbreaks. Based on this media-driven premise, demanding new requirements makes sense. However, the media and activists rarely explore or report on other factors affecting food safety, such as weather events, wildlife population explosions, urban encroachment, the enhancement in detection methods in recent years (e.g., the increased use of technologies such as whole genome sequencing), or even the government’s changes to the definition of foodborne outbreaks. When we engage in a reactive approach that tends to add regulatory requirements regardless of whether they will truly enhance the safety of the food supply, we continue to promote an economically unsustainable approach that will likely drive many operations out of business. While public health is a necessary cost, efforts should focus on continuous, measurable improvements and data-driven preventive measures, rather than on reactive regulations that come with high uncertainty and overlook gaps in scientific knowledge.
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