Theres been a bit of breathless reporting on the new Government Accountability Office (GAO) report on what the FDA needs to do to improve oversight of imported seafood. In many cases the headlines replete with buzz words like risks, drug-tainted and harmful arent quite as impactful when you find the recommendations that the FDA be more risk-based and better leverage its resources have actually already been widely addressed in the Food Safety Modernization Act that came out in January. The GAO report recommends sampling based on targeted risk. That not only makes sense but goes to the core of how an effective HACCP system works.

So, keep in mind when reviewing stories like these; Report Faults FDA Over Risks From Imported Seafood, Something’s Fishy With FDA’s Oversight Of Imported Seafood, GAO: Could Drug-Tainted Fish Be Slipping Through the Safety Net?, FDA Told to Improve Oversight of Imported Seafood, Imported Fish Not Tested For Harmful Drug Residues: GAO that despite recommendations for improvement, HACCP is actually a very effective regulatory structure with a long track record of keeping seafood consumers safe.

In fact, a just published review of CDC data shows that there are 17 other food/pathogen combinations that present a risk to consumers before seafood is even mentioned. So, in keeping with that much lauded risk-based approach, the GAO writes about, it is pretty clear that at the outset seafood is not a tremendous food safety risk.

The GAO report certainly illustrates the need to fully fund the FDA. Unfunded mandates have been commonplace at FDA and were just now getting away from those, so to have GAO essentially note that FDA is doing more with less and needs to look to force multipliers like NMFS to bolster its efforts also makes sense.

Inside FDA resource allocation is key and Americans only eat 15.8 lbs of seafood a year so using a focused risk-based approach to regulating seafood is appropriate. It’s important to keep in mind when reading the GAO report that seafood and even just imported seafood is a small snapshot of FDAs regulatory world.

FDAs HACCP system is an internationally recognized system which is, quite frankly, very effective. Theres a fundamental misunderstanding of FDAs system by some who suggest its all about, or should be all about, waiting at the dock to test seafood thats coming in. That’s not how HACCP works. Conversely it seeks to solve the challenges before they become problems at the dock and it does a good job of that. We welcome efforts to confront challenges as far from our boarders as possible and endorse GAOs recommendations.

So, while this report points out things FDA can do better or ways it should enhance the focus of its existing system it doesnt break much new ground or go much further than the issues that are being addressed in the Food Safety Modernization Act. Rather, the report simply says heres how you improve FDAs already existing HACCP system.

Its also important to understand that this report does not conclude imported seafood is unsafe. Reviewing levels of sampling or numbers of tests or comparing regulatory structures is fine and the FDA is, in the end, presented with a list of suggested improvements but such recommendations do not mean the product is unsafe.