Data Systems: Sustainable Solutions for Food Safety
Efforts aimed at improving food safety point to the role data plays in addressing foodborne disease (FBDs). Data can support development efforts to improve capacity in low- and middle-income countries (LMICs) to promote safe food exports, and data can measure the impact of such efforts on consumer health and even on the impact on LMIC producer and processor livelihoods.
Reduced FBD is a public good and an important part of consumer trust. FBDs are a significant source of morbidity and mortality throughout the world and closely linked to poverty, as illustrated by the Foodborne Disease Burden Epidemiology Reference Group (FERG). Regulatory agencies tasked with food safety in LMICs usually have food safety challenges such as:
- Poor infrastructure they must work around.
- Unreliable electricity that jeopardizes the integrity of cold chains.
- Non-functioning laboratories that undermine the testing and monitoring of food.
- Weak public capacity that impedes the ability to address problems.
Without assistance and stronger capacity, the FBD situation is bound to get worse in these countries, with global implications. Increased global attention on improving food safety needs to be accompanied by effective training and capacity building efforts. But figuring out what is effective calls for actions aimed at measuring impact. That is the direction of the U.S. Food Safety Modernization Act (FSMA). Under FSMA, Congress mandated the Food and Drug Administration (FDA) to both train domestic and foreign suppliers and measure the impact of such training.
Two things happen when the impact of training and capacity building on food safety is measured: 1) It can justify and galvanize future efforts; and 2) It can identify future improvements. This benefits everyone: consumers, producers, distributors and regulators. Data lets stakeholders see what a difference it makes, and data informs new actions. Figure A illustrates how this works.
Training may or may not be effective, and it is not effective by itself. A number of other things need to happen to achieve long-term impacts, as shown by the "chain of impacts" in Figure B. Data collection has a cost, so it is important to check what data already exists and what additional data is needed.
Collective attention to capacity building efforts by public and private sectors globally starts with identifying what data they already have and agreeing on what types of indicators are missing and need to be tracked to measure impact.
The good news: There already is some existing data.
Public sector data currently exists on a smattering of platforms, including FDA refusal and inspection data, Department of Commerce trade data and Centers for Disease Control and Prevention (CDC) trace-back data. However, this data is limited, less than comprehensive and not well targeted to measure the impact of food safety capacity building. Existing secondary data by the public sector is usually collected for specific purposes other than measuring the impact of food safety capacity building. Its format may not correlate to specific food safety capacity building efforts.
The other good news: The private sector — producers, manufacturers, suppliers and sellers — also collects data
Companies collect information to help manage their enterprises both for internal and external purposes. Some of that data is reported to the government, but much of it pertains to internal compliance and control measures. This includes data around the number of test results within acceptable values, audit scores, "risk" scores for plants and suppliers, external certifications of facilities and regulatory violations.
If private sector data could be made available and aggregated, with trend information depicted over time, it could prove very useful for evaluating the impact of food safety capacity building
Data sharing would allow us to improve how capacity building efforts are delivered, targeted and funded. We can figure out the weak links on a macro scale by comparing regions. Weak links on micro scales can be identified by mapping the quality of training design and delivery in a way that provides value to both public and private sectors.
Sharing data is not without challenges. Data often belongs to different organizations or groups and can be considered quite valuable. In particular, private sector data belongs to individual private companies; it is usually proprietary. To share data, the private sector needs a good justification, a suitable plan and risk mitigation measures to get the go-ahead from their CEOs to share.
To this we say: Let’s make the case. Let’s identify the challenges and tackle them, together. Since FSMA was developed as a market-driven regulatory framework, the public-private dynamic is already built in. Public-private partnership makes sense because food safety is not optional; either the market steps up or regulations follow.
And private-private partnership also makes sense because food safety is not about competition; everyone is interested in a preventive approach that saves lives, promotes trust and contributes to the public good. To make this work, data that is aggregated and leveraged to inform future capacity building efforts, as well as regulatory training requirements, can follow two baseline principles:
- Data sharing is voluntary.
- Submitted data is open.
Sharing data is essential for training, environmental monitoring, managing false positives, compliance and best practices. It is part of the approach recommended globally to food and drug regulatory agencies in 2020 by the National Academy of Medicine’s "Stronger Food and Drug Regulatory Systems Abroad":
- To participate in research, data sharing, technology adoption and training activities with international partners.
- To grow capacity to assess the health and economic impact of regulations and use that information to inform action to protect public health.
To address the common need to understand the impact of food safety capacity building efforts, and to enable compliance with regulatory requirements, now is the ideal time to build a platform to share existing data on the impact of food safety capacity building efforts. Rather than work in silos, now is the time to establish a public-private partnership to collect additional agreed upon data. This can result in the virtuous cycle shown in Figure C.
We propose to start the establishment of a public-private partnership by:
- Holding listening sessions with stakeholders to identify concerns and opportunities; this is currently planned for June 2021.
- Forming subgroups with specialists from public and private sectors to develop solutions to concerns so as to facilitate data sharing.
If you have ideas, if you have data, if you want to learn more about improving food safety capacity building or if you simply want to improve food safety, please join our conversation. You can also take a look at the full white paper.
Clare Narrod, Ph.D., is the director of University of Maryland, Joint Institute for Food Safety and Applied Nutrition (JIFSAN) Risk Analysis Training and Monitoring and Evaluation Programs.
Andrea E. Stumpf, J.D., is a lawyer, practitioner and author with over 30 years of experience in both the private and public international sectors. She specializes in the structure, design and sustainability of international partnerships and has written two how-to guides.
Wendelyn Jones, Ph.D., is executive director of the Institute for the Advancement of Food and Nutrition Sciences (IAFNS). Dr. Jones has a strong background in the food, agriculture and chemical industries, with over 20 years of global experience in industry and government. She applies her PhD in life sciences to extend IAFNS’ contribution to, and impact within, diverse scientific and health communities.