Case study Analysis

Farming down the drain: Unintended consequences of the Food Safety

Modernization Act’s Produce Rule on small and very small farms

Intended consequence
For almost 70 years, system remained same, developing bigger gaps as time changed. FSMA’s
primary goal was to reduce food borne illness rather than dealing with the issues and illness after
it happened.
More effective prevention of food safety issues rather than post-hoc reactions
For 70 years the world reacted to food borne illnesses and the number kept increasing as we
moved forward. To cut the number of deaths due to food borne illness the Congress had to put in
place a system which will prevent food safety issues, hence the implementation of FSMA.
Prevention is better than cure- was the motive behind FSMA.
Included both human and animal food
Since the primary goal of FSA was to prevent human illnesses from food, they couldn’t avoid
but include the pet foods/animal foods. In past there was a salmonella outbreak in humans who
came I contact with contaminated pet food.
Establish science based produce safety standards
Historically, the federal government and states have largely relied on public policy that used to
encourage voluntary strategies for producing safe foods on farms and ranches, through
education, cooperation, and market-based incentive. Tese variation among producers practices
also was a reason to food borne illnesses. To help create a uniform understanding of the law,
FSMA developed training and awareness programs for domestic and foreign producers to clarify
expectations through compliance documents, training programs, and tools.

Include supply chain partners to ensure a more systematic prevention

To prevent food borne illness, food producers and manufacturers had a significant responsibility.
Hence FSMA included Supply chain preventive controls and foreign supplier verification
program in addition to traditional HACCP. All hazards couldn’t be eliminated at final
processing, and everyone in the supply chain in farm to fork needs to be responsible for the food
they make.
Unintended consequences
Confusion and complex gray area exception
Changes in implementation periods, whether the operation constitutes a farm or a facility, and who the buyer is and
where the buyer is located create confusion regarding who qualifies for the exemption. The division and exemption
based on annual income was not the best way to rule out exemptions. more detailed considerations of different types
of businesses must be made
Stifled food innovation
FSMA has a good effect on prevention but negative impact in regards to cost of implementation.
Due to high cost of implementation the new innovators who were from small businesses were
forced to shut down. While making food safe, FSMA reduced the chances of new innovative
products.
Cost and red tape drive farms out of business
Red tape here means exemptions from FSMA rule. Exemptions, created an unintended fear in
consumers mind that exempted business produce unsafe food. And hence even if they were
exempted on basis of profit made, they were forced to enact FSMA to stay in business. When
they cannot handle the cost, many farms were facing shutdowns.
Food supply shortages
Food safety compliances practices, reduced crop yield, groundwater level. While trying to make
all food in the market safe, the natural habitats was disturbed and lead into extinction of certain
wildlife. That extinction in turn caused animal originated food supply shortage. The fertilizers
used for safe produce making, also killed fish, which was another important food source. Killing
natural pathogens making the soil and farm more safe, also reduces productivity because there
were good nutrients which were removed along with harmful organisms.
Negative environmental and human health impact
FSMA required a cleaner environment to reduce food borne illnesses. They were successful in
that but immune related illnesses increased. People got adapted to super clean environment and
immune system weakened without natural nutrients (which was removed during cautious
processing and safe food compliance procedures). People began to increase sensitivity to
allergens and pathogens. Producing safe food reduced the immune power of humans.
How does the 7 major rules of FSMA help prevent food safety issue?
FSMA covers farms that produce raw agricultural commodities or those that can be consumed in
their raw state thus reducing food safety issues and illness from raw commodities. It helps to
minimize or prevent the identified threats and also keep food safe from contamination during
transportation by preventing issues such as failure to properly refrigerate and protect food and
inadequate cleaning of vehicles between loads. FSMA requires manufacturers to check if
imported food has been produced in a manner that meets applicable U.S. safety standards
thus increasing importer accountability on any potentially harmful food that they may be
carrying. It also put in place training and procedures that helps in preventing intentional
adulteration from acts intended to cause wide-scale harm to public health, including acts of
terrorism targeting the food supply, which happened in frozen food industry, Japan in 2013

Could we have prevented food safety issues without the FSMA-

No. We definitely needed a new system that would incorporate and fix all the gaps we had in the
traditional food safety systems. If it was not FSMA it would have had to be something else but
very similar to FSMA. FSMA has identified the key areas in food supply chain which needed to
be escalated as preventive controls and it is helping to avid major food safety issues.
2. In your opinion do you believe the intended consequences outweigh the unintended
consequence in preventing the food safety issues or the unintended consequences
pose a bigger threat to the future of food supply. ½ page. (5 points)

Intended consequences outweigh unintended ones. Unintended consequences in mainly quantity

based items. Quality is important than quantity.

All the unintended consequences can be worked upon without compromising FSMA rules. It
might be difficult, but, just like how FSMA took years to come out with a great plan, if we
continuously work on processes which can solve unintended consequences, we will get there.

Intended consequence includes prevention of deaths due to food borne illness. If death of
humans is prevented, we have more people to work on finding solutions to the unintended
consequences.

Small business can survive with the help of government. Government can provide training to
them and subsidies to get the proper technology and manpower they need for implementing
FSMA. Small farms should be able to use schools for produce testing and low cost technologies.

Stringent rules in processing can be loosened if people are trained on how to properly process
and handle food at home and markets. A big part of food safety issues can be solved in that way.
Also reducing the lab test turnaround time can reduce the recall scope.

Researches on Farming methods if funded effectively will come up with solutions that will
prevent extinctions of wildlife, for example, seasonal cropping. During off seasons and based on
wildlife migrations farming areas can be suitably used according to FSMA rules.