Public health needs should set the pace for codification.
Once a public health driven need is identified, local resources seek solutions, often with supplier partners. Concept prototypes and programs are developed. Costly research is often involved and manufacturers seek patent protection to make this investment worthwhile. This factor looms large as some links in the chain of innovation confuse basic capitalism with greed, slowing the implementation of new ideas.
The Model Food Code and its supporting Conference For Food Protection represent a valuable process to assess the value of innovations designed to protect public health. Innovations commonly show up first in local jurisdictions who are unfortunatley pressured by the FDA not to move faster than the Model Food Code.
Resisting change is a human trait and in this case the status-quo bunker is well armed. "We need more research", "let's form a committee" are two favorites in the arsenal of delay. There is no accountability for the potential suffering or even deaths between the flash of innovation and codification.
Local codifiers have tools like the Variance process and a Letter Of No Objection under which experience can be garnered while controlling risk. Here are some perspectives to consider as food safety professionals prepare for CFP 2018.
- Interview with Dr. David Acheson, former chief of Food Safety Inspection Services (FSIS):
- FSMA's Priority of Prevention:
- CDER & SaniTwice:
- Food Code Flaws Undermine the Handwashing Priority. Impossible goals block progress.:
- The Trickler Vs. SaniTwice:
- Kick the Bucket ... and Reusable Sanitizer Rag:
The inherent limitation in moving the Model Food Code forward faster stems from a foundational conflict. The Code is inspection-based (what is seen in a brief inspection) while innovators work from a science base, defining product and process effectiveness. The innovators also acknowledge behavioral considerations.
The Model Food Code does not prioritize the "when to wash" and thus is not risk-based. It also specifies a single hand wash for all occasions and doesn't recognize process alternatives. The operators make their choices based on their interpretation of risk. Hats off to those early adopter leaders. We look forward to further supporting them, working together in the interests of public health, using all available tools to encourage investment in hand and high-touch surface cleanliness.