A diverse coalition of food policy stakeholders representing consumers, industry, and state and local regulators reiterated its call for significant structural reform of FDA’s foods program ahead of the agency’s anticipated January 31 announcement on how it intends to implement recommendations from a report by the Reagan-Udall Foundation.
The coalition commended the report when it was released in December last year, noting that the expert panel accurately captured problems related to the structure, leadership, culture, transparency, and accountability within the FDA’s foods program. Importantly, the report reinforces the coalition’s call for an expert, empowered deputy commissioner for food who could unify the program and elevate its stature within FDA.
The coalition reiterated the need for bold reforms that incorporate the following elements:
Full Unification of the Human and Animal Foods Program under an Expert Leader
Establishing an empowered deputy commissioner position with direct line authority over all components of the FDA’s human and animal foods program is foundational to its operational success and essential culture change. In practice, this means unifying into a cohesive organizational structure — headed by the deputy commissioner — the Center for Food Safety and Applied Nutrition (CFSAN), the food and feed-related activities of the Center for Veterinary Medicine (CVM), and all the food-related components of the Office of Regulatory Affairs (ORA), including inspection and compliance, food-related laboratories, import oversight, state partnerships, training, and information technology.
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Candidates for the empowered deputy commissioner role should possess the attributes recommended in the report, including expertise and knowledge in food safety and/or nutrition; demonstrated strong leadership, management, and communications skills; and the ability to lead and make timely decisions in a complex regulatory environment.
An Elevated, More Prominent Foods Program
The empowered deputy commissioner should be viewed internally and externally as the commissioner’s surrogate for all FDA food activities and as the agency’s leader, spokesperson, and decision-maker for the foods program.
The position should have the authority and stand within FDA and HHS to represent FDA on foods program issues and funding before Congress, within the executive branch, as well as with stakeholders and foreign partners.
Cultural Change and Modernization
Reframing the culture within the foods program is a prerequisite to the success of its structural reform. The currently fragmented structure and lack of central authority and leadership contribute to a culture of silos, indecision, inaction, and delay in implementing the prevention mindset called for in the Food Safety Modernization Act (FSMA).
The deputy commissioner should also be mandated to modernize the program to facilitate transparency, timeliness, and meaningful stakeholder engagement as part of its decision-making process.
The FDA’s foods program is a distinctive part of the agency and deserves a structure and leadership model appropriately customized to fit its mission. We look forward to FDA Commissioner Califf’s pending announcement and remain committed to working with the agency as changes are implemented.
The coalition is comprised of the following organizations:
American Frozen Food Institute
Association of Food and Drug Officials
Consumer Brands Association
Environmental Working Group
International Fresh Produce Association
STOP Foodborne Illness