Academy Comments to FDA re Food Safety Health Diet Survey

September 13, 2018

Office of Information and Regulatory Affairs,
OMB
Attn: FDA Desk Officer

Re: Info Collection: Food Safety, Health, and Diet Survey (OMB control number 0910-0345)

Dear FDA Desk Officer,

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food and Drug Administration (FDA) at the United States Department of Health and Human Services (HHS) related to its August 14, 2018 information collection "Food Safety, Health, and Diet Survey." Representing more than 104,000 registered dietitian nutritionists (RDNs),1 nutrition and dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of nutrition and dietetic professionals in the United States. Our members provide various medical and professional services, including nutrition education for the public and supervision of food safety practices and procedures across multiple settings.

The Academy supports the information collection as a means to further measure consumer understanding and response to the revised Nutrition Facts Panel (NFP), menu labeling, and adequate and effective food safety measures observed at home and elsewhere.

The Academy commends the FDA on stabilizing some foodborne illness outbreak trends.2 However, the Academy also notes the challenges faced by agencies at all levels of government in enforcing food safety regulations. As the American population becomes more ethnically diverse, so does the proportion of small independent ethnic food service facilities, including retail markets and restaurants. Data suggest that these facilities may present increased food safety risks due to language and cultural barriers and infrastructure variability.3 Combined with the aging population and associated potential increases in risk and severity of foodborne illness,4 the result is a perfect storm of theoretically huge impacts to individuals, to the health care and food safety surveillance systems, and to Medicare.5

Accordingly, important specific suggested topics for the survey within the food safety context include:

  1. assessing consumer “thermometer literacy” (including selection, calibration, cleaning and sanitation, storage, and appropriate use of thermometers);
  2. measuring consumer understanding and compliance with recommendations to avoid rinsing raw meat products; and
  3. evaluating consumer ability to recognize and respond appropriately to questionable food safety practices observed in food service and retail establishments.

It is also important that surveys be conducted across diverse populations—particularly low-literacy, non-English speakers of various ethnicities and older populations. As noted above6, these subgroups are likely to be most vulnerable to food safety concerns.

Outside of food safety, the Academy commends FDA on implementation of the new NFP. We encourage the FDA to assess the effectiveness of the NFP by including an assessment of consumer satisfaction, understanding, and trust of the NFP, and whether purchasing behavior was altered as a result. The FDA should also consider surveying consumer ability to understand the Agricultural Marketing Service's proposed labeling system for genetically engineered foods and whether purchasing behaviors may be altered as a result.

The Academy appreciates the opportunity to comment on the proposed information collection for the "Food Safety, Health, and Diet Survey docket. Please contact either Jeanne Blankenship at 312-899-1730 or by email at jblankenship@eatright.org or Mark Rifkin at 202-775-8277 ext. 6011 or by email at mrifkin@eatright.org with any questions or requests for additional information.

Sincerely,

Jeanne Blankenship, MS, RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Mark E. Rifkin, MS, RD, LDN
Manager
Consumer Protection and Regulation
Academy of Nutrition and Dietetics


1 The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation's food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.

2 "Food Safety." Accessed July 25, 2018.

3 Quinlan, JJ. Foodborne Illness Incidence Rates and Food Safety Risks for Populations of Low Socioeconomic Status and Minority Race/Ethnicity: A Review of the Literature. Int. J. Environ. Res. Public Health 2013, 10(8), 3634-3652.

4 "Food Safety for Older Adults." Accessed July 25, 2018.

5 Lucado, J, et al. Infectious Enteritis and Foodborne Illness in the United States, 2010. Statistical Brief #150. Agency for Healthcare Research and Quality. Healthcare Cost and Utilization Project. March 2013.

6 Quinlan JJ. Foodborne illness incidence rates and food safety risks for populations of low socioeconomic status and minority race/ethnicity: a review of the literature. Int J Environ Res Public Health. 2013 Aug 15;10(8):3634-52.