February 21, 2017
U.S. Department of Agriculture
Food Safety and Inspection Service
Docket Clerk, Patriots Plaza 3
1400 Independence Avenue SW.
Mailstop 3782, Room 8-163A
Washington, DC 20250-3700
Re: Notice of Request for a New Information Collection: In-Home Food Safety Behaviors and Consumer Education: Annual Observational Study FSIS-(2016-0036)
Dear Sir or Madam,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food Safety Inspection Service (FSIS) at the U.S. Department of Agriculture related to its open docket regarding "Notice of Request for a New Information Collection: In-Home Food Safety Behaviors and Consumer Education: Annual Observational Study (FSIS-2016-0036)," published in the Federal Register on December 20, 2016. Representing over 100,000 registered dietitian nutritionists (RDNs),1 nutrition dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation's health through food and nutrition and to providing medical nutrition therapy (MNT) and nutrition research and counseling to enhance America's food safety.
The Academy strongly supports the proposed behavioral research to include observational studies, which we anticipate "will provide insight into the effect FSIS consumer outreach campaigns have on consumers' food safety behaviors." Our members look forward to utilizing forthcoming research results to enhance members' ongoing efforts to work with clients and patients to improve and protect health through evidence-based food safety messages.
A. Academy of Nutrition and Dietetics’ Commitment to Food Safety
Foodborne illness is preventable, yet the United States experiences significant economic costs, loss of productivity and reduced quality of life as a result of more than 56,000 people per year becoming ill in the U.S. from food safety concerns.2 It is the policy of the Academy that "[r]egistered dietitian nutritionists and nutrition dietetic technicians, registered, are encouraged to participate in policy decisions, program development, and implementation of a food safety culture."4 In addition, "RDNs and NDTRs have unique roles in promoting and establishing food safety cultures when practicing with high-risk populations, which include children younger than age 5 years, seniors aged 65 years or older, pregnant women, and individuals who have compromised immune systems due to health conditions or their treatment, such as diabetes, human immunodeficiency virus/acquired immune deficiency syndrome, kidney failure, and cancer."4
The Academy has long been committed to developing and providing effective and evidence-based food safety messages, and we continue to maintain robust food safety materials for consumers at our website: http://www.eatright.org/resources/homefoodsafety. We recognize that consumers and RDNs obtain food safety information differently and encourage FSIS's research to focus on both these direct and indirect ways in which consumers gain home food safety knowledge.5
B. Enhancing the Quality, Utility, and Clarity of the Information to Be Collected
The proposed new information collection has the potential to expand the ongoing surveys on consumer food safety behaviors conducted by FSIS. Observational studies will extend the work by FDA and by earlier investigators. The data will be useful in developing compelling, actionable food safety messages for consumers. Recognizing we were unable to review the collection instrument, the Academy urges the following:
- Information collected include information on thermometers available personally to the consumer, including the accuracy of the thermometers. We note that using faulty equipment or equipment that has not been calibrated may give a false sense of security.
- Information on "thermometer literacy" be collected.
- Observed behaviors of the consumers include selection of appropriate thermometers, calibration of thermometers, cleaning and sanitation of thermometers, protective storage of thermometers, and appropriate insertion and reading of thermometers.
- Demographics of participants be determined so that they include households inclusive of vulnerable populations.
- Consumers be educated on the use of thermometers to improve safety and the culinary quality of food. We note that cooking to visual endpoints is unpredictable for both.
- Technologies, such as Skype or other interactive technologies, be used to collect information from geographically dispersed participants.
Finally, we suggest FSIS consider other emerging areas of food safety for collection of behavioral data, such as food safety at farmers' markets ; home prepared lunches brought to school (with concerns related to temperatures and cross contamination) and the cleanliness of the re-used lunch box; office food safety; and 'desktop' dining food safety.
The Academy appreciates the opportunity to comment on the data collection related to the information collection “Home Food Safety Behaviors and Consumer Education: Annual Observational Study FSIS,” and we will continue to be at the forefront of home food safety, both by encouraging research of consumer home food safety behaviors and by ensuring our members are proactive in discussing safe food handling practices with consumers, clients, and patients. Please contact either Jeanne Blankenship at 312-899-1730 or by email at firstname.lastname@example.org or Pepin Tuma at 202-775-8277 ext. 6001 or by email at email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Pepin Andrew Tuma, Esq.
Government & Regulatory Affairs
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 Byrd-bredbenner C, Berning J, Martin-biggers J, Quick V. Food safety in home kitchens: a synthesis of the literature. Int J Environ Res Public Health. 2013;10(9):4060-85.
3 Cody MM, Stretch T. Position of the Academy of Nutrition and Dietetics: food and water safety. J Acad Nutr Diet. 2014;114(11):1819-29.
4 Cody MM, Stretch T. Position of the Academy of Nutrition and Dietetics: food and water safety. J Acad Nutr Diet. 2014;114(11):1819-29 (internal citations omitted).
5 Consumer Knowledge of Home Safety Practices Survey (April 2011). Accessed February 17, 2017.