January 8, 2018
Office of Information and Regulatory Affairs, OMB
Attn: FDA Desk Officer
Ila S. Mizrachi
Office of Operations, Food and Drug Administration
Three White Flint North, 10A-12M
11601 Landsdown St.
North Bethesda, MD 20852
Re: Food Safety Survey (OMB Control Number 0910-0345—Extension)
Dear Sir or Madam,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Office of Management and Budget (OMB) and the Food and Drug Administration (FDA) at the U.S. Department of Health and Human Services (HHS) related to its open docket regarding "Food Safety Survey (OMB Control Number 0910-0345—Extension)," published in the Federal Register on December 7, 2017. Representing over 100,000 registered dietitian nutritionists (RDNs);1 nutrition and 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 information collection for the Food Survey, which "measures consumers' knowledge, attitudes, and beliefs about food safety research." Our members look forward to utilizing forthcoming research results to enhance members' ongoing efforts to work with clients, patients, and policymakers 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 dietetic technicians, registered, are encouraged to participate in policy decisions, program development, and implementation of a food safety culture."3 In addition, "RDNs and DTRs 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 the FDA's research to focus on both these direct and indirect ways in which consumers gain home food safety knowledge.5
Academy members use a variety of engaging and effective nutrition education interventions that include social marketing initiatives to empower consumers to make safe, healthy food choices, as directed in the National Prevention and Health Promotion Strategy. It is important that consumers be given accurate and easy-to-understand information to make these food choices. The Academy’s Home Food Safety (HFS) program developed in conjunction with ConAgra Foods generated a steady cadence of news and practical home food safety over multi-media sources that made a difference in increasing consumer and practitioner awareness of food safety.
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 the FDA and can be complemented and extended by the observational studies conducted by the USDA's Food Safety and Inspection Service. 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 supports and urges the following regarding thermometers:
- 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.
- 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. Multiple methods of contact will increase the likelihood of reaching an appropriate, varied sample.
In addition, we support determination of participants' demographics so that they include households inclusive of vulnerable populations. Specifically, in addition to oversampling Hispanics and African Americans, we encourage the FDA to oversample American Indian and elderly populations.
Finally, we suggest that the FDA 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.
C. Kitchen Utensils
The Academy supports inclusion in the Food Safety Survey questions designed to identify consumers’ food safety habits including the handling of food utensils during food preparation. A recent review found that:
- Kitchen utensils and cutting boards . . . are key cross contamination routes. In fact, research in the U.K. suggests that 14% of all foodborne illnesses may be due to inadequately cleaned cutting boards and knives. Although nearly all consumers report they wash these items after using them with raw meat or produce, observational data indicate that the vast majority of consumers do not clean cutting boards and utensils sufficiently to prevent cross contamination.6
The lack of sufficient cleaning of knives, graters, and other utensils in between uses leads pathogens to spread and increases the risk of harm. We support efforts by the FDA to collect information enabling the development and promotion of messages to prevent cross contamination.
The Academy appreciates the opportunity to comment on the data collection related to the information collection "Food Safety Survey," which will provide insight for nutrition educators to develop, review, and implement appropriate consumer nutrition education to reduce food borne illness, and address consumer concerns regarding food safety practice in industry. The Academy 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, patients, and policymakers. 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 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). Available at http://www.eatright.org/resource/homefoodsafety/about-us/surveys/2011-consumer-knowledge-of-home-food-safety-practices-survey. Accessed February 17, 2017.
6 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. (Internal citations omitted.)