January 19, 2018
Office of Policy and Program Development
Food Safety and Inspection Service, USDA
1400 Independence Avenue SW
Room 6065, South Building
Washington, DC 20250-3700
Re: Notice of Request for a New Information Collection: Food Safety Behaviors and Consumer Education: Focus Group Research (FSIS-2017-0042)
Dear Ms. Kouba,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food Safety and Inspection Service (FSIS) at the U.S. Department of Agriculture (USDA) related to its open docket "Notice of Request for a New Information Collection: Food Safety Behaviors and Consumer Education: Focus Group Research (FSIS-2017-0042)," published in the Federal Register on November 20, 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, which will "provide insight into how to effectively inform consumers about recommended safe food handling practices[, . . . [because t]he results of this research will be used to enhance messaging to improve consumers' food safety behaviors and help prevent foodborne illness."
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."5
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 FSIS'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 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
Academy members reviewing the information collection report that the overall design of this study looks sound and that good and useful data could be gathered. The proposed new information collection has the potential to expand the ongoing surveys on consumer food safety behaviors conducted by the Food and Drug Administration and can be complemented and extended by the observational studies conducted by the FSIS. The data will be useful in developing compelling, actionable food safety messages for consumers.
The Academy respectfully suggests several additional recommendations in developing consumer education messages and programs:
- In families with young children, examine food preparation practices and management at home related to food allergen exposure (i.e., wheat; egg);
- In families with children of all ages, develop an understanding of consumer behaviors in the selection, storage, and preparation of foods purchased at farmers markets;
- Conduct a focus group of vendors at farmers markets to understand food safety practices they follow as well as messages they share with consumers;
- Assess raw milk practices and messages related to use of raw milk, especially with infants, children of all ages, and individuals with compromised immunity;
- Identify trusted sources for communications about home food safety;
- Assess consumers' understanding and food preparation behaviors of foods and meats labeled 'ready to eat' and 'ready to heat;' and
- Incorporate knowledge about consumers’ food safety practices and consumers’ food waste at home.
To make the message more personal, we suggest the FSIS consider focusing nutritional messaging on caregivers of young children who want to help their children be safe and healthy. This study would also be applicable to grandparents who are raising or caring for young children. Research suggests that if the nutritional message indicates that by making a change, the child can have a healthier lifestyle, the message has greater impact on caregivers.6 Messages created using this framework focus on the values and emotional reasons that can motivate change. As a result, the messages are more likely to have a positive result and therefore can be more effective.
The Academy appreciates the opportunity to comment on the data collection related to the "Notice of Request for a New Information Collection: Food Safety Behaviors and Consumer Education," 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 through 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 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). 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 National Academies of Sciences, Engineering, and Medicine. Food literacy: How do communications and marketing impact consumer knowledge, skills, and behavior?: Workshop summary. http://www.nationalacademies.org/hmd/Reports/2016/Food-Literacy-Communications-Marketing-Impact-on-Consumers-WS.aspx. Published April 27, 2016. Accessed May 1, 2016.
Selected Additional References
Harrison, J.A. et al. 2013. Survey of food safety practices on small to medium-sized farms and in farmers markets. J Food Prot 76(11):1989–19s93.
Young I, Thaivalappil A, Reimer D, Greig J. 2017. Food Safety at Farmers' Markets: A Knowledge Synthesis of Published Research.
J Food Prot. 2017 Dec; 80(12):2033-2047.
Boor KJ, Wiedmann M, Murphy S, Alcaine S. 2017. A 100-Year Review: Microbiology and safety of milk handling. J Dairy Sci. 2017 Dec;100 (12):9933-9951.
Scott H. Sicherer, Katrina Allen, Gideon Lack, Steve L. Taylor, Sharon M. Donovan, Maria Oria. 2017. Critical Issues in Food Allergy: A National Academies Consensus Report. Pediatrics. 140:2