Allen L Mozek, MPH, a Fellow of the International Food Protection Training Institute (IFPTI) and public health advocate for prevention of areca nut diseases, writes in this (as yet unpublished) letter to the editor of Food Safety magazine that the October/November 2016 issue sings “Kumbaya” about the Food Safety Moderization Act (FSMA)  – let’s step back and be politically incorrect:

HACCP was never supposed to be a regulation but “an approach to inspection” – per Dr. Frank L. Bryan – HACCP pioneer.

Ready-to-eat produce and sprouts, due to outbreaks and lack of CCP, would not be permitted if not for Salinas CA producers and sprout association lobbying.

Preventive controls is “another regulation” that will mitigate hazards but not provide the conventional 5 log reduction of pathogens with these products.

Second, food fraud is intentional adulteration for economic gain and not amenable to either HACCP or preventive controls but is rather an ethical problem. See the essay:

Market Economies With Churches and Market Economies Without Churches, by Zhao Xiao

Third, I would like to see thorough answers to three questions (courtesy of economist Thomas Sowell):

1.     What is the empirical evidence for this legislation?

2.     Compared to what will this legislation be an improvement?

3.     What is the cost?

Fourth, please answer the charge of “conflict of interest” and “sham”, regarding third party auditors, exclaimed by renowned foodborne illness attorney Bill Marler and barfblog.com editor Doug Powell.