A Food Safety Meeting Of The Minds

By Laurel Maloy, contributing writer, Food Online

FSIS and APHIS-VS, both agencies of the USDA, have drafted guidelines for joint collaboration on root cause assessments of foodborne illness outbreaks

A recently drafted Memorandum of Understanding (MOU) lays the ground rules for two agencies under the USDA to collaborate in order to trace foodborne illness outbreaks. Under the terms of the MOU, the Food Safety and Inspection Service (FSIS) and the Animal and Plant Health Inspection Service-Veterinary Services (APHIS-VS) will collaborate, sharing information towards a common goal — the trace-back to ground zero of instances of foodborne illness contamination.

The MOU specifies the mutual and individual responsibilities of each agency and defines the process by which a “root cause assessment” will be initiated. Under ARTICLE 3 – MUTUAL RESPONSIBILITIES, the first item makes clear that the MOU will in no way restrict APHIS or FSIS from coordinating with other agencies, private or governmental. The second item clarifies the fact that the MOU is not a fiscal or “funds obligation” document, which is reiterated for the individual agencies under both ARTICLES 5 and 7. ARTICLE 8 of the MOU prohibits the transfer of fiscal resources and makes clear the MOU’s contingency on appropriations by the Congress of the United States.

Detailed by the MOU, the process for achieving permission to share information appears to be somewhat cumbersome:

• FSIS must designate the Applied Epidemiology Staff Director as its authorized representative
• APHIS will designate the VS Chief Epidemiologist as its authorized representative

Permission must be received for the two agencies to “collaborate” from the FSIS Emergency Management Committee (EMC) in accordance with Directive 5500.2.

• FSIS will submit that request, routing the request to the VS Chief Epidemiologist, following VS protocols, of course
• APHIS will review the request, assessing the potential costs, benefits, and availability of resources, providing details to senior VS leadership
  • APHIS will then forward requests needing immediate implementation (within 48 hours) to the Assistant Administrator for the Office of Public Health and Science (OPHS), FSIS.
  • APHIS will send requests not requiring immediate implementation to the VS Leadership Team for assessment within 5 business days.

At this point, either the VS Senior Leadership or the Assistant Administrator for the OPHS will make a decision on whether or not to trigger a joint assessment. In the event a joint collaboration under the MOU is triggered:

• APHIS and FSIS will determine the size, expertise, number, and specific skills required of the assessment team in order to meet the objectives of the assessment
  • Local staff will be used where possible
  • Voluntary participation of food producers or companies associated with the outbreak will be enlisted
  • When necessary a team of epidemiologists, lab personnel, and field veterinarian officers will be deployed
  • Funding of the deployment team will be determined at the time the team is assembled

Finally, the entire intent of the MOU is laid out in one sentence, under ARTICLE 6 – APHIS RESPONSIBILITIES, 8. Summarize and disseminate the results of the assessment in ways that provide flexibility in communicating among investigators, decision makers, and producers participating in the assessment.   

Is anyone else wondering why a Memorandum of Understanding is necessary to encourage two governmental agencies with very similar responsibilities and scope to work together towards a common goal? And then, why involve a third agency, OPHS? Maybe the answer would be to combine these two agencies and do away with the time constraints, the red tape, and wondering who is going to pay for what; and get to the business of protecting the public’s health.