Comparison of US and EU Food Safety Systems

This assignment explores the differences in food safety management between the United States and the European Union. It examines the Hazard Analysis and Critical Control Points (HACCP) system used by the EU and the Food Safety Modernization Act (FSMA) implemented in the US. The paper analyzes the strengths and weaknesses of each system, highlighting areas where they diverge and suggesting improvements to ensure effective food safety across both regions.

Running head: COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT
Comparison of the US and EU food safety management
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1COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT SYSTEMS
Table of Contents
Abstract:.....................................................................................................................................2
Introduction:...............................................................................................................................3
Comparison of the US and EU food management system:........................................................3
Drawbacks of HACCP system:..................................................................................................7
Gauging the HACCP system with ideas of FSMA:...................................................................7
Conclusion:................................................................................................................................7
Reference:..................................................................................................................................8

2COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT SYSTEMS
Abstract:
Food security is one of the important factors around the word and when it comes to
implementing it, then both the US and EU has strict plans. Food security governining body of
the US, FDA and the governing body of the EU, EFSA has came into agreement to
implement the HACCP and FSMA into their food security system reducing the trade barriers
in order to promote Transatlantic Trade and Investment Partnership between them. The report
has found that there is certain difference in the structure and implementation of both the
FSMA and HACCP and at first, it need to be mitigated in order to implement the TTIP. The
report to conclude has find the key difference between the two forms of food security
management and it has mentioned various steps to gauge the difference.

3COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT SYSTEMS
Introduction:
Since the year July 2013, negotiations regarding the Transatlantic Trade and
Investment Partnership (TTIP) have been originated between the US and the European Union
(EU) in order to promote free trade by decreasing the trade barriers1. To achieve the desired
goal, one of the key element was to mitigate the difference between the food safety standard
of the two continents and address the inter alia barriers in the field of food and agriculture
production. Though both the participants have well established food safety management,
however difference is present in their basic structure, implementation and principle. The
report is aimed to discuss the difference between the US and EU food safety management. In
order to perform this analysis, the report will consider the Food Safety Modernization Act
(FSMA) and Hazard Analysis and Critical Control Point (HACCP), which will aid to trace
the structural difference between the food safety management of the two continents.
Comparison of the US and EU food management system:
Both the US and the EU has a strong food security system that performs at the
regional and federal level. Owing to the various countries and regions with different religious
believe and custom in the EU, the food security system out there is more complex compared
to the food security system of the US, which has a balanced approach. 15 agencies in the US
works with 30 food safety related laws at federal and regional level under the principal
authority known as the Food and Drug Administration (FDA) of the Health and Human
Services (HHS) of the US2.

4COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT SYSTEMS
Figure 1: Partial FDA organisation structure
Source: (Created by Author)
FDA of the US has a three parent bodies under its organisational structure, which are
namely Center for Drug Evaluation and Research (CDER), Center for Biological Evaluation
and Research (CBER) and Office of Regulatory Affairs (ORA)3. Operation of the FDA
covers a wide area in the whole US that ranges from medicine over cosmetics, tobacco to
drugs4. From the figure 1, partial organizational structure of the FDA can clearly be seen and
it can be envisaged from the above figure that the FDA is one of the parent institution that
works under the HHS of US and it is responsible for food system management in the
continent. Considering the figure 2, it can clearly be seen that the FDA is divided in to
various layer. Head of the institution is the commissioner, under whom the other departments
of the organization operate.
HHS
FDA
CDER CBER ORA

5COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT SYSTEMS
Figure 2: FDA Administration Overview
Source: (Waksman, Pendyala, 2015)5
It has been long pending to implement the FSMA in the US food security and let the
FDA operate according to the directions of regulated by the international bodies. Implying
the FSMA, FDA has become able to enforce and release the internal controls of food
security. Back in 2011, FSMA was clubbed in the FDA of the US and since then it has been
four years, when the realisation of the act came into effect6. FDA took almost three years to
frame the final rules and regulation and in the 2016, the administrative authority implemented
the laws at national level. One of the main introductions that influenced the FDA structure
was Hazard Analysis and Risk-Based Preventive Controls for Human Food, which came into
action back in 2013, when FSMA came into action7. Not only the food security, moreover
FSMA altered the existing laws for eggs, meats, poultry, juice production, seafood
manufacturing and other businesses.

6COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT SYSTEMS
Figure 3: EFSA organisation structure
Source: (EFSA, 2014)8
Coming to the EFSA of the EU it has been in action since 2005 around the 28-
member country. Until 2014, there were almost 901 regulations under the EFSA system that
controls the food and safety of the EU. Owing to the fact that, there are almost 28 members in
the EU, EFSA system has lots of patchwork that varies depending upon the place of its
operation9. From the figure 3, the organisational structure of the EFSA can be seen, which
three primary bodies and it is an independent food security management body that performs
the risk management on regular basis to avoid the any shock. HACCP is another
instrumental operation, which has been mandatory to follow in the EU since 2005 and in the
US from 2011.This food safety body aids both the US and EU to analyze and control the food
safety and promote a preventive system of food management in both the place.

7COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT SYSTEMS
Drawbacks of HACCP system:
Although both the EU and the US has HACCP in their food safety management
operations, they have operational and structural differences. When it comes to HACCP, then
FDA and EFSA have different form of implementation. According to the FDA, structure of
the HACCP there is seven important principles that promote preventive system of
management and the EU structure is more complex owing to the different place of operation.
EU has self-control mechanism of implementing the HACCP and it does not acknowledge
the other important factors that may affect the food safety of the region with the flow of
time10. Besides this HACCP model of the EU does not have any layered structure that makes
it problematic when it comes to implementing and regulating new law.
Gauging the HACCP system with ideas of FSMA:
HACCP is applicable to the EU since 2005; however, it is not enough to control the
recent changes of the food safety measurement around the world. One of the key preventive
controls for animal and human food is to introduce hazard analysis, which is not present in
the HACCP model but available in the FSMA. Besides this, HACCP allows third party
assessment of food security, which is not suitable for the accurate evaluation according to the
FSMA11. Thus, it is good practice to gauge this features in the HACCP model to make it
suitable for the present situation of the food safety.
Conclusion:
This report has found that there is difference in the structure and implementation of
the HACCP and FSMA by the EFSA and FDA respectively; however, with the flow of time
it needs to be gauged for better food security. Various differences and the drawbacks of both
system has been evaluated here and it was found that the competent authority need to prevent
them in order to implement the TTIP in the EU and US regions.

8COMPARISON OF THE US AND EU FOOD SAFETY MANAGEMENT SYSTEMS
Reference:

1 Felbermayr, G., Heid, B. and Lehwald, S., 2013. Transatlantic trade and investment partnership (TTIP). Who benefits
from a free trade deal? Part 1: Macroeconomic effects. Books.
2 Hamm MW, Bellows AC. Community food security and nutrition educators. Journal of nutrition education and
behavior. 2003 Jan 1;35(1):37-43.
3 Carpenter D. Reputation and power: organizational image and pharmaceutical regulation at the FDA. Princeton
University Press; 2014 Apr 24.
4 Barnett WP, Carroll GR. Modeling internal organizational change. Annual review of sociology. 1995 Aug;21(1):217-
36.
5 Waksman R, Pendyala LK. Overview of the Food and Drug Administration circulatory system devices panel meetings
on WATCHMAN left atrial appendage closure therapy. The American journal of cardiology. 2015 Feb 1;115(3):378-
84.
6 Strauss DM. An analysis of the FDA food safety modernization act: protection for consumers and boon for business.
7 Stewart K, Gostin LO. Food and Drug Administration regulation of food safety. Jama. 2011 Jul 6;306(1):88-9.
8 EFSA Scientific Committee. Guidance on the structure and content of EFSA's scientific opinions and statements.
EFSA Journal. 2014;12(9).
9 Anadón A, Martínez-Larrañaga MR, Martínez MA. Probiotics for animal nutrition in the European Union. Regulation
and safety assessment. Regulatory toxicology and pharmacology. 2006 Jun 30;45(1):91-5.
10 Taylor E. HACCP in small companies: benefit or burden?. Food control. 2001 Jun 30;12(4):217-22.
11 Fortin ND. HACCP and Other Regulatory Approaches to Prevention of Foodborne Diseases.