Dog owners are dying in much greater numbers of course, a fact that the Post will likely get around to mentioning in the very near future. A National Research Council (NRC) report issued in 1998 cited an estimate that there may be as many as 9ꯠ human deaths a year from 81 million annual cases of food poisoning. Those numbers seem exaggerated. But the fact they appeared in a very credible federal report means those statistics will ignite some fireworks. They already have, actually. In the wake of the report, President Clinton appointed a Council on Food Safety. The council, chaired by the secretaries of agriculture and health and human services and with no industry representatives, had three meetings around the country between October and December of last year. Clinton's charge to the council is to examine the recommendations made in the "Ensuring Safe Food" report from the NRC, and then to report back to him by Feb. 1999 on which recommendations the President should follow up on. Presumably, the President would then put together a legislative package and send it to Capitol Hill. Any proposed legislation will undoubtedly push food companies to take additional steps to prevent microbiological contamination. Some of these steps could involve how packaging is used and stored. "Packaging material certainly is of concern," says Gilbert Leveille, recently retired as vice president, research and technical services, Nabisco, Inc., Fair Lawn, NJ. Leveille served as one of the members on the National Research Council committee which prepared the Aug. 1998 report "Ensuring Safe Food." Leveille thinks Congress and the Clinton administration will be concerned with post-processing contamination, where the issue is whether packaging has been contaminated by pathogens prior to being put in use, or once it gets to the packaging line. "That is not regulated now," he explains. Effect of HACCP That is not entirely correct. Packaging is considered a "critical control point" in food processing. As such, packaging must be addressed under HACCP (Hazard Analysis Critical Control Point) systems that are required of large meat and poultry processors and marketers of seafood. The U.S. Department of Agriculture requires HACCP systems to be in place at medium-sized meat and poultry companies this month and for all such plants by 2000. The Food & Drug Administration, which regulates a much wider variety of foods than the USDA, has started to embrace HACCP as fully as the Department of Agriculture, which simply cannot afford to pay inspectors to finger individual carcasses of beef at every meat processing plant in the country. Not only do USDA resources not permit close inspections, that old "touch-and-smell" system of inspection is ineffective since it does not single out the "riskiest" operations-either by plant or by assembly-line function-for federal surveillance. Five years ago, the FDA had attempted to make full-scale use of HACCP. The agency published an "advanced notice of proposed rulemaking" that is the first step in instituting a new federal program. "But that got quashed by the food industry," states Caroline Smith Dewaal, director of food safety for the Center for Science in the Public Interest, a Ralph Nader-affiliated group. The FDA has since taken an incremental approach. Besides requiring HACCP at seafood plants, the FDA has pushed fruit juice manufacturers in that direction. Manufacturers had to have HACCP systems in place by Nov. 5, 1998, or else put warning labels on their packages. Citrus juices were given an extra eight months as long as they established interim procedures. Fresh fruit programs? Also last fall, the FDA published guidelines for the packing of fresh fruit. "At one point, the agency had given strong consideration to a HACCP-based regulation," says John Aguirre, vice president of government affairs for United Fresh Fruit & Vegetables, a trade group. Aguirre says United is glad HACCPs were set aside; the group is very positive about the guidance document. But Aguirre admits that some corners of his industry consider the voluntary guidance as the "first inexorable step" toward a fresh fruit and vegetable HACCP program. Sure as Michael Jordan can jump, the FDA will extend HACCP to other food categories. Brian Folkerts, vice president of government affairs for the National Food Processors Assn., thinks FDA's next move may be toward HACCPs for minimally processed foods such as packaged salads. "Can HACCP be employed more widely?" he asks. "Absolutely." And in fact, some food processors have already voluntarily adopted HACCP. That is true, for example, of General Mills, Inc., Minneapolis, MN, according to spokeswoman Pam Becker. The Clinton Food Safety Council will undoubtedly give an "amen" to the NRC report's song of praise for HACCP. "It is widely accepted by the scientific community that the use of HACCP systems in food production, processing, distribution, and preparation is the best known approach to enhancing the safety of foods," the report says. Low marks for USDA But the report implied that the USDA wasn't doing too good a job with its new HACCP system, mostly because the Food Safety and Inspection Service (FSIS) was at the same time sticking with its traditional inspection system of hand-checking every carcass during the inspection. The FSIS just doesn't have enough money to do both. "Adequate resources have not been provided to enable the implementation of HACCP-based inspection effectively, efficiently and without disruption," the NRC Committee concluded. Is the FSIS helpless on HACCP? The agency certainly has not developed a handy-dandy database. The USDA's latest quarterly report on administrative actions taken at HACCP plants (during the period July 1, 1998-Sept. 30, 1998) gives no breakdown on why plants were penalized. Liz Lapping, a spokeswoman for the FSIS, says she does not know whether packaging problems played any role in those violations. After making phone calls to other FSIS officials, she still couldn't get a breakdown of the violations. Undoubtedly, between the time this appears and the time the President's Food Safety Council makes its recommendations to the White House, there will continue to be highly publicized incidents like the ones that transpired as the President's Council began its nationwide public meetings last October. Continuing contamination Just three days after the President's Council held its first meeting on Oct. 20, the FDA announced Hormel Foods Corp., Austin, MN, was recalling its 4.8-oz packages of Quick Meal frozen cheeseburgers because of potential contamination by Listeria monocytogenes. That was the same day Dixie Packers, Inc., Madison, FL, started what turned out to be a three-phase recall of lunchmeat and hot dogs suspected of being contaminated with Listeria. Liz Lapping at the FSIS says Dixie is a HACCP plant. With regard to microbiological contamination of food, perhaps the question ought not be whether packaging is complicit, but rather whether it can be corrective. Some corporate scientist, or some technician in a lab coat at a packaging vendor, would be well on his or her way to a Nobel Prize if they came up with some sort of new-age biocidal-injected packaging that could identify and snuff out Listeria (or any other pathogen) once it sank its claws into someone's hamburger patties. Asked whether Hormel is developing any pathogen-fighting packaging, Meri Harris, a spokeswoman for Hormel, says, "We are not willing to share that information. We don't want anyone else to know what we are doing." Of course, it is not just meat processors who could use anti-contaminant packaging. Don Greenwood, manager of packaging development for Tropicana, Bradenton, FL, a company now working under the FDA's "HACCP or warning label" mandate, says, "I'm not willing to talk about new packaging technologies. But nothing is impossible." Microbiological contamination is the primary concern of the President, his new Food Safety Council and the FDA. But it is not their only concern. Chemical contamination is also under the microscope. Here the issue is leaching of indirect food additives in packaging into food. A number of food packaging materials are among the 15ꯠ chemicals slated to be tested by the EPA as "endocrine disruptors," meaning they interfere with the estrogen, androgen or thyroid hormone systems. The prescreening starts in early 1999. The National Research Council's report said that food packaging materials contain some of the chemicals that could be problematic. Tony Maciorowski, who runs the testing program, says the 15ꯠ chemicals to be tested have not been categorized as to their application. But he notes that chemicals such as bis-phenol-A, which is widely used in food packaging, is on the list. So are many plasticizers. Brian Folkerts of the NFPA says his group is watching that effort closely. "No alarm bells have been set off yet," he notes. But NFPA has its ears cocked.