Environmental Health Programs under Fire

By Knight, Mel | Journal of Environmental Health, December 2011 | Go to article overview

Environmental Health Programs under Fire


Knight, Mel, Journal of Environmental Health


During the past several months the U.S. has experienced some of the highest-profile foodborne illness outbreaks with well-documented reports of illnesses and deaths. At the same time Congress has taken action to deny funding for implementation of landmark food safety programs and has rejected a candidate for a presidential nomination, stating that food safety regulation is an unnecessary burden on the food industry. While food safety is the most prominent target, other public health and environmental protection programs also face unprecedented reductions and potential elimination. Apparently the preferred alternative to some people is free market self-regulation, although that is not entirely clear.

I generally shy away from partisan political rhetoric, as I respect the right of others to hold opinions that may be very different from my own. The recent tenor of political discourse has grown so polarized that I feel compelled to speak out in advocacy for our noble mission and profession. To quote the late Senator Daniel Patrick Moynihan, "Everyone is entitled to their own opinion, but they are not entitled to their own facts." I believe the facts clearly support the public value of governmental environmental health and protection programs, both from a risk/benefit and a cost/benefit perspective. Self-policing is an important aspect of public protection, but experience has shown that it is not the entire solution.

An Imperfect System

I think we can begin with an agreement that not all laws and regulations are necessary or appropriate. Many are outdated, inefficient, unenforceable, or poorly written. Periodic reviews and streamlining are always in order and should be a regular part of the process. I have been a participant in a number of regulatory review projects, and it has been my experience that the major obstacle to statutory or regulatory change is not the regulator, but the parties that were originally responsible for initiating the rules: elected officials, special interests, and advocacy groups. That is a part of the democratic process.

Self-regulation and industry policing are essential components to public protection, although these are generally driven by liability avoidance rather than public health protection. Truly neutral audits with the authority to require corrective actions and investigate foodborne illnesses are also required, and these functions are best fulfilled by governmental agencies.

Modern environmental health and protection laws and regulations are required to be based on sound science. Food codes, air and water quality criteria, and other standards are required to have established evidence of their ability to be protective of public health and the environment. These laws and regulations go through public hearing and vetting processes that allow for extensive input and dissent. If a bias exists, it is generally guided by the principle of erring on the side of public health protection.

Risk/Benefit

Few can dispute that environmental public health risks are real and significant. Just taking food safety as an example, the most recent Centers for Disease Control and Prevention estimates are that one out of six Americans suffers from a foodborne illness every year, with 128,000 of those resulting in hospitalization. Ultimately, 3,000 people die from foodborne illness in the U.S. annually. These cases are largely preventable, and much documented evidence exists that the education, inspection, and enforcement activities by environmental health programs are effective in reducing the conditions associated with foodborne illnesses as well as other diseases with an environmental health component.

Cost/Benefit

Georgetown University's Produce Safety Project reports that foodborne illness has a public cost in the U. …

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