The April upsurge in the deaths of cats and dogs in the United States alerted authorities to an emerging health situation that was ultimately determined to have been caused by pet food contaminated by imported wheat and rice gluten intentionally spiked with chemicals from China. Aside from causing the deaths of household pets, contaminated byproducts of the adulterated pet food entered the human food chain as animal feed, affecting 20 million chickens, 56,000 pigs and unknown numbers fish in North America (Reuters, May 7). While there appears to be no risk to human health in this case, the incident exposes a nascent threat to health stemming from the increased trade in Chinese foodstuffs as well as the capabilities and limits of U.S. monitoring capacity.
Food safety and defense are important elements of global health governance. China and the United States share a common interest in ensuring the safety and security of the global food chain. The U.S. government has increased its commitment to “food defense,” as established in The Bioterrorism Act of 2002, but recent incidents have established that increased monitoring capacity at home is necessary to prevent adulterated products from being imported and entering the food chain. Increasing domestic budgets and working closely with trading partners, particularly large volume partners like China will help reduce future incidents.
Chinese and international media reports routinely expose the damage caused by counterfeit and adulterated foodstuffs. Since the transition to a market economy, Chinese farmers have increasingly used dangerous or illegal pesticides and fertilizers to increase yields, used improper antibiotics and hormones to improve livestock and fish growth and employed illegal preservatives to increase marketability of semi-processed products. In a highly publicized 2004 tragedy, 13 babies died in Fuyang in Anhui province from fake milk powder that had virtually no nutritional value (China Daily, April 21, 2004). Hundreds in Panama have died from an additive, diethylene glycol, which was added to cough syrup (China Daily, May 24). Toothpaste manufactured by a Chinese company and exported to Panama and Australia is suspected of containing the same ingredient and is currently being recalled (Reuters, May 23). In addition to the discovery of adulterated pet food ingredients in the United States, U.S. customs officials have discovered and embargoed numerous shipments of foodstuffs from China that are filthy or contaminated with banned chemicals. From the production standpoint, these incidents reflect two things: poor manufacturing practices due to the producers’ effort to increase profits at the expense of safety and the Chinese government’s inability to effectively regulate a decentralized production base.
Oversight of China’s large and decentralized food processing and distribution industry is the responsibility of 10 government departments, particularly the State Food and Drug Agency (SFDA). Yet, responsibility for food safety is shared by departments within the Ministry of Health, Ministry of Agriculture, local animal husbandry departments, industry commerce bureaus, and the Administration of Quality Supervision, Inspection and Quarantine. Overlapping jurisdictions, weak legislation, a predominance of cottage-industry production with little or no documentation and growing access to international markets is combining to create a significant challenge to China’s regulators as well as trading partners.
Improved rural communications in China coupled with the liberalization and growth of global trade means that smaller, rural producers in China now have greater direct or indirect access to overseas markets. There are an estimated 1 million food processing operations in China, with as many as 70 percent of them as family businesses with less than 10 employees (China Daily, March 15). Animal husbandry, in particular, is dominated by rural households. As globalization advances and China is increasingly economically integrated with the world, its government faces the progressively more complex task of enforcing international standards on a still relatively isolated rural production base. As these small, often rural producers’ products increasingly gain access to the global market, their potentially poor manufacturing practices present a global health governance challenge to governments tasked with protecting the health of their citizens. While counterfeit and contaminated foodstuffs are not new phenomena in China, the U.S. government, non-governmental organizations (NGOs) and importers will be forced to address this relatively new and growing problem.
China’s Food Processing Industry Challenges
Chinese regulators tasked with overseeing food safety face numerous challenges ensuring that Chinese products are safe for consumption. Environmental, structural and political factors all contribute to these challenges.
Environmental pollution poses a significant problem for food processors and the regulators that oversee their output. Access to clean water is a particular concern. Even the famed Maotai-brand liquor has been threatened as its water supply, the Chishui River, becomes increasingly polluted (Xinhua, May 14). Processors must take precautions to ensure their products are not inadvertently contaminated by heavy metals, bacteria, fertilizers and other chemicals from water used in processing.
While the Chinese government plays a dominant role in regulating food and pharmaceutical production, it has had limited success in establishing a culture of safety in the industry and ensuring that unlicensed and unqualified processors and their products do not enter the market. The government, in particular, is unprepared to proactively address food safety when many producers are little more than cottage processors. Small processors often lack appropriate documentation and rarely have the technical capacity to ensure compliance with regulations. Worst of all, small producers often see government oversight as capricious and corrupt, and spend more energy trying to outwit and avoid the system, rather than “buying in” and focusing on compliance and good manufacturing practices.
The government’s task is made even tougher by the widespread corruption at multiple levels. Local officials often collude with local companies, stymieing attempts by higher-level authorities to enforce safety regulations. At the highest level, the SFDA in China has been wracked by a corruption scandal involving its founding director, which has extended to over 60 people as well as provincial food and drug administrations (China Brief, April 5; Xinhua, April 2). Unscrupulous food and drug producers were able to buy various licenses from the national agency and its provincial and local branches. The astonishing scope of the administration’s inability to effectively monitor industry was revealed when the government reported in 2005 that they had discovered 114,000 unlicensed drug manufacturers and demolished 461 offending factories (People’s Daily, February 8, 2006). Companies that had been issued “Good Manufacturing Practice” (GMP) certificates were later found to be shipping unsafe products. The Chinese government has promised to “clean house.” Premier Wen Jiabao and other senior leaders have publicly vilified corrupt SFDA officials, and the supreme people’s court recently sentenced the former director to death. (Xinhua, May 29)
While government departments intone that they take food safety seriously, they have been unable to effectively oversee the food and drug industry and reduce incidents. They are further hampered by the lack of strong consumer protection laws and independent courts that place consumer protection above local economic and political interests. Additionally, China lacks a robust civil society that collectively represents the interests of consumers as well as manufacturers. Without structural systems, including a strong legal system, insurance companies, industry associations and “consumer watchdogs” in place to support the government, the system lacks a powerful tool to ensure food and drug processors adhere to good manufacturing practices after the government inspector has left the premises.
The U.S. and Chinese Response to the Pet Food Contamination Incident
In response to the contaminated wheat gluten crisis, the U.S. Food and Drug Administration (FDA) sent a team of investigators to China in early May to work with Chinese counterparts at the Administration of Quality Supervision, Inspection and Quarantine to determine the source and extent of the problem. The U.S. FDA expressed appreciation for the Chinese government’s cooperation, pointing out that the Chinese embassy issued travel visas for the team the same day they received the passports . In addition to product recalls, the U.S. government has also responded by increased inspections of pet food, vegetable protein products and animal feed imported from China .
In the case of the intentionally adulterated pet feed ingredients that resulted in the deaths of animals, the Chinese authorities have treated it as a criminal case limited to two manufacturers, rather than a more fundamental problem with its food processing industry. Consistent with criminal detentions for previous contamination incidents, Chinese authorities detained the factory owners who shipped the adulterated products (AP, May 8). More broadly, however, the Chinese government has expressed its commitment to improve food safety and improve policies. In response to corruption at the SFDA as well as the relative ineffectiveness of the 10 government departments in eliminating food-related incidents, the government is considering the formation of a Food Safety Commission under the State Council, which would unify oversight in one body (China Daily, November 18, 2004).
While Chinese and U.S. investigations have focused on the specific wheat gluten case, the incident has sparked recognition that both countries need to work more closely to ensure the security of the food chain. Reassuringly, discussions toward that end are reportedly underway. Dr. David Acheson, Assistant Commissioner for Food Protection of the FDA stated in mid-May that “there are preliminary discussions about formalizing future cooperation with China on food safety and food defense issues, and those discussions will continue in the forthcoming weeks.”
The Chinese government recognizes that it will have to take significant steps to improve food and drug safety. Their efforts should help reduce future embarrassing incidents that ultimately threaten to tarnish the “made in China” brand and reduce Chinese manufacturers’ competitiveness and market share. Yet, the government’s approach to improving food and drug safety must go beyond protestations of concern and new legislation to have a measurable, long-term affect.
“Increasing supervision” of the food-processing sector is not necessarily the most durable solution. Crackdowns and campaigns do not solve underlying problems and prevent crises from reoccurring. Small manufacturers that are shut down in one campaign can re-open in another neighborhood under another name, effectively driving the problem underground. Likewise, creating unrealistic financial and administrative barriers for manufacturers to enter the market legitimately can drive processors into unregulated situations, making certification and traceability extremely challenging. Incentivizing processors to voluntarily comply with clear and reasonable regulations will be vital to ensure long-term food safety.
Developing non-governmental resources to support safe manufacturing practices in China should also be considered. In the United States, NGOs play a vital role in both policymaking and ensuring food and drug safety. For example, the Grocery Manufacturers Association-Food Products Association represents food processors in dialogues with regulators and provides education and training for processors to ensure that they have the ability to adhere to regulations and good manufacturing practices. Other organizations, such as the Partnership for Food Safety Education, work with companies and regulators to educate the public about safe food handling.
Improving production practices and traceability in China should also be prioritized. Future enforcement of regulations in the United States will likely require accurate country of origin labeling that processors and suppliers exporting to the United States will have to adhere to. In addition, there are existing production and tracing models, which can be adapted for use in China, such as HACCP (Hazard Analysis and Critical Control Point).
Finally, increased quality and safety will necessarily result in increased costs. A consequence of the widespread reporting on the effects of adulterated and counterfeit products from China will be calls from buyers seeking certification and testing from reliable laboratories, placing the burden on the supplier to prove the safety of its products. Responsible buyers, however, must recognize that added costs cannot be borne by the supplier alone and that some increased costs will ultimately have to be borne by the end user.
The U.S. government, for its part, can continue to actively engage Chinese counterparts, providing technical support and maintaining a dialogue on global health governance issues within the structure of the two countries’ strategic dialogues. To improve food and drug safety, the United States can share its experiences in food safety with the Chinese government and encourage greater involvement of Chinese non-governmental groups in the sector. China and the United States can also jointly develop and fund innovative initiatives, such as training and awareness programs for small processors in China that would build their knowledge of international standards and increase their willingness to voluntarily follow safe production techniques, a role for which NGOs are well suited.
The recent spate of incidents has exposed how important it is for governments to work with producers, exporters and importers to develop systems to ensure food safety. The melamine-spiked wheat gluten incident highlights the importance of carrying out the concepts embodied in the Bioterrorism Preparedness and Response Act of 2002, which require the U.S. FDA and Customs and Border Protection to jointly develop regulations pertaining to the registration of food and animal feed facilities, the prior notification of imported food shipments, the establishment and maintenance of records, and the administrative detention of suspect shipments. Increasing the FDA and USDA’s budgets to enable them to increase detection capacity and efficiency would prove to be a valuable investment. With its experience inventorying North American food facilities and collecting data on imported foods and handling chains, the United States has valuable experience to share with counterparts in China.
The adulterated wheat gluten incident should underscore to officials in both countries that they share mutual interests in building systems to ensure safe food production and prevent agroterrorism while still providing open markets to each other’s products.
1. U.S. Food and Drug Administration, “Transcript of FDA Press Conference on Contaminated Animal Feed,” May 10, 2007. Available online at: http://www.fda.gov/bbs/transcripts/transcript051007.pdf.