By Drew Thompson
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 of fish in North America.
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 US 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 US 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, Anhui province, from fake milk powder that
had virtually no nutritional value.
Hundreds in Panama have died from an additive, diethylene glycol, which was
added to cough syrup. Toothpaste manufactured by a Chinese company and exported
to Panama and Australia is suspected of containing the same ingredient and is
currently being recalled. In addition to the discovery of adulterated pet food
ingredients in the United States, US 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' efforts 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 for China's regulators and 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% of them as
family businesses with fewer than 10 employees.
Animal husbandry, in particular, is dominated by rural households. As
globalization advances and China is increasingly integrated economically 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 US government, non-governmental organizations (NGOs) and importers will be
forced to address this relatively new and growing problem.
China's food-processing 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. Processors must take
precautions to ensure their products are not inadvertently contaminated by
heavy metals, bacteria, fertilizers and other chemicals from water used in
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 address food safety proactively 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 officials 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 racked by a corruption scandal
involving its founding director, which has extended to more than 60 people
as well as provincial food and drug administrations.
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 the industry was revealed
when the government reported in 2005 that they had discovered 114,000
unlicensed drug manufacturers and demolished 461 offending factories.
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.
While government departments intone that they take food safety seriously, they
have been unable to oversee the food and drug industry effectively 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.
US and Chinese response
In response to the contaminated wheat gluten crisis, the US Food and Drug
Administration (FDA) sent a team of investigators to China in early May to work
with their Chinese counterparts at the Administration of Quality Supervision,
Inspection and Quarantine to determine the source and extent of the problem.
The US 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 US
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.
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.
While Chinese and US 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 under way. Dr David Acheson,
assistant commissioner for food protection at 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,
"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 reopen in another neighborhood under
another name, in effect 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 US government, for its part, can continue to engage Chinese counterparts,
providing technical support and maintaining a dialogue on global health
governance issues within the structure of the two countries' strategic
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 US 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's 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.
Copyright 2007 Asia Times Online Ltd.
All rights reserved.