Impossible criteria?

In the Food Safe message board, I recently posted the column co-written by Tom Stenzel and Bryan Silbermann that was published in The Packer. The column brought this reaction I'm posting here from one message board member. It speaks to an important question; how can FDA and lawmakers regulate according to risk when there is insufficient data to meet that criteria? What is the solution to that?


Quoting from Stenzel and Silbermann...
"These measures must be risk-based and commodity-specific to address the greatest areas of risk as identified by government. They must also be science-based, to ensure they are proven effective at improving food safety"
while i would certainly appreciate hearing other perspectives, my sense is that at the moment the science is not in place that would make it possible to fulfill these two criteria . . . my sense is that although considerable research is currently in process on risk attribution in foodborne illness (pathogen, vehicle, source), the kinds of definitive results that would meet the silbermann-stenzel criteria are not yet available . . . in part this is because the database for the analysis of these questions is so weak (only a small percentage of foodborne illness outbreaks are ever traced to a vehicle, and outbreaks themselves represent only a small percentage of foodborne illness in the u.s.) . . .
if that description of the current situation is accurate, do the silbermann-stenzel criteria present a reasonable effort to move forward on food safety, or a hurdle that cannot be overcome in the forseeable future . . .
cheers,

craig
craig k harris
department of sociology
michigan agricultural experiment station
national food safety and toxicology center
institute for food and agricultural standards
food safety policy center
michigan state university http://www.msu.edu/~harrisc/