Rising or Falling Food-borne Illnesses, And Who is to Blame? (edited)

There have been a lot of salmonella outbreaks in food in the news lately, but who is to blame? Last year, Paul Krugman set the responsibility squarely on the Bush administration and ideological libertarians like Milton Friedman who want to limit food safety regulations:

Without question, America's food safety system has degenerated over the past six years. We don't know how many times concerns raised by F.D.A. employees were ignored or soft-pedaled by their superiors. What we do know is that since 2001 the F.D.A. has introduced no significant new food safety regulations except those mandated by Congress.

This isn't simply a matter of caving in to industry pressure. The Bush administration won't issue food safety regulations even when the private sector wants them. The president of the United Fresh Produce Association says that the industry's problems "can't be solved without strong mandatory federal regulations": without such regulations, scrupulous growers and processors risk being undercut by competitors more willing to cut corners on food safety. Yet the administration refuses to do more than issue nonbinding guidelines.

Why would the administration refuse to regulate an industry that actually wants to be regulated? Officials may fear that they would create a precedent for public-interest regulation of other industries. But they are also influenced by an ideology that says business should never be regulated, no matter what.

The economic case for having the government enforce rules on food safety seems overwhelming. Consumers have no way of knowing whether the food they eat is contaminated, and in this case what you don't know can hurt or even kill you. But there are some people who refuse to accept that case, because it's ideologically inconvenient.

That's why I blame the food safety crisis on Milton Friedman, who called for the abolition of both the food and the drug sides of the F.D.A. What would protect the public from dangerous or ineffective drugs? "It's in the self-interest of pharmaceutical companies not to have these bad things," he insisted in a 1999 interview. He would presumably have applied the same logic to food safety (as he did to airline safety): regardless of circumstances, you can always trust the private sector to police itself.

Alex Tabarrok at Marginal Revolution fires back that outbreaks of foodborne illnesses have declined since the end of the Clinton administration. Here is his data derived from CDC surveillance:

This data would appear to vindicate the proponents of deregulation at least of the charge of making the situation worse. (Whether it has made the situations better is a matter of whether you believe that trend line.)

Who is right? A look at the complete data set suggests the results are more mixed.

To get a fuller, story I have reproduced the entire data set for outbreaks and cases below. This includes the data that Tabarrok used in the chart above, but also includes data for cases (not just outbreaks) and data back to 1990. To generate these charts, I took the number of all cause outbreaks/cases -- including those of unknown etiology -- listed in each of the reports here.

If you would like to check my data or use it for your own purposes, here is an Excel file with it.

Three things strike me looking at the whole data set.

1) Krugman is wrong to suggest that the Bush administration is to blame for the increase in cases (if you attribute that increase to regulatory laxity). The large increases in food-borne illness cases and outbreaks happened at the end of the Clinton administration.

2) On the other hand, we can't entirely vindicate the advocates of deregulation. What is really important in this cases is a history of FDA food supervision during the Clinton administration. I don't know this, but did some major event in deregulation of the food market happen at the end of the Clinton administration? Without knowing the relationship between the law and illnesses, it is very difficult to tell.

(Ed. The apparent increase in the mid-90s in cases and outbreaks was due to a change in the way that outbreaks and cases were reported. See below in the comments. I failed to notice the regulatory change when I looked up the data. My mistake.)

3) I don't think that all-cause outbreaks/cases of food-borne illnesses is the relevant statistic here. What would be really helpful is disease rates (because it accounts for population increase) broken down by type of illness.

I went and looked this data up -- also at the CDC. Here is an important figure from their preliminary 2007 report on food-borne illnesses.

The figure shows the rates common food-borne illnesses relative to their rates in 1996-1998. As you can see, there has been a slight decline in Campylobacter, Listeria, Shiga-toxin producing E. Coli (STEC), and Vibrio rates during the period. However, there has also been a slight increase in the rates of Salmonella. (In the interests of honesty, the authors do note that decreases in the diseases listed above were before 2004 and have not continued to 2007.)

There are admittedly deficiencies in CDC data by the nature of how it is collected. First, because the CDC surveys labs in hospitals, it is selective for those cases of food-borne illness that end up in the hospital. Children might be over represented, for instance. Also, some food-borne illnesses are not tested in hospital (such as viruses like norovirus).

That being said, it is difficult to establish whether deregulation has resulted in reduced or increased cases of food-borne illnesses. I think that Krugman is being selective when he focuses on the recent spat of salmonella cases in the media. Cases of other illnesses have not increased, and the large rise in cases happened during the late 90s. On the other hand, I have no insight into the regulatory history of the FDA, so I cannot affirm or deny whether deregulation caused the rise in cases at the end of the Clinton administration.

(Ed. Again, see in comments. The apparent increase in the Clinton administration was due to reporting changes.)

Aside from the data, what is my personal opinion about food safety deregulation?

I think that illness prevention measures are a lost cause. I don't think the FDA, the USDA, or anyone else has the resources to police the entire food supply to prevent outbreaks of this nature, and even if they did it would be prohibitively expensive to try. (Government agencies serve an important function identifying the sources of contaminated food when outbreaks happen, but this is another matter.) Deregulation, in my opinion, is merely the acceptance that the problem of tainted food cannot be regulated out of existence. Further, in our reflexive push towards government involvement, we ignore the fact that most of us have very poor food handling practices in our own homes. These practices put us at risk to at least a comparable degree and possibly more than anything food producers are doing.

If you want to limit food-borne illness, the cheapest and most effective way is to change your behavior -- not to shout at the government to do it for you.

Hat-tip: Cafe Hayek