The numbers say that the most outbreaks and illnesses are attributable to produce, but, in reality, fruits and vegetables are really quite safe. How can this be? A new report from the Center for Science in the Public Interest (CSPI) takes a look at the number of cases of foodborne illness relative to the amount eaten. That is, when foodborne illnesses are considered together with consumption rates, meats, poultry, and seafood are far more likely to cause illness than produce. Thus, although CSPI agrees with the basic numbers in CDC’s 2012 report (Attribution of Foodborne Illnesses, Hospitalizations, and Deaths to Food Commodities by using Outbreak Data, United States, 1998–2008) which put the spotlight on produce as causing the most cases of foodborne illness, it did not draw the same conclusions. In the white paper, Outbreak Alert! 2001‐2010 A Review of Foodborne Illness in America, published in March, CSPI analyzed 4,229 foodborne disease outbreaks occurring between 2001 and 2010, as identified by CDC and other sources. However, the difference between the CSPI and CDC report was that CSPI took the numbers a step further. When analyzed “pound-for-pound” with the amount of each type of food consumed by Americans, seafood rose to the top as the most hazardous food, followed by poultry products – two products for which HACCP is already required. With this extended analysis, the CSPI report backs up the assertions we made in our February 7 newsletter when the CDC report came out (From Farm to Consumer: Where is the Real Risk for High-Risk Foods and How Does FSMA Fit In?). As we stated, and asked, then: “With its statement that ‘more illnesses were attributed to leafy vegetables (22%) than to any other commodity,’ the CDC report puts the spotlight heavily on produce and its on-farm production. … But does it really deserve that spotlight? “ We don’t want to undermine any industry efforts in raising the level of safety for produce–or any other foods. We just want to ensure that produce is not getting undue blame or focus to the detriment of other foods that need just as much – or more – of that focus. The report also went another step further to analyze the locations most often associated with outbreaks. Although occurrences in restaurants and private homes impacted the fewest number of people per outbreak, the number of outbreaks were the greatest in these two locations, and contributed to the greatest number of illnesses. The number of illnesses associated with restaurant outbreaks (32,919) were, in fact, almost three times greater than that of any other single location–with private homes coming in second (12,666).  Again, while we don’t want to take the food safety onus off the food manufacturing industry, it is important that food safety be considered at further steps of the chain where the food is handled and served, rather than blindly placing blame on the manufacturer or farm, and thus putting the majority of the “regulatory eggs” into those baskets. It’s currently impossible to determine how many outbreaks are due to cross contamination, poor employee hygiene, temperature abuse, etc., and these considerations can have great bearing on the foods associated with outbreaks. Taking produce as an example again: if lettuce is chopped on a cutting board that wasn’t properly cleaned after raw chicken was on it, is it fair to incriminate lettuce as the cause of salmonellosis? It’s these kinds of issues that make what seems like straightforward data analysis not so straightforward, and makes discerning the truly high risk foods very difficult. A further interpretation of the CSPI data is that cross contamination in food service or home environments or inadequate food preparation such as cooking, is, in fact, the major contributor of foodborne illness in the U.S. today. CSPI’s paper was based on the 4,229 outbreaks between 2001-2010 that were reported by public health officials with both an identified pathogen and contaminated food; the database was largely compiled from CDC’s Foodborne Outbreak Online Database (FOOD). While conceding that the 106,635 cases of foodborne illness caused by these outbreaks are only a small fraction of total foodborne illnesses, CSPI stated that they represent those outbreaks that provide the most useful information for attribution analysis. The CSPI study also found a decline in complete reporting between 2001 and 2010 with 54 to 68% of all outbreaks reported annually to CDC lacking necessary information, such as the contaminated food or contaminant. It conjectures that this may be due to recession-reduced budgets for public health departments at the end of the decade, with influenza pandemics and post-9/11 bioterrorism investments possibly diverting attention away from foodborne illness investigations. Clearly, if we don’t have complete information about the agent causing the illness and the food vehicle, we can’t put measures in place to prevent issues in the future. Better traceability may help, but there are many factors at play and issues to be addressed in order to ensure that the public health community can be more successful in “solving” outbreak investigations. While the CSPI and CDC analyses are incredibly useful, they provide an incomplete picture of foodborne illness outbreaks due to the limited availability of data. We sincerely applaud the work of CSPI, its robust approach to the analyses in this report, and its ongoing work as a consumer organization. We see the variations in the conclusions between the CSPI and CDC reports as, in fact, showing the difficulty of trying to discern which food is problematic, and which are or should be designated as “high risk.” It will be interesting to see how FDA slices and dices outbreak and other data to determine what foods receive the “high risk” designation. Although emphasizing the responsibility of the consumer in food safety is often an unpopular message, it is one that is still very important. Vast resources have been spent by the manufacturing industry on food safety with a concomitant regulatory focus. Clearly, we should not back down on that focus, but perhaps it is time to turn our attention closer to the consumer and take on the tough challenge of behavior change at that end of the supply chain. We should not confuse the “don’t blame the consumer” message with the “we all have a responsibility to keep food safe” message. No one, from farm to fork, irrespective of size, can abdicate from that responsibility of doing their part to keep food safe and expect others to do ALL the work for them. This article originally appeared on the Leavitt Partners’ Food Safety blog April 4, 2013.