Following our call for stronger FDA nutrition regulation, a devastating expose of FDA’s growing food and nutrition failures, and an ongoing infant formula shortage FDA seems to have made worse, an expert panel has proposed FDA’s food policy woes could be solved by combining the agency’s food units into a separate organization that reports directly to the Health and Human Services secretary. While we wholeheartedly agree that it’s time to move FDA’s food programs, we believe they should be consolidated at the Department of Agriculture in order to create a true “farm-to-fork” food system.

Federal food and health policy is fragmented and spread across the government through a patchwork of overlapping authority that has resulted in 200 different efforts across 21 agencies, according to a recent GAO report. This fragmented system has contributed to the growing toll of diet related disease, which indeed has gotten worse virtually every year for decades. GAO concluded that Congress should identify and direct one federal entity to lead development and implementation of federal diet and health strategy. We believe it should be USDA.

Disparate groups have called for fundamental changes to our food system to solve the accelerating failures, including the Rockefeller Foundation, the American Action Forum, and the European Union.

A true “farm-to-fork” approach to food and nutrition policy that combines the critical elements of a healthy food system – from farming to food processing to our dining tables, would better ensure the health and safety of our food supply. It would reduce the staggering number of Americans who are made sick by our food, cut the resulting skyrocketing health care costs, and eliminate the most serious threat to our military readiness.

USDA is best positioned to succeed due to its history and mission. Created by President Abraham Lincoln to be the “people’s department,” USDA has the comprehensive resources and authorities needed to succeed: 15 nutrition assistance programs with a $175 billion budget, farm executive directors in every state, transformative extension agents in literally every county, and the nation’s leading food and nutrition research programs.

Specifically, we propose that the FDA’s Center for Food Safety and Nutrition (CFSAN) merge with USDA’s Food and Nutrition Service (FNS) and Food Safety and Inspection Service (FSIS) under one Food, Nutrition and Health mission area at USDA.

This reorganization would allow the federal government to better align its food and nutrition efforts. The FDA and USDA currently pursue similar nutrition goals but often in disjointed and ineffective ways. For example, the USDA instituted needed sodium reduction standards for the National School Lunch Program, which led to overall healthier meals. The FDA has also issued sodium targets, but they are voluntary short-term targets for packaged foods that took almost five years to finalize and release (final long-term targets are forthcoming). Merging these programs would allow for more effective and coordinated sodium reduction in both the federal nutrition programs and the private sector.

Reorganizing FDA’s food policy responsibilities under USDA would also lead to stronger acute food safety oversight. The USDA, despite only regulating the safety of 20% of the food supply, has more than half of the two agencies’ combined food safety resources.

In addition, the USDA FSIS’s food safety statute is more rigorous than the FDA’s authority. FDA’s implementation of the Food Safety Modernization Act has reinforced its food safety program. Consolidating and building on the strengths and synergies of FDA’s and USDA’s food safety systems would make our food safer.

Congress would also be more likely to approve merging CFSAN with FNS and FSIS at USDA.  In 1940 after more than 30 years, the FDA was moved from the USDA to the Federal Security Agency, which became today’s HHS. However, the Congressional Appropriations Subcommittees on Agriculture maintained authority over the FDA even after it was separated from USDA. The subcommittees would more likely support a consolidation and funding FDA’s food and nutrition activities if they were returned to USDA.

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We recognize that the proposed reorganization is difficult and will lead some to reflexively howl in protest and delay action. However, there are steps that can be taken immediately to improve federal food policy coordination.

The White House should appoint a Deputy Assistant to the President for Food, Nutrition, and Health who would join the heads of USDA’s and HHS’s food and nutrition programs to lead an empowered Interagency Committee on Human Nutrition Research to coordinate all federal food and nutrition policy, not just research. The new food and nutrition deputy should be put in charge of implementing the White House National Strategy on Hunger, Nutrition, and Health and the FDA Expert Panel recommendations.

Whether CFSAN, FNS, and FSIS officially merge or do so virtually while remaining in their silos, our current food policy challenges are too urgent for inaction.

Jerold Mande is former senior adviser to the FDA commissioner and deputy undersecretary at the U.S. Department of Agriculture. He is an adjunct professor of nutrition at the Harvard T.H. Chan School of Public Health. 

Thomas Grumbly has held senior policy roles in the Office of Management and Budget, the US Department of Agriculture and the FDA. He is vice-chair of the Supporters of Agricultural Research (SoAR) Foundation Board. Both are co-founders of Nourish Science.

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