Why Food Safety Needs a Project 2027

I have been doing this since January 1993. A hamburger at Jack in the Box put me in the food safety business, and I have said for more than thirty years that I would like to be put out of it.

I am not out of it. I am busier than ever.

That is the problem, and it is why I spent this fall writing something I never expected to write: a working agenda for American food safety. I call it Project 2027. It is not a manifesto. It is a list of things that can be done, by people who already exist, with bills, dockets and deadlines attached.

What we lost in two years

Here is what happened while most of the country was looking the other way.

In April 2025, USDA withdrew its Salmonella framework for raw poultry after three years of work.

In July 2025, CDC cut FoodNet, the system that measures whether anything we do is working, from eight pathogens to two.

In September 2025, the Justice Department eliminated the Consumer Protection Branch, the people who prosecuted food crimes.

In November 2025, the law that ended the shutdown carried a rider that bars FDA from enforcing its own traceability rule before July 2028. The House bill for this year repeats the bar.

In December 2025, FSIS delayed indefinitely testing under its own 2024 determination that breaded stuffed chicken with Salmonella is adulterated. The standard is law. Nobody is checking for it. Consumer Reports asked for the data behind that decision in June. I am not aware of an answer.

Almost none of that took an act of Congress. It was done by notice, by budget line and by rider. Which means most of it can be undone the same way.

And then the bills came due

This summer the country ran the largest Cyclospora outbreak in its history. More than 18,000 laboratory-confirmed cases. That is only the people who got a stool test that found the parasite. There is no kill step for Cyclospora, and we had stopped measuring the trend a year earlier.

Fifty-two babies were hospitalized with botulism after drinking powdered infant formula: 48 in the ByHeart outbreak and four more in the Nara outbreak. Whole genome sequencing tied them to one supply of milk powder. Federal rules still require formula to be tested for exactly two organisms, and Clostridium botulinum is not one of them.

In October, fifty people got sick from E. coli in ready-to-eat chicken wraps. FDA said the product had been “proactively removed.” It named no brand, no maker and no state. The public learned the brand from a lawsuit. When the agency closed the file, it said more detailed information “would not have provided consumers with an action they could take.” Check FDA’s own outbreak table on any given week and count how many investigations name no food at all.

USDA’s economists put the cost of foodborne illness at $74.7 billion a year. Salmonella alone is about $17 billion of it. Deaths are 56 percent of the cost, and long-term health problems are another 31 percent. None of it buys anybody a new kidney.

This is not only about bugs

I have spent my career on bacteria and viruses. My paper shows it. But I want to say something plainly that the first draft did not say well enough.

Chronic disease is not somebody else’s fight.

Ninety percent of the nation’s health care spending goes to people with chronic and mental health conditions. Obesity alone costs the health system nearly $173 billion a year. The foodborne number is real, and it is a rounding error next to that.

The two halves of this community, the people who fight pathogens and the people who fight diet-related disease, have treated each other as separate worlds for too long. We want the same things more often than we admit. Honest labels. Real review of what goes into food before it is sold. School meals that are both safe and nourishing. States that keep the right to protect their own people.

That is why Project 2027 now treats chronic disease at the same weight as the pathogen items, in the same signature block and the same hearing requests. And it gives the chronic side its own first item.

David Kessler petitioned FDA in August 2025 (docket FDA-2025-P-3071). The statutory clock ran out long ago. FDA sent a procedural interim response in February. The Secretary then said on national television that the agency would act. It has not.

The ask is one letter to FDA and to OMB: release the response. Nourish Science has committed to sign it. EWG is willing. I will draft it before the end of the year. It costs the government nothing, and it is the one place in the whole agenda where both halves of this community are asking the same office for the same thing.

What Project 2027 is

The first draft went out in September to about thirty people: consumer groups, former agency heads, state regulators, industry food safety people, law professors and scientists. It came back with dozens of comments and more than 180 separate points.

Some of the best came from people I fight in court. A produce industry veteran sent twenty-six comments and offered to do the research herself. A former director of FDA’s food center corrected me on what the agency had already done, and she was right. A state regulator with fifty years in the work reminded me that most food safety in this country happens at the state and local level, not in Washington.

They also told me thirty-plus items is too many. I heard them. The next draft will be shorter.

What survives are things with a vehicle and somebody already pushing them:

Keep the traceability rider out of the next spending bill.
Test infant formula, and the milk powder it is made from, for the organism that paralyzed these babies.
Restore surveillance, laboratories first.
Name the companies in outbreaks, recall or no recall.
Publish recall consignee lists the day a recall is announced.
Let FDA take samples at the animal operation next to the field when an outbreak points there.
Bring back produce testing, this time in statute.
Release the response to the Kessler petition.

Bring back the MDP

That produce testing item deserves its own paragraph.

From 2001 to 2012, USDA’s Microbiological Data Program tested 10,000 to 15,000 produce samples a year. That was roughly 80 percent of all federal produce testing, for about $4.5 million a year.

In 2012 it found Listeria in cantaloupe from Burch Farms. The recall reached nearly 189,000 melons, and nobody was reported sick. That was eleven months after Listeria in Jensen Farms cantaloupe killed 33 people. I represented those families.

Then it was shut down after years of produce industry lobbying. The scientists who analyzed its data wrote in 2016 that the monitoring had to continue somewhere. It has not.

I have been asking to bring it back since 2024. Now there is a drafted bill, the Produce Pathogen Surveillance Act. It has permanent authorization, whole genome sequencing of every positive, and no more “blind” sampling. Firms behind confirmed positives get named. It was a Bush-era program, and it should not be a partisan one now.

Seven petitions you can comment on now

I have also drafted seven citizen petitions from the agenda, six to FDA and one to FSIS. None has been filed. All are still open for comment.

They cover:

botulism testing in formula
naming firms in outbreaks, which backs up Stop Foodborne Illness’s own petition
consignee lists and prompt recall classification
sampling at implicated animal operations
Salmonella in raw poultry
warning labels on raw sprouts and on raw milk cheese

Each one is paired with the legislation that would do the same thing if an agency will not.

The election changed the math

On January 3, a new Congress takes office with new majorities in both chambers. Every committee chair this agenda addresses will change. Every bill in it dies and has to be reintroduced.

That sounds like a setback. It is an opening.

New members come with new ideas and no settled habits, and plenty of them campaigned on what is in our food. The incoming House majority already has a planning memo with infant formula, heavy metals in baby food and GRAS reform at the top. It has almost nothing on pathogens. This community should hand them a page that does.

And there is still time this year. Government funding runs out December 11. The infant formula bill, S. 272, passed the Senate without a single objection in April. It has sat at the Speaker’s desk since May. The House could pass it before Christmas, or amend it with the testing language of H.R. 7867 and send it back.

Credit where it is due: this administration just proposed the first update to formula nutrient standards in nearly thirty years, and I said so. Food safety has never been a party question. In 1994, USDA declared E. coli O157:H7 an adulterant in ground beef after Jack in the Box. Every Congress and every administration since has left it alone. It took my beef practice away, and it is the best thing that has happened to food safety in my lifetime.

What I am asking

If you work in food safety, public health, nutrition, agriculture or the food industry, read the draft. Tell me which items your organization would sign. Item by item is fine; nobody has to sign the whole thing. Tell me what is wrong or missing. Comment on the petitions.

I would also like to host a working meeting in Washington in December, after the funding deadline. It will be one day, with a way to join remotely. I want both halves of this community in the same room, settling the shorter version that goes to the new Congress in January.

None of this is radical. Most of it is finishing what somebody already started. Food safety is not expensive. Outbreaks are expensive.

Put me out of the lettuce business, please. Put me out of the formula business and the chicken business too. That is what Project 2027 is for.

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