Senior officials at agencies routinely ask Congress for more funding, so the latest call from the Food and Drug Administration’s Michael Taylor for more money to implement regulations promulgated under the Food Safety Modernization Act isn’t that unusual. But regulators rarely provide evidence that additional funding will actually help solve the social problems the money is intended to address.

According to Taylor, the food safety law means that the FDA “cannot do all that is asked of us without additional resources.” Based on the last time the agency got an infusion of cash, however, it’s not clear what the agency can do even if it has all of the additional resources it asks for.

Much of the new regulations would implement a food safety system called Hazard Analysis Critical Control Points, or HACCP, that focuses on tracking and managing hazards before they get into food. The system was created by the food industry industry originally for space foods in the 1970s. Later on, it was adopted and applied to regular, everyday foods.

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In the 1990’s, the FDA decided to make it a mandatory system, overseen by FDA, for seafood processors. They were able to do so because, in the mid-1990s, the FDA had its food safety budget doubled. So far, so good. But there was one little glitch in this scheme: Seafood is no safer today than when mandatory HACCP was implemented 14 years ago.

Nevertheless, the new system was later mandated by FDA for raw fruit juices. But the problem with raw fruit juices wasn’t the lack of tracking and recordkeeping that a HACCP program would address. It was that juice needs to be pasteurized to kill pathogens, so HACCP was unnecessary. Although the USDA has had some success with the HACCP system for meat and poultry, there is no proof that massive new regulations mandating HACCP for all other foods are likely to produce any major reductions in foodborne disease. In fact, food safety overall hasn’t improved much since the original budgetary increase in the 1990s.

Fiscally speaking, the FDA has managed to do quite well over the years. In 1990 the FDA’s budget was at $560 million. By 2010, that budget had grown to an astounding $3 billion, an increase of 536 percent. It has been projected to grow to $4.7 billion by this year, an additional increase during this administration of 55 percent, while the private economy has grown only a little over 8 percent in that time period.

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Two common assumptions frequently underlie the rationale for funding health and safety agencies: more funding and more regulation equals more health and safety. As the FDA’s experience shows, that is not necessarily true. There are two ways that agencies need to prove that funding is useful: well done, peer reviewed benefit-cost analysis of future regulations and retrospective review of similar regulations done in the past to show their effectiveness. Until these are provided, it is unclear whether additional funding will help anyone except FDA.

