A tip of the pen this morning to Matthew Perrone at the Associated Press, who has been on the lettuce Cyclospora outbreak since July and did not walk away from it when the case counts slowed down. His piece today takes the outbreak and asks the question that outlasts it. How often does anyone from our government actually look at the foreign farms and plants that feed us?

The answer, from agency records he reviewed, is less often every year. Inspections of foreign food sites are down nearly 35 percent since 2019. They fell another 17 percent last year, to 1,140 in fiscal 2025. FDA inspectors reached the Taylor Farms site in Guanajuato in mid‑August, roughly a month after the July 17 recall, and it was the first time anyone from the agency had been there since 2019. Seven years.

This is not new, and I have written about it before

The Government Accountability Office laid it out in January of last year, and I posted it then. From fiscal 2018 through fiscal 2023, FDA averaged 917 foreign food inspections a year against a statutory target of 19,200. That is about five percent. The best year in the set was fiscal 2019, at 1,727, or about nine percent. As of July 2024 the agency had 432 investigators to cover both domestic and foreign work. FDA has told GAO for years that the 19,200 figure is unrealistic and unachievable. GAO recommended in 2015 that the agency tell Congress what a realistic number would be. It still has not.

The arithmetic, which is what a hearing is for

CBS News reported FDA’s own cost estimate last month. An average of $38,700 per foreign inspection. Meeting the mandate Congress wrote into law would run about $743 million a year, more than ten percent of the entire FDA budget. In its most recent budget request, the agency asked for an additional $9 million to expand foreign inspection capacity. The human foods appropriation for this fiscal year is roughly $1.17 billion for the whole program.

Put those numbers side by side. Congress set a target of 19,200 inspections, directed the hiring of 5,000 inspectors under FSMA, and then never appropriated the money for either. The agency now asks for nine million dollars against a mandate that costs seven hundred forty three million. Everyone involved understands the target is fiction, and nobody has to say so on the record because nobody has been asked in a room with a transcript.

That is the hearing. Not a scolding, an appropriation. Ask FDA to state, under oath, the number of foreign inspections it believes is defensible, what that number costs, how many investigators it requires, and what it will take to keep them, given that people in those jobs can spend half or more of their working time traveling. Then ask the appropriators whether they intend to pay for it. If the answer is no, the public deserves to hear that plainly instead of reading a target nobody funds.

What I would not pretend at that hearing

An inspection of that packing operation probably would not have found this parasite. Cyclospora travels through water and human waste, there is no validated test that reliably finds it in irrigation water, and a facility walkthrough is not built to catch it. I have said before that FDA should be looking at foreign growers and their water, not only the packing plants, and before an outbreak rather than five weeks after a recall. A hearing that only counts inspections will miss that.

The list of questions is short. What is the right annual number of foreign inspections, and what does it cost? What does the new one‑day inspection pilot actually document, and what does it miss? Why did it take four weeks to get investigators to Guanajuato, and how much of that was the elimination of the staff who used to book their travel? What would it cost to inspect grower water in the countries that supply our produce? And what would it cost to enforce the traceability rule that Congress has prohibited FDA from spending a dollar to enforce until July 20, 2028?

Invite a consumer

One more thing, and it is the part that always gets left off the witness list. The table at these hearings is agency officials, former agency officials, academics and trade associations. Every person seated at it is paid to be there. I have testified in front of Congress more than once, and the most useful voice in the room has never been mine.

Seat someone who spent July on a bathroom floor. Ask her what the emergency room visit cost, how many weeks of work she lost, and how many doctors she saw before anyone ordered the right test, because routine stool panels do not look for this parasite unless someone asks. Michigan has reported two deaths in this outbreak. Ask that family. CDC counted 18,445 lab‑confirmed cases between May 1 and August 31, with 990 hospitalizations, across 49 states and the District of Columbia. The lettuce outbreak alone accounts for 11,458 of them in 20 states, with 495 people hospitalized. There is no shortage of witnesses.

Thirteen members of Congress wrote to FDA, CDC, HHS and Taylor Farms this summer, and not one published answer has appeared. Letters are the polite instrument. A hearing is the next one, and a subpoena is the one after that.

The AP reports that FDA is studying how many foreign inspections it should conduct each year so that oversight of imported food is comparable to what we expect at home. Good. Finish the study, bring the number to Congress with a price tag attached, and say it out loud in a hearing room, with a consumer sitting at the same table. Thank you, Mr. Perrone, for staying on it.