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VIEWPOINT
New Year’s Resolution: A Better Approach to Food Safety Inspection?
By Al Yancy
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As we move into the holiday season, one traditionally takes stock
of the year that was, and begins to look forward to the coming year
with wonder. It seems fitting then, to take a few moments to reflect
back on what 2007 meant for regulatory food safety, and to attempt
to predict where 2008 may take us.
This past February, the U.S. Department of Agriculture’s Food
Safety and Inspection Service (FSIS), announced a proposal to implement
a new Risk-Based Inspection (RBI) system in processing establishments.
In this system, inspection personnel would continue to visit every
federally inspected establishment during each day of operation, but
they would utilize a detailed formula (or algorithm) to determine what
level of inspection each facility should receive.
Factored into that algorithm would be the types and respective volumes
of product produced, and (among other things) microbiological test
results and regulatory compliance history specific to each establishment.
Use of the proposed algorithm would result in an establishment-specific
score indicating the focus and relative amount of inspection activity
each facility should receive.
In this way, FSIS proposed to shift somewhat more inspection time and
resources away from those facilities with better regulatory compliance
histories and/or that produced product with lower inherent public health
risk, toward those facilities with more problematic regulatory compliance
histories and/or that produced product with higher inherent public
health risk. FSIS suggested this process would enable them to better
utilize their resources where they could have the greatest positive
impact on food safety, and would be an improvement over the current
system that requires inspection resources to be relatively uniformly
distributed across all establishments.
The U.S. Poultry & Egg Association (USPOULTRY) supports the concept
of RBI, as it is a means by which to more appropriately incorporate
risk assessment and applied science to the current regulatory food
safety inspection system. FSIS inspection personnel presently weigh
many of the factors included in the RBI proposal to make daily decisions
regarding the utilization of inspection resources. RBI, however, would
formalize this process, and provide the necessary tools and guidance
for proper decision making that could help to remove subjectivity that
exists in the current system.
This is not to say, however, that the current RBI proposal is without
flaws. To the contrary, the way in which FSIS proposed to address matters
related to volume is quite problematic. FSIS suggested that the volume
of respective product produced by an establishment be factored into
the algorithm as a measure of the inherent public health risk posed
by that establishment. This assertion is based upon a preconceived
(worst-case) scenario in which each pound of product is already suspected
of being adulterated.
Simply put, FSIS believes the more product an establishment produces,
the greater the inherent risk posed to the public by that establishment.
This overly simplistic approach to conducting a food safety risk assessment
is not adequately supported by basic Hazard Analysis and Critical Control
Point (HACCP) principles.
Additionally, by proposing to use the volume of product produced to
calculate the risk posed by a given establishment, rather than the
volume of product shipped, FSIS would generate inaccurate data that
failed to take into account the various systems an establishment could
use to identify and address questionable product, thereby preventing
it from entering commerce.
USPOULTRY believes the primary determinant of the extent to which volume
impacts the public health risk attributed to a given establishment
should be the relative success or failure of the measures taken by
that establishment to control the risks associated with their respective
products and/or processes. In other words, product volume should factor
into the algorithm more in cases when there is a well-documented history
of inadequate process and/or product control, and less when an establishment
has a good history of controlling risk. Lastly, the volume of product
shipped from an establishment should drive such calculation, as that
is the most accurate measure of the potential public health risk posed
by any given establishment.
Despite our above-stated concerns, and the fact that congressional
funding for implementation of RBI in the prototype locations has (currently)
stalled, USPOULTRY remains optimistic that, working alongside the rest
of the meat and poultry industry, we may satisfactorily resolve our
differences with FSIS, and help answer the necessary questions that
will facilitate initiation of this program in the coming year. And,
given that RBI stands to help improve food safety inspection, we are
committed to doing so.
Al Yancy is vice president of Food Safety and Production Programs for
the U.S. Poultry & Egg Association.
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