OK, I have established that I do not personally
think another huge, monolithic bureaucracy is likely, nor can its
creation alone improve food safety. And I have offered up my opinion that
USDA/FSIS should inspect all things that have a heartbeat and food
products that come from them. Everything else -- including all
canned products and things made from processed meat and poultry -- would
be under the authority of the FDA.
So what can be done with this reorganization to
improve food safety in these tough economic times?
Risk-based inspection. FSIS tried very hard to get
this done in their processing plants during the last four years, but it
has been postponed until their new, improved PHIS computer system is up
and running. This will provide better data and more uniform inspection
activities to improve upon the risk prevention performance scores of the
plants they are present in. Pretty simple, really. A plant with a poor
performance record making an inherently riskier product like ground beef
or ground chicken, will get more inspection than a plant with a sterling
safety record and making a low risk product like baked canned hams.
This could be applied across the board to ALL food
products produced in the US. All products could be ranked based on
science and attribution data and using expert elicitation panels like
FSIS uses to rank the products it inspects. The riskiest products get the
most intense inspection, and the lowest risk products maybe get regular
audits instead of daily inspection. Put the resources where the risk is
greatest, and take the resources from where the risk is the lowest.
This is the 21st Century. Do we really
need to be in every meat and poultry plant daily if most of what we are
doing in some of them is temperature graph validation, or HACCP
procedures validation? A lot of that can be done by electronic
communication, just like we do for banking, shopping and for some, even
dating. By doing this E-inspection,
time spent traveling from plant to plant today could be put to better use
by increasing in-plant inspections in plants producing higher risk
To make this work, however, and not be a step backwards, there still has
to be continuous inspection in some facilities, daily inspection for
others and unscheduled, drop-in inspection in many others, all based on
risk of product and plant safety performance record.
A famous woman in the meat business once said, “If
you want to cut down on drunk drivers, you do not put your police outside
of church on Sunday morning, you put them outside the bars on Saturday
What do you think?