Point/Counterpoint: Risk-based Inspection

Point: Risk Based Inspection will be a giant step forward in food safety (Pete Hisey)

Despite its clumsy implementation, USDA's risk based inspection program will improve food safety in the meat industry considerably, with little or no added cost to the industry. The program, which ranks slaughter and processing facilities by the inherent risk of their product and their safety track record over the years, will all FSIS to cluster its inspectors where major food adulterations are most likely to occur, while scaling back somewhat at less risky facilities.

All, however, will receive daily inspections. The advantages to this plan are both obvious and subtle. Obviously, more scrutiny at places where pathogens are most likely to reach the American consumer will be good for food safety in general and the public image of the meat industry as well. More important, it will send a message to our export markets that the U.S. government is taking concrete steps to guarantee that our meat products are the safest in the world. In most other markets worldwide, the government plays a larger role in overseeing food safety than in the U.S., and underlying their often obstructive behavior regarding our exports is a suspicion that slaughter and processing facilities are essentially unsupervised. You probably won't hear it spoken aloud, but most of the opposition to RBI is led by the largest players, who see the plan as a return to government regulation that the HACCP program was supposed to end.

HACCP is essentially self-policing, with inspectors reduced to reviewing paperwork once the company itself has conducted its own inspections. The suspicion among consumers and export partners alike is that companies will inspect only when they are certain no violations will be found. RBI offers some reassurance that the largest and most potentially risky operations will have extra eyes observing their procedures and in-plant behavior. That, in turn, will make reopening our export markets much easier, as we will be providing their governments with an argument that will reassure their constituents. It will also reassure consumer advocates, who have urged USDA for years to keep closer tabs on meat processors.

Counterpoint: Risk based inspection will be a giant stumble forward (Chuck Jolley)

There's an old adage often tied to the U.S. Army: "Hurry up and wait." The USDA managed to reverse the order when they made the surprise announcement that RBI is a done deal. For years, they've asked the industry to wait while they tried to figure out the intricacies of such a program. On February 22, FSIS Under Secretary Dr. Richard Raymond announced the 'hurry up' part.

With almost no warning and beginning in April, RBI will roll out at 30 "prototype" sites representing about 250 pure processing facilities of varying geography and product type. Slaughterhouses will remain exempt from the program, a puzzling exemption in itself. Is e.coli not a risk to be considered? If all goes well, Raymond said, FSIS will increase its coverage to as many as 150 prototype locations by Jan. 1, 2008, and work to fully implement the program by mid-summer of the same year. "Full implementation" wasn't defined.

The odds that all will go well are slim to none. The politics proved much more dangerous than either Secretary Johanns or Under Secretary Raymond expected. Witness their all out push for NAIS and their sudden reversal when thousands of cattlemen said, "Hell no, we won't go."

So my first thought when reading about RBI and the fast responses from such odd bedfellows as the American Meat Institute and Center for Science in the Public Interest condemning the initiative as ill-thought out and to quick on the draw was the politics will kill it. Much like NAIS, this looks like an idea that's still-born. Or it should be.

Caroline Smith DeWaal, food safety director for C.S.P.I, and a long-time Washington insider said, "One of the concerns is that this is simply an effort to save money in a tight budget year. We want to make sure a budget shortfall is not what's driving these important inspection decisions." Even the inspectors, the guys on the line who have to do all the actual work, fear the added workload will be staggering.

Stan Painter, chairman of the National Joint Council of Meat Inspection Locals said, "Too many plants, too little time, too little authority. Tell me how we could do a better job when we already have the flexibility to do what they're talking about?"

My second thought was spurred by what looks like a surprising lack of direct stakeholder support. If the USDA has any hope of pushing a program forward, it has to have the backing of a majority of the people and institutions involved. According to a third party report by Resolve, stakeholders would have a better understanding of the RBI if the agency did a better job of detailing its "vision, plans and described the work it has already conducted and continues to conduct" Resolve concluded that most stakeholders support the general concept of RBI, based on criteria that adequately and accurately reflect risk.

The major problem they had, though, is the FSIS is establishing an "elaborate scoring system" without clear data—or a way to gather them. And businesses large and small could face significant losses, even closure, if they fall on the short side of that scoring system. An important question to ask: Does the USDA have the legal standing to create such a program? We already know the FSIS lacks authority to enforce performance standards so wherein lays the clout to make the program effective?

Maybe if the "scoring system" was better understood and there was some general agreement that RBI would be a positive force in advancing food safety, it might work. As it stands now, RBI is not a run batted in.

Point: Baby...bathwater (Pete Hisey)

The most remarkable thing about RBI is that virtually every segment of the industry and its outside critics agree it's a good idea. The last time that it happened, the subject was, “Resolved: Babies Are Cute.”

Plainly, concentrating inspection resources where the threat is greatest makes a great deal of sense and, as I have mentioned, would be reassuring to our trade partners, which is no small thing in the present business environment.The objections, at least publicly, revolve around implementation. USDA has decided to pull the trigger, and has been virtually silent as to why. However, a recent statement by Dr. Richard Raymond indicates, for those with the tea-leaf reading abilities necessary to decoding USDA releases, that certain segments of the industry oppose implementation until more data is available to measure risk and support the effectiveness of RBI.

USDA, it appears, feels that the only way to accumulate such data is to implement a pilot program, if its data from present operations are so unacceptable. Hence, 30 plants got the news in late February that they were participants in this pilot, like it or not.

Raymond thinks that the only way to produce a final product that will meet all objections is to show that it works. Admittedly, this reeks of a bull in a china shop, but where's the real hardship for anyone? Thirty plants will be subjected to greater or lesser inspection, and a comparison of data before and after will provide a metric that can prove or disprove RBI's effectiveness. And, parenthetically, it will give our negotiators with Korea, Japan and China something to talk about convincingly.

Raymond indicated in a brief statement that a couple of issues are holding up the entire program. One, stipulated by consumer groups, is measuring the severity of disease attributable to various products; i.e., E. coli in ground beef is more likely to cause fatalities than most other pathogens. Raymond feels that issue can be debated as the program is rolled out, then changes can be made to the algorhythm measuring risk as needed. I agree.

My suspicion is that most of the opposition to RBI is based on suspicion that it amounts to re-regulation of the meat industry after a decade of deregulation. In some degree, this is true. The meat industry as a whole has been commendable in its voluntary control of pathogens. Many processors have invested heavily in advanced technology such as robotics, more sensitive testing, pathogen reduction and the like to produce a safer product.

This has not, however, made the entire industry safer. There are rogue operators and under funded processors continuing to operate and these deserve greater supervision. The real weakness in RBI, from my point of view, is that processors receive no credit for their investments in intervention technology. If you look at what giants like Cargill and BPI have spent over the years on food safety technology, it's stunning. That they should not be credited for these advances is puzzling, and I assume that USDA is looking at ways to quantify this technology and include it in its rankings.

The important thing here, though, is that no one has a real beef with the concept of RBI, only its implementation speed and the less-than-public nature of its procedures and assumptions. I think those will work themselves out in time.Remember, Raymond only has about two years left in his tenure; there will likely be a complete shake-up of USDA after the 2008 elections. RBI, if not implemented now and perfected over the next two years, could die altogether under a new regime.Let's not throw the baby out with the bathwater. HACCP isn't going to go away in the interim, and most inspection will still take advantage of HACCP plans. If RBI is a dud, it can be abandoned.But it just makes too much sense to kill it at birth over a few technical objections.

Counterpoint: No. It’s Bathwater...baby. The government still has things in the wrong order (Chuck Jolley)

Pete’s argument reminds me of a way-to-truthful friend who, presented with a truly homely newborn at a party, felt compelled to say something nice. After all, a phalanx of politeness had preceded him. Dozens of people had already done the proper thing, cooed convincingly and marveled over the little fellow’s cuteness.

Bob couldn’t make himself take that path. He sucked it up and managed to say, “Wow, that’s some baby!”

“Wow, that RBI is some government program!”

Ugly beyond belief.

Everyone is for making advances in food safety. That’s a God, mother, apple pie and cute baby thing. But trying out what might be a half-baked concept in a public forum that could close plants and cost hundreds of jobs is not the way to do it.

It’s like putting a man on trial in the newspaper for a hideous crime, then taking him to court and, unfortunately, finding him innocent. I say “unfortunate” because the damage was already done in the public’s mind before the trial and it can never be erased. If a plant receives a damaging “score” then the algorithm is found to be defective, can it ever regain its reputation? Probably not.

To be fair, let me agree with the concept of risk based inspection. Most everyone does. But let me heartily disagree with foisting an ill-considered plan on an industry that’s already moved mountains to upgrade the quality of its product. There has been plenty of time to get the numbers right.

Why not take the time to get it right before inviting the hanging judge to sit on the bench? No one says RBI is a bad idea; almost everybody says it’s poorly thought out in its current guise. That should tell you something.