An Economic Assessment of Food Safety Regulations

·

Adopt Hazard Analysis and Critical Control Points

(HACCP) procedures,

·

Set targets for microbial pathogen reduction, and

·

Require microbial testing to determine compliance

with the targets.

The FSIS also established initiatives to set standard

operating procedures  (SOP’s) for sanitation, antimicro-

bial treatments, and carcass-cooling standards.  The

proposals included near- and long-term initiatives.  The

near-term initiatives required each plant to: (1) develop

and maintain sanitation standard operating procedures;

(2) maintain carcasses and raw-meat products at

specified temperatures during handling, holding, and

shipment; (3) apply antimicrobial treatments to carcasses

prior to treatment; and (4) perform microbiological testing

(for 

Salmonella) on each slaughter class and/or species

of ground meat processed each day.  The long-term

initiatives added the development and maintenance of a

HACCP plan for each process of each animal species.

Each of these initiatives, except the application of

antimicrobial treatments, requires a plan, employee

training, and recordkeeping and review.

After public review of its testing plan, FSIS (May 17,

1996) published a revised version of its pathogen-

reduction rules.  This revision retained sanitation SOP's,

modified HACCP plan and microbiological testing

requirements, and dropped mandatory time and tem-

perature requirements.  FSIS also made substantial

changes to the microbiological testing component of the

pathogen reduction rule.  Those changes included: (1)

microbial testing for generic 

E. coli rather than for

Salmonella on a production rather than daily basis, and

(2) agency rather than plant 

Salmonella sampling to

verify production process compliance with regulatory

pathogen performance standards.  If meat or poultry

production processes are not in compliance with perfor-

mance standards, then the plant must modify its produc-

tion processes to obtain performance compliance.  The

inspection at the slaughterhouse (U.S. Congress, 1967).

A patchwork of inconsistent and conflicting State stan-

dards and inspection practices, highlighted by the USDA

survey, led Congress to mandate that State efforts be

upgraded to match or equal Federal inspection efforts.

Federal funding was made available to pay for half of the

State inspection costs.  States were also given the option

of transferring their entire meat and poultry inspection

programs over to the Federal Government.  This resulted

in a budget saving to the States, but greater Federal

budget expenditures.  The new regulations were enacted

in two parts: the 1967 Wholesome Meat Act and the

1968 Wholesome Poultry Act.

The Acts required that all carcasses and all meat prod-

ucts be inspected.  The 1906 Act, for example, provided

for mandatory inspection of carcasses after slaughter to

ensure that they were “sound, healthful, wholesome, and

fit for human food.”  Inspection of meat products was to

assure that they were “sound, healthful and wholesome,

and contain no dyes, chemicals, preservatives, or

ingredients which render such meat or food products

unsound, unhealthful, unwholesome, or unfit for human

use.”   Rules, as reflected in the procedures, emphasized

inspection at slaughterhouses.  By the mid-1990’s,

USDA’s Food Safety and Inspection Service (FSIS) had

more than 7,400 inspectors in 6,200 slaughter and

processing plants (USDA/FSIS, 1996).  FSIS conducted

a labor-intensive examination of each carcass and its

internal organs, paying particular attention to the condi-

tion of the lymph nodes -- important indicators that an

infectious disease might be present.  If the lymph nodes

were normal and there were no other visual evidence of

disease, the animal was considered suitable for human

consumption.   FSIS also inspected processing plants.

However, unlike slaughter inspection, not all processed

products were inspected; rather, the emphasis was on

monitoring inspection in the plant.  For smaller plants, an

inspector was assigned to a circuit of several plants.

Larger plants might have had one or more full-time

inspectors.

In addition to checking the quality of the meat, inspectors

would check the operation of equipment (such as

verifying refrigeration and cooking temperatures), and

they would oversee plant sanitation during processing

and cleanup.  Additional duties involved checking the use

of labels, product net weight, and the ingredients actually

used in making processed meat and poultry products.

Although this inspection system removed diseased

animals from the food supply and enforced sanitary

standards in meat slaughter and processing, a serious

gap remained.  The inspection system relied largely on

organoleptic (sensory) methods -- sight, smell, and

sense of touch -- to identify unsafe products.  It did not

---

7

Economic Research Service/USDA

An Economic Assessment of Food Safety Regulations

next section discusses the HACCP system in more

detail.