An Economic Assessment of Food Safety Regulations
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- Bu səhifədəki naviqasiya:
- Table 4--Scenarios used to evaluate HACCP rule and benefits estimates
- Table 5--Comparison of HACCP rule costs
- FSIS Preliminary and Revised
- IFSE
- Revised
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Landefeld & Seskin
Salmonella 0.9 3.5
50 75 0.5 2.6 Campylobacter jejuni/coli 0.7 4.3
75 75 0.5 3.2 E. coli O157:H7 0.3 0.7
75 75 0.2 0.5 Listeria monocytogenes 0.1 0.3
50 50 0.1 0.2 Staphylococcus aureus 1.2 1.2
50 50 0.6 0.6 Clostridium perfringens 0.1 0.1
50 50 0.1 0.1 Total
3.3 10.1
n/a n/a
2.0 7.2
VOSL = 5 million Salmonella 4.8 12.2
50 75 2.4 9.2 Campylobacter jejuni/coli 1.2 6.6
75 75 0.9 5.0 E. coli O157:H7 0.9 2.2
75 75 0.7 1.7 Listeria monocytogenes 1.3 2.4
50 50 0.7 1.2 Staphylococcus aureus 3.3 3.3
50 50 1.7 1.7 Clostridium perfringens 0.5 0.5
50 50 0.3 0.3 Total
12.0 27.2
n/a n/a
6.7 19.1
1 Data for these two columns were supplied by FSIS. n/a = Not applicable Source: Buzby and Roberts, 1996 9 Microbial pathogens can be present in foods other than meat and poultry; the 1996 outbreak of E. coli O157:H7 from bottled apple juice is one example.
12 Economic Research Service/USDA An Economic Assessment of Food Safety Regulations
Effectiveness: Valuation method Annualized net pathogen Discount
for premature benefits
1 Scenario/description reduction rate
death/disability Low
High ------Percent------ -------- $ billion (1995) ----- Preliminary FSIS 1995 proposal 90 7
2 8.4
42.1 Low-range benefits estimates 20 7
1.9 9.3
Mid-range benefits estimates I 50 7 Landefeld & Seskin 4.7
23.4 Mid-range benefits estimates II 50 3
3 = 5 million 26.2 95.4
High-range benefits estimates 90 3 VOSL = 5 million 47.2
171.8 1 Benefits begin to accrue five years after the HACCP rule is enacted, and extend over 20 years. 2 Landefeld and Seskin VOSL estimates after averaging across gender and updating to 1995 dollars using BLS usual weekly earnings. 3 VOSL = Value of a statistical life Source: Economic Research Service Table 5--Comparison of HACCP rule costs FSIS preliminary cost FSIS revised cost IFSE cost Intervention Initial
Yearly Initial
Yearly Initial
Yearly Million Dollars Sanitation SOP 1 3.0 16.7 3.0
16.7 - - HACCP planning and training 2 61.0 - 95.0
4.0 136.4
142.8 HACCP recording 3 -
54.1 - 54.1 - 260.3
Temp.
control 4 15.9
16.7 - - - - Antimicrobial treatments 5 - 19.8 - - - - Testing
6 24.0
68.0 3.0
16.9 - 550.0 Modify process 7 - - - 5.5-20.0 - - 1 Revised'>FSIS Preliminary and Revised: identical. The initial cost includes plan development and training. The annual cost includes recording, recording review, and record storage. 2
training course for each employee, additional updates. IFSE: no guidance on plant; $10,000-per-plant training cost. 3
4
5
plants to treat carcasses. 6
Salmonella. Costs include sampling, training, and sampling plan development costs. Revised: requires the use of E. coli testing for slaughter plants on a production basis. FSIS does Salmonella testing. IFSE: assumes daily composite samples of ground products, weekly composite samples of subprimals, and at least nine other samples of either carcasses or production areas weekly. 7
Source: Economic Research Service, based on data from: USDA, FSIS; Institute for Food Science and Engineering, Texas A&M University no rationale for HACCP plan costs and assumes a far greater number of microbial test samples would be required to assess process control of the plant produc- tion process. Table 5 indicates far higher cost estimates from IFSE than from FSIS. The FSIS estimates for sanitation SOP’s and HACCP plan development appear to be more reasonable than the IFSE estimates because: (1) FSIS is 13 Economic Research Service/USDA An Economic Assessment of Food Safety Regulations producing only about 1 percent of annual slaughter and processed meat and poultry output under the preliminary HACCP plan. The cost disadvantage of small plants in the prelimi- nary pathogen reduction rule stems from the require- ments for one HACCP plan and microbial test for each process of each animal species. Small plants tend to slaughter more animal species than large plants and have a similar number of processes per species as large ones (Ollinger et al., 1996). Conse- quently, the preliminary FSIS pathogen reduction plan required a far greater number of microbial tests and imposed higher HACCP recordkeeping costs per pound of output for small plants relative to large plants. By requiring only one HACCP plan per plant and placing microbial testing on production rather than on the daily schedule, the revised pathogen reduction rule greatly lowered the cost disadvantage of small plants relative to large plants. The ability of a plant to remain profitable depends on its cost disadvantage relative to competitors and the product market in which its sells its products. Using Longitudinal Research Database (LRD) data at the U.S. Bureau of the Census, we provide estimates of plant regulatory costs per pound of output by industry for very small, small, and large plants in table 7. Beef slaughter plants are those plants producing car- casses, boxed beef, boneless beef (including ham- burger), and edible organs (SIC 20111). Pork, chicken, and turkey slaughter plants have products identified in SIC 20114, 20151, and 20153. Table 7 contains cost estimates of both the prelimi- nary and revised FSIS pathogen reduction rule for plants in seven slaughter and processing industries and the three plant size categories identified by FSIS. The pathogen reduction rule is more costly for small plants than for large ones. However, the revised plan greatly reduced costs in general and the cost disad- vantage of small plants in particular. For example, pathogen reduction costs for very small beef plants dropped about 66 percent, while pathogen reduction rule costs for very small pork processing and sausage plants dropped about 99 percent. Although industry classifications in table 7 are based on particular product lines, they do not show geo- graphic or service considerations that may confer market advantages on small plants relative to a large one. Additionally, Ollinger et al. (1996) found that from 60 to 90 percent of small (less than 25 employ- ees) beef/pork slaughter and pork processing and sausage plants failed to survive to the next census year (5 years) after entry. Given the modest differ- providing considerable plan development and implemen- tation support; (2) plants currently maintain production records, and can easily add additional records; and (3) few differences exist between the preliminary and revised FSIS estimates, suggesting that FSIS, industry, and outside experts agree on the costs. Some uncertainty exists about the effectiveness of microbiological testing. A review by USDA’s Office of Risk Assessment and Cost Benefit Analysis (ORACBA) suggests that the E. coli and Salmonella sampling tests have a low probability of detecting whether
E. coli or Salmonella are present on the carcass. Additionally, ORACBA suggests that sam- pling should be based on the incidence of Salmonella within species and species class; is skeptical that E. coli testing can verify a Salmonella reduction; and believes that not enough information is available to assess process modification costs (USDA/ORACBA, 1996). There are also questions about the cost estimates of process modifications. FSIS claims that, since many low-volume producers use bed-kill slaughtering processes, better training and closer monitoring alone can be used to meet pathogen reduction goals. 10 However, Dr. David Swerdlow of the CDC indicates that meat from bed-kill operations tends to have higher pathogen levels than meat from online process- ing facilities, suggesting that plants with bed-kill operations may require more, not fewer, process modifications than online plants. Moreover, the costs of one type of modification, antimicrobial treatments, may be higher for the bed-kill operations than for the larger online plants because the treatment must be applied in a batch rather than in an inline automated system (Swerdlow, personal communication). To make a meaningful comparison of benefits and costs, we also need to estimate the annualized costs of the FSIS pathogen reduction rule over time (that is, the present value of costs discounted over 20 years). Table 6 compares the costs of the initial proposal and the final rules, annualized over a 20-year period, starting in 2000 (when all provisions of the final HACCP rule become fully effective). The changes made to the preliminary pathogen reduction rule appear to have come mainly from concern about the costs imposed on small plants. ERS estimated that small plants would have borne about 45 percent of new regulatory costs, while 10 Bed-kill processing is where small numbers of animals are slaughtered one at a time in one location, as opposed to assembly- line slaughter processes. 14 Economic Research Service/USDA An Economic Assessment of Food Safety Regulations
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