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Table 6--Estimated 20-year annualized costs of HACCP rule
Regulatory component
Proposal
Final rule
--------Millions of dollars (1995)--------
Sanitation SOP’s
175.9
1
171.9
Time/temperature requirements
45.5
0.0
Antimicrobial treatments
51.7
0.0
Microbial testing
1,396.3
2
171.4
Compliance with
Salmonella standards
NSE
55.5 - 245.3
3
Compliance with generic
E. coli standard
n/a
NSE
HACCP
Plan development
35.7
54.8
Annual plan reassessment
0.0
8.9
Recordkeeping (recording reviewing, and storing data)
456.5
440.5
4
Initial training
24.2
22.7
4
Recurring training
0.0
22.1
4
Additional overtime
20.9
17.5
5
Subtotal - industry costs
2,206.6
968 - 1,156.0
FSIS costs
28.6
6
56.5
Total
2,235.2
1,024.5 - 1,212.5
1
The preliminary analysis included a higher cost estimate for sanitation SOP’s ($267.8 million) that resulted from a programming
error. The cost estimate of $175.9 million is based on an effective date of 90 days after publication.
2
The preliminary analysis was based on the premise that microbial testing would be expanded to cover all meat and poultry process-
ing after HACCP implementation. The proposed rule only required sampling for carcasses and raw ground product. Thus, the cost
estimate of $1,396.3 million was higher than the actual cost of the proposed sampling requirement.
3
The preliminary analysis accounted for some of the cost of complying with the new standards under the regulatory components of
microtesting, antimicrobial treatments, and time and temperature requirements.
4
These costs are slightly different from the proposal because of changes in the implementation schedule.
5
FSIS added costs for recurring training based on review of public comments.
6
Based on the current estimates for the cost of training, inspector upgrades, and $0.5 million for annual HACCP verification testing.
NSE - Not separately estimated
n/a - Not applicable
Source: Economic Research Service, using data from USDA, FSIS (1996)
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