Transparency, Part Deux

Effectiveness

Due diligence works based on only one condition: Transparency must be present and practiced on all parts. The biggest barrier to this is the wall between the inspectors and the establishment, particularly in examining establishment’s records of pathogen performance standards.

Should inspectors be allowed to examine the establishment’s results of salmonella or Listeria testing? According to regulations continuous failures can lead to a suspension in operations. Do inspectors go too far in enforcing the suspension of operation on the basis of results from a salmonella performance test, as was ruled in the Supreme Beef case, or based on various sanitation issues as was under debate in the Nebraska Beef case?

In the case of Supreme Beef, the courts ruled that failed salmonella and E. coli testing should not have been enough to stop operations, and in a statement by Dr. Elsa Murano, the USDA’s under secretary of food safety, the agency changed its policy to agree with this.

Dr. Garry McKee, administrator of the Food Safety and Inspection Service, also said that while Nebraska Beef demonstrated poor sanitation issues, the inspection service would follow the Rules of Practice. Regardless of this decision, the question still remains. Do inspectors have the authority to search an establishment’s records? Can an establishment prove trustworthy and still prevent this?

The Precautionary Principle

Hand-in-hand with this goes the precautionary principle. This principle works when an activity could be harmful to the public. However, no cause and effect of a particular event can be established by scientific means either to prove the harm or the benefits of the event.

In employing this principle and policies based on this principle, establishments are guided to use care in how they employ various methods of slaughter and processing in order that hazards, either unforeseen or those accounted for in the hazard analysis, are noted and corrected, eliminated or reduced, even though scientific evidence may not be overtly present to verify that the cause is due to machinery, personnelor operations. Precautionary principle has been used in developing environmental policy throughout the United States particularly in the past six years, when the concept truly caught fire.

The precautionary principle is also present in biotechnology and food emergencies.10 The policies developed from this err on the side of public health and are based on using scientific uncertainties to demonstrate that until further knowledge can be gained if there is public health significance, i.e. if illness or fatalities can be associated with the particular process or product produced, there should at least be a warning to the public.

The precautionary principle first arose in dealing with pollution issues in the 1970s and it is used in the event there are limits to predicting threats to public health with only the use of science. That is, the availability of product alternatives must not be discounted if the original is not suitable or causes problems whether or not reported by the public. Finally, there is the need for continuing evaluation of economic consideration to all sides.

The precautionary principle allows for seeking out alternatives to methods that appear to be innovative and effective in productivity but which may , over the long term, be injurious or at least not aesthetic or acceptable to the public. The use of ISO along with HACCP may in fact give some of those assurances to the public that using just HACCP cannot, since HACCP is solely concerned with food safety and sanitation and not the whole picture.

An establishment feels more accountable to be up-to-date with their HACCP and SSOP plans because of the food safety and sanitation issues and these are weighted heavier in some regards, but also because records generate more of how the process in a particular establishment is run, whether or not the records themselves are accurate. In other words, records will show whether or not an establishment is transparent and open about its process, much more so than records that are of finished product standards.