Safe Food_ Bacteria, Biotechnology, and Bioterrorism - Marion Nestle [46]
FIGURE 5. A Hazard Analysis and Critical Control Point (HACCP) plan for a cooked meat product. This plan depends on three critical control points (CCPs) to prevent growth of pathogenic bacteria. The product must be cooked to a temperature high enough to kill bacteria (CCP #1), then chilled quickly (#2), and packaged while cold (#3) to prevent bacterial regrowth. (Source: USDA/FSIS. Federal Register 61:32053–32054, June 12, 1997.)
SCIENTISTS RECOMMEND HACCP: A SCIENCE-BASED METHOD
With that understanding, we can now return to the history of attempts to require HACCP plans for meat production and processing. In the early 1980s when the General Accounting Office (GAO) first suggested reforms of meat inspection, the USDA agreed to study the matter. By that time, the department’s Food Safety and Inspection Service (FSIS) was responsible for meat safety. In 1983, the FSIS asked the National Research Council (NRC), a private research organization often recruited to conduct studies on matters related to federal policies, to evaluate whether the poke-and-sniff inspection system had any scientific basis and, if not, to recommend ways to give it such a basis. The NRC’s 1985 report pulled no punches; it said that the best way to reduce food pathogens was to require HACCP throughout the entire food chain—from production to final sale. In recommending HACCP, the NRC recognized that the USDA’s underlying conflicts of interest could work against controlling what it euphemistically referred to as “aesthetic” problems in meat:
The various federal meat and poultry inspection acts clearly give USDA multiple responsibilities with respect to the food supply. While FSIS has public health objectives, the laws also require that USDA assist in the marketing of products and that FSIS be concerned with aesthetic quality. . . . Neither law nor history provides FSIS with any good guide on which of these tasks—health protection, market assistance, or aesthetic control—should predominate, or how conflicts should be resolved.10
The NRC was quite correct about problems likely to be caused by USDA’s conflicts of interest, as soon became evident.
Later in 1985, the NRC released a second report, this one dealing with microbial hazards in food. HACCP, it said, was remarkably successful in eliminating botulism in canned foods of low acidity, and should be extended to other food products. This report also noted food companies’ lack of enthusiasm for HACCP but attributed the reluctance to “adversary attitudes and lack of cooperation between regulatory agencies and the food industry.” It recommended the appointment of a multiagency commission to oversee federal food safety efforts, thus becoming one of the first groups to demand more government accountability for food safety—a call that resonates to this day.11 Together, the two NRC reports revealed the extent to which the USDA’s approach to food safety in the mid-1980s remained tied to 1906 laws and to the interests of industry. Both reports expressed concerns about the need to break through what food safety advocates later called “the closed society of meat inspection,” in which the USDA and its inspectors viewed the industry they regulated as the group to which they owed primary allegiance.12
In 1987, partly in response to the National Research Council reports, Senator Patrick Leahy (Dem-VT) proposed the Safe Food Standards Act, to provide “farm-to-fork” protection against microbial pathogens. His bill would have required microbial testing of feed