Consensus Approached-But Not Reached-at USDA Roundtable
by Gary J. Kushner
USDA completed its two-day roundtable session focusing on application of the Hazard Analysis and Critical Control Points. The session was broadly promoted, long in planning and viewed skeptically by many. Although it is too early to predict results of the two days of intense dialogue-and many issues certainly remain unresolved-anyone who attended would have to agree it was a surprisingly constructive and productive exercise.
Roundtable members represented virtually all identifiable interests, including representatives from the meat and poultry industries, consumer advocacy groups, FSIS and public health organizations. In terms of format, the program included general plenary sessions during which broad issues were introduced, followed by breakout sessions (three multidisciplinary working groups met concurrently to debate), followed by general sessions during which the three working groups reported their deliberations.
Observers also had their chances at the microphone. A record was kept during the general sessions, and a transcript of the proceedings will be prepared. Within the next several months, USDA is expected to develop a proposed HACCP regulation, drawing at least in part upon the information obtained.
A steering committee selected from roundtable members had met in advance of the session to establish ground rules and identify issues to be considered. The working groups focused on the following six key issues: HACCP plan approval, training/certification, phase in, measures of effectiveness, compliance/enforcement, and relationship and effect of HACCP on inspection procedures. These topics encompassed many related issues, including the adequacy and effectiveness of existing USDA enforcement authority; the likely effects of HACCP on the industry; possible changes in inspection resources and techniques; the possible role of physical, chemical or microbiological guidelines; and the scope of HACCP (whether it should be mandatory or voluntary, to which products and processes it should apply, and factors that should be taken into account for implementing it).
Striving for a consensus
Although there was certainly no shortage of controversy-at times the meeting was quite heated-there was also movement toward consensus, at least with respect to some of the fundamentals. For example, there was general support for the notion that HACCP principles should be employed, especially for products and processes determined on the basis of scientific evidence to present higher and more severe risks to human health.
There was also much sentiment that proper training of both plant and FSIS personnel will be critical to success of the program, and that there should be some means to ensure a uniform level of competence in any training programs that might be established.
There was general consensus that a HACCP program should be based on seven principles developed by the National Advisory Committee on Microbiological Criteria. And there seemed to be agreement that implementation of HACCP will take some time if it is to be done right (maybe three to eight years), and that its utility as a food safety assurance tool must not be oversold.
Of course, the "devil is in the details." When USDA publishes its proposed HACCP regulation, the real debate will begin. Issues will include:
-- Whether USDA should approve company HACCP plans and, if so, to what level should agency review take place;
-- How much flexibility a company should have in tailoring a plan to its particular product, processes and capabilities;
-- What records should be maintained and to what extent USDA inspectors should have access to them;
-- If HACCP becomes mandatory, what kinds of products and processes should come first;
-- What regulatory consequences could come from HACCP plan deviation?
There were also some "sacred cows" that were barely touched upon during the roundtable; some of them are politically sensitive, but they will have to be considered. For example, almost everyone seemed to acknowledge that, as inspection becomes more science based, the focus of FSIS inspection resources will shift from organoleptic factors to an evaluation of a company's ability to demonstrate that it is consistently producing a safe product.
This suggests that the labor-intensive inspection system that has been around since 1906 will become increasingly antiquated. But if this ultimately means fewer inspection jobs, who is going to tell the union? And, to the extent that industry antagonists see this creating a void in FSIS oversight, just how much additional government enforcement authority, if any, will industry accept in exchange?
A good idea, but...
In short, at least on the surface, the USDA roundtable turned out to be a better idea than it appeared. It demonstrated that historically diverse interests can both work together and actually approach consensus on wide range of questions. It also showed, however, just how far there is to go before agreement-even on some of the basics-will be reached.