McReynolds position that the primary source of pathogen contamination is large-scale processing and distribution and not farms is confirmed by a January 2010 report commissioned by the Alliance for Food and Farming called "Analysis of Produce Related Foodborne Illness Outbreak." The report found that only "21.9 percent of all foodborne illnesses were associated with produce. Of that 15.8 percent were a result of improper handling after leaving the farm and 6.1% of illnesses were associated with the growing, packing or shipping of produce. Food items other than produce caused 87.7% of the outbreaks or 78.1% of the foodborne illnesses from 1990 to 2007."[15] These findings strongly suggest that legislating costly and business-busting requirements on farm operations is misplaced and unwarranted, especially in light of its negative impact on farmers' livelihoods.
The very last thing this job-creating movement needs is to have policies legislated on behalf of vested interested in control of the global food system create unnecessary regulatory obstacles that make entering or staying in business financially ruinous. McReynolds says that "Not only will FDA rules impact how these farmers grow produce, but it will impact their ability to maintain diversified farm income, and impact their ability to manage input costs." [16]
"Unintended" Consequences and Other Fairy Tales
While McReynolds politely characterizes the legislation's consequences as unintended, recent history and a review of the economic literature suggests that it is well understood by those pushing the legislation that it will shut down small- and medium-sized businesses. In fact, an argument can be made that the consequences are acceptable collateral damage and even a desirable outcome from the viewpoint of vested interests.
Key provisions in the legislation require farmers who sell more than 50% of their crops to the wholesale market to register as "facilities" and create safety plans Hazard Analysis and Risk-Based Preventive Controls (HARPC) -- for each crop they grow. HARPC is a variation of HACCP (Hazard Analysis Critical Control Points), an approach to food safety originally developed for industrially processed foods by microbiologists at Pillsbury.[17] HACCP greatly assisted the manufacturers of processed foods by assuring the safety of their products without any need to engage in costly, wasteful and ultimately ineffective product testing. It could achieve this success with HACCP because processed foods undergo a "kill step," such as cooking, drying, refining or acidification that eliminates any pathogens that may be present.
But applying HACCP to raw food processing, where there is no such critical control point or kill step to eliminate pathogens, is an unscientific fraud perpetrated by those with agendas other than food safety. In the early nineties, HACCP was mandated for all raw meat and poultry slaughter and processing plants by the current Food Czar Michael Taylor, a former King & Spaulding lawyer for Monsanto who would go on to become its Vice President of Public Policy. The maneuver, a politically-based policy masquerading as a science-based measure, succeeded in privatizing the meat inspection process for large-scale plants and hyper-regulating small- and medium-sized plants out of business.[18]
The regulations Taylor crafted limited meat inspectors authority to reviewing paperwork compiled by company employees at company-designated critical control points and eliminated inspectors' authority to pull obviously contaminated meat from anywhere on the assembly line.[19] These changes allowed contaminated meat out the door with the USDA seal of approval. If that contaminated meat was later discovered, smaller downstream processors were left accountable for problems caused by the original slaughterhouses.[20]
Twelve years later, the USDA's Food Safety and Inspection Service (FSIS) is calling for more microbial testing at downstream plants, an admission that the FSIS-style HACCP system regularly allows substantial amounts of contaminated meat shipped into commerce.[21] This development has led the Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America (R-CALF) to call for FSIS-style HACCP to be abandoned or revamped.
Expected Collateral Damage
Economists who have analyzed the costs associated with implementing HACCP plans consistently and clearly state that the costs are significant. In "The Economic Implications of Using HACCP as a Food Safety Regulatory Standard," Laurian Unnevehr and Helen Jensen write that "The fixed costs of adding control technologies and for HACCP training may be prohibitively large for small firms. Thus its mandate may pose a greater burden on small firms, and lead to further concentration in the processing industry. Some observers have suggested a need for public education directed towards small firms. Others have suggested that there are operating efficiencies to be gained once HACCP is in place, through better organization of labor or processes (Mazzocco, 1996; Henson, et. Al., 1998) which small firms could capture if they overcome initial adoption costs. However, it is clear that there are economies of scale in human capital needed to implement HACCP, and thus its imposition will favor large firms." [22]
The authors note that mandating HACCP not only leads to greater food industry concentration, but that "HACCP regulations may also create incentives for greater vertical coordination to control food safety throughout the production process." [23]
In an article entitled "HACCP in small companies: benefit or burden?" Eunice Taylor writes that "Practical experience and a review of food safety literature indicates that success in developing, installing, monitoring and verifying a successful HACCP system is dependent on a complex mix of managerial, organizational and technical hurdles. In coping with this set of interrelating factors, even the largest food companies, equipped with significant resources of money, technical expertise and management skills may face a difficult challenge; the small company may feel that the difficulties of HACCP are potentially insurmountable." [24]
Trained personnel are key to successful HACCP plans. Eunice Taylor points out that "In large companies, the training and technical departments often lead the HACCP project: most small companies do not have these resources. It is evident therefore that even if owner-managers can be convinced of the necessity of HACCP, the allocation of sufficient "time' for its development becomes a major constraining factor. This is compounded by the requirement for specific HACCP training and the need to access the necessary technical expertise" To the small business this translates into a heavy financial burden and most owners look to Government or other agencies for external help at minimal costs." [25]
In a 1996 presentation on "Improving Cost/Benefit Analysis for HACCP and Microbial Food Safety: An Economist's Overview," Laurian Unnevehr and Tanya Roberts discuss how HACCP costs are not only substantial but that economies of scale directly benefit larger industry players. The authors explain that the costs of HACCP "include the costs of designing and implementing controls that achieve the standard for pathogen reduction. The array of control options available will vary with type of animal product and by type of changes required to control a specific pathogen. HACCP involves a large fixed investment to develop the plan and to train staff. It may also require new capital equipment. These fixed costs mean that there are economies of scale in HACCP. The variable costs are often minor in terms of labor and materials. Thus costs will vary by scale of plant, with implications for industry structure. A full accounting of costs would recognize process redesign. However, these generalizations may not hold for HACCP at the farm level, where variable costs could be more important." [26
The United Nation's Food and Agriculture Organization has also reviewed the economics of HACCP and is quite clear about HACCP's ability to drive small- and medium-sized business into bankruptcy: "HACCP rules mandated across an industry will have different impacts on the industry, depending on the market structure of the industry. In general, HACCP rules will likely impose higher costs on small firms than on large firms. An example of this is provided by estimates of market structure change on the United States meat and poultry slaughter and processing industry predicted to result from HACCP. Industry leaders predict that the regulation will drive small producers out of business. The actual effects on small producers will depend on the cost disadvantage faced by small firms, and the degree to which small plants can raise prices in the event they face a cost disadvantage. It will also depend on the ability of small plants to occupy small market niches that allow them to pass along higher product costs. For the United States meat and poultry industry, economists predict that if small producers do exit the industry, the pattern will be an increase in the rate of exits and decrease in the rate of entries." [27]
Other countries have had some experience with food safety laws being used as a pretext to destroy local food production and traditions. Speaking in India at a 2006 conference called "Beyond the Monoculture," Vandana Shiva tells how food safety laws are forcing people to globalize, a process that displaces their traditional foods. Shiva says that "the pretense of food safety has been another way of dismantling the local food economy."[28] By claiming traditional ways of food production are "dangerous," laws have been passed that deregulate big industry and criminalize the methods of those trying to make an honest living.
Next Page 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 | 10 | 11
(Note: You can view every article as one long page if you sign up as an Advocate Member, or higher).
1
1
