Prior to the development of HACCP, quality control consisted of testing batches of product for quality and safety. However, the problem with testing product samples is that the technique, if done properly, requires testing a great deal of product in order to establish a statistically relevant result. This approach proved not only costly, but -- in the final analysis -- unreliable, because a low level of contamination could still easily escape detection.[4] Bauman's solution was to design safety into the processing stage of processed food production. The solution was so effective that HACCP was adopted by NASA so that the astronauts would not be put at risk of food-borne illness in space.
Sperber has carried on Bauman's work with HACCP throughout his career. In a lecture given this past June at the Institute of Food Technologists at its Annual Meeting and Food Expo in Anaheim, CA, Sperber discussed how major food safety regulations developed in the 1990s " the Pathogen Reduction/HACCP rule, often referred to as the "MegaReg, for raw meat and poultry products; the fish and fishery products HACCP regulation; and the juice HACCP regulation -- "bear little resemblance to HACCP, even though they are called HACCP rules. [5]
Sperber notes that the MegaReg, which was developed behind closed doors in secrecy, should have included the use of aerobic plate counts to effectively monitor process control and verify safety. Instead, testing protocols were established, which amounted to a warmed-over quality control program " just the thing Bauman's HACCP approach was designed to replace.
Testing " Providing a False Sense of Security
Sperber says the testing that is used today "provides a false sense of security that something useful is being done, while hindering our ability to develop and use regulations and procedures better suited to protect the food supply. Words have meaning: HACCP is not quality control. The HACCP system emerged precisely because product testing can not reliably detect low-incidence contamination that is responsible for most, if not all, foodborne illness outbreaks. [6]
Safety failures, Sperber notes, are most often the fault of non-compliance with sanitary design and cleaning. Problems occur when sanitizing procedures are not followed. Providing the necessary resources to ensure sanitary procedures are followed is the key to safe food production.
The folly of relying on testing protocols is further demonstrated by USDA's lack of willingness to engage in effective of oversight of its own regulations. In a report called "Hamburger Hell: The Flip Side of USDA's Salmonella Testing Program by Felicia Nestor and Patty Lovera, the authors expose "a systematic breakdown in the integrity of the sampling program, to the extent that its results are unable to support conclusions about changes in contamination rates. Whether due to systematic incompetence or bad faith, USDA's "don't look, don't find policy means it it's fundamentally deceiving the public with false reassurances. [7] This disturbing review of data obtained through the Freedom of Information Act shows that the USDA consistently postpones intervening at plants, especially large ones, even after tests show the presence of harmful pathogens. Really now -- What's the point of all this testing if you're not even going to act on clear evidence proving that product posing a threat to human health is repeatedly entering the marketplace?
Given the way the USDA conducts itself, you might even begin to wonder why we bother to budget the agency's regulatory activities at all. Perhaps the reason we have regulatory agencies is because they make it so easy for vested interests, once they've captured the agency, to game the system to their advantage.
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