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Inspectors vs. Management: Will the Cold War End?
By Lydia Guillot, Inspector, Food Safety and Inspection Service
Plant inspection authorities and plant management have been at loggerheads with each other, because under “command and control”, the inspector was always right and the plant was wrong. Things have changed with the introduction of HACCP and now it is known that plant management is just doing what it is told to do from those in higher positions than themselves. HACCP is now the order of the day and the philosophy of “command and control” is obsolete. The time to end the Cold War between plant and inspection authorities has finally arrived.
When I was very young, I was always afraid of monsters like the Mummy or Dracula and maintained that if I could just hold them at bay I would survive. As I grew older, I realized that those were only Hollywood characters acted out by Boris Karloff and Bela Lugosi. The "me vs. them" motif seemed silly, and the bad guys weren't so bad. When I first started in the Food Safety Inspection Agency, this is how it was as well, because inspection was still under the auspices of "command and control" and what the Inspector-in-Charge of the plant said was gospel and we were the "good guys" and what the plant said was not right and they were the "bad guys". Two things have since happened: 1) I grew up, having spent the last 15 years in the Agency, and now I know plant management is just doing what it is told to do even from those in higher positions than themselves, 2) HACCP is now the order of the day and the philosophy of "command and control" is obsolete, at least in red meat and poultry inspection.
Please realize that the latter is much more important than the former. Not that I shouldn't have grown up. All those involved with inspection on both sides of the fence must get along for safe and wholesome food to be produced. But HACCP is here to stay. It exists in spite of those that would keep the Cold War fueled between Inspection and Establishment. It exists because "command and control" does not work, not to the protection of the consumer. HACCP on the other hand is an idea whose time has at last come. After 1998 and the passage of the Final Rule, the time for changing the Agency's way of thinking began.
And what we learned is that HACCP is a continually changing modality. That change causes equalization of both parts in order to get the job done right. Allowing HACCP to work and change will put an end to the Cold War that in fact continues to exist between the Agency and meat and poultry establishment. One of those changes that will help the process is combining HACCP and ISO. This concept is already being done at Stoller's Honey1, Sealord2, and has been described by Chilton Consulting3.
Unfortunately, while meat and poultry establishments have complied with implementing HACCP4, the implementation of ISO and HACCP is not a welcomed thought. Why? Three reasons: 1) Many companies feel their own quality systems are sufficient to provide good quality5. They simply don't feel the need to improve on what they have in place, especially since regulators don't place emphasis on quality programs (known as OCPs or Other Consumer Protection items under the HACCP codes) that are put on items of sanitation or food safety. The consensus is, "if it ain't broke, don't fix it". 2) Many governmental workers and some establishment personnel are unaware of ISO and its purpose in the worldwide scheme of things, even those that are well versed in the HACCP and SSOP regulations found in 9 CFR 416 and 9 CFR 417. Some establishment personnel are aware of ISO but are not using the system6, 3) It would simply cost too much money. Many establishments are just now recovering from implementing HACCP, especially smaller operations. The costs of devising new plans or revamping old plans and retraining personnel would be astronomical7.
These arguments against combining ISO and HACCP are well founded. It would indeed mean a major overhaul of both establishment's and regulatory personnel. The "if it ain't broke, don't fix it" motif gives a false sense of security. Regulations as they are work well but can always use improvement. What the food industry doesn't realize is that while the regulations on Finished Product Standards (FPS) in poultry or the Boneless Meat Reinspection in red meat can be indicative of problems within an establishment, they are seldom used as such. That is, accountability is lacking. For example, consider Finished Product Standards, in which the processing and trimming of poultry carcasses is tested for compliance with 9 CFR 381.76. A line test fails and then fails again. At that point, testing is done not only on the line but at the chiller as well until the line checks pass twice. Suppose that after two or three more failures the two tests are passed. The chiller is then marked, and product coming from the chiller is tested until those markers exit the chiller. Testing at the line is complete with two tests. Once those markers exit, regardless of whether or not the poultry carcasses would have passed the subsequent check from the chiller, operations are allowed to resume and the carcasses that exit at this point are considered acceptable.
The problem with processing or trim may not have been corrected. And since this is not considered an issue with food safety or sanitation, there is little if any emphasis on FPS. Again, this gives a false sense of security. Everything may not have been handled when the problem first occurred and may in fact reappear at a later date. It may not. Only continuing to perform FPS testing can tell that for sure, and more often than not time constraints and other inspection issues preclude follow-up.
ISO could provide the stronger accountability now lacking. But there is one drawback. For the combination of ISO and HACCP to be effective, there must be more transparency in the application of HACCP and SSOP than is now present. The transparency must come from both regulators and industry. Regulators must be consistent in application of the regulations and in allowing establishments to work through their process. Establishments must be more transparent so that they may demonstrate effectiveness and efficiency in their process. All departments in establishments and in various levels of the Agency must consistently demonstrate transparency, or true compliance with regulations cannot be demonstrated8.
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