|
Inspectors vs. Management: Will the Cold War End? continued... page 2
This is why training classes in Food Safety Regulatory Essentials (FSRE) are so vital. It provides to both regulators and management in establishments the essentials of the authority of the Agency and its field officials. It provides training in the use of the Directive 5000.1, "Verifying an Establishment's Food Safety System" as well as various task codes which are enumerated in the HACCP system9. And it nails the coffin shut on "command and control".
But just how far does the Agency's authority extend? This is often confusing, because the Agency is responsible for the safety of the nation's food supply. Yet there have been two landmark cases in which the authority of the Agency was called into question and in which inspectors were cited for harassment, even though the inspectors claimed to be following the Rules of Practice, 9 CFR 50013-15. For the Rules of Practice to be effective and for "command and control" to remain obsolete, both Agency field officials and establishment management must be kept informed. Agency officials are kept informed by being up-to-date on directives and regulations and on reading IKE (Interactive Knowledge Exchange) for the application of regulations and directives. Establishment management are kept informed through informal discussion or actual HACCP meetings in which Non Compliance Records, as well as regulations and IKE, are discussed. Establishment is also kept informed via the distribution of relevant directives and notices.
Not only are directives and notices important, but also lab results (both from Agency labs and establishments' labs) regarding E.Coli, Salmonella, and Listeria. There are available to concerned parties lab results for all establishments on LEARN10, enabling all parties concerned to make correlations between lab results and what is seen in the HACCP task results. From the establishment's standpoint, transparency regarding results may come reluctantly, if not at all11. Establishments often regard their lab results as confidential company business, in which regulators need not interfere. But while this is true with many aspects of the establishment, if anything concerns food safety or sanitation, the regulators have a right to review various records and to make correlations between Agency labs and establishment labs. The far reaching effect of this reluctance is suspicion.
Without a doubt then transparency is necessary in order to maintain processes and continue to produce safe, wholesome food as well as to assure compliance with regulations that govern meat and poultry inspection. But it is also important for world trade between various establishments globally. Regulators oversee that which is imported and exported to assure compliance with export requirements. Without transparency, compliance cannot be determined. How transparent an establishment is determines how that establishment will meet the Sanitary and Phytosanitary Standards and Technical Barriers to Trade Agreements. Barriers often arise from lack of transparency and the lack of good science8. Because ISO is used worldwide and because it provides the establishment with accountability, many countries would welcome the trade with establishments here12.
References
- http://Stoller's Honey recognized by NSF International for exceptional food safety and quality systems (Winter 2000).htm
- http://www.sealord.co.nz
- http://www.chiltonconsulting.com/, Q Pro Con System description
- http://www.ers/usda/gov/Data/HACCPSurvey/%20meat.htm, Food Safety Technologies and HACCP Compliance Survey of Meat and Poultry Slaughter and Processing Plants, Olinger, Micheal, Nov. 2003.
- A telephone conversation with Christine Bedillion, NSF, January 2004.
- "Tweaking HACCP", Lydia M. Guillot, DVM, in a paper presented in completion of special projects class, VM 815: Appendix, Team Building, Michigan State University, May 2004
- www.ers.usda.gov Meat and Poultry Plant's Food Safety Investments: Survey Findings/ TB 1911. pp 13-36.
- International Openness, Science. Vol. 272. May 24, 1996. pg 1086-1087.
- HACCP Regulatory Process For HACCP-based Inspection, USDA/FSIS Human Resource Development Staff, Jan 1998
- http://www.fsis.usda.gov/ LEARN: Laboratory Electronic Application for Results Notification. Found in FSIS Directive 10200.1
- http://www.fsis.usda.gov/OA/recalls/%20Pennsylvania firm recalls turkey and chicken product for Listeria contamination, Oct., 2002
- www.iso.ch/iso
- http://www.usda.gov/news/releases/2001/12/%200267.htm , USDA to continue testing for Salmonella in Meat
- FSIS News and Notes. www.usda.gov/OA/news/2003/McKee012703.htm , Congressional and Public Affairs Office, Nebraska beef, Inc. sues USDA, 9 inspectors. Pg. 2, May, 2003
- www.usda.gov/OA/news/2001/supremem&f.htm , Inaccuracies in news articles concerning the decision by US Court of Appeals for the Fifth Circuit in Supreme Beef Processing, Inc.
Lydia Guillot has been an Inspector with the Food Safety and Inspection Service (USDA) for 15 years. She graduated from Tulane with a Bachelor's in Biology cum laude in 1981 and from Louisiana State University with a Doctor of Veterinary Medicine in 1988. She also completed work to obtain a Master's in Science in Food Safety at Michigan State University. Lydia is also co-chairman of the NSF Advisory Council on Food Safety. For article feedback, contact Lydia at LGuil42909@aol.com
|