Safe Food: The Politics of Food Safety (14 page)

The origins of HACCP date to the dawn of the space age. In 1959, the National Aeronautics and Space Administration (NASA) asked the Pillsbury Company to develop a food system for astronauts in outer space consisting of total meal replacements in the form of bars for foods and tubes for liquids. NASA demanded safety as the highest priority. The agency did not want its astronauts to come down with microbial food poisoning while on space missions—a difficulty likely to be especially unpleasant under conditions of zero gravity. Pillsbury scientists examined every stage of food production, transport, preparation, and storage, “from farm to rocket ship” (translation: they conducted a hazard analysis). They identified each of the steps—critical control points—at which microbial contamination might occur. They then developed methods to eliminate those possibilities (and accomplish pathogen reduction). The company designed this decidedly science-based process to
prevent
contamination at every stage of production and processing. The plan required supervisors to sample for microbial contaminants only when needed to prove that control measures were working. Later, Pillsbury used this system in its flour mills and processing plants, with great success.
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TABLE 8
. The seven principles of HACCP (Hazard Analysis Critical Control Point)

SOURCE
: USDA/FSIS.
Federal Register
61:32053–32054, June 12, 1997.

HACCP is simple in its basic concepts and can be highly effective when it is used correctly (we will soon see what happens when it is not). In addition to its demonstrable success in outer space, studies on earth also show that appropriate use of HACCP reduces foodborne illness. HACCP requires food companies to analyze production processes intelligently, anticipate safety hazards at appropriate critical control points, and establish effective prevention controls and standards.
Table 8
outlines the seven principles of HACCP. These principles place the burden of ensuring safe food on its
producers
. Under HACCP, USDA inspectors would no longer poke and sniff animals or meat products. Instead, their job would be to examine control point records to make sure that companies were adhering to the HACCP plans.
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Figure 5
illustrates a typical HACCP plan for a cooked meat product. In this plan, the company takes temperatures and records them at three critical control points, and USDA inspectors check the temperature records. Even so simple an example makes it evident that the effectiveness of any HACCP plan requires a major commitment from all parties concerned and entirely depends on (1) the diligence with which companies develop their plans, select critical control points, and monitor what happens at them, and (2) the diligence with which USDA inspectors oversee and enforce the plans.
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FIGURE 5
. A Hazard Analysis and Critical Control Point (HACCP) plan for a cooked meat product. This plan depends on three critical control points (CCPs) to prevent growth of pathogenic bacteria. The product must be cooked to a temperature high enough to kill bacteria (CCP #1), then chilled quickly (#2), and packaged while cold (#3) to prevent bacterial regrowth. (Source: USDA/FSIS.
Federal Register
61:32053–32054, June 12, 1997.)

With that understanding, we can now return to the history of attempts to require HACCP plans for meat production and processing. In the early 1980s when the General Accounting Office (GAO) first suggested reforms of meat inspection, the USDA agreed to study the matter. By that time, the department’s Food Safety and Inspection Service (FSIS) was responsible for meat safety. In 1983, the FSIS asked the National Research Council (NRC), a private research organization often recruited to conduct studies on matters related to federal policies, to evaluate whether the poke-and-sniff inspection system had any scientific basis and, if not, to recommend ways to give it such a basis. The NRC’s 1985 report pulled no punches; it said that the best way to reduce food pathogens was to require HACCP throughout the entire food chain—from production to final sale. In recommending HACCP, the NRC recognized that the USDA’s underlying conflicts of interest could work against controlling what it euphemistically referred to as “aesthetic” problems in meat:

The various federal meat and poultry inspection acts clearly give USDA multiple responsibilities with respect to the food supply. While FSIS has public health objectives, the laws also require that USDA assist in the marketing of products and that FSIS be concerned with aesthetic quality. . . . Neither law nor history provides FSIS with any good guide on which of these tasks—health protection, market assistance, or aesthetic control—should predominate, or how conflicts should be resolved.
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The NRC was quite correct about problems likely to be caused by USDA’s conflicts of interest, as soon became evident.

Later in 1985, the NRC released a second report, this one dealing with microbial hazards in food. HACCP, it said, was remarkably successful in eliminating botulism in canned foods of low acidity, and should be extended to other food products. This report also noted food companies’ lack of enthusiasm for HACCP but attributed the reluctance to “adversary attitudes and lack of cooperation between regulatory agencies and the food industry.” It recommended the appointment of a multiagency commission to oversee federal food safety efforts, thus becoming one of the first groups to demand more government accountability for food safety—a call that resonates to this day.
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Together, the two NRC reports revealed the extent to which the USDA’s approach to food safety in the mid-1980s remained tied to 1906 laws and to the interests of industry. Both reports expressed concerns about the need to break through
what food safety advocates later called “the closed society of meat inspection,” in which the USDA and its inspectors viewed the industry they regulated as the group to which they owed primary allegiance.
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In 1987, partly in response to the National Research Council reports, Senator Patrick Leahy (Dem-VT) proposed the Safe Food Standards Act, to provide “farm-to-fork” protection against microbial pathogens. His bill would have required microbial testing of feed and animals, but it never reached the Senate floor, largely because “the very industries that the bill aimed to regulate owned the committees that had to pass it.”
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Industry lobbying groups such as the American Meat Institute strongly opposed the bill and continued to oppose similar bills introduced soon after.

In 1988, the USDA and the Food and Drug Administration (FDA)—in a rare moment of unity—appointed a joint committee to advise the agencies on how best to keep microbial pathogens out of the food supply. Like previous committees dealing with this problem, this one extolled the virtues of HACCP and provided detailed instructions about how to proceed with such plans. By the late 1980s, health officials understood HACCP to be the most sensible and scientifically grounded approach to reducing the risk of microbial food poisoning, but the regulated industry strongly opposed it.
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Despite the almost complete unanimity among scientists that properly developed HACCP plans could reduce pathogens, neither the industry nor federal agencies nor Congress promoted the idea. Instead, Congress passed a law in 1986 ostensibly designed to focus USDA inspection efforts where they were most needed. The law eliminated requirements for daily on-site inspections of meat-processing plants and gave the USDA the discretion to decide how often plants had to be inspected. This meant that the department could
reduce
the frequency of certain inspections. As part of the discretionary plan, the USDA proposed to “streamline” its inspection system by delegating some of the duties to the meat processors themselves (as would be done under HACCP).
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The department tried out a preliminary version of this program in 1987 and 1988. Although this pilot study identified some problems, the USDA decided to expand discretionary inspection nationwide.

At this point, both consumer and industry groups charged that the USDA was deliberately choosing to ignore problems with discretionary
inspection. Congress held hearings to review such complaints. At the hearings, meat inspectors raised vehement objections. With a graphic description worthy of Lafcadio Hearn or Upton Sinclair, Delmer Jones, the president of the inspectors’ union, explained why his group believed that daily
visual
inspections of meat plants must continue. The problem, he said, is

no control by industry of product that falls on the floor. . . . Product becomes a sponge when it falls to the floor. Many of the products are ready to eat. The problem . . . is because of chemical residues, fecal contamination, abscesses; the employees spit on the floor, blow their nose on the floor; they go in the bathrooms and track it back out into the plant and whatever they tracked into the plant, that is what you eat in cold cuts when you place that meat on a sandwich.

According to Mr. Jones, meat packers have a “stronger commitment to make money than to take care of sanitation and public health concerns.” For this reason, he said,
more
visual inspection was needed, not less.
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Thomas Devine, the legal director of a government group that protects the rights of meat inspectors who blow the whistle on safety violations, raised yet another issue: harassment. In this early warning of the increasingly violent opposition of the meat industry to USDA safety requirements, Mr. Devine told the Congressional committee:

The political climate is such that the special interest groups supporting the meat and poultry industry have won and now they have the ears of Washington. . . . The height of this program is an industry honor system . . . but I would like to tell you why we can’t live with it because of what it will do to the plant employees who want to be whistle-blowers. They will be fired on the spot. . . . In fact, the bad news is so severe that plant management at some companies verbally and physically harass even the Federal inspectors. They have reported physical beatings that required hospitalization, death threats, letting the air out of their tires, chasing one inspector into the USDA office, trying to kick in the door, yelling, cussing, and generally keeping him a prisoner for a half hour.
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Soon after, the USDA withdrew its discretionary inspection plans for “further study,” an action considered a sure sign that the idea had failed.
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A year later, yet another National Research Council report, this time of the streamlined inspection system, concluded that such a system could not possibly protect the food supply unless “the reduced oversight by government inspectors is . . . compensated by a total commitment to product quality on the part of industry.”
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Such a commitment seemed unlikely.

If a single incident forced federal agencies to recognize the need for improvements in food safety regulation, it surely must be that of the disastrous December 1992 outbreak of
E. coli
O157:H7. Four young children in the Pacific Northwest died early in this outbreak. All were found to have eaten hamburgers at Jack in the Box restaurants. By February 1993, when the contaminated meat had been recalled and no new cases were emerging, Washington State alone had reported 400 cases and 100 hospitalizations, and another 100 cases had occurred in other states. Jack in the Box hamburgers were implicated in more than 90% of these cases.
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Despite the compelling circumstantial evidence, the source of the outbreak was not immediately apparent. The meat came from a California meat packer who said that his company had complied with federal regulations “and like other plants, has Federal inspectors who work on the premises” (translation: it’s the USDA’s fault).
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Officials suspected that the meat had been contaminated in the slaughterhouse (it’s the slaughterer’s fault), but could not immediately confirm that suspicion.