If one considers the public well-being as the raison d’etre for regulating food establishments, the use of HACCP and ISO combined to encompass all food safety and food quality issues should enhance consumer confidence that the establishments and regulators are in fact working in their best interest. But is this always the case?
With consumer confidence, establishments should be more at ease and be more open in their dealings. This, in fact, is necessary. In order for any food system to function with precautionary policies, as well as for due diligence to be effective, transparency is a must. Transparency is the only way to build good faith, and without good faith and trust it is impossible to work HACCP and ISO successfully.
Consumers interact with industry and regulatory agencies in many ways:
Establishments are willing to share some, but not all information regarding the safety of their food with consumers. Regulatory agencies as well sometimes don’t make all information with regard to food safety in establishments available to the public.
USDA and establishments often are not transparent with each other with regard to information. That is the purpose for the presence of 9CFR 500, Rules of Practice.
USDA personnel in two separate but nearby plants or even between two shifts in the same plant are not open with each other. For meaningful enforcement, there must be consistency and uniformity, and for this to happen; there must be communication.
Finally, there must be openness between the USDA field personnel and the upper supervisory levels, in order to accomplish the mission of the agency, and that doesn’t always happen. Again, good communication must take place.
The weakest link in any regulatory situation is transparency and openness, and this is demonstrated most prominently during the BSE situation in England in the late 1980s and early 1990s. In order to keep the public informed, all interested parties must be given a chance to respond to problems.
During the BSE crisis in England, this didn’t occur. The main complaint in England was that consumers were not kept in the loop of information when the situation with BSE certainly concerned them. The ensuing furor was so strong that The Food Safety Act and its enforcing agency, the Food Safety Agency, were born. The FSA has since developed into an independent agency, with various committees. Its purpose is to keep the public informed of food safety and sanitation issues, as well as provide regulators with authority for enforcing the given regulations. In the US, while there are links that consumers can log onto on the USDA and FSIS websites, and while there are programs such as Fight-Bac and Thermy which provide public education, the consumer still is not fully aware of what goes on in the world of both industry and regulatory agencies.
Keeping Consumers in the Loop vs. Food Security
The reason given by both industry and the regulatory agencies concerning consumers is this. Not all information need to or get to consumers. Why? After all, isn’t it in the best interest of consumers to know methods for reducing pathogens and how these work on pathogens? Perhaps not, for some information that regulators, academians and those in industry may be aware of may not be within the best interest of the general public to be made aware of and may in fact be dangerous to the security of local, state or even national security.
Who decides what information is important? Should that be the government? Or should an independent body, similar to FSA, decide what is in the best interest of the public? That is a dilemma that will be hard to solve. On one hand, one deals with public trust of the government, regulators, academians and industry. On the other hand, there are certain members of society that would want to do harm to the public for the promotion of a cause. It becomes the task of those in public service to use best judgment in relating to the public what it needs to know to be in the best of health, while exercising care that no one is able to use such public knowledge and get access to research from universities and industry that he/she would use for his/her own means to everyone’s detriment. Securing the food supply is a hard road for government and industry alike.