However, Rottenberg takes issue with the report’s characterization that the USDA did not have the assurance that its decisions were risk-based.
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“Although FSIS agrees that it can take additional steps to internally document its process for creating and updating pathogen reduction performance standards,” Rottenburg writes, “it does not agree with the GAO that the agency does not have assurance its decisions are risk-based and that the agency personnel will not know the process when making decisions. FSIS has consistently documented and published its process within the Federal Register through which FSIS announces or proposes new standards. Agency personnel use these Federal Register notices as guidances and as historical reference when developing new standards.”